expectations towards Euro VI AECC Technical Seminar Brussels, 25 th October 2007

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European Motor Industry expectations towards Euro VI AECC Technical Seminar Brussels, 25 th October 2007

Consultation on Euro VI ACEA supports the principles of better regulation endorsed in the conclusions of the CARS21 program. Commission must conduct a full and transparent impact assessment before deciding on a proposal for Euro VI. Public consultation: No background information on the 4 scenarios: Stakeholders unable to make a reasonable and rational comparison of the costs and the effects of the 4 proposed scenarios. Impact on fuel economy must be part of Euro VI policy considerations.

Influencing factors for Euro VI Political pressure to adopt Euro VI limits that are similar to US2010. Comparison with US standards should take into account the specific rules applied by the US-EPA: i.e. units, procedures, rounding rules, flexibilities, deficiencies, emission-averaging banking & trading, NTE rules etc). US applies Averaging, Banking & Trading system & FEL: upper limit (cap) for the FEL of 0.65g/kWh NOx and 0.03g/kWh PM; credits gained in the years prior to a new emission standard; many engines will be certified to NOx and PM FEL's higher than the numeric limit values of 0.3g/kWh and 0.02g/kWh; likely NOx levels will range between 0.4g/kWh and 0.65g/kWh.

Influencing factors for Euro VI Scenarios A and D are broadly equivalent to US2010 in terms of the engine technology. Timing and introduction of standards: Application of US standards can be spread over a number of years; European limitsit apply to 100% production from a certain fixed date.

ACEA proposal p on Euro VI A single Euro VI step that sets emission limits which are technically challenging and achievable with sufficient i industry lead-time. Alignment of the Euro VI and US emission standards must be the final goal of European policy makers: technical feasibility to be fully demonstrated; will produce a large air quality benefit with very high costs. Euro VI should apply no earlier than 36 months after the date of adoption of the complete Euro VI package: Euro VI in the timeframe: 1 st October 2013 for new types and, 1 st Otb October 2014 for all new registrations ti and sales.

Euro VI NOx and PM: ACEA proposal p on Euro VI Scenario A (referred to the ETC), i.e. 0.4g/kWh NOx and 0.01 g/kwh PM. Test cycles: The WHDC cycle must be the basis for Euro VI: UN-ECE Regulation No.49 to be completed; The Commission should adopt a Euro VI proposal this year on the basis of the ETC; The Commission must confirm its intention to introduce WHDC (UN-ECE Regulation No.49 version) through the comitology process; Regulation must establish the appropriate Euro VI WHDC-based emission limits on the basis of a well-established correlation between ETC and WHDC.

WHTC procedure (UN-ECE R49) Cold start soak 1 st test 2 nd test 5min 10% 90% Weighting i factor

Approach Engine systems are optimised to comply with emission requirements while offering best performance and best fuel economy under conditions of use. Hence, engine emaps might be shaped accordingly and it is very difficult to obtain a simple correlation between very different test cycles operating in different load/speed areas. This conclusion was already drawn in the report of the WHDC validation studies.

Approach Introduction of cold start hot soak warm start procedure in the WHTC: New requirements added which have a major influence on the engine calibration and, by default, to any test cycle correlation; For this reason, a simple back-to-back testing of current production engines on different test cycles is not meaningful. Correlation ETC-WHTC: ACEA focused on current / future engine systems with emission levels better than Euro V; Applied engine calibrations taking into account the additional requirements of cold and warm start emission controls.

ETC-WHTC hot pre-conditioning - initial situation 7.0 6.0 EU engines EGR ETC NOx (g/kwh) 5.0 4.0 3.0 JPN engines CR-DPF CRT 2.0 1.0 0.0 0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 WHTC NOx (g/kwh)

ACEA correlation study y( (ETC R49) Studies of all European OEM s At low NOx-levels g/kwh With advanced engine system technologies ETC WHTC cylinder displacement max power max torque Technology ETC cold start hot soak combined number litre kw Nm A 1.7 2.23 1.67 1.73 6 12.8 362 2237 EGR+DPF B 1.7 2.4 1.61 1.69 6 12.8 325 2237 EGR+DPF C 0.14 2.38 0.44 0.54 6 12.8 362 2237 EGR+DPF+SCR D 0.19 1.88 0.38 0.53 6 12.8 325 2237 EGR+DPF+SCR E 1.02 2.5 1.33 1.45 6 6 220 1050 DPF+SCR F 1.02 2.2 1.05 1.16 6 6 220 1050 DPF+SCR+thermal G 0.18 1.34 0.28 0.38 6 12.8 335 2237 EGR+DPF+SCR H 0.39 0.53 6 12.8 335 2237 EGR+DPF+SCR I 1.6 2.23 2.38 2.37 6 12.8 335 2237 EGR+DPF J 3.5 3.35 6 12.8 335 2237 EGR K 1.57 2.23 6 10.5 287 1900 EGR+DPF L 1.54 2.69 2.71 2.71 6 na na na EGR M 0.18 1.27 0.56 0.63 6 12.9 355 na EGR+DPS+SCR N 0.18 1.1818 0.38 0.46 6 12.9 355 na EGR+DPF+SCR thermal mgmt

