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ACEA proposals to WLTP Regulation 2017/xxx and the proposed WLTP Correction Regulation

1. Amendments to the WLTP Regulation 2017/xxx and,

2. Amendments to the WLTP Correction Regulation – version on CIRCABC website of TCMV 16

November 2016

Title of the WLTP Correcting Regulation

The title of the WLTP Correcting Regulation is as follows:

"[...] Commission Regulation correcting Commission Regulation (EU) 2017/xxx implementing and amending Regulation (EC) No 715/2007 of the European Parliament and of the Council (Euro 6), Commission Regulation (EU) 201x/xxx amending Regulation (EC) No 692/2008 as regards the methodology for the determination of evaporative emissions and Commission Regulation (EC) No 582/2011 implementing and amending Regulation (EC) No 595/2009 of the European Parliament and of the Council with respect to emissions from heavy duty vehicles (Euro VI)"

Note that the WLTP Regulation 2017/xxx says "supplementing Regulation (EC) No 715/2007 of the European Parliament and of the Council on type-approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information [...]".

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WLTP Regulation 2017/xxx

Article 17 – referring to Article 16a

Transitional provisions

Regulation 20017/xxx, Article 17:

Amendments to Regulation 692/2008

"Article 16a

Transitional provisions

With effect from 1 September 2017 2018 in the case of categories M1, M2 and category N1 class I vehicles, and from 1 September 2018 2019 in the case of N1 vehicles of class II and III and category N2 vehicles, this Regulation shall only apply for the purposes of assessing the following requirements of vehicles type-approved in accordance with this Regulation before those dates:

[...]”

Article 17 point (2) of the new WLTP regulation agreed by TCMV on 14 June 2016 adds a new Article 16a into Regulation 692/2008 that appears to limit, from 1 September 2017 or 1 September 2018 (for certain LCV’s) the application of Regulation 692/2008 only in respect of COP, ISC and RMI.

Although a manufacturer would not normally plan type approval actions during the last year of validity of an approval, instances may occur which demand this. An example of this is where a supplier would go out of business and another is found which can supply technically the same part but with different markings (i.e. part number). In order to maintain production, this change would need to be included in the approval package. As type approval is not listed in the new Article 16a of the WLTP Act, such extensions would be prohibited.

The proposed one year amendment of the dates would reduce the problem but it is not unknown for approval extensions to be necessary after the end of production in order to keep repair and maintenance components in conformity.

ACEA’s general view is that this Article is unnecessary and could be covered by the repeal of the Regulation.

Therefore, in Article 16a the first date of "1 September 2017" should be changed to "1 September 2018" and the second date of "1 September 2018" should be changed to "1 September 2019".

If not, ACEA requests COM to provide a written confirmation of this interpretation.

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WLTP Regulation 2017/xxx

Article 15

Transitional provisions

Amend point 5 of Article 15 as follows:

“5. Until 8 years after the dates given in Article 10(4) of Regulation (EC) No 715/2007:

(a) type 1/I tests performed and completed in accordance to Regulation (EC) No 692/2008 until 3 years after the dates given in Article 10(4) of Regulation (EC) No 715/2007 shall be valid for the purposes of fulfilling the requirements of Annex VII and/or Appendix 1 to Annex XI to this Regulation;

(b) procedures performed in accordance with section 3.13. of Annex III to Regulation (EC) No 692/2008 until 3 years after the dates given in Article 10(4) of Regulation (EC) 715/2007 shall be accepted by the approval authority for the purposes of fulfilling the requirements of the second paragraph of point 1.1 of Appendix 1 to Sub-Annex 6 to Annex XXI of this Regulation.

(c) Durability demonstrations where the first type 1/I test was performed and completed in accordance to Regulation (EC) No 692/2008 until 3 years after the dates given in Article 10(4) of Regulation (EC) No 715/2007 shall be valid for the purposes of fulfilling the requirements of Annex VII to this Regulation;

This point was discussed and it was agreed in an earlier Commission meeting in Brussels.

