WLTP: will the real winners be PHEVs?

n97 mini

Panic starting to set in about the switch-over to WLTP testing to establish economy/CO2 figures. The big losers are possibly going to be diesels, but it's also looking like "self-charging" hybrids are going to lose out: the Prius will no longer be exempt from the London congestion charge, for example (limit is 75g CO2/km, Prius is going from 70g under NEDC to 78g under WLTP).

But looking at PHEVs, they're still well below any real threshold. The Outlander is going from 41g to 46g (while at the same time getting a 2.4L engine, up from 2.0L). So are we going to see an explosion in PHEVs as they'll be the next big thing for chape tax?

(EVs have no CO2 emissions, so tax and VRT rates are unaffected)

ELM327

It looks like they haven't removed the fact that the PHEV can start with a full "tank" of electricity and that screws up their figures.
If the test range is say 50km and an outlander can do 40km on EV it can do 10mpg on petrol and then get a great emissions score which is irrelevant in the real world unless you happen to drive exactly 50km.

Lossy

A difficult one to nail down.
Real world PHEV emissions are so varied.
My wife could mon - fri commute with 50% all electric and 50% hybrid. I could theoretically mon - fri on all electric and i guess there could be some out there not even bothering to charge up.

FriendsEV

ELM327 wrote: »

It looks like they haven't removed the fact that the PHEV can start with a full "tank" of electricity and that screws up their figures.
If the test range is say 50km and an outlander can do 40km on EV it can do 10mpg on petrol and then get a great emissions score which is irrelevant in the real world unless you happen to drive exactly 50km.

50km a day X 7 is pretty real world

18k km a year is European average?

ELM327

FriendsEV wrote: »

50km a day X 7 is pretty real world

18k km a year is European average?

But do they all plug in to allow each trip on EV?

Shefwedfan

The problem with any test is that it cannot take into consideration every single person's trip or usage. So they need to take averages

So on average around the World most people live around a city. Most people travel short distances and lots of them. Very few travel long distance. SO you put the test around that.

Take Ireland, majority of people live in the Dublin area. Most people are doing less than a 50km trip to work and some are even doing less round trip. So to test for that you take a 50km trip. If a PHEV can do most of that on battery then of it will be better but if most people in the city are also going to run on battery for the day it makes sense to reward them with lower tax.

In the end what the goal is to remove the fumes from cars. If you have 100,000 PHEV's going into Dublin tomorrow morning instead of 100,000 diesel/petrol I would imagine the air would be a lot cleaner.

Longer term when the battery technology advances more then the requirements will grow larger, or I hope they do like the UK have indicated, then a PHEV will required to go further.

Would I love to see 100,000 BEV going into Dublin tomorrow, yes I would but the range is not available for this to happen.

The i3 is really unique in this regard, longer range than some BEVs and little generator than can go for 100-140 Kms, 8 seconds to fill the tank and you're on the road again, brilliant car to be honest, It's a shame Nissan didn't release the Leaf with an optional generator it could have got far more people into the idea of EV.

KCross

I was butchering that other thread on this emission stuff so I said I better move over here...

liamog wrote: »

Right now there is zero reasons for a manufacturer to sell an EV other than demand. From 2020 manufacturers have to reduce their fleet emissions. Each 1g CO2 per km costs them €95 per vehicle should. Every zero emission vehicle counts twice when calculating the average. If you sell 2,000,000 Vehicles and reduce your emissions by 7.5g by selling 200,000 EVs you can avoid €1.4 Billion in fines.

To me that sounds like a great reason to start pricing EVs at a lower level to sell to the masses.

KCross wrote: »

Its a fair point but let me throw in an alternate possibility....

There are other ways to reduce emissions besides investing in BEV's... look at Toyota. No fines on the horizon, already meeting the upcoming emissions requirements AFAIK(?).

BMW have said they are investing in hybrid and PHEV before BEV. Im not agreeing that that is the way forward, just saying that that is how manufacturers are likely to see things.

If you have an ICE car with twice the margin of a BEV you might just decide to take the hit on the emissions fines. Selling more BEV's (if you can even get the batteries) might not actually improve your financial situation at all if investing in hybrid's gets you to your target anyway.

