9 Test procedures for vehicle emissions
| Committee's assessment
| Politically important |
| Committee's decision | Cleared from scrutiny
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| Document details | Draft Commission Regulation on emissions from light passenger and commercial vehicles
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| Legal base | Article 15 of Regulation (EC) No. 715/2007
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| Department | Transport
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| Document number | (36571), —
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Summary and Committee's conclusions
9.1 The current EU requirements for the emission
performance of light duty vehicles include a laboratory based
test, in which the vehicle is driven according to a well-defined
drive cycle. This is based on a cycle first used in the 1990s,
representing a simplified, but repeatable, driving pattern, and
it was considered that a vehicle which performed well in the test
also performed well when driven on the road. However, concerns
have grown that modern vehicles are designed to comply under the
limited laboratory test conditions, and that the test results
may no longer reflect actual performance. In particular, real
world test results have shown that, whilst most pollutants are
well controlled, the emission of nitrogen oxides (NOx) from diesel
vehicles is much higher than might be expected on the basis of
the laboratory tests.
9.2 Although we have not seen an official text, the
Government has told us that the Commission is proposing to enact
a Regulation which would introduce into the regulatory approval
regime a new procedure for assessing the tail-pipe emissions from
light duty vehicles. This will require for the first time that
the vehicle manufacturer demonstrates that these emissions are
controlled under a wide range of real driving conditions, whilst
avoiding testing at unrealistic extremes. The Government recognises
that emissions of nitrogen oxides in particular can have adverse
health effects, and it therefore supports the measure. It also
describes it as challenging for manufacturers, and will be exploring
a number of ways in which the burden on industry might be reduced
without diluting the air quality benefits.
9.3 This draft Commission Regulation, which is
supported by the Government, does not appear to be controversial,
and we see no reason to withhold clearance. However, it addresses
an issue — namely the discrepancy between the results produced
by the tests used to measure emissions and what happens under
real driving conditions — which has attracted a measure
of interest recently, and we are therefore drawing it to the attention
of the House.
Full details of the document:
Draft Commission Regulation amending Regulation (EC) No. 715/2007
and Commission Regulation (EC) No. 692/2008 as regards emissions
from light passenger and commercial vehicles (Euro 6): (36571),—.
Background
9.4 The current requirements for the emission performance
of light duty vehicles are set out in Regulations (EC) No. 715/2007
and Commission Regulation (EC) No. 692/2008, which form part of
the wider type approval framework under Directive 2007/46, setting
out the safety and environmental requirements which must be met
before a vehicle can be placed on the market in the EU. The Regulations
include a laboratory based test (known as the type 1 test), in
which the vehicle is driven according to a well-defined drive
cycle, with acceleration, braking, steady speed and stationary
phases. The exhaust emissions are collected during the test, and
must be below the regulatory limit value for each regulated gaseous
pollutant before the vehicle can be approved.
9.5 The drive cycle is based on one first used in
the 1990s, when emission standards were introduced, and is known
as the new emission drive cycle (or NEDC). It represents a simplified,
but repeatable, driving pattern, and it was considered that a
vehicle which performed well in the test also performed well when
driven on the road. However, as regulatory limits have been tightened
and other pressures, such as CO2 targets, have been
introduced, concerns have grown that modern vehicles are designed
to comply under the limited laboratory test conditions, and that
the test results may no longer reflect actual performance. These
concerns have been confirmed since the advent of portable emission
measurement systems (PEMS) which can be installed on a vehicle
and driven on the road: real world test results have shown that,
whilst most pollutants are well controlled, the emission of NOx
from diesel vehicles is much higher than might be expected on
the basis of the laboratory tests.
The current proposal
9.6 In order to address these concerns, the Commission
is proposing to enact a Regulation under the regulatory procedure
with scrutiny which would introduce into the approval regime a
new procedure — a real driving emissions (RDE) test —
for assessing the tail-pipe emissions from light duty vehicles
(passenger cars and light vans). It supplements the existing approval
tests for vehicle emissions, and will require for the first time
that the vehicle manufacturer demonstrates that tail-pipe emissions
are controlled under real driving conditions. A separate proposal
will be made early in 2015 containing the compliance criteria
for vehicles subjected to this test.
9.7 Although we have not seen an official text, the
Government has told us that the vehicle manufacturer would be
required to demonstrate that the emission control equipment continues
to function effectively when a vehicle is driven on public roads
under a wide range of conditions (i.e. motorway, urban, and rural
routes, summer and winter conditions, laden and un-laden, and
at sea level and altitude). However, to help constrain the amount
of testing, certain boundary conditions — which would limit
testing between temperatures from -7 °C up to 35°C and
at altitudes up to 1300m — have been proposed, and are intended
to ensure that all normal driving conditions are covered, whilst
avoiding testing at unrealistic extremes. In addition, compliance
will only need to be demonstrated at speeds up to 145kph (90mph),
and, in order to minimise further the test burden, manufacturers
will be permitted to define vehicle 'families' with similar engine
characteristics, whilst having to demonstrate that a proportion
of these vehicles are compliant to obtain approval for the entire
family.