Durability testing is time-consuming and the length of the durability test has to be recognised in the transition from NEDC to WLTP. It therefore needs to be clearly written down in the WLTP Regulation that any durability test that was started before September 2017 using the NEDC as the point-to-point Type I test must remain acceptable for completing the durability test and for use for WLTP type-approvals after September 2017.

WLTP Regulation 2017/xxx

Definitions

37.‘net power’ means the power obtained on a test bench at the end of the crankshaft or its equivalent at the corresponding engine or motor speed with the auxiliaries, tested in accordance with Annex XX (Measurements of net power and the maximum 30 minutes power of electric drive train), and determined under reference atmospheric conditions;

This definition is inconsistent with the new definition of rated engine power and should be deleted.

45. ‘Fuel Storage System’ means devices which allow storing the fuel, comprising of the fuel tank, the fuel filler, the filler cap and the fuel pump;

This definition is inconsistent with the definition in GTR15 and Mutual Resolution 2.

Also the fuel pump does not store fuel and is not necessarily physically associated with the fuel storage system.

47. ‘Monolayer tank’ means a fuel tank constructed with a single layer of material;

48. ‘Multilayer tank’ means a fuel tank constructed with at least two different layered materials, one of which is impermeable to hydrocarbons, including ethanol;

These definitions do not make it clear how a steel tank is classified as it has one layer but is impermeable.

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In addition, concerning definitions, ACEA would point out that we have many definitions that are not consistent and are contradictory between the WLTP Regulation 2017/xxx and the WLTP GTR.

The following definitions are examples where there is inconsistency:

[....].

ACEA makes a simple request fro better regulation and we request the COM to therefore ensure a consistent regulation.

Amendments to Regulation (EU) No 201x/xxx (EVAP Regulation)

Article 1 in Regulation 201x/xxx says:

“(2) In Article 17, the following paragraph is inserted after the second sub-paragraph:

"Annex VI as amended by Regulation xxx/2016 shall apply from 1 September 2019 to all new vehicles registered on and after that date."”

It is assumed that “Regulation xxx/2016”means the EVAP Regulation that is now referred to as Regulation 201x/xxx in the WLTP Correcting Regulation.

WLTP Regulation 2017/xxx, Article 20 and,

WLTP Correcting Regulation, Article 4

Entry into force [and application]

WLTP Regulation 2017/xxx says:

“This Regulation shall enter into force on the twentieth day following its publication in the Official Journal of the European Union.”

WLTP Correcting Regulation xxxx/xxx says:

“This Regulation shall enter into force on the third day following its publication in the Official Journal of the European Union.”

Depending when the WLTP Regulation, the RDE3 Regulation and the WLTP Correcting Regulation will be published, there may be three sets of changes to the CoC to be implemented. That may well be impractical and we know that all stakeholders will require time to make those changes to the CoC layout in their IT systems.

ACEA recommends that a deadline be set for all these new CoC changes coming from these 3 new Regulations and it should be mandatory for all new vehicles from September 2018.

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WLTP Regulation 2017/xxx

Annex I, paragraph 2.4.1

Annex I, paragraph 2.4.1, Table I.2.4:

Table I.2.4 includes new rows:

Gaseous pollutants RDE, (Type 1A test), and,

PN RDE, (Type 1A test).

However, although there is a footnote (2) under that table it appears not to be used in the table.

The following footnote has NOT been carried over from Regulation 692/2008 to Regulation 2017/xxx

(6) The particulate number RDE test only applies to vehicles for which Euro 6 PN emission limits are defined in Table 2 of Annex I to Regulation (EC) No 715/2007.

ACEA suggests this footnote should be added to Regulation 2017/xxx Figure I.2.4, in order to avoid ambiguity in RDE testing requirements.

It must be clearly noted that the RDE PN test only applies to GDI for the purposes of both measurement of PN and assessment against a CF.

WLTP Regulation 2017/xxx

Annex I, Appendix 6

Various amendments to the Approval characters table in Appendix 6 appear in the WLTP Regulation 2017/xxx, the WLTP Correcting Regulation and the RDE 3 Regulation.

