Euro 5 Impact Assessment - Automotive Industries Association of ...

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will be made of open filters to reduce the mass of particulates. This would lead to asituation where high emission levels of ultra-fine particles continue to be created.The use of a particle number standard is a means to ensure that emissions of ultra fineparticles are controlled and that developments in filter technology continue to focus on theremoval of ultra fine particles. Present test procedures set down in European legislationdo not include a method for measuring particle number. Therefore a new procedure wouldbe required to be adopted if such an emission standard were to be introduced. Work ondeveloping and testing a new measurement protocol for both particulate mass and numberhas been taking place at the United Nations Economic Commission for Europe (UN-ECE)under the World Forum for Harmonisation of Vehicle Regulations (WP 29) in Geneva.Once this work is complete, the new standard shall be implemented into Europeanlegislation.Introducing a new test procedure introduces costs to industry and testing facilities inadapting their practices. However as a number of laboratories are involved in the workpiloting the procedures, some of the costs have already been incurred. Furthermore,introduction of the new procedure would be for a wider set of factors rather than simplythe purposes of particulate number counting. The key reason for the development of thetest procedure was to find a method of measuring particulate mass that was more reliablein providing repeatable results at low emission limits. Therefore there are good reasons forintroduction of most of the measurement methodology to improve the accuracy ofparticulate mass measurement, irrespective of whether the number measurementcomponent is used.Consequently, measuring the number of particulates instead of their mass could beconsidered as a more effective means of regulation in the future.6.4.3. Durability requirementsFor the time being, existing regulations require manufacturers to confirm the durability ofpollution control devices in light duty vehicles for 80,000 km. The proposal includes theextension of this durability period from 80,000 km to 160,000 km. The period wouldmore realistically reflect the actual life of vehicles and ensure that emission controlsystems continue to function throughout the life of the vehicle.Given the average life of vehicles across the EU is in the order of 13 years 20 and theaverage distance travelled is at least 13,000 km per year, cars sold in Europe will cover adistance of around 170,000 km in their lifetime. The current durability requirementextends to only half of the distance travelled in the life of a vehicle, therefore this figurehas been reviewed.Extending the durability requirements would therefore be in line with the principle ofensuring that a vehicle continues to produce low emissions for its entire lifetime. Similarprinciples apply in other parts of the world. In the United States, emission standards arenow set for 192,000 km (120,000 miles). California has gone further and now providesincentives to manufacturers for certifying the emissions performance of their vehicles to240,000 km (150,000 miles).20 FEBELAUTO Rapport Annuel, 200426
At present, there are two ways in which manufacturers demonstrate the durabilityrequirement:• Manufacturers can test for durability using either operation on track, road, or on achassis dynamometer using a defined test protocol; or• A manufacturer may choose to apply standardised deterioration factors to themeasured emissions limit. The factors vary for petrol and diesel vehicles and for somepollutants. They reflect the general changes in performance that can be expected overtime of standard emission control technologies.The vast majority of manufacturers make use of the second approach as this avoids theneed for extensive testing. Thus, changing the durability requirements to 160,000 km willnot impose any significant testing costs on manufacturers as they would apply an amendedset of deterioration factors. It does not appear that this requirement as such imposessignificant costs on manufacturers, as aftertreatment devices are designed to function forsuch distances without the need for replacement.6.4.4. Removal of the exemption enabling heavy passenger vehicles to use emissionstandards of light commercial vehicles.Existing emission standards have enabled passenger vehicles (Category M 1 ) with amaximum mass of over 2,500 kg to meet the less stringent emission standards set for lightcommercial vehicles (Category N 1 , Class II and III). This exemption is seen to favour thelargest vehicles on the road as it applies to the heaviest cars and sport utility vehicles(SUVs). Since there is no longer seen to be any justification for this exemption, theproposal removes it.There has already been action in other major markets to remove exemptions to emissionlimits that may benefit the largest vehicles. For example, the California LEV 2 and the USEPA’s Tier 2 standards, which have been phased in from 2004, introduced the same set ofemission limit for all vehicles with a maximum weight of up to 3864 kg (8,500 lbs).For heavy petrol vehicles, the removal of the exemption will have little perceived impacton the costs to manufacturers. Indeed there are very few vehicles type approved at thehigher limit. Large petrol vehicles of this type manufactured in the EU are likely to beengineered for export to markets such as the US. They typically have low emissions sothat they can be sold in those States which use the more stringent Californian regulations.Indeed many such luxury cars already meet today the standards that could be required forEuro 5.The impact will be more significant for diesel vehicles that are not usually exported. A keyconstraint will be the requirement to meet the lower NO x emission limits required forpassenger cars. For some vehicles it is possible that some form of light NO x aftertreatmentmay be required to successfully bring emissions down to the required emissionslimit. There may be some advantages to introducing NO x after-treatment in a smallnumber of vehicles first, in order to stimulate the further development of this technology.As the vehicles are usually high cost relative to the average vehicle fleet, additional aftertreatmentcosts are easier to absorb in the retail price. However there are other views in27
Page 5: 2. PROBLEM DEFINITION2.1. Nature of
Page 8 and 9: 3. OBJECTIVES3.1. Policy objectives
Page 10 and 11: 4. POLICY OPTIONS4.1. Options Ident
Page 12 and 13: offers competitiveness benefits to
Page 14 and 15: The policy option would have some i
Page 16 and 17: 6. IDENTIFICATION OF THE BEST SCENA
Page 18 and 19: or by means of lean NOx traps (LNT)
Page 20 and 21: Figure 2: Type approval values for
Page 24 and 25: measures in other sectors. The Comm
Page 28 and 29: the industry 21 that further NO X r
Page 30 and 31: • In addition, the 5 mg/km limit
Page 32 and 33: 7. MONITORING AND EVALUATION7.1. In
Page 34 and 35: • Key elements of the draft propo
Page 36 and 37: 2010. At present there is not enoug
Page 38 and 39: number standard was unnecessary due
Page 40 and 41: provisions in the United States. A
Page 42: Gas vehicles would therefore fall i

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