Feedback reference
Submitted by
User type
Public authority
Greater London Authority
Organisation size
Large (250 or more)
Transparency register number
Country of origin
United Kingdom

The Mayor of London, through the Greater London Authority, is responsible for transport and environment in Greater London. Below is the GLA feedback on the amendments to improve light vehicle tests and procedures.

WLTP testing.
The introduction of the WLTP is very welcome as it better represents real driving conditions. Furthermore the updates to CO2 and fuel consumption monitoring are welcome providing far more meaningful data for vehicle buyers and for authorities.

RDE testing.
It is encouraging that the RDE legislation has been finalised, in particular, that the methodology for calculation of final results has been defined. The reduction in conformity factor from 0.5 to 0.43 is welcomed, but this figure must be kept under review and further reduced as soon as technology permits. It is imperative for city authorities, especially in Northern Europe, that after-treatment systems remain functional at realistic operating temperatures to ensure the control of NOx and PM. For this reason the GLA has previously expressed a view on Transfer Functions, which are unhelpful to the control of emissions under all operating conditions.
In-service conformity testing
The GLA believes that in-service conformity testing is vital to ensure that type approval utilising RDE is a robust and credible regime to ensure that new vehicles comply with legislation and that the confidence of the public and authorities is restored in the type approval mechanism. The success of euro VI for heavy duty engines should be repeated for light duty vehicles as soon as possible. In this regard it is reassuring that the type 1 tests have been updated and will be augmented with evaporative emissions testing.

Hybrid light duty vehicles.
The GLA would reiterate that a satisfactory methodology to perform RDE testing of hybrid and alternative fuel vehicles is urgently needed. Account should be taken of the specific performance features of these vehicles (eg EV range) so as not to disadvantage this technology type. Whilst a technology neutral approach is important, maintaining neutrality requires that the test methodology is suitable for the technology type. This is vital to encourage uptake of hybrid and plug-in light duty vehicles. At the earliest opportunity, a City Environment Zero-Emission Range duty cycle should be established for this purpose.

Multistage vehicles.
The GLA would advocate that multistage vehicles should be exempt from the RDE requirements, which are too onerous upon SME bodybuilders. The results from an OEM tested and approved sister vehicle should be allowed to stand for multistage vehicle approvals, unless the work of the body builder interferes with previously approved engines and emissions control systems on the vehicle in a way likely to affect their performance.

It is vital to ensure that good transparency exists in the type approval process to restore government and public confidence in the industry. Measures to improve test laboratory accreditation are therefore welcome. Furthermore, the requirement for type approval authorities to publish annual reports on the approval and test activity will be useful for
authorities needing to act on air pollution. To this end, it is important that ensure that OBD information is available to type approval authorities and also, at an appropriate level, to city authorities to assist in the design of pollution control schemes.

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