A 012979 09.12.2016 Committee of Inquiry into Emission Measurements in the Automotive Sector Written questions to UTAC CERAM - EMIS hearing of 11/10/2016 1. For the French government, UTAC retested cars in relation to their CO2 emissions. UTAC found that the best performing car surpassed the CO2 emissions by 15% compared with the type approved value; the worst performing car used 50% more fuel than declared. In your view, do we have to fear for a CO2 scandal in the future? Will the new WLTP test cycle solve the issue? The tests conducted in UTAC for the French government and which are referred to are test simulating a NEDC cycle on a track with a PEMS. The vehicle is not equivalent to the one tested in laboratory essentially on a mass point of view (options+ PEMS) and the environment is different from the one in the laboratory (temperature, hygrometry, wind, road surface ). To this extent, it s not surprising to have discrepancies in CO2 results compared to the ones measured in the laboratory where all the parameters are controlled (CO2 results are directly related to the energy required from engine). The aim of the WLTP is to improve the representativeness of real driving (WLTC) and avoid optimisation by implementing procedures of measurement with less flexibilities that in current emission regulation, and therefore lower the discrepancies between real driving and testing in laboratory. 2. What proportion is the technical testing for type approval of UTAC CERAM's overall turnover? On a total of 52 M turnover in 2015, around 20 % is dedicated to homologation in safety and environment (testing and administrative work). Who are your customers and what do you test for them? For homologation, mainly: PSA-Renault Nissan AVTOVAZ Do you test the entire car or sometimes only specific parts of it? Entire car and part depending on the regulation (e.g. pollutants entire car and power, part=engine) 1
What might be the criteria why an OEM opts for a certain technical service in a specific country? Delay, cost, location 3. Critics of the current EU type-approval system claim that the majority of European national technical services are economically dependent on OEMs. Do you agree with this assessment of the situation of technical services active in the field of type-approval in Europe? As a technical service designated by national authorities and as previewed in the EU regulation, we indeed perform the testing in view of typeapproval, so to this extent, yes we are economically dependent on OEMs. How can the technical services guarantee that they deliver an objective service while at the same time being economically dependent on the OEMs? We have gained the TAA confidence and have annual audits conducted by the French accreditation body (COFRAC) in view of ISO 17025 accreditation. We want to keep intact our reputation after almost 50 years experience in homologation and as the unique technical service in France. 4. French independent committee's investigation has shown that many vehicles present on the French market greatly exceed the legal emissions limits and use illegal thermo-windows. Among those vehicles was Renault, which performs most of its type-approval testing at UTAC CERAM. Could you please explain how it is possible to omit this clear breach of emission standards and allow highly polluting vehicles to receive typeapproval? UTAC conducts testing under EU regulation; the current TA procedures do not enable to highlight this issue. Even COP and ISC tests have never showed any problems of this kind. Do you consider it as a failure of your facilities to allow these cars on the road? It is a not a problem due to the facilities but a problem of procedure. 2
5. Article 3(9)(3) of implementing Regulation 692/2008 requires manufacturer to provide the type approval authority with information on the operating strategy of the exhaust gas recirculation system (EGR), including its functioning at low temperatures. Through investigations on vehicles emissions it has been reported that emission control systems of several diesel vehicles (notably Renault) does not operate or operate less efficiently below certain temperature (20 C, 17 C, 10 C). Did manufacturers provide you with such required information under Article 3(9) and did you request this information from manufacturers? This article concerns low temperature but without specifying any temperatures or limits to comply with. When Euro 5 regulation was developed, Article 3(9) was written due to the fact that no Type 6 test was carried out for Diesel vehicles. At that time, the intention was first to develop regulation for low temperature emissions on petrol car. Regulation for low temperature emissions for diesel cars was intended to be developed in a second stage. Level of NOx diesel emissions at -7 C was discussed and checked with the OEMs (in the spirit of type 6 test), but not at the time the emissions at 17 C. Discussions were more around reliability. Yes, manufacturers provide documents showing low temperature post treatment efficiency for Euro 6 vehicles. Do you believe that type approval authorities should have been made aware by Renault of the fact that the emission control system does not operate below 17 C? Technical services role in the TA process is to conduct testing under the EU regulations. As mentioned previously this issue was not detectable by just applying the type approval test procedure.. 6. Could you explain in detail the testing process that auto manufacturers go through for obtaining vehicle type approval? 1/Discussion on the technical specification of the vehicle to be tested (worst case agreement). 2/Test on UTAC facility or OEM facility with UTAC witness. If the tests are carried out on the OEM facility we carry out an initial assessment of the 3
facilities and then follow the regulation requirements each time we witness a test. 3/ UTAC issues the report(s) and sends it (them)to the TAA for validation along with all the technical information of the vehicle in view of approval. 4/The TAA issues the certificate 5/ The French authorities have designated UTAC for COP verifications; we therefore follow up also the COP process. Could you please describe your step-by-step involvement in the type-approval process? We are involved in every steps described previously. Does the car manufacturer initiate the contact or is it the type-approval authority? Both situations are possible. Are the cars received for testing representative of those that are on the road (in terms of parameters, technical specifications and visual appearance)? Type approval testing can be done on any testing vehicle as long as the influencing parameters for the specific testing comply with the characteristics of the vehicle the OEM wants to type approve. Are you allowed to perform any adjustments to the set-up of the car received for testing?, and we have never been asked to. Have you ever challenged a vehicle manufacturer that the vehicle they have provided you with is not a representative model? Are there any differences in general set-up of the cars received for testing from different manufacturers? 7. Article 3(10) of Regulation (EC) 715/2007 stipulates that: defeat device means any element of design which senses temperature, vehicle speed, engine speed (RPM), transmission gear, manifold vacuum or any other parameter for the purpose of activating, modulating, delaying or 4