9.8 The requirements will apply to new vehicle types
from September 2017, and all vehicles placed on the market will
need to comply from September 2018. As an interim measure, manufacturers
will be required to carry out tests during a monitoring period
from the end of 2015 and publish the results. However, the compliance
criteria will not apply in this period, which is intended to allow
manufacturers and approval authorities to gain the necessary experience
to apply the new test procedure.
9.9 The new test will apply to both spark ignition
(petrol) and compression ignition (diesel) engines, and initially
only NOx will be subject to compliance criteria, in recognition
of the current difficulties which many Member States have meeting
their air quality targets for nitrogen dioxide (NO2),
which is a component of NOx. Portable measuring equipment capable
of measuring particulates with sufficient accuracy will not be
available when the test is first introduced, and will be introduced
at a later date: and, although carbon monoxide will be monitored
and may be included in the future, there are currently no exceedances
for this pollutant in the EU. Likewise, hydrocarbons will not
be monitored as the equipment needed to measure them safely is
not available, though a test procedure may be proposed in the
future.
9.10 The test will complement rather than replace
the existing laboratory-based test procedure, which, despite its
limitations, the Government describes as a controlled and repeatable
test, which will remain as the only method for assessing carbon
dioxide emissions (which will not be measured during an RDE test).
The Government adds that the existing test will also ensure that
steps continue to be taken to control pollutants not assessed
by the RDE test, but that it will be amended under separate proposals
to improve the drive cycle and remove known flexibilities.
The Government's view
9.11 In her Explanatory Memorandum of 15 December
2014, the Minister of State at the Department for Transport (Baroness
Kramer) notes that road transport is considered to be the single
largest source of NOx, representing a third of all such emissions.
She adds that, at high levels, NO2 causes inflammation
of the airways, and that long-term exposure may affect lung function
and respiratory symptoms, as well as enhancing the response to
allergens in sensitive individuals, with NOx also contributing
to the formation of secondary particles and ground level ozone,
both of which are associated with ill-health.
9.12 The Minister says that the Government supports
the Commission's proposal, and sees it as an important step towards
helping the UK to meet its air quality targets, where (unlike
other pollutants) complying with the requirements for NO2
is proving challenging, especially in cities and urban environments.
She adds that the timetable set out above for the introduction
of RDE is also challenging for vehicle producers, but necessary
to ensure that the UK is able to meet its air quality targets
at the earliest opportunity. However, she also suggests that there
is scope to reduce the burden on industry without diluting the
air quality benefits.
9.13 In particular, she points out that:
· the range of test conditions proposed
may be too wide, certainly from the UK perspective, in that, whilst
testing at low temperatures is necessary to ensure pollution control
equipment performs adequately over both winter and summer conditions,
-7 °C is extreme and unlikely to bring significant environmental
benefits, whereas testing down to 0 °C would ensure that
emissions are controlled under most driving conditions;
· whilst a small but significant proportion
of vehicles are driven at speeds above 70 mph and there is evidence
that vehicle emissions can be high at these speeds, the proposal
to require compliance at speeds up to 90 mph is above the national
speed limit, and it must be clear that any testing carried out
in the UK must respect national speed limits: manufacturers will
therefore need to satisfy themselves that they comply with the
higher speeds using track-based testing or by carrying out high
speed tests in countries where such speeds on public roads are
permitted;
· the proposal to group vehicles into families
with similar engine and powertrain characteristics will further
reduce the burden on vehicle manufacturers by minimising testing
to that necessary to give a reasonable certainty of compliance
for all vehicles in the family: however, as a safeguard, the
manufacturer must test a minimum number of vehicles from a family
representing the extremes of performance (in terms of power, weight,
engine capacity, etc), and an approval authority may request any
vehicle within a family to be tested;
· whilst current concerns centre on the
high emissions of NOx from diesel engines, the technology-neutral
approach under which both petrol and diesel engines are within
the scope of the proposal will ensure the compliance of future
technologies as well as addressing the current concerns; and
· the proposal is likely to be disproportionately
burdensome for small manufacturers which do not have the resources
to complete all the required testing prior to approval, and, as
vehicles produced by low volume manufacturers represent a very
small proportion of the vehicle fleet, their contribution to air
quality is not significant: additional provisions, such as longer
lead times, should therefore be included for them.
9.14 The Minister also points out that the Commission
is content that the proposal is supported by the impact assessment
it prepared for the introduction of Regulation (EC) No. 715/2007,
which assumed that manufacturers would install the technologies
needed to give real world compliance. She believes that this view
is broadly correct, and says that the UK's impact assessment presented
prior to the adoption of the Regulation was drawn up on the same
basis.
Previous Committee Reports
None.
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