I dont know but they are heavily invested and indebted to ICE.... more hybrid and PHEV is more likely imo with continued high BEV prices because they will be relatively low volume in the overall mix.... even for VAG its only going to hit 10% of their output in 2025 and they are spending billions. The rest are going to be lagging behind that.

So, while your point makes sense I'm not holding my breath on big price drops until I actually see them.

unkel wrote: »

77g C02 + 25% = 96 which means an emissions fine. And that's the Corolla. I'd say the average overall emissions from all Toyotas sold in the EU this year will be higher than this

And I presume the cut off figure of 95g CO2/km will be dropping in future? Hybrids won't make it without fines.

While looking at this WLTP stuff for 2021 one thing that Im unsure of is that I think the 95g figure is based on the NEDC cycle, not WLTP! :eek:

Do you know liamog?

Some of the details are here
https://ec.europa.eu/clima/policies/transport/vehicles/cars_en

They mention how they progressively moved the targets down but dont mention anything about NEDC vs WLTP which would suggest its NEDC as those targets have been reducing for 10yrs+ which pre-dates WLTP.

I see this article here
https://www.dieselnet.com/standards/eu/ghg.php

Specifically this section...

Emission Targets. Passenger cars (vehicle category M1) must meet the following fleet-average emission targets (NEDC test):

2015: A CO2 emission target of 130 g/km must be reached by each vehicle manufacturer by 2015 using vehicle technology [2874]. (To meet the EU CO2 emission target of 120 g/km, a further emission reduction of 10 g/km was to be provided by additional measures, such as the use of biofuels.)
2020/2021: A CO2 emission target of 95 g/km must be met by 95% of each manufacturers’ new passenger cars registered in 2020, and by 100% of cars from 2021 onwards [3047].
2025: A CO2 emission target equal to a 15% emission reduction from the 2021 target [4202]. Using the current 2021 NEDC target of 95 g/km as a baseline, this would translate to 80.8 g/km.
2030: A CO2 emission target equal to a 37.5% emission reduction from the 2021 target [4202]. Using the 2021 NEDC target as a baseline, this would translate to 59.4 g/km.

If that is right Toyota would have no problem meeting their targets for 2021 with the new Corolla at 77g(NEDC). Its 102g WLTP. It would even pass 2025 targets but eventually get unstuck for 2030.

Have I read that wrong?

I also note that the super credits apply if your car is <50g, which most PHEV's meet so I can definitely see them going that route to meet their targets.... BMW have clearly stated that that is their strategy.


One other article I came across if you have the time to read it. It details how manufacturers are still manipulating the system (even WLTP). Not sure how accurate or biased or otherwise that site is.
https://www.transportenvironment.org/sites/te/files/Ending%20the%20CO2%20cheating_FINAL%20290818.pdf

Mike9832

Don't see much coming in 20/21 compared to BEV to suggest this

Only BMW with a decent line up that I can see

They are a great if done right

15kWh ( useable) for 100km range, powered by a 140bhp electric motor would make a great machine

I'd take a 15kWh pluggin like that over a 50kWh EV in Focus dimensions

Instead we get 7kWh useable for 40km range, powered by a dog slow 80bhp electric motor, that is limited to 120kmh and requires the petrol engine to run for heating

If they iron out those flaws and price is less than full EV they have a big place

September1

ELM327 wrote: »

It looks like they haven't removed the fact that the PHEV can start with a full "tank" of electricity and that screws up their figures.
If the test range is say 50km and an outlander can do 40km on EV it can do 10mpg on petrol and then get a great emissions score which is irrelevant in the real world unless you happen to drive exactly 50km.

First run is started with full tank and then last cycle is purerly ICE powered, then they calculate emissions using ratio of EV to total range. This killed BMW PHEVs, until they upgraded them by growing batteries and shrinking fuel tanks.

unkel

September1 wrote: »

First run is started with full tank and then last cycle is purerly ICE powered, then they calculate emissions using ratio of EV to total range. This killed BMW PHEVs, until they upgraded them by growing batteries and shrinking fuel tanks.