NOx correlation ETC-WHTC (R49) ETC v s ETC WHTC versus WHTC (R49) NOx 4 3.5 EGR +DPF +SCR DPF+SCR EGR+DPF J 3 L WHTC (g/kw Wh) NOx WHTC (g/kw Wh) 2.5 I K 2 A 1.5 1 C M 0.5 D G N 0 E B F H 0 0.5 1 1.5 2 2.5 3 3.5 4 ETC (g/kwh) NOx ETC (g/kwh)

NOx correlation ETC-WHTC (R49) The data supports the conclusion that an additive factor (offset) of 0.3 g/kwh is applied as follows: NOx WHDC = NOx ETC + 0.3 g/kwh Concerning PM, HC and CO it is proposed to apply a correlation factor of 1.0; These conclusions are only valid for the range of tested engine systems; Thermal management lowers both the WHTC-cold start and the hot soak test results but thermal management will not achieve a 1:1 correlation of the hot soak test with the ETC.

Individual results cold-hot weighted ETC versus WHTC (R49) cold, hot soak, combined 4 3.5 3 NOx WHTC (g/kw Wh) 2.5 2 1.5 cold start hot soak combined 1 0.5 thermal mgmt (insulation) 0 0 0.5 1 1.5 2 2.5 3 3.5 4 NOx ETC (g/kwh)

What should be HDV contribution? NOx limits modelled NOx reduction in 2020 PM limits modelled PM reduction in 2020 Cost LD diesel 65 mg/km 263 kt 2 mg/km 21.7 kt 202 per vehicle HD diesel 1.4 g/kwh 125 kt 0.01 0.015 g/kwh 1.8 kt 1,159 per vehicle (1) Total CAFE reduction scenario from road 388 kt 26 kt transport: 1.868 M /year (1) Far lower than the ACEA costs for scenario 2 (NOx = 1.0 g/kwh) in the range 2,250-4,000.

Impact assessment No Commission impact analysis yet: ACEA s impact analysis shows the effect of Euro VI NOx and PM emission limits as per Scenario A will result in: a reduction in NOx and PM of some 500kT and 3.25kT respectively by the year 2020; a reduction in NOx and PM of some 800kT and 5.25kT respectively by the year 2030. 3% fuel economy assumed; Additional technical measures will also bring benefits; No need for Euro VII. rease [ktonnes] Emissions inc 9,000 8,000 7,000 6,000 5,000 4,000 3,000 2,000 1,000 0 CO2 emissions increase ~ scenario A CO2 increase with 3% fuel economy penalty 2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030 Years

ACEA supports Global Harmonisation: Priority thecommissionmustestablisheurovionthe basis of a fully global WHDC: World harmonisation of emission standards should represent the final goal of European policy makers; World harmonisation should not be dictated by one Contracting Parties rules of today; Final agreement on WHDC (options) must not penalise manufacturers through technical measures that would increase the stringency of any future emission limits.

ACEA supports Global Technical Regulations as part of Euro VI: Worldwide Heavy-Duty On-Board Diagnostics (WWH- OBD); Commission has already demonstrated its commitment to this GTR. Off-Cycle Emissions i (OCE) and Portable Emission i Measuring Systems (PEMS), when satisfactorily completed; Based on the current OCE GTR proposal - the requirements as specified would represent a significant and additional change in severity of the Euro VI emission legislation and are more demanding than the US2010 NTE requirements.

Test programs Engine plus Aftertreatment will not meet Euro VI: The complete system has to be optimised; Thermal management has to be optimised across the map; Durability has to be demonstrated; t d Fuel economy has to be realised; The effects of biofuels have to be understood and catered for; Technical solutions have to be adapted to production and packaging. As AECC has shown, if you apply all technical possibilities you can achieve ultra-low emissions but is that a cost- effective and sellable concept for the truck community? ACEA would welcome a joint program with AECC to look at future fuel effects.

Summary A substantial proposal from ACEA. All stakeholders should recognise the contribution that the ACEA proposal will make to the reduction in NOx and PM emissions from heavy-duty vehicles. ces Policy makers should agree to play their part and achieve a Euro VI solution that is based on global regulations for heavy-duty vehicle manufacturers. A technology package applied globally will be a win-win for EU policy makers and for the competitiveness of the European industry.