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25 May 2012 11:26
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Subject:
Real driving emission of light duty vehicles (RDE-LDV): audio/web conference of
Member States
Categories:
Yellow Category
Dear colleagues,
Yesterday we had a quite hot (in any sense) RDE-LVD meeting, for which an executive summary of the conclusions
will be distributed shortly.
It became quite obvious that vehicle manufacturers strongly resist the introduction of PEMS at any stage of type
approval (initially and at in-service conformity), while we are convinced that PEMS is definitely necessary at some
stage for NOx emission measurements under real driving conditions. Actually this ACEA attitude contradicts previous
talks I had with individual manufacturers that were ready to accept PEMS at least at in-service conformity. While we
may speculate now whether these reservations are motiviated by real concerns about practicalities (that would have
to be addressed) or the desire to have the random cycle as an "easier procedure" for emission compliance leaving the
door open for some cycle beating (which has to be avoided) I think we should discuss a third option that may bring
things forward:
1. PEMS procedure is developed as gold standard for NOx RDE assessment.
2. Random test cycle is developed in parallel as "equivalent" procedure (regarding coverage of driving conditions, of
course the issue of intentional cycle beating would remain)
3. Manufacturers may use either PEMS or the random test cycle at type aproval and in-service conformity
4. Member States (i.e. not only the approving type approval authority!) may assess the in-service emission
performance of vehicle families according to the well-defined PEMS procedure. NB: this would be real "market
surveillance" applied in many other product areas, which is not quite common yet in the automotive area. Given the
massive NO2 air quality problems of Member States it appears to be justified.
5. If non-compliance is identified, the case has to be reported to the approving authoritiy and there is a further
investigation (using PEMS and better statistics) for compliance. If final non-compliance is established there are well
defined consequences for the manufacturer, i.e. at least withdrawl of the type approval but also recall or financial
penalties in more severe cases.
I would like to have your views on this option. It is obvious that it would only work if Member States are really willing to
check emission performance of vehicles using PEMS with "sufficient" frequency.
Regards,
1