Any link to this test procedure? I'm not sure if you can even switch off the EV system in every PHEV (to run it purely ICE powered)

September1

unkel wrote: »

Any link to this test procedure? I'm not sure if you can even switch off the EV system in every PHEV (to run it purely ICE powered)

No, there is some description here -> https://www.vda.de/en/topics/environment-and-climate/Global-WLTP-roll-out-for-more-realistic-results-in-fuel-consumption/WLTP-How-are-plug-in-hybrids-and-electric-cars-measured.html


It still raises couple more questions, like how is range calculated and how they know battery is empty.

zilog_jones

I assume they mean "empty" as in EV mode operation is no longer available, which may be indicated by the EV range display going to 0 or disappearing entirely, or some other indication. That page says specifically:

"This is followed by a measurement with an empty battery in which the drive energy originates solely from the combustion engine and regenerative braking."

So this would suggest the vehicle functioning in a hybrid mode, which is usually the default operation for parallel or series-parallel hybrids when the SOC reaches the low threshold for EV operation, which could in reality be something like 20-30% SOC.

I've noticed this also suggests NEDC figures for fleet averages will be used until 2021: https://wltpfacts.eu/wltp-test-co2-targets/
I read other things suggesting that also was going to change in September 2019 to WLTP, but I guess not.

KCross

Mike9832 wrote: »

They are a great if done right

15kWh ( useable) for 100km range, powered by a 140bhp electric motor would make a great machine

I'd take a 15kWh pluggin like that over a 50kWh EV in Focus dimensions

Instead we get 7kWh useable for 40km range, powered by a dog slow 80bhp electric motor, that is limited to 120kmh and requires the petrol engine to run for heating

If they iron out those flaws and price is less than full EV they have a big place

See my Merc thread
https://www.boards.ie/vbulletin/showthread.php?p=111017528#post111017528

Not quite hitting all your requirements but it is a step in the right direction on range and speed and I'm sure it will be much more refined than the asian counterparts we have to date. Will be interesting to see what its like.

KCross

zilog_jones wrote: »

Yeah it's not clear what's going to happen after 2021. Like are they still going to perform NEDC tests for new cars after September so they can calculate these averages?

By my reading of it they will have a multiplier to translate the already agreed NEDC figure to a WLTP figure so the 95g will be translated to a higher WLTP figure and all new cars will have WLTP figures that need to meet that requirement.

zilog_jones wrote: »

Throwing larger batteries at non-plugin hybrids isn't going to make them more efficient. They need more PHEVs and ultimately BEVs.

Well, if Toyota can deliver a Corolla today with an NEDC figure of 77g (significantly beating the agreed requirements) then the likes of Ford, Mazda etc just need to add more batteries to their cars to meet the requirements too?

Whether larger batteries being added to a Corolla further reduces its 77g figure is unknown. The further the car can go in EV mode surely affects the test result?

zilog_jones

KCross wrote: »

Whether larger batteries being added to a Corolla further reduces its 77g figure is unknown. The further the car can go in EV mode surely affects the test result?

The test cycle far exceeds the typical 2-3 km EV-only range of a petrol hybrid, and the driving conditions undoubtedly mean the ICE will be required for acceleration frequently. If you add a larger battery, it's not going to gain more SOC unless it's designed to run the ICE to charge it for longer - which will mean more fuel consumption. They stick to around 1-2 kWh batteries for a reason - you won't gain from much more unless you're doing hill descents all the time.

KCross

liamog wrote: »

It's not possible for them to be ahead of their 2025 Target.
The target requires a fleet reduction of 15% by 2025 and 37.5% by 2030.
The percentage will be taken from the achieved emissions in 2021. So for example if Toyota hit 89g/km by 2021, they'll need to achieve 75g/km by 2025. It's another reason we may see manufactures game the system up to 2022. You need to be under the your 2020 target, but not too far under.

I dont believe that's how it works based on the EU doc that I read

Goto Annex I here:
https://data.consilium.europa.eu/doc/document/ST-5091-2019-EXT-1/en/pdf

You'd need to be a mix of a lawyer and a mathematician to understand some of the formulas but it does not appear to work the way you suggest.

What you suggest would actually reward the manufacturers who have sat on their hands in relation to emissions and penalise those who have actively improved theirs…. Which wouldn't make sense.