RDE package 3 and WLTP Correction regulation draft both make changes to the Appendix 6 table. It is becoming extremely confusing and there is a high risk of further errors and inconsistencies coming into this table as it expands and expands. The definitions under the table are inconsistent and there are errors (see next row below).

ACEA would suggest that the compete table amendments are addressed in one regulatory act and, since RDE package 3 is tied to the publication of the WLTP regulation, and the WLTP Correcting regulation cannot be published before the WLTP regulation, the COM should put everything in the new Appendix 6 table in RDE package 3.

ACEA has carefully scrutinised the Appendix 6 table and we will provide a correct version for the table based on the COM current proposal for RDE package 3 and we are ready with a revised Appendix 6 table to account for any amendments to RDE package 3.

Annex I, Appendix 6 table:

Missing a step for LCV’s.

For letters BH and BI the column “implementation date: new types” should be 01.09.2020.

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WLTP Regulation 2017/xxx

Phase specific Ki factors

• Technically phase specific Ki-values do not make sense, as long as they are not determined via separate tests (which is not the case and anyway would not improve the final result).

• In addition it would contradict the possibility of carrying over NEDC Ki factors (2 phases), which is allowed for good reasons.

• That is reflected in most parts of the regulation, but unfortunately not in all parts.

• It is proposed to change the below mentioned parts accordingly (delete phase specific Ki, just leave entire Ki for total cycle):

• Paragraph 3.2. in Appendix 1 (Ki-procedure)

• Paragraph 2.5.1.3.1. in TA certificate

• Paragraph 2.1.1.2 in test results

• There maybe more occasions, to be identified.

WLTP Regulation 2017/xxx

Addressing FCHEV

Annex I, Appendix 6 table:

The type approval character for Fuel Cell Vehicles (FCVs) has disappeared in xxx/2017, and PEV character is duplicated.

AY character should be re-assigned to Fuel Cell Vehicles, so this type of vehicles can have a type approval character.

In addition, we believe that the implementation dates of AY (and AX/AZ) should be made consistent with those of the WLTP introduction.

Remark: please refer to EU WLTP#2 kick-off meeting ACEA materials.

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Annex IX, Point 3 (Hydrogen Fuel for Fuel Cell vehicles):

Hydrogen fuel content = min 99.99%

Particulates size = max 10um

Particulates concentration = max 10 ug/l

Total gases = max 100umol/mol

He, N2, Ar = max 100umol/mol

'- GTR#15 and EU Regulation requirements are not aligned.

- As vehicle manufacturers we welcome better Fuel Quality requirements, however we need to be able to source the reference fuel

- Regarding H2 purity requirement, the original ISO14687-2 (2008) mentioned 99.99%, but it was revised to 99.97% from ISO14687- 2(2012) and GTR#15 also mentions it. In this case, 99,99% purity is an unnecessarily high requirement. Our Hydrogen fuel supplier informed us that 99.97% is the technically feasible limit, 99.99% can only be achieved randomly (cannot be guaranteed)

- Regarding particulates, ISO14687- 2(2012) has requirements. However, Hydrogen supplier cannot guarantee them because it is too difficult to measure. Therefore the requirements were not included in GTR#15.

- If 99,99% and particulates requirements are kept, we will struggle to source reference fuels.

=> H2 purity requirement should be aligned with GTR#15/ ISO14687- 2(2012) (99,97%)

=> Particulates requirement should be also aligned with GTR#15 (they should be deleted)

=> GTR#15/ ISO14687- 2(2012) also updated other hydrogen requirements, not up-to-date in xxx/2016 (Total gases, He, N2, Ar)

Remark: please refer to EU WLTP#2 kick-off meeting ACEA materials.

Annex XXI, Sub-annex 8, paragraph 4.2.1.2, Table A8/7

(Calculation of final CS fuel consumption for NOVC-FCHVs)

Step3 on the table requires:

ATCT correction according to paragraph 3.8.2 of Sub-Annex 6a.

We believe this is a copy paste error creating inconsistency in the regulation, as FCHEVs are not in the scope of ATCT correction. ATCT only applies to vehicles with tailpipe CO2, please refer to sub-annex 6 par1.

