ICCT’s COMMENTS AND TECHNICAL RECOMMENDATIONS …
the emission budget would necessarily imply higher emission limits (in mg/km) in the hot phase—we refer to the CLOVE figure below from April 27, 2021. We disagree with this rationale for setting the limits, and argue that the cold-started urban emission limits (i.e., the budget in mg) must be decoupled from the hot emission limits (i.e. 0 10 ...
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