A 012036 11.11.2016 Committee of Inquiry into Emission Measurements in the Automotive Sector s to the PSA GROUP No 1 From a technical point of view, exemptions 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 in case 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? Emissions control needs to be considered as an overall system (control of emissions in the combustion chamber, post treatment). The engine durability and vehicle safety result from overall optimisation of this system. The new requirements for the declaration of BES and AES enable type approval authorities to evaluate the overall performance of the system for both safety and environmental performance, which is a significant improvement in the regulation. 2 In your reply to the EMIS questionnaire to car manufacturers you state that the term in normal use in Art. 5(1) is not defined in Regulation 715/2007. What made you come to the conclusion that in normal use would mean the specific controlled test environment combined with specific software to alter the function of the emission control system? We do not agree with this conclusion: In the absence of a precise definition of normal use in the emissions regulation we ensure that our emissions control systems work over a very wide range of conditions, which are much more varied than the test conditions. 3 You claim that the combination of emission control technologies used by PSA works together in a complementary manner in order to provide high efficiency across a very wide temperature range, and that PSA Group's BlueHDi is very reliable and resistant at all temperatures. Could you please explain why environmental NGO Transport & Environment placed one tested Peugeot (5008, 1.6 BlueHDi) and one Citroen (C4 Picasso II, 1.6 BlueHDi) on their list of "Dirty 30", claiming that test results for both vehicles suggest usage of a thermal window (NEDC NOx emissions over 160 mg/km)? Two other vehicles that emit at least more than two times the Euro 6 limit on NEDC are: Peugeot 3008 1.6 HDi and Peugeot 508 2.0 HDi. At the same time, the same report claims that your Peugeot 208 (1.6 BlueHDi) is one of the few cars that actually achieve the air pollution standards in normal use conditions. 1
Can you please explain this discrepancy? Why are you using thermal windows for some of your vehicles while at the same time you are perfectly able to meet the legal standards not only on NEDC but also in real conditions? The report that you refer to compiles test results from several different programmes, undertaken under varied conditions. We have fully cooperated with the national test programmes. There are variations in test results due to a combination of different vehicle characteristics such as vehicle mass and test protocols and conditions (driving dynamics, ambient conditions ). PSA Group s SCR system used for BlueHDI 6.b motorizations makes it possible to treat NOx within the regulatory limits for all vehicles, including the most difficult to satisfy (heavy vehicles fitted with small engines). In customer use the depollution system is in constant use at its nominal operation of NOx conversion. It covers not only the regulatory need, without exception, but it injects a quantity of AdBlue higher on average than the regulatory need for the majority of vehicle applications. 4 Have you actually carried out an internal investigation to find out the reasons for the indicated discrepancies between the measurements of emissions of vehicles (NOx and CO2) in laboratory tests versus in real life on the road? This refers to the fact that in the latter case these are higher by factors not correlating with what could be expected in real-driving conditions as a natural response of the engine and its after-treatments to variations in the load? If yes, with which results or internal measures? In the course of powertrain development we undertake extensive internal testing. This is the basis for the development of our emissions control strategy that is now declared to the Type Approval Authority as BES and AES. The recent development of PEMs has improved our understanding of emissions on the open roads and of some limits for the control of SCR such as ammonia slip. This will enable us to improve our innovative SCR technology and is the basis of the development for the next generation Euro6.D TEMP engines (2017) which will meet a NOx Conformity Factor of 1.5 (2020 requirement). The NEDC test cycle is not representative of our customers typical vehicle use. However we have a legal requirement to use the NEDC cycle and publish these test results on car labels. We have developed with two NGOs (T&E and FNE) a test protocol much closer to our customers use and we publish this information on our websites in a way that avoids creating confusion with the regulatory results. We support the rapid introduction of WLTP and RDE for a regulation closer to our customer s real use. 2