=> Therefore ATCT correction should be removed from this table

Remark: please refer to EU WLTP#2 kick-off meeting ACEA materials.

Remark: please refer to EU WLTP#2 kick-off meeting ACEA materials.

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WLTP Regulation 2017/xxx

xxx

4. For CO2 and EC the normalised values for CO2 and EC shall be used:

xi = CO2test-i/CO2declared.

xi = ECtest-i/ECDC, COP

In the case of CO2 and EC the factor A is set at 1.01 and the value for L is set at 1. So in the

case of CO2 and EC the criteria are simplified to:

(i) Pass the family if Xtests < A – VAR

(ii) Fail the family if Xtests > A – ((N-3)/13) * VAR

(iii) Take another measurement if:

A – VAR ≤ Xtests < A – ((N-3)/13) * VAR

This form of analysis is totally unsuitable for CO2 emissions as it completely removes any protection against making a false fail decision.

According to Article 13(7) of Regulation (EU) 333/2014, the transfer from NEDC to WLTP should ensure ‘comparable stringency for manufacturers [...]’.

This breaks the rules of comparable stringency since manufacturers would be forced to apply a safety margin to all CO2 values.

WLTP Regulation 2017/xxx

For example, Approval documentation paragraph 4.6

4.6. Gear ratios

Gear Internal gearbox ratios(ratios of engine to gearbox output shaft revolutions)

Final drive ratio(s) (ratio of gearbox output shaft to driven wheel revolutions)

Total gear ratios

Maximum for CVT

1

2

3

…

Minimum for CVT

Reverse

It was agreed in the EU-WLTP TA Experts TF that the ratio of the reverse gear is irrelevant to all type approval and should be removed from the manufacturer’s information document.

ACEA asks that all tables delete all references to reverse gear – any change to a reverse gear ratio would otherwise require a new approval, which is ludicrous.

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WLTP Regulation 2017/xxx

More definitions

General comment: There are now definitions in the Act, in Annex IIIA and in Annex XXI without any reference to where each one applies. This gives no legal certainty.

Annex IIIA Annex XXI

1.2.1. “Accuracy” means the deviation between a measured or calculated value and a traceable reference value.

3.1.1. "Accuracy" means the difference between a measured value and a reference value, traceable to a national standard and describes the correctness of a result. See Figure 1.

Two different definitions for the same term (‘accuracy’) in one piece of legislation?

1.2.4. “Calibration” means the process of setting the response of an analyser, flow-measuring instrument, sensor, or signal so that its output agrees with one or multiple reference signals.

3.1.2. "Calibration" means the process of setting a measurement system's response so that its output agrees with a range of reference signals.

Two different definitions for the same term (‘accuracy’) in one piece of legislation?

1.2.12. “Exhaust emissions” means the emissions of particles, characterized as particulate matter and particle number, and of gaseous components at the tailpipe of a vehicle.

3.5.11. "Exhaust emissions" means the emission of gaseous, solid and liquid compounds.

Two different definitions for the same term (‘accuracy’) in one piece of legislation?

1.2.18. “Particle number” (PN) means as the total number of solid particles emitted from the vehicle exhaust as defined by the measurement procedure provided for by this Regulation for assessing compliance with the respective Euro 6 emission limit defined in Table 2 of Annex I to Regulation 715/2007.

3.6.1. "Particle number emissions" (PN) means the total number of solid particles emitted from the vehicle exhaust quantified according to the dilution, sampling and measurement methods as specified in this Annex.

Two different definitions for the same term (‘accuracy’) in one piece of legislation?

1.2.19. “Precision” means 2.5 times the standard deviation of 10 repetitive responses to a given traceable standard value.

3.1.9. "Precision" means the degree to which repeated measurements under unchanged conditions show the same results (Figure 1) and, in this Annex, always refers to one standard deviation.

Two different definitions for the same term (‘accuracy’) in one piece of legislation?

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1.2.25. “Span” means the calibration of an analyser, flow-measuring instrument, or sensor so that it gives an accurate response to a standard that matches as closely as possible the maximum value expected to occur during the actual emissions test.

