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Document Title REC draft regulation: Comments from France
Reference Number REC-14-05
Date
19 Feb 2013
Source(s) France
Rulemaking Area(s) UN R132 Retrofit Emissions
Meeting(s)
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Excerpts from session reports related to this document
REC | Session 14 | 19-20 Feb 2013

Bazzucchi presented the slides circulated as REC-14-08. Regarding the installation of the REC, Baarbé noted that in his opinion the REC Regulation is not the right place to have these provisions; Öhlund agreed to this. Baarbé said that installation requirements could be useful. Himmen noted that establishing such a system would be very complex. Baarbé suggested complementing the REC Regulation with a guidance document, to be drafted at a later stage. This might also be of interest for the EU? Martinez appreciated the French proposal and suggested to focus on the remaining open issues in the REC, but a guidance document could be useful. Billi suggested that some model contract or model training for installers should be part of the approval system. Himmen noted that this is not simple and very country- or even city-specific. Schulte noted that the installation provisions are already covered by the article 20. Galey noted that for the London retrofit there were approved installers notified by the London LEZ authorities. Baarbé concluded that some appropriate wording will be added to article 20 to show that the REC manufacturer has to show it has adequate procedures to select, train and monitor its authorised installers. Bazzucchi agreed to this and noted that the correct installation of the device has to be the responsibility of the REC manufacturer.

Bazzucchi then proposed some improvement for the CoP regarding the REC system. He noted that France will prepare draft wording as an informal document for the next GRPE meeting. Baarbé noted that this informal document (to be sent after 8 March) would then be considered in parallel to the official REC draft document at GRPE. He added that it has now been confirmed that additional CoP provisions can be added to the REC draft. The previous wording on CoP was re-added but can be modified accordingly. Bazzucchi then continued with specific CoP for Level D REC systems (Euro VI). Schulte noted that PEMS testing is already covered in annex 12.

Baarbé noted a further editorial meeting might be needed in the near future, to be decided at the end of this meeting.

Galey noted the editorial comments made by France in doc. REC-14-05. Galey also noted that both main requirements are to be fulfilled at the same time (improving emissions by a Euro- or Stage-level as well as meeting the required reduction efficiency and felt that reduction efficiency had become the main criterion. May indicated that §8.1. specifies that a REC can be approved under this regulation when meeting all of the following criteria: the emission limit values as specified in paragraph 8.2.; the reduction levels as specified in paragraph 8.3.; the NO2 emission requirements specified in paragraph 8.4. and the secondary emissions requirements specified in paragraph 8.6. it was concluded to keep §8.3.2 as is. Schulte noted that we should not change wording that is already used for Euro VI and Stage IV (§7.5.1, 7.5.2). Changes suggested to 8.2 could be accepted as they are editorial; those to §9.3 could be considered.