The Motorcycle Industry in Europe. L-category vehicles type approval regulation ACEM comments on draft TRL durability study

Transcription

1 L-categry vehicles type apprval regulatin ACEM cmments n draft TRL durability study 1. ACEM members welcme the pprtunity t cmment n the draft TRL durability study. Since 2004, ACEM members have supprted legislative emissins durability requirements fr PTWs. They accept that regulatry measures are a necessary element t address scietal and envirnmental cncerns, while ensuring a level playing field. 2. A knwn and validated cycle is needed by industry, cnsidering nly 3 years remain befre the mandatry intrductin f durability requirements fr new types f mtrcycles (and even less fr ptinal cmpliance). This is needed as the basis fr the develpment f new engines. Apprpriate lead-time is essential fr starting prduct develpment and certificatin prcesses. Executive Summary ACEM highlights the general lack f evidence and test validatin behind the analysis and the cnclusins f the TRL study. ACEM challenges: a. The TRL statements n the effectiveness f the AMA cycle b. The real wrld representativity f TRL s newly prpsed SRC-LeCV cycle c. The very limited validatin f the SRC-LeCV cycle d. TRL s incrrect cmparisn f AMA-SRC-WMTC e. The practicality f TRL s defined acceleratins In mre detail: a. AMA cycle effectiveness. The US-based AMA cycle, despite being devised in the 1970s, is still being used in the USA, China, Japan, Taiwan, and Thailand and will be intrduced in Brazil frm 2014 nwards. Tests by AECC have demnstrated the effectiveness f the AMA cycle by easily expsing nn-durable engines. The earliest applicatin f this cycle, which is well-knwn and supprted by industry, is a massive imprvement cmpared t tday's situatin in which there are n durability requirements. b. The real wrld representativity f the SRC-LeCV cycle. (the TRL prpsed adaptatin f SRC t the L categry). The prpsed cycle claims t shrten test prcedure times by utilizing higher vehicle speeds. This is in direct cntradictin t any real wrld representativity. Page 1 / 5

2 c. The very limited validatin f the SRC-LeCV cycle. TRL has cmpleted an initial mini-assessment f the prpsed test-cycle (SRC-LeCV) with nly 30km having been driven by a small number f different mtrcycle types. N full validatin (essential befre intrductin in type-apprval legislatin) is available. TRL simply claims that SRC-LeCV cntains mre relevant degradatin mechanisms fr mdern pllutin cntrl devices fitted n L-categry vehicles than the AMA cycle. But the reality is that such statements can nly be cnfirmed after a full distance accumulatin, cmbined with regular emissins testing and thrugh cmpnent analysis. A test cycle must be validated befre its implementatin in type-apprval legislatin; type-apprval is nt a tl fr validatin f prpsals! d. TRL s incrrect cmparisn f AMA-SRC-WMTC. Based n measurements and wn calculatins ACEM fund that the representatin f the AMA characteristics by TRL is incrrect and misleading. A cmparisn SRCLeCV-WMTC is missing. The cmparisn SRC-WMTC has little value as TRL changed SRC int SRCLeCV (by cutting the lw speed parts, cfr. pint b. abve). e. The practicality f TRL s defined acceleratins. Assessment f its practical applicatin. Dubts exist as t the pssibility f it being run n rads and test tracks due t there being prescribed acceleratins implied as being necessary in the reprt. The lack f such acceleratins being an unfunded criticism f the AMA cycle. This implies a drivers aid is necessary which cmpletely precludes running the test n a track r public rad. Cnclusins Based n detailed and expert engineering analysis, ACEM therefre rejects the TRL study. SRC-LeCV cannt be included in legislatin as it stands. Further wrk is necessary, and industry asks t participate in such wrk, including: Full distance vehicle testing n the full range f L categry Emissin testing at regular intervals Cmpnent analysis Practical issues f the cycle Until such wrk has been cmpleted, the AMA cycle is the nly validated cycle that can be used fr type-apprval purpses, fr all L categries at apprpriate speeds. ACEM requests adptin f this cycle frm Eur 4. Page 2 / 5

