Questionnaire to car manufacturers

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1 Committee of Inquiry into Emission Measurements in the Automotive Sector Questionnaire to car manufacturers No Question Answer 1 In previous hearings we have heard that the exhaust systems are vulnerable to clogging and corrosion. Can you describe how you as a producer adapted the materials used in order to fulfil warranty requirements, leak-free assembly requirements and customer demands for long service life? What is the effect of the higher temperatures that SCR needs to properly function with the materials used? 2 On average, how much does a diesel emissions reduction system cost when purchased and built in? Could you please specify these prices for an exhaust gas recirculation (EGR) system, a NOx storage catalytic converter (NOx trap) and a Selective Catalytic Reduction (SCR) system? And how much would a combination of multiple systems like these costs? In your experience: How many of these costs can be passed on to the buyer? For many years, stainless steel has been the primary material used in both diesel and gasoline exhaust systems to maximize resistance to corrosion while maintaining integrity at high temperatures. Nevertheless, even with low Sulphur fuel, some corrosion phenomena can still occur in presence of condensation and acidic solutions. The structure of all the catalyst substrates is a honeycomb with square or and hexagonal cells. High cell density is one of the main requirements necessary to necessary to maximize performance to convert pollutants into non-toxic gases. The engine system must avoid producing substances, like soot, that can accumulate on the frontal area of the honeycomb substrate. Suzuki purchase the diesel engine, emission system and engine control unit from FCA as a turn-key project. Suzuki therefore does not have access to detailed calculations to derive these costs. 1

2 3 Why did car manufacturers focus mostly on the legal testing cycle NEDC if they knew that it was far from reality and had nothing in common with real emissions? Was it not possible to orientate yourself towards real driving emissions (RDE) -like values from the beginning to generate more trust from the costumer? Why did the automobile industry not take the initiative on its own and communicated more realistic exhaust values of their products? In the homologation procedure the vehicles have to be compliant with the technical legislation that requires repeatable and comparable tests. Only through standardized and comparable processes, is the industry is able to be efficient and competitive. Till now the NEDC cycle represented this reference. The definition of new procedures as WLTP and RDE will be a step forward in representing more appropriately the real use conditions of the vehicles. Suzuki welcomes the introduction of new EU regulations which should provide clarity for customers and the industry. 2

3 4 Article 5(2) of Regulation 715/2007/EC allows for certain derogations to the prohibition of defeat devices that reduce the effectiveness of emission control systems. Do the vehicles you produce make use of the derogation, and if so could you please describe in detail under what conditions do you employ the derogation? Have you indicated and justified the conditions of the operation of such defeat devices to the type approval authority when applying to type approval? If not, why not? Were you ever requested by the technical services or type-approval authorities to provide clarifications on the use of derogations under article 5(2)? It is a fact that no diesel engine can be operated indefinitely under an unadjusted EGR treatment or NSC regeneration without risk of damage or accident to the engine and the safe operation of the vehicle. This is widely recognized and confirmed by testing experience. High EGR rates, particularly if continuous and in demanding driving cycles, may cause massive soot generation and progressive fouling of the components of the engine and after treatment system. This may ultimately end up in engine malfunctioning and component failure, with evident safety risk. Furthermore, continuous use of NSC regeneration events leads to a high amount of hydrocarbons and soot inside the engine combustion chamber and exhaust system line. This may then lead to engine components fouling, increased lubricant oil dilution and irreversible damage to the structure and functionality of catalysts and particulate filter. Modulation of the emission control system is an important safety factor and therefore inevitable. We have indicated the detailed conditions of operation starting from April 2016: for all new Type approvals the list of BES / AES (Base and Auxiliary Emissions Strategy) is presented inside the Homologation paper work as required by (EU) regulation 692/2008*2016/646 art. 5, added points 11 and 12. The functioning principles of EGR, NSC and SCR have been presented to the approval authorities. Furthermore, this explanation has been transferred to the approval authorities to define the procedure for Deterioration Factor determination on experimental basis for diesel engines to guarantee the required durability of emissions control system. 3

