REMOTE SENSING: Improving and Enforcing In-use Compliance Testing of Real Driving Emissions The following paragraphs in this narrative reference the slides which follow. Slide 1: In-Use Compliance Testing of certified vehicle types or models currently requires conducting laboratory-based dynamometer emissions tests on recruited in-use vehicles of each certified model annually. Slide 2 (next page): Portable Emissions Monitoring Systems (PEMS) were developed as a truck testing solution after the 1990s defeat device scandal involving Heavy Duty Diesel Vehicles similar to the recent Volkswagen Light Duty Diesel Vehicle (LDDV) scandal. PEMS enable real world emissions or real driving emissions (RDE) to be measured directly by on-board analyzers and are proposed as a supplement to laboratory dynamometer testing. However, both Lab- and PEMS-based testing are intrusive requiring either an unusual mode of operation or mechanical and electronic connections to the vehicle which can be detected and potentially defeated/cheated. Furthermore, for economic reasons, they can only be practically conducted on a handful of vehicles per model each year, thereby, limiting their coverage and requiring vehicles to be recruited from use. The latter can prove challenging, costly, and may not even be representative of the vehicle model in the end. The Center for Automotive Research (CAR), University Duisburg-Essen, counted more than 3,000 different models of vehicles currently on sale just in Germany in 2014 - car models, body-designs and engine variations. JANUARY 2017 - PAGE 1 OF 11
Slide 3: Remote Sensing Devices (RSD) on the other hand have been used to unobtrusively measure real-world emissions of in-use vehicles for nearly 3 decades. Details about the technology can be found at http://opusinspection.com/remote-sensing-devicetechnology/what-is-rsd/. RSDs require no detectable mechanical or electronic connections to the vehicle and each RSD can measure the RDE of thousands of in-use vehicles each day. Many emissions measurements can be collected annually on each vehicle model operating in a region from their initial sale throughout their useful life. Slide 4: RSDs are widely used throughout the world for general vehicle emissions monitoring and individual vehicle screening. The largest on-going programs in the United JANUARY 2017 - PAGE 2 OF 11
States use RSDs to screen individual vehicles as a supplement to emissions inspection programs. The smaller ones use RSDs periodically to evaluate the in-use vehicle fleet emissions and the performance of the local emissions inspection program. China and Korea use RSDs to identify high emitters, while elsewhere in Asia and Europe, RSDs are routinely used to characterize in-use vehicle emissions. Slide 5: European researchers using RSDs published reports in the early 2010s alerting authorities to the elevated real-world NO x emissions observed from diesel passenger cars emitting well above their certification standards (the solid lines). Each red square is the mean emissions of a model year diesel passenger car and the whiskers are its standard error. JANUARY 2017 - PAGE 3 OF 11
Slide 6 (next page): Opus researchers were asked to examine the LDDVs in our large US databases of remote sensing emissions in order to confirm the finding of our European counterparts. We reported 2-litre VW and Audi diesel passenger cars with on-road NO x emissions well in excess of peers of similar 2-litre and 3-litre engine size and well above certification standards, effectively corroborating the European findings and demonstrating that RSDs can detect such anomalous emissions and be used for in-use compliance surveillance. JANUARY 2017 - PAGE 4 OF 11
Slide 7 (next page): We have since recommended to the EU Commission and the EU Environment Agency, to the US Environmental Protection Agency (EPA) and the California Air Resource Board (CARB) that RSDs be used more extensively to screen certified vehicle models on-road and direct those models exhibiting abnormally high emissions for compliance testing via PEMS and Laboratory techniques. Doing so on a much broader scale would address the recruitment and coverage limitations of PEMS and Lab-based techniques and introduce an independent and unobtrusive emissions surveillance technique that cannot be detected and defeated. The three technologies would thus complement each other and ensure effective enforcement of certification standards, just as the public would expect the enforcement scheme to work: JANUARY 2017 - PAGE 5 OF 11
Slide 8 (next page): RSD datasets of millions of real-world emissions measurements can identify vehicle model with emissions rates exceeding those of peer models and the approved standards with a high degree of confidence. The many measurements of each model that are gathered very efficiently in an active RSD program provide an emission assessment with standard errors sufficiently small for effective screening. The example below uses a single line for each model and year of manufacture to report its on-road emissions, compare its emissions to other models of the same age meeting the same compliance standards, and to estimate emissions in excess of the compliance standards. Color coding (green = OK, yellow = marginally high, red = high and purple = extreme) of the four pollutants (hydrocarbons, carbon monoxide, NOx and particulate matter) allows a rapid assessment of the emissions performance of models representing over 90% of on-road light vehicle activity. Priority can then be given to further investigating the models with abnormally high emissions using PEMS and Lab testing (see examples on the next page). JANUARY 2017 - PAGE 6 OF 11
Recommendation PEMS and RSD complement each other and thus provide informative and reliable results on the emissions of nearly all vehicle models registered and driven on the European Union s streets. Remote Sensing measurement is for compliance surveillance, PEMS measurement is significantly more precise and for compliance enforcement. Combining Remote Sensing and PEMS is a perfect tandem solution to prevent future in-use compliance violations. Contacts: Niranjan VESCIO Remote Sensing Technology Manager Herbert WOOPEN EU Representative 1121 W. Grant Rd. #407 Lawyer, Dr. iur., Docteur en droit Tucson, AZ 85705 Cologne, Germany Office: 520-230-4350 Office: +49 221 943 98 54 Cell: 520-907-4132 Cell: +49 163 38 76 601 Niranjan.Vescio@OpusInspection.com Herbert.Woopen@OpusInspection.com JANUARY 2017 - PAGE 7 OF 11
