Non-Road Mobile Machinery EU Regulation

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1 Power topic # Technical information from Cummins Non-Road Mobile Machinery EU Regulation White Paper By Pedro Ponte, Project Application Engineer Over the past decade, raised awareness and concern over the effect of engine exhaust emissions has led to the introduction of more and more stringent regulatory limits around the world, leading to a significant reduction of pollutant emissions. Despite all this, the level of air pollution in many places is still problematic. Even though the impact of current legislation has been significant, there are still gaps and not all applications or scenarios are regulated. With this in mind on the 14 September 2016 the European Parliament signed a new regulation, laying down new emission requirements for internal combustion engines for Non-Road Mobile Machinery. This new regulation entered into force in the 1st of January 2017, amending and repealing Directive 97/68/EC. An Overview of Regulation (EU) 2016/1628 from the Power Generation Business Perspective The focus of this regulation is on the reduction of gaseous and particulate pollutants, such as CO, HC, NO x and PM, from internal combustion engines used in non-road applications. These type of applications were, until now, regulated by the Directive 97/68/EC that from the 1st of January 2017 was repealed. This recent legislation comes this time under the form of a regulation, meaning that is immediately applicable and enforceable by all Member States. Aligning the trend on further emission reduction with the need to enforce it in equal manner across the member states. The purpose of this document is to provide an overview on the new Regulation on Non- Road Mobile Machinery from the power generation perspective.

2 Definitions (Article 3) (1) Non-road mobile machinery means any mobile machine, transportable equipment or vehicle with or without bodywork or wheels, not intended for the transport of passengers or goods on roads, and includes machinery installed on the chassis of vehicles intended for the transport of passengers or goods on roads; (2) EU type-approval means the procedure whereby an approval authority certifies that an engine type or engine family satisfies the relevant administrative provisions and technical requirements of this Regulation; (3) Gaseous pollutants means the following pollutants in their gaseous state emitted by an engine: carbon monoxide (CO), total hydrocarbons (HC) and oxides of nitrogen (NO x ); NOx being nitric oxide (NO) and nitrogen dioxide (NO 2 ), expressed as NO 2 equivalent; (4) Particulate matter or PM means the mass of any material in the gas emitted by an engine that is collected on a specified filter medium after diluting the gas with clean filtered air so that the temperature does not exceed 325 K (52 C); (5) Particle number or PN means the number of solid particles emitted by an engine with a diameter greater than 23 nm; (6) Particulate pollutants means any matter emitted by an engine that is measured as PM or PN; (16) Liquid fuel means a fuel which exists in the liquid state at standard ambient conditions (298 K, absolute ambient pressure 101,3 kpa); (17) Gaseous fuel means any fuel which is wholly gaseous at standard ambient conditions (298 K, absolute ambient pressure 101,3 kpa); (21) Constant-speed engine means an engine the EU type-approval of which is limited to constant-speed operation, excluding engines the constant-speed governor function of which is removed or disabled; it may be provided with an idle speed that can be used during start-up or shut-down and it may be equipped with a governor that can be set to an alternative speed when the engine is stopped; (23) Constant-speed operation means an engine operation with a governor that automatically controls the operator demand to maintain engine speed, even under changing load; (27) Rated net power means the net power in kw as declared by the manufacturer of an engine at rated speed; (36) Stationary machinery means machinery that is intended to be permanently installed in one location for its first use and is not intended to be moved, by road or otherwise, except during shipment from the place of manufacture to the place of first installation; (37) Permanently installed means bolted, or otherwise effectively fixed so that it cannot be removed without the use of tools or equipment, to a foundation or an alternative constraint intended to cause the engine to operate in one single location in a building, structure, facility or installation; (68) Test cycle means a sequence of test points, each with a defined speed and torque, to be followed by the engine when being tested under steady state or transient operating conditions; (69) Steady-state test cycle means a test cycle in which engine speed and torque are held at a finite set of nominally constant values; steady-state tests are either discrete mode tests or ramped-modal tests; 02 Power Topic # (18) Dual-fuel engine means an engine that is designed to simultaneously operate with a liquid fuel and a gaseous fuel, both fuels being metered separately, the consumed amount of one of the fuels relative to the other one being able to vary depending on the operation; (20) GER or Gas Energy Ratio means, in the case of a dual-fuel engine, the ratio of the energy content of the gaseous fuel over the energy content of both fuels; in the case of a single-fuel engine, GER is defined as being either 1 or 0 according to the type of fuel; (73) Emission durability period or EDP means the number of hours or, where applicable, the distance used to determine the deterioration factors; (74) Deterioration factors means the set of factors that indicate the relationship between emissions at the start and end of the emission durability period;