3.1.12. "Span" means to adjust an instrument so that it gives a proper response to a calibration standard that represents between 75 per cent and 100 per cent of the maximum value in the instrument range or expected range of use.

Two different definitions for the same term (‘accuracy’) in one piece of legislation?

WLTP Regulation 2017/xxx and,

WLTP Correcting Regulation

Annex V and Annex VIII

WLTP Regulation 2017/xxx:

Annex V, paragraph 2.3:

2.3. The road load coefficients to be used shall be those for VL. If VL low does not exist the VH road load shall be used.

WLTP Correction Regulation:

Annex V, paragraph 2.3:

2.3. The road load coefficients to be used shall be those for vehicle low (VL). If VL low does not exist the vehicle high (VH) road load shall be used. VL and VH are defined in point 4.2.1.2 of sub-Annex 4 to Annex XXI.

WLTP Correction Regulation:

Annex VIII, paragraph 3.3:

3.3. The road load coefficients to be used shall be those for vehicle low (VL). If VL low does not exist the vehicle high (VH) road load shall be used. VL and VH are defined in point 4.2.1.2 of sub-Annex 4 to Annex XXI.

Annex V, paragraph 2.3:

“2.3. In the absence of road load coefficients derived for type-approval to Regulation 692/2008, the road load coefficients to be used shall be those for VL vehicle low (VL). If VL vehicle low (VL) does not exist the vehicle high (VH) road load shall be used. VL and VH are defined in point 4.2.1.2 of sub-Annex 4 to Annex XXI.”

Annex VIII, paragraph 3.3:

“3.3. In the absence of road load coefficients derived for type-approval to Regulation 692/2008, the road load coefficients to be used shall be those for VL vehicle low (VL). If VL vehicle low (VL) does not exist the vehicle high (VH) road load shall be used. VL and VH are defined in point 4.2.1.2 of sub-Annex 4 to Annex XXI.”

The poor terminology VL and VH is a minor point but the more critical point is that Type 6 tests may have to be repeated merely due to minor changes in road load.

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WLTP Regulation 2017/xxx and,

WLTP Correcting Regulation

Directive 2007/46

Point 6.6. to 6.6.5. shall be replaced as follows:

“6.6. Tyres and wheels

6.6.1. Tyre/wheel combination(s)

6.6.1.1. Axles

6.6.1.1.1. Axle 1: . . . . . . . . . . . . . ..

6.6.1.1.1.1. Tyre size designation:………….

6.6.1.1.1.2. Load-capacity index:…………..

6.6.1.1.1.3. Speed category symbol (for tyres of category Z intended to be fitted on vehicles whose maximum speed exceeds 300 km/h equivalent information shall be provided):………….

6.6.1.1.1.4. Wheel rim size(s):…………

6.6.1.1.1.5. Wheel off-set(s):…………

It would be sensible to include some text to clarify that these new sub-paragraphs are to be included in the manufacturer’s information documents of Regulations other than this one where 6.6 occurs.

48. Exhaust emissions (m)(m1)(m2):

Number of the base regulatory act and latest amending regulatory act applicable: …

1.1. test procedure: Type I or ESC ( 1 )

CO: … . HC: … . . NOx : … . HC + NOx : … . Particulates: …. .

Smoke opacity (ELR): … (m–1)

This section can be deleted as the ESC test has been removed from legislation.

The light duty type 1 test could be integrated in the results from WHTC

2.1. test procedure: ETC (if applicable)

CO: … NOx: … NMHC: … THC: … CH4: … Particulates: …

This section can be deleted as the ETC test has been removed from legislation

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49. CO2 emissions/fuel consumption/electric energy consumption (m) (r):

1. all power trains, except pure electric vehicles (if applicable)

NEDC values CO2 emissions

Fuel consumption in case of emission testing according to Regulation (EC) No 692/2008

This removes the fuel consumption values for NEDC as soon as a vehicle is approved to WLTP. This contradicts the communication on labelling from DG-CLIMA.

