European Small Volume Car Manufacturers Alliance (ESCA) Comments and proposals ahead of the 3 rd package of measures on Real Driving Emissions 22 January 2016
BACKGROUND SVMs face unique circumstances with regards to compliance with new regulatory requirements: Lack of resources available to larger manufacturers to carry out the necessary research and development, and ultimately testing Negligible impact on current air pollution levels (NOx emissions in particular) due to small volumes Car usage is very modest Given the limited environmental benefit, the significant disproportional burden for SVMs compared to larger manufacturers, a more flexible regime for SVMs manufacturers would be more appropriate.
SVM CHARACTERISTICS Long product cycles Dependence upon other manufacturers for technologies such as powertrain, which makes the implementation of new emission requirements in a small timeframe very challenging. SVMs typically use the Small Series type approval to access the EU market. Small Series vehicles represent 0.07% of the total number of vehicles registered in the EU per year. ESCA members cars have an annual mileage of ~9,000km/year on average. Most SVMs produce vehicles with petrol engines, whose emissions are not very different from real driving conditions (in particular for NOx). Only 10% of the vehicles registered under Small Series are actually diesel vehicles, therefore representing 0.007% of the European fleet registered in one year.
ISSUES WITH RDE TEST The execution of the RDE test by ESCA members may still require some bodywork because of the peculiarity of the vehicles they produce when it comes to interior space, maximum technically permitted axle mass, vehicle design and geometry of the exterior. The share of the test burden for SVMs is disproportional compared with large volume manufacturers. Small companies producing very specialised products would suffer extra costs which cannot be amortised over very large sales volumes. In addition, the burden of the test will be very high because SVMs will typically not make use of the engine family concept. Many SVMs actually buy engines initially developed by a high volume manufacturer and adapt them to their products. They face different types of challenging situations when it comes to RDE testing Please refer to the series of scenarios outlined in Slides 5-9. The costs of an RDE test itself is estimated at around 7,000 but the development of the car for the full RDE testing programme could cost more than 400,000, resulting in very high costs per car for SVMs.*
ISSUES WITH RDE TEST: EXAMPLE OF SVM TESTING AHEAD OF AN OEM An SVM adopting a Powertrain from an OEM Current Powertrain into an Existing Type All Registrations SVM from an OEM Existing Type No OEM RDE Family SVM will be testing before the OEM. Test and development falls to the SVM
ISSUES WITH RDE TEST: EXAMPLE OF SVM TESTING AHEAD OF AN OEM An SVM adopting a Powertrain from an OEM Current Powertrain into an All Registrations Existing Type OEM Production stops before All Registration. No OEM RDE Family Test and development falls to the SVM
ISSUES WITH RDE TEST: EXAMPLE OF SVM TESTING AHEAD OF AN OEM An SVM adopting a Powertrain from an OEM Current Powertrain into an Non EU Existing Type All Registrations OEM engine not certified in EU. No OEM RDE Family Test and development falls to the SVM RDE required.
ISSUES WITH RDE TEST: EXAMPLE OF SVM TESTING AHEAD OF AN OEM Multi Stage adopting a Powertrain from an OEM Multi Stage All Registrations Base 1 st Stage Existing Type Final Stage Multi Stage Vehicle 1st stage Manufacturer stops production before 2 nd stage manufacture has registered all cars. No OEM RDE family. Test and development falls to the SVM
ISSUES WITH RDE TEST: EXAMPLE OF SVM TESTING AHEAD OF AN OEM Multi Stage adopting a Powertrain from an OEM Multi Stage All Registrations Base 1 st Stage Existing Type Final Stage Multi Stage Vehicle 1st stage Manufacturer Batch builds vehicles and stops production. RDE required. Test and development falls to the SVM
CONTACT US ESCA secretariat c/o Burson-Marsteller Brussels 37 Square de Meeûs, Brussels, B-1000 Tel. + 32 2 743 6611 chiara.gaudenzi@bm.com www.esca-online.eu