New WLTP emissions test to increase testing burden by 6-8 times
24 March 2017
ACEA has warned that the shortage of testing facilities for type approval will become acute from September, when the real-world WLTP (Worldwide Harmonised Light Vehicle Test Procedure) begins. It also warns that the EU’s proposed wireless car data access could make it ‘impossible’ for OEMs to keep connected vehicles secure.
The switch to the new test, which aims to better replicate real-world driving and replaces the NEDC test, is expected to increase the burden on existing compliance test facilities, where there is already a shortage, to 6-8 times current levels, according to ACEA.
Manufacturers already undertake around 40% of type approval tests for new car models at their own facilities, or in third party laboratories – under strict monitoring by their national government’s type approval authorities – and ACEA says this practice should remain as part of the new ecosystem.
While ACEA ‘fully support’ the introduction of the real-world WLTP, which it says will restore trust in the emissions testing system post-Dieselgate, it has deep concerns about several aspects of the EU’s revised proposals for the type approval process, particularly relating to this shortage of testing facilities. It is also raising concerns surrounding proposals for access to repair and maintenance information (RMI) and safe access to in-vehicle data.
The report by the European Parliament’s Internal Market and Consumer Protection (IMCO) Committee on revising the type approval system – whereby national authorities give certification to the OEM for the sale of the new car type across the entire European Union – proposes that EU member states must oblige to take 20% of new car models off the road for testing in labs to ensure compliance with the new legislation.
ACEA warns: ‘This would place a massive burden on national authorities, with some countries having to test tens of thousands of vehicles for conformity,’ adding that it has ‘grave concerns about how this would work.
It adds that even if this 20% new car test requirement were dropped, the 6-8 times additional burden from WLTP would still leave testing facilities extremely stretched. This ‘permanent high demand’ would almost certainly place even greater reliance on in-house testing capability and put the entire system under immense strain.
ACEA has further concerns with the IMCO’s proposed changes. It welcomes the Commission’s recommendation to move RMI provisions (that allow third parties to access relevant data, to provide services and boost competition) from emissions legislation to the type approval framework. ACEA says this is sensible because RMI access does not only apply to emissions information. However, the IMCO report proposes to make changes to the content as this transfer occurs.
ACEA says this should not happen, because the EU has not carried out a proper impact assessment for these changes. The Commission is still in the process of investigating the effectiveness of the current rules of RMI access – hence ACEA sensibly says it is only appropriate to make amendments that confirm or clarify existing law at this stage.
ACEA also raises alarm at the content of the RMI proposals revealed in February. It warns of a ‘fundamental breach of data protection legislation’ from the EU’s suggestion to disclose vehicle identification numbers (VIN) of all vehicles, together with the exact specifications of each vehicle.
It also highlights a critical failure of a second proposal, which it says ‘would make it impossible for manufacturers to fulfil their liability obligations – especially in the case of connected and autonomous driving.’ This would scupper the fundamental need to build trust to facilitate the incoming driverless car revolution. The proposal aims to provide direct access to in-vehicle data by means of a wireless connection. This would enable third parties, says ACEA, to introduce or re-write software that might affect the vehicles integrity.
ACEA alerts: ‘Providing uncontrolled remote access to vehicle data poses much greater risks to security, safety and liability than giving RMI access when the vehicle is physically brought to a workshop by the consumer.’
ACEA therefore calls for these revisions to not be included in the type approval revisions. It is currently in discussions with automotive suppliers and stakeholders exploring various technical solutions to find a system to provide safe and secure access to vehicle data for interested parties.
Finally, prior to the new type approval process coming into effect, ACEA calls for market-boosting measures to ensure that it remains 'cost-effective.' It hints that the emissions burden is becoming severe, and even has fundamental technical barriers; ‘We should ensure that the new system remains practicable and implementable for our industry.’ Analysts already expect WLTP will result in certain OEMs having little choice but to invest in expensive selective catalytic reduction (SCR) technology to remain compliant with the new stringent testing regime.