Avenir Développement Durable
ADD
Titulaire d’un brevet européen de mesure de la consommation de carburant des véhicules routiers, notre expertise nous implique naturellement dans les différentes propositions de loi qui sont préparées par les instances européennes sur ces sujets.
ID: 519633832153-54
Lobbying Activity
23 Mar 2021
We welcome the new specifications and capabilities of the new "smart" tachographs to be fitted in vehicles as of August 2023.
As a company very active on fuel consumption and CO2 emissions issues, we think that the smart tachograph could also be highly efficient at collecting and transferring Fuel consumption data.
An in-tank real time Fuel volume information could be implemented as a control measurement for HDV fuel consumptions and CO2 emissions.
Combined with a timestamps and geolocation info, a vehicle's fuel volume data could address many regulatory cases such as :
- CO2 and consumption data within the VECTO framework
- Country Fuel taxation for international trips
Besides the legal framework of the tachograph could help the OBFCM challenges regarding data collection and data transfer.
In this context, we highly recommend to assess the opportunity to add CO2 emissions and fuel consumption datas in the future datas added to the smart tachograph.
Ranked at the 3rd world place of Cleantech scale-up, the French company created in 2009 alertgasoil, a universal solution with 58 patents using a set of sensors to measure the real fuel consumption of heavy-duty vehicles and therefore related emissions.
Read full responseResponse to Development of Euro 7 emission standards for cars, vans, lorries and buses
17 Apr 2020
We welcome this opportunity to provide feedback on the roadmap regarding the creation of a new EURO7 emissions standard. We support this initiative as a decisive step to tackle CO2 emissions, in the context of the Green Deal
The option 3 identified into this document considers the introduction of real-world emission monitoring through on-board monitoring (OBM). As an expert regarding this issue, ADD strongly support such an option
We would like to highlight the fact that not all OBM technologies are equal regarding the assessment of CO2 emissions. In our recent work with the EC on the VECTO project, we have isolated 5 criteria regarding the CO2 emission data that we think are necessary to respect: accuracy, Real-time availability, Universality/Standardisation, Independence/Neutrality, Acceptability/Scalability
We know that several methodologies and equipment are being considered by the EC to deliver such a data: ECU-based modelling (FMS/OEM data), Exhaust gas analysis in Lab, Exhaust gas analysis on road (PEMS), Fuel level measurement in-tank, Fuel flow metering
We believe that only a tank-based approach, through an in-tank Fuel volume measurement on the vehicles, is a viable methodology, in order to provide a Fuel consumption and CO2 emissions info, for the following reasons:
• A tank-based Fuel Consumption and CO2 emissions info reflects a “real-world” data with an accuracy > 99%. The precision/accuracy criteria disqualifies ECU-Based modelling, proved to present poor accuracy in addition to involving manufacturers in the calculation
• It monitors fuel inventory real-time and continuously giving the opportunity of a simple and regular data collection. This real time criteria disqualifies technologies involving Lab testing, lacking representativeness of real-world on-road data with highly variable driving parameters
• It is a “plug&play” device allowing retrofitting our first-mount equipment scenarios. Based on a physical volume measurement data, it does not imply any OEM-dependent calculations and therefore provide a unique standardized value for all vehicle. This universality disqualifies ECU modelling solutions that use different calculations depending on brands
• It is fully trustworthy and independent from data provided by manufacturers/OEM equipment. This independence criteria disqualifies ECU-based modelling methodology
• It is using existing vehicle connectors and can be added to the original vehicle gauge, allowing a very cost-effective implementation for 100% of vehicles. This scalability criteria disqualifies expensive equipment like Fuel flow meter or PEMS
Moreover, a fuel-volume measurement approach will allow a breakthrough change to foster optimized driving behaviours and avoid costly events (frauds, thefts and idling) for end-users. During its business activities, ADD is allowing its clients to save up to 15% on fuel costs with such a methodology, which would make it highly accepted by vehicles’ owners and manufacturers. This virtuous cycle should be an objective as the EC could help end- users save money while regulating and reducing CO2 emissions
We developed a universal smart solution, Alertgasoil™, with 58 patents to measure real fuel consumption thanks to sensors directly put in tanks with high accuracy by providing real-time information fully independent from the data given by constructors
As a member of the DG CLIMA OBM-TF, we are glad to share our expertise and advocate towards a scenario where products are designed with what is already out there in terms of hardware, platforms and protocols. This collaborative approach involving all players is set to enhance what is already present on trucks. It is a responsible, sustainable, convenient and cost-effective approach to stimulating progress
We call the EC to monitor the respect of the EURO7 standard by a measurement system providing a real-time information, to make this standard a full success and the way toward a carbon free future for transport
Read full responseResponse to Implementing Regulation on the methodology for assessing the reference CO2-emissions
13 Aug 2019
The implementing regulation proposed by the European Commission as regards the collection of certain data for heavy duty vehicles is a decisive step to tackle CO2 emissions. We acknowledge the fact that the responsibility of monitoring and reporting correct, robust and reliable data is being put into the hands of manufacturers solely. Within such a manufacturer-centred data collection model, some facts and risks must be highlighted:
(1) Reliability of data: energy consumption and CO2 emissions is a very complicated element to monitor especially when it comes to diesel engines. The manufacturers have developed Electronic Control Modules (ECM) able to provide this data using comprehensive algorithms. However, this data has never been studied precisely to qualify its large-scale accuracy. The few studies performed on the topic have shown significant discrepancies between estimated data and physically measured consumption/emission rate (average value of 7.41% ). It is then very unlikely that manufacturer’s data, in order to get a real-world consumption/emission value, will meet the criteria of “robustness”, “quality” and “reliability”.