Bear with me…. By my reading of it it works like this for 2021…

- In 2020 each new model a manufacturer sells gets a "specific emissions of CO2" target assigned to it using this formula
CO2 = 95 + a · (M – M0)
M=Mass in running order of the vehicle in kilograms (kg)
M0=1379.88kg
a=0.0333

So, for a start the 95g figure is not a hard figure that they all have to reach. If you are a manufacturer that supplies primarily heavy diesel SUV's (Daimler, BMW etc) then your target will be higher than 95g as you are allowed more emissions (3.3g/100kg above the average) the heavier your car is.

Once you get this target for each of your models you then calculate your weighted average based on how many of each you sell and that's your overall figure for 2021 and as long as its under your target you're golden. It all centrers around 95g but it could be 92g or 102g also depending on the weight of your cars.


Interestingly, using Toyota again as an example, its M figure for the Corolla is 1380kg so its specific emissions of CO2 figure will be 95g and since it is its best selling car (in Ireland anyway) this year and its in the middle of its range of cars with some heavier, some lighter it seems that Toyota's overall target will be fairly close to 95g and the Corolla is currently sitting at 77g in its NEDC test so well exceeding the requirement for 2021. Thats all OK and easy enough to understand/calculate.



Then the 2025 bit, which is the crucial bit really…

A WLTP reference value for each model is calculated in 2021 and a 15% reduction (average) on that is required. It doesn't mean you take the measured CO2 value and take 15% off that. Big difference!!!!!

The formula is
𝑾𝑳𝑻𝑷𝑪𝑶𝟐𝒎𝒆𝒂𝒔𝒖𝒓𝒆𝒅 ∙ (𝑵𝑬𝑫𝑪𝟐𝟎𝟐𝟎𝑭𝒍𝒆𝒆𝒕 𝑻𝒂𝒓𝒈𝒆𝒕/𝑵𝑬𝑫𝑪𝑪𝑶𝟐 )+ "some weight adjustments"

Again, for Toyota (using Corolla as its average) that roughly would be 102*(95/77)=125g which would be its "EU fleet-wide target2021" on page 83 of the doc above and a 15% reduction has to be applied to that which would give it a figure of 106g (WLTP) being its required target come 2025.

The Corolla has an on the road WLTP figure of 102 today so already exceeding the 2025 target.

I'm sure I'll be out a few figures here and there but I'm in the right ball park. Toyota, by my reading of it, are well ahead of the game with others looking at billions in fines.

Looking at a Volkswagen Golf TDi and its starting out with an NEDC figure of 109g today (130g WLTP) and you can understand why VAG had to do something and push in some BEV's asap. They are still in for a harsh fine whatever they do.


There's a lot to take in there but have a read of Annex I and tell me if and where I'm wrong, but I dont think I am.

unkel

Lucky timing for Toyota too. First they were unable to produce a modern diesel, so they had to buy them from BMW, which wasn't very profitable for Toyota. Made more sense to ditch diesel altogether and make "self charging" hybrids. Sell them at high enough prices (base price of the hybrid C-HR, a tiny crossover the size of Kona is a staggering €32k, Prius hybrid also base price of €32k :eek:) and profitability is fine. And the up and coming and looming emissions fine system sorted

Will they be quick enough getting BEVs out too by the time ICE will be banned though? Norway 2025, Netherlands 2026, many other countries 2030? They don't seem to have access to enough batteries.

KCross

unkel wrote: »

Will they be quick enough getting BEVs out too by the time ICE will be banned though? Norway 2025, Netherlands 2026, many other countries 2030? They don't seem to have access to enough batteries.

Personally, I dont think ICE will be banned by then. Market realities will dictate that it has to continue. It takes several years to ramp up the battery factories and there would need to be a **** load of them going up now to meet those targets. It aint going to happen.

Just think again.... VW has put the most money on the line and its ambitous plan is that 10% of its output will be BEV by 2025. If VW cant sell the other 90% do you think Merkel will let VW go to the wall.... right ya!


And for 2030 the EU is simply talking about further % reductions in CO2 targets. They arent talking about bans on ICE. Norway, locally, can ban ICE if it wants but the rest of the world is not going to follow, imo.

The fines are very harsh though and thats going to be a major stumbling block for alot of them.


I think Toyota will produce BEV's when the next battery tech comes through. I think it just doesnt believe in the current tech. I'd bet they will have something prior to 2025 and they have the EV drivetrain experience and scale to make it happen.

unkel

KCross wrote: »

I think Toyota will produce BEV's when the next battery tech comes through. I think it just doesnt believe in the current tech. I'd bet they will have something prior to 2025 and they have the EV drivetrain experience and scale to make it happen.

