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Written evidence from HORIBA MIRA (VTA0028)
HORIBA MIRA is a global provider of engineering, research, test and certification services to the automotive, defence, aerospace and rail sectors. We work in close collaboration with vehicle manufacturers and suppliers around the world, providing comprehensive support ranging from individual product tests to turnkey engineering design, development and build programmes. As part of this we offer an independent certification service utilising the vast experience gained during engineering programmes ensuring standards are adhered to not only at the final certification test, but also in the spirit intended of the standard during the full development and validation programme.
With over 70 years’ experience in developing some of the world’s most iconic vehicles, our engineers utilise the latest test facilities and simulation tools to make vehicles and journeys safer, cleaner, more efficient and rewarding. Our suite of 37 major test facilities, 100km of specialised proving ground and wealth of engineering experience, combined with our expanding international presence, means we are confident that we can achieve our vision – that by 2020 every journey in the world will be positively influenced by us.
Progress towards achieving our vision has been significantly accelerated through the creation of MIRA Technology Park, Europe’s largest transport technology R&D cluster.
HORIBA MIRA welcomes the opportunity to submit written evidence to the Transport Select Committee inquiry into vehicle type approval. This is supplied in addition to our participation in the session on 29th February 2016 and is submitted with the objective to add experience and knowledge to the investigation into European Type Approval and to begin to ensure recommendations can be made on an informed basis. Like the SMMT, we believe the UK automotive industry recognises the issues related to one element of the type approval scheme, vehicle emissions testing, and like them we fully support a more representative test.
European Whole Vehicle Type Approval is a process which provides a mechanism for ensuring that all vehicles meet relevant environmental, safety and security standards which are set by the European Commission, informed by all European member states through a network of working groups. In order to bring products to the EU market, all automotive manufacturers have to comply with this process which even provides provision for small volume manufacturers. It is not practical to test every single vehicle made, so therefore all necessary tests are performed on a production vehicle, as being representative of the “type”. To ensure all vehicles are tested in a consistent manner, the test methodology is outlined in the relevant EC Directive/Regulation or UN Regulation and the tests are carried out at an appropriate and approved test facility with a Type Approval Authority witness. All of these test facilities must be approved by the Type Approval Authorities the test facility works with. In addition, where the test facility proves it has the necessary capability,
experience and impartiality, a Type Approval Authority can delegate its witnessing function – in this situation the delegated organisation is referred to as a Technical Service. An independent certification group witnesses the certification tests on behalf of the Type Approval Authority and collates all the necessary documentation for the Type Approval Authority to review and issue the Type Approval Certificate for the witnessed system/component test.
Once all of the system and component approvals are in place, all approvals will be reviewed as part of a whole vehicle inspection and will be approved as an entity by the designated approval authority.
Following completion of the physical vehicle tests, a further Conformity of Production assessment needs to be completed before issuance of the Type Approval. The assessment must take place at a designated manufacturing facility which has the appropriate equipment, required testing environment and importantly relevant and robust quality processes to ensure rigorous sample control and continuous improvement for the manufacturing process to ensure controls are in place for the tested vehicle being representative of the regularly manufactured vehicle.
A successful inspection accompanied by the submission of the relevant manufacturer’s information documents will result in the issue of a European Whole Vehicle Type Approval certificate. This certificate will be accepted throughout the EU without the need for further testing until a standard is updated or the design of the vehicle changes. Once a vehicle is type approved, the manufacturer commits to demonstrate ongoing compliance through periodic Conformity of Production checks and audits by the Approval Authority.
Each vehicle needs to adhere to a large number of standards. Please see the Picture 1 for a pictorial illustration of the many standards applied under Europe Whole Vehicle Type Approval for a category M vehicle (passenger vehicle) under Directive 2007/46/EC.
There are four stakeholders in the Type Approval “ecosystem”:
Each member state in Europe has a Type Approval Authority either as part of Government or representing the Government in the country. For the UK, the Type Approval Authority is the Vehicle Certification Agency (VCA). The vehicle manufacturer decides which approval authority it wishes to work with and that Approval Authority does not have to be based in the country of the vehicle manufacturer. In other words a UK manufacturer can use any of the European Approval Authorities, they are not limited to using just the VCA.