3 Scope This regulation is applicable to all engines installed in Non-Road Mobile Machinery. Included in this definition are diesel and gas generating sets power nodes across the entire range, from 0 kw to infinity. NRMM Timeline 2017 Directive 97/68/EC is repealed Article 64 This regulation does not apply to Stationary machinery. Article October Member States shall provide for penalties for infringement of the regulation Article 57 What Changes? A few things change with the introduction of the new regulation and the Stage V limits. While not exhausted below, the next topics represent the most significant high level changes. Regulation and not Directive: Unlike its predecessor, this legislation comes this time under the form of a regulation. Meaning not only that it is immediately applicable and enforceable by all Member States, but also that the requirements are exactly the same across all Member States. Complete range covered: Similar to what was happening already in the US with EPA requirements, the regulation imposes limits across the entire range of power nodes. The new Stage V limitations are imposed with a new categorization and from 0 kw to infinity. Stage V Limits: The limitations on gaseous and particulate emission are also, up to a point, aligned with US EPA Tier 4 final requirements. Where the regulation separates itself from the American counterpart is with the imposition also of particulate count from 19 kw to 560 kw, tackling this way the emission of smaller particulates. Added responsibilities for distributors and importers: As before the equipment under this legislation is subject to EU Type-Approval and therefore compliance to the requirements is an obligation of the manufacturer. This time however the regulation places the responsibility also in OEM s, distributors and importers, making them equally obliged in ensuring the equipment they provide meets the legal requirements. Chapter II Penalties: Aligning the need of stringent emission limits with the need to enforce more actively the requirements, the regulation also describes the infringements that are subject to penalties. These include, amongst others, the use of defeat strategies, falsification of test results and non-compliance with limits. In cases where the equipment is found non-compliant member states have the power to require the repair or recall of engines. Article 57 Placing on the market of Stage V generating sets with a rated net power, P < 56 kw and P 130 kw (sub categories NRE-c-1, NRE-c-2, NRE-c-3, NRE-c-4, NRE-c-6, NRG-c-1) Annex III 2020 The Commission shall submit a report laying down harmonised measures for the installation of retrofit emission control devices in engines in non-road mobile machinery that has already been placed on the market. This report shall also address, technically and financially, possible actions against air pollution in densely populated areas Article 60 (1) 2 January Placing on the market of Stage V generating sets with a rated net power, 56 P < 130 : sub category NRE-c-5) Annex III 2021 Member States shall inform the Commission of the application of the EU type-approval procedures laid down in this Regulation Article 59 (1) 2022 The Commission shall submit a report regarding the use of the exemption clauses for engines used in field testing and explosive atmospheres, and the emission monitoring results. The report should take into account related Union and international standards and where appropriate should be accompanied by legislative proposals Article 60 (3) The Commission shall submit a report regarding the assessment of further pollutant emission reduction potential, on the basis of available technologies and a cost- benefit analysis. This report should also address the identification of potentially relevant pollutant types that do not fall within the scope of this Regulation. The report should take into account related Union and international standards and where appropriate should be accompanied by legislative proposals Aricle 60 (2) Based on the information supplied before, the Commission shall submit a report on the application of this Regulation Article 59 (2) Power Topic #

4 Emission Limit Values The new Stage V emission limit values, as defined in the scope of this regulation applicable to power generating sets, are summarized on the table below. The new power nodes covered are highlighted in grey. Annex I to V Ignition type Sub category Power range (kw) CO Stage V emmission limit values HC NOx PM PN A factor EDP hours Non-road steady state cycle Mandatory date of application for placing on the market of engines CI NRE-c-1 0 < P < NRE CI NRE-c-2 8 P < CI NRE-c-3 19 P < x CI NRE-c-4 37 P < x D2 NRE-c-5 56 P < x All NRE-c P x NRG All NRG-c-1 P > Note: The A factor defined above in the table is applicable to gas and dual fuel engines and is used to obtain the HC emission limit values for these applications. This limit can be calculated by using the formula: HC=0.19+(1.5 A GER). In case the value exceeds A, the limit for HC is then set to A. Figure 1 NRMM Stage V resume table for constant speed engines. Power range based on rated net power (Annex I to V) Exemption from Compliance A few exemptions are made in this regulation for specific applications: Engines for export to third countries or to be used for the armed forces and also engines for the purpose of field testing shall not be subject to this regulation. Article 34(1) to (2) Engines to be installed in potentially explosive atmospheres (ATEX), defined in this regulation as Special Purpose Engines, will be able to comply with less stringent emission limit values aligned with the previous Stage IIIA defined in directive 97/68/EC. Article 34(5) Exemptions for new technologies and concepts are also foreseen. Engines that incorporate new technologies, and as a result of that, might be incompatible with one or more aspects of the regulation might still apply for an EU type-approval. Article 35 The exemption for special purpose engines is foreseen within the regulation by allowing the previous limits Stage IIIA limits, from directive 97/68/EU, to be still in place. The below table summarizes the emission limit values for SPE. Ignition type Sub category Power range (kw) CO SPE emission limit values HC NOx PM A factor CI NRE-c-1 0 < P < CI NRE-c-2 8 P < Power Topic # CI NRE-c-3 19 P < NRE CI NRE-c-4 37 P < NRE-c-5 56 P < All NRE-c P NRG All NRG-c-1 P > Figure 2 Special Purpose Engine (SPE) Emissions Limit Values (Annex VI)