Update: the adopted DG-CLIMA implementing regulation Annex says:

“5. RECORDING OF DATA

The type approval authority or the designated Technical Service shall ensure that the following information is recorded:

(e) the NEDC CO2 (all phases and combined) and fuel consumption values (all phases and combined) determined in accordance with point 4.2 of this Annex, in entry 49.1 of the certificate of conformity as specified in Annex IX to Directive 2007/46/EC.”

Therefore the text “in case of emission testing according to Regulation (EC) No 692/2008” should be deleted from the CoC

Verification Factor:

In the type-approval documentation, the verification factor appears to have been cut& paste from M1 and N1 to several other vehicle categories where they are irrelevant.

Please check and delete “verification factor” where they are irrelevant.

WLTP Regulation 2017/xxx and,

Annexes XIX and XX

Annexes XIX and XX were missing from the WLTP Regulation adopted by TCMV on the 14 June 2016 TCMV website.

Annex XIX should be reserved, but the absence of Annex XX suggests that the member states in TCMV all voted for the deletion of engine power measurement.

Can Commission please clarify?

WLTP Regulation 2017/xxx

More definitions

3. Definitions For legal security, all definitions should appear in the same area of a legislative act.

3.2.19. "Target road load" means the road load to be reproduced.

3.2.19. "Target road load" means the road load to be reproduced on the chassis dynamometer.

6.1. Limit values

Limit values for emissions shall be those specified in Annex I of Regulation (EC) No 715/2007.

Should the specific table in Annex I be referred to?

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5.1.1.1. The road load force for an individual vehicle shall be calculated using the following equation:

. . . . .

RR is the tyre rolling resistance of the individual vehicle of the road load matrix family, kg/tonne;

RR is the tyre rolling resistance class value of the individual vehicle of the road load matrix family, kg/tonne;

5.1.2.1. The running resistance for an individual vehicle shall be calculated using the following equation:

. . . . . .

RR is the tyre rolling resistance class value of the individual vehicle of the road load matrix family, kg/tonne;

8.2. Chassis dynamometer load setting using the torque meter method

This method is applicable when the running resistance is determined using the torque meter method described in paragraph 4.4. of this Sub-Annex.

In the case of a road load matrix family, this method shall be applied when the running resistance of the representative vehicle is determined using the torque meter method as specified in paragraph 4.4. of this Sub-Annex. The target road load values are the values calculated using the method specified in paragraph 5.1. of this Sub-Annex.

8.2. Chassis dynamometer load setting using the torque meter method

This method is applicable when the running resistance is determined using the torque meter method described in paragraph 4.4. of this Sub-Annex.

In the case of a road load matrix family, this method shall be applied when the running resistance of the representative vehicle is determined using the torque meter method as specified in paragraph 4.4. of this Sub-Annex. The target running resistance values are the values calculated using the method specified in paragraph 5.1. of this Sub-Annex.

WLTP Correcting Regulation

Amendments to 582/2011

In Annex 3 of the WLTP Correction regulation, point (2) addresses Annex II, point 1 of Appendix 1:

“(2) Annex II, point 1 of Appendix 1 is replaced by the following:

"1. INTRODUCTION

This Appendix describes the procedure to determine gaseous emissions from on vehicle on-road measurements using Portable Emissions Measurement Systems (hereinafter ‘PEMS’). The pollutant emissions to be measured from the exhaust of the engine include the following components: carbon monoxide, total hydrocarbons and nitrogen oxides for compression ignition engines and carbon monoxide, non-methane hydrocarbons, methane and nitrogen oxides for positive ignition engines. Additionally, carbon dioxide shall be measured to enable the calculation procedures described in Section 4.”

Wrong. The proposed text for point 1 corrects an error (i.e. “section 5” should be deleted) but what is now confusing is if sub-paragraphs 2 and 3 of point 1 are being deleted, because that has consequences regarding PEMS measurement equipment purchased.

Keep paragraphs 2 and 3 of point 1, as follows:

"(2) The first sub-paragraph of point 1 of Appendix 1 to Annex II is replaced by the following:

1. INTRODUCTION

This Appendix describes [...] the calculation procedures described in Section 4.”