Supercapacitors at commercially viable cost by 2025? That's a pretty tall order!

KCross

unkel wrote: »

Supercapacitors at commercially viable cost by 2025? That's a pretty tall order!

I've no idea what the next breakthrough is going to be.... isnt there graphene and solid-state and a bunch of other things being researched. Could be any of those or something we havent even heard of.

Tesla are gone the Supercapacitor route with the Maxwell acquisition.... remains to be seen whether that replaces or just enhances Li-ion tech. I remember an analysis of supercapacitors at the time saying that it would be used as an enhancement to allow faster charge times and improve performance and take the pressure off the main battery but not completely replace the HV battery.

Its a long way off making it into an every mans car either way!

Mike9832

unkel wrote: »

Supercapacitors at commercially viable cost by 2025? That's a pretty tall order!

Toyota will be showing off solid state at the Tokyo Olympics in 2020

They ain't sleeping, far from it

https://europe.autonews.com/automakers/toyota-pulls-forward-electrification-plan-eyes-solid-state-battery-next-year

unkel

From your link:

But EVs have taken on fresh priority. As part of the new plan, Toyota plans to introduce an ultra-compact, two-seat EV in Japan in 2020. It will have a range of 100 kilometers (62 miles).

That's clever too. Cheap 2 seater that can do most people's commute.

KCross

Shefwedfan wrote: »

Carmakers are throttling demand to avoid over-performing on average fleet emissions in 2021, on which future CO2 goals will be based.

The first half of that sentence is true. The second bit isnt or is at least misleading.

The 2020 targets were already agreed and set several years ago.

The 2025 and 2030 targets are a percentage reduction from those predefined figures (calculated on a per manufacturer basis based on their fleet)

If a manufacturer exceeds their target in 2020 they dont get hammered for it in 2025 and 2030. They still have the same predefined figure to achieve in 2025(15%) and 2030(37.5%)


The only thing the manufacturers can control is their level of fines and of course once they hit their targets they have no incentive to sell EV for the rest of that year if their ICE counterparts have better margin, so it is to be expected that they would throttle EV deliveries in that case.

liamog

@KCross, your percentages are correct, but the important thing is the baseline

Target levels
Regulation (EU) 2019/631 sets new EU fleet-wide CO2 emission targets are set for the years 2025 and 2030, both for newly registered passenger cars and for newly registered vans.

These targets are defined as a percentage reduction from the 2021 starting points:

Cars: 15% reduction from 2025 on and 37.5% reduction from 2030 on
Vans: 15% reduction from 2025 on and 31% reduction from 2030 on
The specific emission targets for manufacturers to comply with, are based on the EU fleet-wide targets, taking into account the average test mass of a manufacturer's newly registered vehicles.

https://ec.europa.eu/clima/policies/transport/vehicles/regulation_en

KCross

liamog wrote: »

@KCross, your percentages are correct, but the important thing is the baseline



https://ec.europa.eu/clima/policies/transport/vehicles/regulation_en

Yes, and those target were set years ago.

See the top of the page you posted

The new Regulation maintains the targets for 2020, which were set out in the former Regulations.

The target each manufacturer needs to hit this year is a predefined number. Its not a case of sell anything you like and then we will use that figure for later calculations.

The target they need to hit this year is predefined, years ago.
And 2025 and 2030 are simply set % reductions from that. They cant manipulate it. All they can do is reduce their level of fines and they can then throttle EV delivery accordingly.

liamog

It's pretty easy to manipulate.

Simplfying to remove the weight component, as a manufacurer of automobiles I can achieve 80g/km in 2021. I pay no fines because I'm under the 95g/km target. In 2025 my target is now 68g/km (15% reduction from 2021).
My competitor sells just enough EVs, and only achieves 95g/km, they also pay zero fines. Their target in 2025 is now 80.75g/km.

KCross

liamog wrote: »

It's pretty easy to manipulate.

Simplfying to remove the weight component, as a manufacurer of automobiles I can achieve 80g/km in 2021. I pay no fines because I'm under the 95g/km target. In 2025 my target is now 68g/km (15% reduction from 2021).
My competitor sells just enough EVs, and only achieves 95g/km, they also pay zero fines. Their target in 2025 is now 80.75gkm.