There are significant differences between how each of the nations’ Authorities work - some are more active than others and some pass more of the Technical Service activity to private sector organisations than others. Using the three larger Type Approval Authorities as examples:
HORIBA MIRA is a Technical Service to the Dutch Authority (RDW) for the majority of 2007/46/EC subjects and a Technical Service for the VCA and Irish NSAI for very specialised and limited scope elements, chiefly Electro-Magnetic Compatibility (EMC). In this capacity the organisation acts on the Type Approval authorities’ behalf and a separate and independent team of specialist engineers witness the certification test, collates the necessary information and submits this to the Type Approval Authority for approval and for them to issue the certificate. In addition HORIBA MIRA is one of many approved test organisations who has facilities at which both development and certification tests can be undertaken.
As mentioned above each vehicle to be sold in Europe needs to adhere to a large number of standards and manufacturers will be testing to all of the appropriate elements for their vehicle. One of these is emissions testing.
All vehicles sold throughout Europe are required to undergo an official emissions test carried out over a New European Driving Cycle (NEDC). The test is carried out in a laboratory which operates in strict conditions to ensure consistency, repeatability and a level playing field across Europe. For this purpose the test cycle and limits are specified through legislation in order to ensure consistency and comparability of the results from one vehicle to another and although the drive cycle used is indicative of usage, the drive cycle was not designed to demonstrate the results drivers may achieve in the real world. The test cycle is designed to produce a broad benchmark performance for comparison between vehicles.
It is acknowledged that the test was derived many years ago and when first devised, technology that is now common in most vehicles was either not standard or not available at all in new vehicles. It is also acknowledged that laboratory tests are bearing less relevance to performance for current real world driving. However the vast variations in temperature, road and vehicle conditions and driving styles mean that no laboratory test can ever replicate exactly the experience of every consumer.
In future, the European legislative emissions test will comprise of two elements:
The WLTP element will be undertaken in the same highly regulated laboratories as the current NEDC tests but the drive cycle has been derived from real world driving data and is longer and faster than NEDC, with less idling and more aggressive acceleration. The RDE element requires new on-board Portable Emissions Measurement Systems (PEMS) to be fitted to the vehicle whilst under test on a set of pre-approved routes. These routes must be approved by the Type Approval Authority prior to any official certification test being carried out.
These new test protocols are significantly different to the existing NEDC laboratory test. It is important they are seen as a different set of tests rather than a test to fully answer and offer solutions to the discontent and questions raised by consumers. To develop a testing regime which fully reflects all driving styles, road conditions and vehicle technology and at the same time offers a robust and repeatable test is unfeasible.
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In 2013 the EU type-approval framework for motor vehicles was subject of a comprehensive fitness check. It confirmed that the EU Type Approval legal framework was appropriate for achieving the main goal of European harmonisation, effective operation of the internal market and fair competition as set out in the European Commission Proposal for a Regulation of the European Parliament and of the Council on the approval and market surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles. However, the fitness check also recognised that differences in interpretation and strictness in application of the requirements across Member states were reducing the effectiveness of the framework. The Commission is therefore undertaking a full review of Directive 2007/46/EC (the Directive governing European Whole Vehicle Type Approval) as a matter of urgency and in particular to focus on the following areas:
Triggered by the outburst of the VW emissions scandal, the European Parliament adopted on the 5th October 2015 a Resolution on emissions measurements in the automotive sector, calling on the Commission to significantly strengthen the current EU Type Approval regime including more EU oversight, in particular with regard to market surveillance, coordination and follow-up regime for vehicles sold in the Union.
Of the areas reviewed, HORIBA MIRA believes the push for improving market surveillance provisions and the increase in both the Type Approval authorities and the EU Commissions’ scrutiny role is important and we fully support and welcome consistent and transparent scrutiny and enforcement procedures across all European organisations involved in Type Approval activity, this being the Type Approval Authorities themselves, Technical Services or approved laboratories. It is important the manufacturers are given a consistent service throughout Europe to not only ensure products of a consistent quality meeting environmental and safety standards are made available to consumers, but also so a competitively level playing field is maintained between the many organisations involved in offering tests and certification.
3 May 2016