deactivating the operation of any part of the emission control system, that reduces the effectiveness of the emission control system under conditions which may reasonably be expected to be encountered in normal vehicle operation and use Regulation (EC) 715/2007 provides for three derogations to the general ban on the use of defeat devices: a) the need for the device is justified in terms of protecting the engine against damage or accident and for safe operation of the vehicle; b) the device does not function beyond the requirements of engine starting; c) the conditions are substantially included in the test procedures for verifying evaporative emissions and average tailpipe emissions. Do you consider that switching off the emissions control system of a vehicle after operating the vehicle for 22 minutes of (slightly exceeding the 20-minute duration of the NEDC test) must be considered a defeat device? Yes, could be considered as a defeat device but we do not have enough technical data to judge. Do you consider that switching off the emissions control system of a vehicle below 17 C (slightly below the 20 C minimum temperature of the NEDC test) must be considered a defeat device? Yes, could be considered as a defeat device. If not, which of the derogations outlined above do you consider to apply in these situations? In both cases a) would apply, but OEMs need to prove the necessity of using it, it needs to be discussed and technically logical 8. Type approval authorities interpret EU legislation concerning permissible exemptions from the ban of defeat devices on a case-by-case basis. In the written reply to previous EMIS questionnaire to the French type approval authority it was stated that under the current tests there is no possibility for technical services to systematically detect defeat devices. On which grounds or methodological guidelines do you actually then verify this in type-approval testing regarding the fact given that any guidelines from the European Commission are actually missing? This is the problem; we do not have any possibility to systematically detect an illegal defeat device in the current regulation. As a technical service, we are in favour of methodological guidance for all the testing procedures in the regulations in order for all the technical services to work in the same way and not be subject to interpretation. Have you ever informed the European Commission about the actual weakness of either definition or the methodological guidance to effectively enforce the ban of defeat devices which is the responsibility of the Member States? 5
We have had the opportunity to give this position in the different working groups in which we take part in for EU regulation development. 9. Your organisation has been accredited to carry out emissions measurements set in Regulation (EC) 715/2007. According to your understanding what does the emission limit of 80 mg/km in normal use means in Regulation (EC) 715/2007? To us, normal use means average use, outside laboratory conditions. This debate of normal use has taken place during the RDE regulation development and the debates outlined the difficulty to identify normal use around the table. On average, how many cars annually you have tested and are in accordance with Regulation (EC) 715/2007? Difficult to identify in terms of number of cars because you can perform more than one test for 1 model. 10. What is your understating of the meaning of normal use according to Article 5(1) of Regulation (EC) 715/2007? It s a lack in the regulation not defining what is meant by normal use. How do you make sure that vehicles type approved in your country respect limits in normal use? ISC testing and now RDE testing What is the purpose, in your understanding, of fixing limits of pollutants from exhaust fumes by introducing Euro classes for light vehicles? If the question concerns emission limits in function of vehicle category, we notice today that vehicle development is different in function of the category. Since when have you been aware of the huge discrepancies, especially for NOx in diesel cars, between type approval testing and RDE? Since studies using PEMS have been published. 6
What actions, if any, have you undertaken to verify the data and fix up the problem with type approved car tested under your responsibility? actions have been undertaken as all are in compliance with EU regulation. Do you think the big discrepancies between RDE and emissions measured during test are due to use of cheating devices or the combination of non-representative drive cycle and test on golden cars? Optimisation of testing procedures Do you think that the use in type approval of "golden cars" that do not represent the behaviour of actual vehicles on the market could hinder achieving the goals of Regulation (EC) 715/2007? Yes it could, but difficult to type approve a vehicle under production, as production is generally launched once the vehicle is type approved 11. Could you please describe your step-by-step involvement in the testing procedure performed at the premises of the car manufacturer? Calibration of facility check Witness all emission tests Coast down quick check after each emission test Vehicle conformity (Gearbox, parts, ) Do you have any insight into the preparation of the tests? We are not present during vehicle preparation. Are you able to assess all the parameters of the test performed at the in-house laboratory? We have access to all information if requested. Do you believe the car manufacturers should be allowed to test their own vehicles for the purpose of type-approval? As a technical service, difficult to answer yes, but apart from that, allowing self-testing would not go into improving discrepancies between type 7
approval and real use. 12. According to article 4 para 2 of the regulation 715/2007 durability testing for a light-duty vehicle's pollution control devices shall cover 160,000 km. Has your service ever been requested to check whether the long term durability of the emission control systems of in-use vehicles is guaranteed? We check the in service compliance requirements described in EU regulation on a yearly basis. What were the results? Yearly presentation of the results by the manufacturer. real problems have been encountered but on the other hand the vehicles are with the application of the approval procedure as required by the legislation. 8