(2) Model integrity: recent scandals over major automotive brands and their ability to rig data on diesel engines via hidden software or non-real-world representative in-lab testing are also involving business ethics into the CO2 emissions data collection. It might be wise not to rely on data provided by manufacturers to comply with strict regulations.
Avenir Developpement Durable has been proving that another type of CO2 emission data source is possible with an accuracy (>99%) largely superior to data provided by manufacturers. Consumption/emission value of a vehicle can be determined by monitoring the fuel tanks of the vehicle. The depth of the fluid from the surface to the bottom of the tank can provide a volumetric value. This volumetric value coupled with other embedded vehicle’s data can then provide an extremely precise consumption/emissions info. Besides the total independency from manufacturers, this model presents several key advantages:
(1) Easy implementation: immediate, scalable, durable and cost-efficient sensing technology that could easily replace the current manufacturer’s gauges.
(2) Cost reducing model: this new fuel/CO2 data can be the source of tremendous savings for fleet operators. This will allow a global behavioral change in the entire industry, not only focusing on the manufacturers but also including fleet operators and drivers.
(3) Legal data collection: once the right sensing technology installed on the vehicles, it is simple to build a legal environment to provide a fuel/CO2 data through a certified data channel. The use of the new generation on-board mandatory digital recorders (smart tachographs) could be relevant.
This model makes full use of advanced digital technologies such as satellite positioning, short range communication for legal enforcement and interconnection with other telematics application, through a harmonized intelligent transport system interface. It will allow automatic and real time recording of start and final journey locations and will enable remote access to data for continuous authority control. Implemented along with existing manufacturer’s recording devices, a fuel sensor would be the right tool for regulators to control consumption/emission data provided by the manufacturers and add to this data the necessary precision for such a regulation.
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Identification number on the Transparency Register: 519633832153-54
Read full response14 Jun 2019
The regulation proposed by the European Commission as regards the type approval testing for heavy duty vehicles is a decisive step to tackle CO2 emissions. But The use of portable emission measurement systems is not a global solution able to deliver information real time for legal control and for management by the end user.
We need a permanent embedded device able to communicate real-time and have a continuous measurement capability.
Moreover, the solution refers to different type of measurement systems. Not all technologies or solutions are equal and can ensure the same level of accuracy:
- Out-of-tank sensing technologies with flow meter and pressure sensor can measure fuel consumption and CO2 emissions linked. Yet they can be easily by-passed by connecting an auxiliary cable.
- Testing sets/boxes are not scalable and can only monitor CO2 emissions without any information on the fuel consumption.
- Laboratory PEMS (boxes plugged to the tailpipe of the vehicle) only monitor CO2 emissions. Moreover, this system can be questioned, as manufacturers could only test the best model under conditions that are not linked with the reality of the driving.
In order to make a breakthrough change and foster eco-driving, the system must have the following requirements:
- Measure both fuel consumption and CO2 emission. Indeed, we only manage what is measured and technological improvement could be reduced by human behaviours.
- Be fully trustworthy and independent from the data provided by manufacturers CAN BUS. Indeed, Avenir Development Durable observed in its business activities, several situations where the data provided by our devices (with an accuracy > 99%) were very different of the data given by the manufacturers.
- Be universal and ready-to-use to reduce the costs for high-duty vehicle users
This technology already exists. Indeed, Avenir Développement Durable, Cleantech scale-up, developed a universal smart solution, Alertgasoil™, with 58 patents to measure real fuel consumption thanks to sensors directly put in tanks with high accuracy by providing real-time information fully independent from the data given by constructors.
A solution based on an in-tank sensing technology, adapted to all type of fuels, is the best solution because the monitoring is in real-time and under real driving situation. We call the EC to ensure independent measurement of the fuel consumption and CO2 emission based on a permanent on-board fuel inventory. This seems to be the only way for effectively reduce emissions.
You will find attached to this answer a presentation of the Alertgasoil™ technology, demonstrating the technology needed to ensure constant and efficient control already exist.
Read full response