ADDENDUM: In-use Compliance Testing of Heavy-Duty Vehicle Real Driving Emissions 1. The recent VW dieselgate scandal is not the first time authorities have discovered that a vehicle manufacturer had been cheating on their diesel emissions type approval tests. In 1998 the USEPA sued seven major diesel engine manufacturers 1 for equipping heavy trucks with devices that defeated the engines emissions control system, resulting in the emission of illegal amounts of pollution slide 1. 2. Remote sensing technology was in its infancy in the mid- to late-1990s when these cheating trucks plied the roads, however, the limited data collected on US hightailpipe diesel trucks corroborated the laboratory and tunnel studies being conducted at the time slide 2. Together they exposed NOx rates under real driving conditions that far exceeded the permissible limits. 1 Engine Makers Fined in Settlement with EPA, 1998; http://articles.herald-mail.com/1998-10- 23/news/25108825_1_engine-manufacturers-emissions-tests-pollution-controls JANUARY 2017 - PAGE 8 OF 11
3. The effect of those defeat devices on NOx emissions is clearly evident in 2005 data because those emissions control systems still had not been reprogrammed - slide 3. Almost 2,000 total truck emissions measurements of all model years were gathered in the 2005 Dumont and Golden, Colorado remote sensing studies. The data clearly show the real driving NOx emission rates for the cheating models between the red bars far exceeded, and even increasingly diverged from, the applicable USEPA standards. Slide 3 Slide 4 4. By 2010 those engine control systems had been reprogrammed. In the remote sensing study conducted on Federal Way, Washington slide 4, it was clearly evident that corrective action had been taken. Effects of other emissions regulations are also evident in this slide. With the introduction of diesel particulate filters (DPF) to address the new particulate matter (PM) requirement, NO 2 emissions increased substantially in 2008. 2 Finally, with the introduction of ammonia selective catalytic reduction (SCR) to address the new NOx requirement, total NOx emissions dropped in 2011. 5. The effects of 2007 and 2010 emissions regulations are also clearly evident in results of the 2012 study conducted in the Fraser River Valley in Vancouver, British Columbia. 3 17% of the class 8 trucks registered in the Greater Vancouver area (11,700) were measured along with 23,600 LDVs over 55 days. The decile charts presented below once again show the remarkable 2008 drop in PM and the 2011 drop in total NOx slides 5 and 6 (next page). However, these charts also reveal that not all those modern trucks operated with low PM and NOx emissions. The existence of high emitters among DPF- and SCR-equipped trucks was evident and once again highlights the need for real driving emissions inspection and timely maintenance of in-use vehicles. 2 DieselNet; https://www.dieselnet.com/tech/dpf.php#performance; jump to Emissions Performance. 3 Vancouver RSD Study; http://www.feat.biochem.du.edu/assets/reports/2013_canada_ohms_rsd_hdv_study.pdf JANUARY 2017 - PAGE 9 OF 11
Slide 5 Slide 6 6. Periodic emissions inspections of HDVs is generally limited to idle testing and measurement of exhaust opacity because cost-effective technologies for measuring diesel emissions currently do not exist. 4 However, Opus has successfully operated a remote sensing-based HDV emissions inspection program for over 10 years that proves otherwise. 5 In Boston, the Massachusetts Bay Transportation Authority s ~1,000 municipal buses are emissions-inspected daily by remote sensors as they return to eight municipal depots in order to ensure clean and efficient operation slide 7. As high emitters are identified, depot mechanics are notified and provided emissions reports. Over time, the depot mechanics became adept at associating certain high emission patterns to common component failures (e.g. high hydrocarbon emissions to an oxygen sensor failure on a CNG bus) slide 8. In this manner routine maintenance of Boston s municipal buses has been made far more efficient and effective through remote sensing of real driving emissions. Slide 7 Slide 8 4 Diesel Inspection Review: http://search.proquest.com/openview/68ccc829cf853c7c51366939454e4e56/1?pqorigsite=gscholar&cbl=34654 5 MBTA: https://www.mbta.com/uploadedfiles/about_the_t/environment/mbta%20rsd%20history.pdf JANUARY 2017 - PAGE 10 OF 11
Recommendation Remote sensing devices are able to collect large volumes of measurements very efficiently. The millions of light duty vehicle (LDV) remote sensing measurements collected to complement US periodic inspection programs, enable non-compliant LDV types to be identified with low standard errors (i.e. high certainty). With few active heavy-duty vehicle periodic emissions inspection programs and none measuring more than exhaust opacity, heavy duty vehicle remote sensing has been limited to small boutique studies generating small datasets. Nevertheless, these studies clearly show that the effects of both non-compliant and compliant actions can be efficiently detected by the remote sensing of real driving emissions. A remote sensing program identifying heavy-duty vehicles with defeat devices or tampered emissions controls would allow countries and cities to protect their air quality from fleets of heavy-duty vehicles with excessive and illegal emissions. Contacts: Niranjan VESCIO Remote Sensing Technology Manager Herbert WOOPEN EU Representative 1121 W. Grant Rd. #407 Lawyer, Dr. iur., Docteur en droit Tucson, AZ 85705 Cologne, Germany Office: 520-230-4350 Office: +49 221 943 98 54 Cell: 520-907-4132 Cell: +49 163 38 76 601 Niranjan.Vescio@OpusInspection.com Herbert.Woopen@OpusInspection.com JANUARY 2017 - PAGE 11 OF 11