4 5 During recent investigations (e.g. in Germany) manufacturers admitted to using so called thermo windows to switch off emission control systems under certain ambient temperatures in order to protect the engine. It has become clear that there is a broad range of temperatures used for lower switch-off limits (e.g. below 10 C or 17 C). This suggests that the setting of these temperature limits are rather arbitrary. Please explain the discrepancy in temperature limits used by car manufacturers to justify switching off emission control systems (including EGR). Are these limits really needed to protect the engine and at which ambient temperatures? 6 Do you use emissions control systems with different operational limits (e.g. ambient temperature or engine loads) or quality (design, components or materials used), or of different durability when producing vehicles for US and EU markets? Are you aware of such discrepancy between OEMs on the EU market? It is well known that EGR rate has to be modulated as a function of ambient temperature in order to: - avoid combustion instability up to misfire, which would cause uncontrolled production of HC and CO emissions that, together with soot, can generate varnishing/damage on engine components. - reduce the risk of water condensation on EGR and the air intake system with consequent corrosion (especially on the vehicle Intercooler which is constantly exposed to low temperature air flow even with a warm engine) - avoid vehicle jerking caused by combustion instability. This is why current rules provide an exemption for strategies that are justified in terms of protecting the engine from damage or for safe operation of the vehicle. Suzuki stopped sale of automobiles in the US in Suzuki has never sold diesel vehicles in the US market. 4

5 7 At a meeting of transport ministers in Luxembourg on 7 June 2016, the following wording on when the ban on defeat devices should not apply was proposed: even if the best available technologies are included, no other technology is available to protect the engine against damage or accident and for safe operation of the vehicle. In this regard, what is your understanding of the best available technologies? Can you provide us with a list of currently best available technologies for lowering NOx and CO2 emissions? The general system underlying Regulation 715/2007 is not based on available techniques or technical standards but on emission limit values, which shall be observed by using emission control systems. The technical solution is left to the discretion of each manufacturer. An approach based on the best available technologies risks to increase the uncertainty on the interpretation of the regulation, which is exactly the opposite of intent of the proposal. In this case, the responsibility of selecting the best available technologies would be left to the Member States technical services. This would also risk to block potential technological innovations not matching with this selection. The proposal would cause significant uncertainty with regard to the term available. It does not specify where, when, to whom and at which cost a technology must be available in order to fulfil the requirement. It, inter alia, remains unclear whether a technology is available if it is not yet introduced in European market, it is not yet type-approved in any Member State, it cannot be provided in due time, it is patented or legally protected in another way, its costs are disproportionately high, it does not fit to the technology implemented in the relevant vehicle. The same is true with regard to the term best technologies. Again, the proposal lacks clarity and, in particular, does not specify the reference: does the expression refer to the engine in general or to the emission control system? Does it refer to technology in general or to the concrete technology employed in the respective vehicle? Does it reflect the differences between small cars, compact cars, medium-sized cars, etc.? Irrespective of this, the proposed wording would be unbalanced since it merely and strictly refers to the best technologies available, without taking into account the differences between the types of vehicles placed on the market. (small cars versus premium cars, f.i.) 5

