Quote:
Originally Posted by P1 Motorcars
I know what you're saying and I saw your responses to my other comments. Here's what got my curiosity. It was comments like these:
- "1. The Member State which grants an EC type-approval shall take the necessary measures in accordance with Annex X to verify..."
- "When a Member State which has granted an EC type-approval ... "
Is there such a thing as a member state which doesn't grant EC type approval? What happens when a vehicle fails to gain certification because it doesn't pass section 8.1 during testing? Does that mean that car can't be sold in the EU? I still have my doubts.
When I made that post, I almost highlighted the section now appearing in RED. But I thought it was obvious enough, that I didn't think I would have to. When I read this, here's what it meant to me. Section 8.1 discusses the variance allowed for the specific engine submitted for test. Section 8.2 defines the variance allowed to ensure conformity of production. Yes both are required (who thought I said they weren't?), but 8.1 is the specific engine submitted for test, and 8.2 is to ensure conformity of production.
Once again, I'm going to mention the irony of others arguing against SAE/EEC weather correction formulas while at the same time arguing for the inviolate law of EEC regulations whose enforcement depends on the accuracy of these same weather correction formulas.
I don't remember if they were your comments or not. I wasn't singling out any individual just making a general comment and admitting I only saw two posts. If it all got corrected in the end then it all worked out. |
Many member states don't issue type approvals. Germany, Italy, France, England are the main countries issuing type approvals. That's because that's where manufacturers mostly are placed and where there are technical services (test laboratories) placed to do this. If a car model has received type approval, that means it can be sold and registered in any EU country (just like a US car that has the "This vehicle conforms with all applicable FMVSS standards in place at the date of manufacture" can be sold in every US state. A car can't have more than one EU type approval. If it has a type approval number starting with e1, that means it was issued in Germany.
I see you have your doubts as regards type approval in EU. But, yes I can assure you that a mass produced passenger vehicle in category M1 (a car with a maximum of 9 seats in total) that fails to meet the requirements of the technical directives, can not be registered in member states. There are certain allowances for small volume type approval, one off vehicles and amateur built vehicles. A one off vehicle in category M1 can instead undergo a IVA procedure (Individual Vehicle Approval), but this means that EACH individual car has to be documented according to each of the technical Directives in Annex IV of 2007/46/EC. And that includes engine power as well...
I will once again quote what Directive 2007/46/EC says about the need to comply with the required standards:
Quote:
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3. Member States shall register or permit the sale or entry into service only of such vehicles, components and separate technical units as satisfy the requirements of this Directive.
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EU type approval is the cornerstone of vehicle registration within EU and was introduced as a way of harmonization and free trade of motor vehicles between member states.
As I said previously, type approvals and EU legislation is something I work with on a daily basis. Getting the M3/4 type approved for sale in EU isn't something BMW can opt out of!
As regards the engine power testing, I'm not sure where the confusion is?
The manufacturer has to submit a engine for testing. This has to be measured according to the standards and the entire power curve has to be verified. If the max power is within 2% of the stated hp and if the remaining test points are within 4% of what the manufacturer states, then the engine's factory claimed power can be accepted.
This is 8.1 and concerns the engine submitted for testing. That has to be within 2% of factory claimed max hp.
And then we have 8.2 which concerns conformity of production. This means that when the authority, or technical service, does spot checks during production (which could be today, next month or in two years), the engine they pick for conformity of production (a random engine) has to be within 5% of the approval figure.
For type approval testing, the requirement is a tolerance of max 2% on max power. For the subsequent testing for conformity of production the tolerance is higher at 5%.
Which is why we repeatedly have said that if the S55 indeed is under rated, then that most likely won't be more than by the EU tolerance of 5%.
Since this both IS a legal requirement that BMW needs to adhere to, AND a requirement BMW has adhered to in acquiring EU type approvals for the M3/4, this should lead to the following conclusions:
1. BMW presented a engine (with DME, intake and exhaust systems as per production spec) for type approval testing that was within 2% of the claimed HP
2. The engine submitted for testing was either:
-Completely in conformity with requirements and with the engines subsequently used in production vehicles
-Not in conformity with the engines later used in production vehicles
If BMW have chosen the latter solution, then they are playing a dangerous game as they risk getting caught cheating as soon as conformity of production spot checks take place... To me this seems unlikely and such a policy would result in hugely bad PR for BMW in EU if they are caught cheating (heads would roll at BMW M HQ)!
And I would say that any claim of under rating in the magnitude that is claimed (60-70hp) certainly also HAS to imply wrongdoing by BMW with regards to type approval testing. Unless we are to believe that the engine dyno test is so flawed that it misses the engine's performance in the car by 60-70hp (or 14-16% in this case)... I don't believe that there is anything "magical" happening when the engine is mounted in the car that suddenly increases power by 60-70hp over what it had on the engine dyno! That means that any claim of under rating also needs to consider the likelyhood of BMW knowingly deceiving the governing bodies of all EU countries these cars are marketed in. Yes, that might be the case. Maybe BMW couldn't care less about possible consequences and loosing type approval for the F8x (and thereby be unable to sell the cars in the EU).
And, it doesn't matter who made the comments about MAHA whp. You said that this was "completely misunderstood". I would REALLY like to have your explanation on what was completely misunderstood and what the correct understanding is.
The MAHA dyno is something we genuinely have debated here and are curious to learn more about! Since you claimed that we had completely misunderstood the whp from a MAHA, I'm sure you can explain where we went wrong (at least in the two posts you read)!