EMIS naire to car manufacturers - Kia No 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? We conducted intensive testing and invested considerably in the hardware of our engines to achieve the best possible results. Various hardware solutions for a far-reaching and successful NOx reduction were subsequently implemented. Kia is currently fitting its powertrain with exhaust systems and its materials as follows: EGR valve: SUS (stainless steel) for most parts EGR cooler / pipe (stainless steel) DPF (diesel particulate filter, silicon carbide which is widely used for high durability requirements with precious metal like platinum and palladium) LNT (lean NOx trap, cordierite with precious metal like platinum, palladium, rhodium and NOx absorption material such as ceria and barium oxide) SCR (selective catalytic reduction) under further development Our decisions with regard to the emissions control strategy and the materials used are all based on a very thorough three step process, comprised of: thorough engine test bench development; extensive car durability tests in the development phase; and market surveillance on the field starting from mass production. As regards step 1 (test bench development), the engines are tested under test bench conditions for extensive running hours with different test modes. This comprises full load, heat soak back and special test mode for soot deposit evaluation. The lessons learned on the test bench regarding the engine part failures are then included in the engine set-up. In step 2 (durability tests), the engines are tested in cars on the road in various weather conditions, including various low temperature conditions, and in various countries to cover a broad range of climatic conditions. We check every possible damage or failure of emissions related parts and investigate solutions. The lessons learned from engine part failures during these durability tests are then included in the vehicle set-up. In step 3 (market surveillance), we monitor cars in the field after start of mass production to detect field failures. This information is used to make sure that the set-up is chosen in a proper manner which also works in the field. From this wide range of test runs we can ensure reliable and stable quality level with our products. We have developed and are preparing our SCR technology to ensure compliance with RDE requirements in accordance with the above described process. We are currently validating the effect of the higher temperatures that SCR needs (lower exhaust gas temperature for light-off and high exhaust gas temperature for not damaging SCR catalyst) to properly function with the materials used. - 1 -
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? Please note that cost and pricing for each vehicle is different and depends on each individual vehicle set-up as well as specifics of procurement and production. Also, cost and pricing information in a competitive environment is generally sensitive and subject to confidentiality. Generally the costs of exhaust gas after-treatment components such as EGR, LNT and SCR as well as their integration into the vehicle are a significant part of the production cost (at least several hundreds of euros) and therefore also of the sales price of the vehicle. To what extent costs can be passed on to the buyer also depends on the use of a combination of multiple systems and on each car model and segment. - 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? Our research and development aims to improve our product continuously and it is directed to address future developments in many aspects. RDE is a very important development and, in fact, we are part of this development long before the current emissions investigations. We have started our internal off-cycle emissions study early on in a cooperative way with various institutes. When the discussions with the Commission on RDE started in 2011, we fully supported this development. We have also cooperated with other institutes on real road emissions. We have also monitored development and availability of PEMS hardware for passenger cars over the last few years. Thus, we are orientating our development towards real road emissions already for quite some time. We also supported organizations such as ADAC and car magazines to carry out extended emissions tests in order to satisfy customer expectations in terms of off-cycle emissions. We are compliant with all laws and test cycles currently applicable to our vehicles, but our focus is on future developments including WLTP and RDE regulations. - 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)? We use the derogations in Article 5(2) of Regulation 715/2007/EC only as far as necessary for engine protection or safe operation of the vehicle. Our emissions control system is developed individually for each engine/vehicle combination in a very thorough process (please see 1). Thus, please understand that a detailed description would vary from engine to engine. Nonetheless, we would like to provide examples to illustrate the use of such derogations: It is a widely known fact in the scientific community and the automotive industry that diesel engines of all designs and hardware encounter issues with soot deposition at low temperatures. Soot deposits can cause engine damage. The increased presence of hydrocarbon at low temperatures was also confirmed at our testing. We recognized severe engine damage on the EGR valve, swirl control valve, EGR cooler and air control valve by soot condensation. Soot