5 On 07.06.2016, EU Observer quoted Commissioner Bieńkowska saying that the car companies have not acted in good faith. She further stated that there is a lack of enforcement on a national level that had led to an environment in which carmakers believed they could get away with it. How do you understand these statements? Do you feel you did not act in good faith with regard to the ban of defeat devices? PSA s vehicles comply with applicable regulations in all countries where they are sold. PSA has a history of voluntarily introducing innovative after-treatment technologies that bring real world benefits, as illustrated by our pioneering work on diesel particle filters and more recently the generalization of SCR on all our diesel cars/powertrains. This is proof of our good faith. 6 Manufacturers are accused of not using the full potential of emission control systems of diesel-fuelled light duty vehicles on purpose, to increase the durability of the diesel particle filters. Would switching off the emission control and reduction systems result in a lower accumulation of ash and soot in the LDV's diesel particle filter? PSA is proud to be the inventor of the diesel DPF. Our proprietary system is very robust and does not limit our use of the emissions control system for gaseous pollutants (EGR, SCR.) 7 How many and which patents in the sectors of emissions reduction and of emission after-treatment, in particular of diesel-fuelled light duty vehicle engines has the PSA Group developed/filed? PSA is consistently the number 1 patent filer in France. The league table of the INPI (l'institut national de la Propriété Industrielle) for 2015 indicates 1012 patents for PSA compared to the second place of 769 patents. Concerning diesel technology we have filed more than 1000 patents specifically on diesel technology and approximately 3000 on engine technology between 2000 and 2014 # # 2014 is the most recent data as there is a delay of 18 months between patent application and approval. 8 PSA decided to apply SCR across the board for all EURO6 diesel: what motivated this decision? Albeit less excessive than vehicles equipped with LNT, discrepancies with limit values are still measured with SCR technologies: would it possible to programme the emission control software of the PSA vehicles to enable reducing the NOx discrepancies to meet the limit values on the road? What would that entail for the manufacturer and the 3
consumer? From the vehicles type approved and registered in the EU market it is clear that the number of cars with LNT has been increasing (from 5% in 2012 to 55% in 2014) while SCR represented only 40% in 2014 when about 1 million Euro 6 diesel passenger cars were sold in the EU-28. What do you think about the emission strategy of other manufacturers who decided not to introduce SCR for EURO6 diesel vehicles and that exceed the legal limit even more? Do you believe this is fair competition? PSA s decision to generalise SCR on all its Euro6.b engines was based on our internal conviction that it was the best technical solution and with the highest potential for future improvements. However, we do not claim that other combinations cannot reach the same efficiency level and we believe that it is preferable and possible to define performance levels rather than technology. The best way to ensure fair competition is a robust and modern regulatory system and we therefore support the rapid introduction of a combination of a repeatable laboratory test (WLTP) and a real driving test (RDE). The engine software management is directly linked to the engine hardware and there is very limited possibility of adaptations. However since our launch of SCR for our complete range of diesel engines we have continued research and development to improve this innovative technology. This is why we will be able to meet the 1.5 Conformity Factor (regulation for 2020) as early as September 2017 (see question 9) 9 PSA has committed to meeting the 2020 RDE's Conformity Factor level of 1.5 starting from September 2017, while other car manufactures and Member States argue that even meeting the 2017 Conformity Factor level of 2.1 will be very challenging for the industry. Can you please explain the discrepancy in approach? Can you please tell us how this would be possible? Since launching SCR for our complete range of diesel engines, we have continued research and development to improve this innovative technology. At this stage the exact technology package for our powertrain euro6.2 is confidential. We will publish details of this technology package when we launch these powertrains in 2017. 10 Has the so-called witness-testing at manufacturers sites been used during the type approval procedure for light duty vehicles of the PSA Group? If so, what is the share of witness-testing within the total number of type approval tests of the PSA Group? We support the provision of witness testing in the type approval regulation as technical authorities cannot have sufficient testing capacity for our needs. For example, the introduction of Euro6.D TEMP in a 12 month period will require our Group to obtain type approval of over 150 powertrains. This will 4
be followed by the rapid introduction of Euro6.D with a similar work load. 11 The French government set up a program to test vehicles for NOx and CO2 emission after the Volkswagen scandal. Has the PSA group taken part in it either the planning or testing phase? Does your group have an in-house technical service? If yes, does it provide the results of technical testing to type approval authorities? The French government program is completely independent of Groupe PSA. PSA has not participated in the vehicle selection/planning/ testing. No testing has been performed on PSA facilities However PSA has been questioned on the test results of PSA vehicles We do not have in-house technical service in the sense of type approval regulation. However we have internal test facilities for development purposes 12 Please explain the PSA Group's efforts to improve the environmental sustainability of your current fleet and to reduce emissions more efficiently. Is retrofitting considered to be a solution? Since launching SCR for our complete range of diesel engines, we have continued research and development to improve this innovative technology. The engine software management is directly linked to the engine hardware and there is very limited possibility of adaptations. 5