6 8 With emissions norms progressively tightening, the introduction of the WLTP testing in 2017 and new emissions measurement procedures better reflecting real-driving conditions (RDE), what is, according to your own research and experience, the optimal combination of the best available technologies in order to comply with NOx and CO2 standards? Are the required technologies currently available for mass production or do they need more research and development before they can deliver the expected results? Do certain best available technologies damage the engine? If yes, why? 9 Do you agree with the statement that the engine control unit (ECU) is a black box, without type-approval obligation and without external supervision on how it is configured or how it functions? Would you be in favour of the introduction of a type-approving provision for this unit with, for instance, the possibility for the certificating authority of accessing the software and its code, and request detailed information on the use of the software, in order to avoid any unwanted software modifications, including unwanted modifications after type approval and before true production? What benefits or risks would you identify in such a procedure? As stated before a best available technology definition does not exist. Currently, for diesel engines, the emission limits of 2017 (RDE) and the introduction of the WLTP cycle require for emissions control the mass production of SCR system in combination with DOC+DPF+EGR. SCR technology is currently available, even if in the near future the use of SCR on filter coupling the SCR and DPF function in the same substrate catalyst might be more effective. For this reason, research and development from the catalyst suppliers is needed. The improved technologies do not per se damage the engine, but the overall system performance on RDE conditions has to consider the engine protection needs. The new AES/BES RDE regulation : 692/2008*2016/646 art. 5, added points 11 and 12. requires OEMs to submit a summary describing emission control strategies and any variation between the vehicle bench test and real world driving conditions. Suzuki supports this approach. 6

7 10 From the manufacturers point of view, what kind of role other aspects such as increase engine efficiency play in the emission reduction? What kind of research is carried out, other than the pipeend technologies, to reduce the emissions? There are many different factors and conditions to be taken into account but it is possible to say that an engine efficiency increase is generally linked to an incylinder reduction of incomplete combustion by-products (e.g. HC, CO and PM). Unfortunately, this is not true (generally is the opposite) for the NOx that are not only linked to the Fuel combustion but are produced at high temperature by a combination of Nitrogen and Oxygen both available in the fresh air. Fuel Injection control (timing and pressure), air-to-fuel mixing into the combustion chamber, turbocharger control, and EGR have been the main leverages traditionally followed for emission reduction on diesel engine with substantial improvements realized thus far. In cooperation with other parties such as FCA, research activities on combustion are ongoing to further improve the NOx-CO2 trade-off. 7

8 11 According to the JRC, exemption for the use of devices interfering with pollution control systems, as provided for in Article 5(2) of Regulation (EC) 715/2007, are not justified from a technical point of view as the same results (i.e. protecting the engine from damages) can be obtained in many different ways. Do you agree with this assumption? If not can you explain in detail why? Suzuki has developed and applied various technologies taking into consideration their availability, reliability, regulation compliance and economical affordability. For example, SCR technology is not affordable for small cars. Then, many factors have been considered in order to select the best technologies for each vehicle. This selection has been always made in full compliance with regulations in force. During the EMIS hearing on 19 April 2016, JRC stated: There are indeed circumstances under which a modulation or even a deactivation of emission control systems might be necessary. But there is no general answer regarding the necessity because for each of the possible technical problems leading to such exemptions, a possible technical solution may be found. Therefore such exemptions should be made on a case by case basis, taking into consideration technical progress and the best available technology on the market within the different vehicle categories. This is in line with the choices that Suzuki has made until now. As new technologies mature, new opportunities may become realized. This is the case of NSC and SCR, that now can guarantee good performances and suitable duration but it was not the case few years ago. The industry has recently consolidated the necessary technical knowledge to improve NOx emissions in various conditions. The challenge is now the ability to apply them with the necessary lead-time, according to the RDE procedure. 8

9 12 The EU law (Regulation 715/2007/EC Article 5(1)) requires manufacturers to equip vehicles so as to enable the vehicle to comply with the emission limit values contained in the Regulation in normal use. How do you explain the conclusions of the German Federal Motor Transport Authority (Kraftfahrt-Bundesamt) investigation that on average the Emission Control Technologies are off or turned down around 75-80% of the time? Please describe in detail for which normal use conditions (temperature, altitude, engine load, etc.) your engines are designed to operate in Europe? We have already explained in our answer to question 4 why emissions control systems need to be modulated to in order to protect the engine from damage or accident and to ensure safe operation of the vehicle. We believe that in this matter manufacturers have been exercising their best judgement in order to develop control strategies that meet the objective of reducing NOx emissions and at the same time preserve the engine from damage and the occupants from safety risks, as they were required by the regulatory framework. Starting from 1st September 2017, the operative terms will be defined by the conditions of the RDE Legislation. 9

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