deposits are therefore opposing necessary engine protection and safe operation as they can lead to engine failures. Thus, we undertook significant testing efforts to assess how far the EGR could remain active despite the known temperature issue and determined the necessary adaptation of the EGR strategy. This is done to obtain the best coexistence of sustainable, maximum NOx reduction as well as necessary engine protection and safe operation for each engine separately and explains why temperatures may differ depending on the respective vehicle type and engine. Also, high exhaust gas temperatures generated by high engine loads can pose risks to the integrity of the EGR system. For example, any EGR valve has a certain temperature limitation. To protect the integrity of the system, it is therefore necessary to adapt the EGR rate to avoid excessive temperatures on the valves that could cause damage to the valves and lead to engine stall. Such adaptation is again only done temporarily and only as long as necessary, when the respective engine conditions exist. With regard to the type approval process, we have always cooperated with technical services and type-approval authorities and we provide all information required in the course of the type-approval process. Detailed information requirements on the emissions control strategies for type-approval are implemented by the RDE packages. - 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? Our DPF and LNT are permanently active. EGR is switched off at ambient temperatures at around below minus 10 and above plus 50 degree Celsius. We verify the setting of these limits as well as any adaptation of EGR activity in a very thorough three step process already explained above (please see 1). It is a widely known fact in the scientific community and the automotive industry that diesel engines of all designs and hardware encounter issues with soot deposition at low temperatures. Soot deposits can cause engine damage. The increased presence of hydrocarbon at low temperatures was also confirmed at our testing. We recognized severe engine damage on the EGR valve, swirl control valve, EGR cooler and air control valve by soot condensation. Soot deposits are therefore opposing necessary engine protection and safe operation as they can lead to engine failures. Thus, we undertook significant testing efforts to assess how far the EGR could remain active despite the known temperature issue and determined the necessary adaptation of the EGR strategy. This is done to obtain the best coexistence of sustainable, maximum NOx reduction as well as necessary engine protection and safe operation for each engine separately and explains why temperatures may differ depending on the respective vehicle type and engine. We assume that a discrepancy in temperature limits used by car manufacturers also derives from differences in the concrete set-up of the respective technologies and the specific characteristics of each emissions control system. However, please appreciate that we cannot comment on other OEMs. Since other OEM s technical development strategy is a business secret and consequently kept confidential, we do not have the information to comment on this. - 5 -
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? We are currently not selling diesel cars in the US. Please appreciate that we cannot comment on other OEMs. Since other OEM s technical development strategy is a business secret and consequently kept confidential, we do not have the information to comment on this. - 6 -
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? Please appreciate that it is difficult to determine "a" best available technology. Such evaluation will largely depend on the current level of development of each technology and therefore vary. Also, each technology and each combination of technologies will always have advantages and disadvantages that must be considered from case to case. We would therefore rather not rank technologies, but we can share the following: With regard to NOx tail-pipe reduction technologies, in our view, a combination of EGR, LNT and SCR technology is a good solution to effectively reduce emissions on the road. This combination is currently under mass production development. We are therefore implementing this combined technology to ensure compliance with RDE requirements. With regard to CO2 and NOx reduction technologies, there is a huge amount of information and new technologies. But if we summarize our technical development roadmap, it can be as follows: Engine combustion efficiency improvement: higher injection pressure, high precise injection control strategy, higher volumetric efficient port, more efficient turbocharger, optimized compression ratio and combustion chamber design, improved engine thermal management and exhaust heat recovery system etc. Engine friction reduction: aluminium block, steel piston, DLC (diamond like carbon) coating, variable coolant/oil pump, more efficient high pressure fuel pump, cam shaft journal width optimization, low friction oil seal etc. Reduction of vehicle road load: optimized body design, lower rolling resistance tire, reduction of brake friction etc. Electrification: hydrogen based fuel cell technology, plug-in hybrid, full hybrid, electric vehicle etc. - 7 -