3 The AMA cycle: Annex 1 Detailed cmments n the TRL study Based slely n literature, TRL claims that the AMA cycle cntains numerus driving mdes which n lnger cntribute significantly t deteriratin (p. 34). This directly cntradicts the study made by AECC/Ricard (based n actual distance accumulatin, nt a simple literature study), and included in the TRL references (p. 194). Hwever, apart frm referencing this in the intrductin (p. 1-2: 'This is nly ne example'), it is cmpletely ignred in the main bdy f the TRL study itself and in the cnclusins. The significance f the AECC/Ricard study CANNOT be ignred, as it in fact demnstrates that the AMA is effective, expsing a PTW s pr durability perfrmance after nly a few 1000-km s AMA-driving. TRL mentins that the cycle is used fr testing in the USA, but mre imprtantly mits that it is als used effectively in Japan, Taiwan, Thailand and China and will be intrduced in Brazil frm 2014 nwards. It is als available fr car testing under UNECE R83. The AMA cycle is the nly currently available basis fr internatinal harmnizatin and simplificatin. EPA s cnclusin that AMA is utdated was made cncerning passenger cars nly. It is incrrect t carry-ver such a cnclusin t L-categry vehicles. The AMA cycle is still the EPA cycle t test emissins durability f mtrcycles. TRL has made a calculated cmparisn f AMA-SRC-WMTC, i.e. a cmparisn n paper nly (bar charts p ). This cmparisn is flawed: Driving f nly ne mde (30 km) is nt enugh. Only a full durability distance prvides sufficient cnfidence fr cmparisn and verificatin purpses. (AMA, SRC, WMTC) The AMA data (in the bar charts n page 63-64) is misleading and des nt match with the infrmatin in table 4-14 (see annex 2 fr details). Based n these bar charts TRL cncludes: - The biggest part f the AMA cycle is spent at lw engine lads, simulated by lw vehicle speeds. - The SRC is similar t WMTC. The cnclusin f ACEM s wn analysis (see annex 2) hwever is very different frm TRL s: - The biggest part f the AMA cycle is spent at high engine lads fr the majrity f the vehicles, simulated by high vehicle speeds. - The SRC is NOT similar t WMTC. Page 3 / 5

4 The newly prpsed SRC-LeCV: TRL uses the term Mini-validatin t refer t the fact that a limited number f L-cat vehicles have simply run 30km n the cycles. This is nt a validatin. At best this shws that the test cycle can actually be driven and shws the abslute exhaust temperature levels that are generated. It has n relevance t the validity f the cycle t highlight durability issues. Based n this Mini-validatin TRL cncludes the cycles are validated. Validating a brand new durability cycle thrugh 30km running f a limited number f machines nly is unprecedented and simply unacceptable. Only full distance accumulatin, cmbined with emissins testing and cmpnent analysis is able t validate r invalidate a certain cycle and the industry cannt accept anything ther than such validatin. This is cmmn practice nt nly in ther regins f the wrld, but als in Eurpe fr ther categries f vehicles (M, N, O,...) and withut this it is unclear hw vehicle develpment and testing culd cntinue. The statement n p if implemented in type apprval requirements, test data culd be used t directly mnitr practicality issues is unacceptable as a basis fr legislatin. A test cycle must be validated befre its implementatin in type-apprval legislatin; type-apprval is nt a tl fr validatin f legislatin! Regarding the Efficiency f cycle (reductin in number f laps) as utlined n pages 71 t 74: Remving the first tw slwer speed laps (which represent city driving) negatively impacts the real wrld representativity. 'Cst (time) fr testing' is ptentially reduced at the expense f real wrld representativity. Such a higher speed test culd induce a higher prduct cst, which is unnecessary fr real wrld riding. Fr L3e categry vehicles the SRC-LeCV cntains n average much higher vehicle speeds cmpared t WMTC. Fr ther L categry vehicles, there is n real wrld driving data available t allw meaningful cmparisn. Cnclusins I. The basis that TRL uses (bth theretical and calculated) t cnclude that the AMA cycle is bslete, is incrrect. II. A new cycle cannt be cnsidered as validated withut a full mileage accumulatin, emissins testing and cmpnent analysis. At best, this study can be cnsidered as a starting pint f in-depth discussins between all stakehlders and the setting up f a prper validatin fr any prpsed new cycle. This will require wrk that is clearly nt cmpatible with the current calendar f the regulatin. Until such wrk has been cmpleted, the AMA cycle is the Page 4 / 5

5 nly validated cycle that can be used fr type-apprval purpses, fr all L categry vehicles. ACEM requests adptin f this cycle frm Eur4. Page 5 / 5