Thats where you are wrong though AFAIK.

If your target for 2020 is 95g (predefined and set several years ago) and you hit 80g your target for 2025 is 15% off your 2020 target(95g) not 15% reduction from what you actually achieved in 2020 (80g). Thats the point.

So in your example the manufacturers target for 2025 is 80.75g.

liamog

Ok, because I'm interested in this

The target for 2025 is outlined in 6.1.1 of Part A of Annex I of REGULATION (EU) 2019/631 (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019R0631&from=EN)

The details are in the linked regulation, but effectively the target for 2025 is defined as

Target2025 = Target2021 x (1 - 0.15)

Where we seem to disagree is what Target2021 is.
It's defined in the regulation as

Target2021 = WLTPCO2 * (NEDC2020TARGET/NEDCCO2) + 0.0333 (SpecificManufacturerAvgMass/AllManufacturerAvgMass)

I'm going to assume equal mass, and NEDC2020Target is 95g/km.
So that means there are two variable in Target2021. WLTPCO2 and NEDCC02.
These are defined as

"WLTPCO2" is the average, for each manufacturer, of the measured CO2 emissions combined of each new passenger car registered in 2020, as determined and reported in accordance with Article 7a of Implementing Regulation (EU) 2017/1153;

"NEDCCO2" is the average specific emissions of CO2 in 2020 determined in accordance with Implementing Regulation (EU) 2017/1153 and calculated in accordance with the second indent of Article 4(3) of this Regulation, without including CO2 savings resulting from the application of Articles 5 and 11 of this Regulation;

Articles 5 and 11, deal with super credits and eco innovations. They are excluded from the NEDCCO2 target.

So basically, your 2021 target is based on your 2020 achievement, and your 2025 target is based on 85% of the 2021 target.

KCross

liamog wrote: »

Ok, because I'm interested in this

The target for 2025 is outlined in 6.1.1 of Part A of Annex I of REGULATION (EU) 2019/631 (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019R0631&from=EN)

The details are in the linked regulation, but effectively the target for 2025 is defined as



Where we seem to disagree is what Target2021 is.
It's defined in the regulation as

Target2021 = WLTPCO2 * (NEDC2020TARGET/NEDCCO2) + 0.0333 (SpecificManufacturerAvgMass/AllManufacturerAvgMass)

I'm going to assume equal mass, and NEDC2020Target is 95g/km.
So that means there are two variable in Target2021. WLTPCO2 and NEDCC02.
These are defined as



Articles 5 and 11, deal with super credits and eco innovations. They are excluded from the NEDCCO2 target.

So basically, your 2021 target is based on your 2020 achievement, and your 2025 target is based on 85% of the 2021 target.

liamog, moving here as the eGolf owners will lose the will to live if we have a EU regulation debate in their thread!

Some light reading for you here
https://theicct.org/sites/default/files/publications/EU-LCV-CO2-2030_ICCTupdate_201901.pdf

The 2020 target is based on the 95g figure (already set per manufacturer regardless of what they sell this year) and manufacturers have to hit that target or face massive fines.

The formula you have referenced is to set the 2021 figure in WLTP terms (because thats what the EU are now pushing... WLTP, not NEDC which is what the 95g is), which involves adding a multiplier based on real world emissions of cars sold in 2020, but the biggest part of that formula is still the 95g figure that has to be met.

Once they do the multiplier they will then apply the 15% and 37.5% figures to that for 2025 and 2030 respectively but the 95g is still the predominant figure in the calculations and has to be met. Once a manufacturer is confident they can meet their goal they will of course throttle EV sales.

TL;DR... it is not the case that they only look at 2020 sales and that decides everything for 2025 and 2030. Thats not true. Hope that makes sense.

liamog

Mod Note: Moved the posts from e-Golf thread

liamog

Ok I can see where I made a mistake, the bit I was looking at was dealing with calculating the NEDC to WLTP ration and then converting the fleet wide 95g/km NEDC to a fleet wide WLTP number.

So effectively it's 15% reduction from 95g/km but with a ratio calculated to work out what that is in WLTP terms.
If you wanted to game the system you'd have to get every manufacturer on board to manipulate the NEDC results and WLTP to make the ration more favourable.