Proposal to clarify and improve the text of the new Real Driving Emissions type approval regulation per the following justifications:

1. In paragraph 3.3.7. the text in brackets is a repeat of content in an Annex. It is good practice to keep definitions to one sentence where possible. Adding “of the tested vehicle” avoids any confusion with family test mass definitions.
2. The syntax of the term “power-to-mass-ratio” (with hyphens between all words) should be consistent throughout the document.
3. Where a requirement only applies to the approval authority which issued the approval this should be made clear in the text.
4. Additional to the technical specifications listed in Annex 5, the Regulation assumes measurement accuracy of PEMS equipment. It therefore appears reasonable that the PEMS equipment is required to also deliver these measurement accuracy.
5. As vehicles are designed to be driven predominantly forwards, and rearwards driving although normal practice is an exceptional situation, the possibility to drive rearwards for extended periods should be removed.
6. “Velocity” as a physical term is a vector and has to be accompanied by a direction. For clarity this should be replaced with “speed”.
7. A large (> 20 K) ambient temperature difference between one day and the next is not representative of real life and can result in unrepresentative catalyst performance. The possibility of a preconditioning at 23 °C followed by a test at below freezing should therefore be removed.

Proposal to introduce levels in the draft new UN Regulation on Real Driving Emissions type approvals based on the following:

1. Since RDE testing has been introduced in the European Union, there has been criticism of the difficulties encountered when planning a valid RDE test.
2. This situation would be worsened by introducing the requirement for a test to be suitable for analysis according to both 3-phase and 4-phase concepts.
3. As levels have already been introduced in Regulation No. 154 and these are becoming accepted and understood by technical services and approval authorities, the introduction of these levels in this Regulation would be a clear alignment.
4. As the temperature boundary conditions from this draft Regulation are already being transposed into European legislation, OICA members see no need to differentiate between boundary conditions for the proposed levels.
5. The inclusion of these few amendments would return the planning burden to that currently experienced in the EU, at least for markets which apply the 4-phase WLTP concept.

Proposal to update the previously adopted text (GRPE/81/Add.2 and in document WP.29/2020/120) with changes introduced into European legislation on RDE. This document is available with tracked changes in pdf version and docx format.

This document is also available with tracked changes in word format and pdf version.

Summary report discussing implications for developing a commercial passenger bus event data recorder (EDR) standard, focusing on the feasibility of equipping heavy vehicle event data recorders (HVEDRs) in motorcoaches, buses and school buses.