5 About the author Pedro Ponte is a Project Application Engineer in the Sales Application Engineering team. He joined Cummins in April 2014 and provides technical support to distributors and consultants across Europe and Russia. Pedro graduated from the Portuguese Military Academy with a B.Sc. in Military Mechanical Engineering and from the Instituto Superior Técnico (Lisboa, Portugal) with an M.Sc. In Mechanical Engineering Applied Thermodynamics. Directive 97/68/EC Regulation (EU) 2016/1628 kw Stage V 0 8 Not regulated (7.5) / 8.0 / 0.4 NRE-c Not regulated (7.5) / 6.6 / 0.4 NRE-c / 1.5 / 5.5 / 0.8 (7.5) / 5.5 / 0.6 (4.7) / 5.0 / / #1x10 12 NRE-c / 1.3 / 5.0 / 0.4 (4.7) / 5.0 / 0.4 (4.7) / 5.0 / / #1x10 12 NRE-c / 1.3 / 5.0 / 0.4 (4.7) / 5.0 / / 0.19 / 5.0 / / #1x10 12 NRE-c / 1.0 / 5.0 / 0.3 (4.0) / 5.0 / / 0.19 / 5.0 / / #1x10 12 NRE-c / 1.0 / 3.5 / 0.2 (4.0) / 3.5 / / 0.19 / 3.5 / / #1x10 12 NRE-c-6 > 560 Not regulated 0.67 / 0.19 / 3.5 / NRG-c-1 Stage II Stage IIIA Stage V Figure 3 Non-Road Mobile Machinery resume table Conclusions References NO X / HC / CO / PM / #PN (g/kw-h) (NO X + HC) / CO / PM / #PN (g/kw-h) (g/kw-h) x = (g/bhp-h) The new regulation which came into force the 1st of January 2017 imposes a new stage V limitation on non-road mobile machinery that covers the entire range of power nodes. Whilst strongly aligned with US EPA Tier 4f limits, the legislation separates itself in some requirements that makes it more stringent and broad in coverage. Amongst these requirements we can include the particulate number count and the methane slip calculation for both gas and dual fuel engines. The need to enforce more actively and strongly, the requirements imposed is also clear in the new document. OEM s, Distributors and importers are, together with the manufacturer, made responsible and have the obligation to maintain and ensure the compliance of the equipment. Additionally Member States are given the powers to require a repair or recall of engines in cases of non-compliance. Some exceptions are allowed for engines in special purpose applications, mostly applicable to equipment to be installed in potentially explosives atmospheres (ATEX). Figure 3 summarizes the emission limit values and placing into market of engines used in non-road mobile machinery applicable to the power generation business. Regulation (EU) 2016/1628 of the European Parliament and of the Council of 14 September 2016 on requirements relating to gaseous and particulate pollutant emission limits and type-approval for internal combustion engines for non-road mobile machinery, amending Regulations (EU) No 1024/2012 and (EU) No 167/2013, and amending and repealing Directive 97/68/EC Directive 97/68/EC of the European Parliament and of the Council of 16 December 1997 on the approximation of the laws of the Member States relating to measures against the emission of gaseous and particulate pollutants from internal combustion engines to be installed in non-road mobile machinery ISO : Reciprocating internal combustion engines Exhaust emission measurement Part 4: Steady-state test cycles for different engine applications Cummins is a registered trademark of Cummins Inc. All rights reserved. power.cummins.com Bulletin / Cummins Inc. 05 Power Topic #