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? As to the best available technologies, please see 7. Our development strategy to meet WLTP and RDE regulations and mass production schedule is as follows: We are narrowing down our technical solutions into one common concept to meet WLTP and RDE regulations. The most feasible solution according to our research currently is a combination of EGR, LNT and SCR technology. We are planning series production with this solution from 2017. We are pursuing highest quality standard, which is why it needs some time to set up and fully evaluate our new technology (please see 1). - 8 -
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? The ECU consists of hard- and software, which are both provided by the supplier. We do not have access to the software code, but we receive the information (description of software functions) that is needed for the calibration of the software to run the engine. Thus, we are calibrating based on the supplier s software. The software falls under business confidentiality and is protected by intellectual property rights of the supplier. We fully respect the supplier's rights and cooperate in this manner. We generally support the principle of transparency as set out in the latest RDE regulations. If type approval authorities want to check ECU functionalities, we will be happy to cooperate in this regard and to the extent possible for us. Our benefit and risk assessment is as follows: A benefit might be that this could help build up customer s trust in the automotive industry and improve the transparency of technical information of emissions control systems, though we would also have to acknowledge confidentiality of such information, as also set out in the latest RDE regulations. A risk is the possibility of unidentified or illegal modification by third parties if, for example, confidential information becomes public. Another risk is further administrative efforts for authorities, OEMs and suppliers. - 9 -
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 pipe-end technologies, to reduce the emissions? The after-treatment system is not an isolated system but it is part of the engine. Thus, many other aspects play a role for emissions behaviour and reduction. As discussed in 7, the engine development plan to reduce emissions consist of (not after-treatment technology): Engine combustion efficiency improvement: higher injection pressure, high precise injection control strategy, higher volumetric efficient port, more efficient turbocharger, optimized compression ratio and combustion chamber design, improved engine thermal management and exhaust heat recovery system etc. Engine friction reduction: aluminium block, steel piston, DLC (diamond like carbon) coating, variable coolant/oil pump, more efficient high pressure fuel pump, cam shaft journal width optimization, low friction oil seal etc. Reduction of vehicle road load: optimized body design, lower rolling resistance tire, reduction of brake friction etc. Electrification: hydrogen based fuel cell technology, plug-in hybrid, full hybrid, electric vehicle etc. In addition to this, we are working on low pressure combustion and a variable valve system to enhance internal EGR with the focus of engine-out (raw) NOx reduction. - 10 -
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? In the EMIS questionnaire, the JRC states that "[t]here are indeed circumstances under which a modulation or even a deactivation of emission control systems might be necessary. This could be for example the case at low temperature where EGR systems might encounter condensation damaging the engine Therefore such exemptions should be made on a case by case basis " This is why our emissions control system is developed individually for each engine/vehicle combination in a very thorough process (please see s 1 and 4). During the development process of a product, engineers will usually consider several technical variations and alternatives to reach a certain goal, and they will test and verify these solutions and also modify some of these ideas for several reasons. We develop and design our engines in order to comply with all applicable regulations. If we choose to make use of one of the exemptions as provided for in Article 5(2) of Regulation (EC) 715/2007, we do this to the best of our knowledge as well as for engine protection and safe operation of the vehicle only. JRC also states that the use of such exemptions must be made by "taking into consideration technical progress and the best available technology on the market with the different vehicle categories". This is why our research and development aims to improve our product continuously by developing and using the best technologies available to us (please see s 7 and 8). We are undertaking significant efforts to effectively reduce emissions and ensure compliance with RDE requirements. - 11 -
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 know that the definition of "normal use" is currently being discussed, not only in the course of the current emissions investigations, but already in the past in the context of the RDE discussions. The first RDE packages have been adopted only recently and RDE will be introduced step by step. In general, we understand that normal use is a broad term which is not defined in the applicable regulations and which depends on several factors (region, driver behaviour etc.). Putting it simply, it is normal driving under usual conditions, i.e. it does not include excessive driving (e.g. highly aggressive driving) or extreme conditions (e.g. below -7 degree Celsius). As set out in 1, we are testing under various different driving conditions and continuously monitor our vehicles in the field. - 12 -