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The Evolution of the Eec Regulations on Vehicle Emissions
A. Crucq (Editor), Catalysis and Automotive Pollution Control ZI 0 199 1 Elsevier Science Publishers B.V., Amsterdam
35
THE EVOLUTION OF THE EEC REGULATIONS ON VEHICLE EMISSIONS H. Henssler, Commission of the European Communities
1 - INTRODUCTION This paper deals mainly with the evolution of the regulations of the European Communities relating to the control of exhaust emissions from motor cars since the first CAPOC-seminar in 1986. As an introduction the main principles of the so called "Luxemburg Compromise" of June 1985, are briefly recalled as they represent the key for understanding the further evolution of the European emission standards. These principles were : (a) to set up European standards which in their effect on the environment were equivalent to the emission standards of the USA, however, taking into account the specific conditions of Europe concerning its car fleet and traffic patterns. (b) to allow for a choice of technologies to comply with the future European standards, these technologies being essentially the closed loop three-way catalyst and, as an alternative supposed to be cheaper, lean burn engine concepts, if necessary, fitted with simple oxidation catalysts. The realisation of these principles have led to a regulation containing 3 distinct sets of limit values according to 3 categories of engine capacities : 2 litres and more, 1.4 to 2 litres and less than 1.4 litres. In correspondance with the assumed availability of the concerned technologies also distinct implementation dates have been fixed : - For the category above 2 litres : 1 October 1988 for new car types, 1 October 1989 for the registration of new cars, - For the category between 2 litres and 1.4 litres : 1 October 1991 for new types and 1 October 1993 for all new cars and - For the category below 1.4 litres : 1 October 1990 for new types and 1 October 1991 for all new cars. The standards of the Luxemburg compromise are based on the existing European test procedure, the so-called urban driving cycle, but allowing, as a transitional measure, the alternative use of the US - FTP 75 driving cycle. These standards also require all spark ignition engines to be adapted to the use of lead-free petrol of 95 RON. They are equally applicable to diesel engines, however, engines with more than 2 litres being submitted to the standards of
36
the medium category. The Luxembourg compromise had to wait until 3 December 1987 to become an EEC Directive thanks to the European Single Act of February 1986, which introduced the possibility of decisions by a qualified majority, thus overcoming the Danish and Greek vetos. This Directive with the reference 88/76/EEC represents the 5th amendement to Directive 70/220/EEC which had established in 1970 the basic emission standards of the European Community. For the sake of completeness it may be added that the United Nations' Economic Commission for Europe translated in 1988 this latest EEC Directive into a new ECE Regulation no 83 intended to replace their traditional regulation no 15 covering motor car emissions.
-
2 FURTHER EVOLUTION The further evolution of the European emission standards since 1985 has been largely determined by a number of commitments which were part of the Luxemburg compromise or have been taken in connection with the adoption of Directive 88/76 : These commitments concerned : - the substitution of the interim standards for the car category below 1.4 litres by more severe European standards - the completion of the existing urban test procedure by sequences representing driving conditions on highways and motorways - the setting of standards for the emission of particulate matter by diesel powered cars - the introduction of requirements concerning the durability of emission control devices and the evaporation of fuel.
2.1 - The Extra-Urban Driving Cycle Immediately after the Luxemburg Council the Commission charged its well established expert group on vehicle emissions known under the abbreviation MVEG with the technical work resulting from these commitments. This group is composed of the experts of the interested national administrations, of the motor and petrol industry and of consumer and environmental organizations. Its work in relation to the future European extra-urban driving cycle started on the basis of studies of typical highway and motorway driving patterns in Germany and the United Kingdom and by the Committee of Common Market Constructors. The results of these studies were put together and resulted in a synthesized driving cycle which was presented in March 1988 as the European Extra Urban Driving Cycle "EUDC", caracterized by a relatively simple driving pattern and presenting a peak speed of 120 km/h and an average speed of 62.6 kmh. MVEG then examined the possible combination of this cycle with the
31
existing urban driving cycle with the help of tests carried out on a representative sample of 133 cars of different types and featuring different emission control systems. Eventually, the group agreed on a combination where the urban cycle precedes the extra-urban cycle, a combination which became known as "MVEGA" and which preserves the potential of the urban cycle to measure emissions at a cold start.
2.2
-
Diesel Particulate Standards
In parallel, MVEG worked on the future European standards for the emissions of particulate matter of cars powered by diesel engines on the basis of an investigation of the actual emissions from present European diesel car models. As sampling and analyzing method that of the present US regulation was retained and efforts were made to adapt it to the European test procedure. In June 1988 this work resulted in the adoption of Directive 88/436/EEC. Because of the lack of precision of the sampling method and the resulting relatively high limit values (1.1 dtest for type approval and 1.4 g/test for the control of production conformity), it was understood that this Directive could only represent a first stage of the particulate control in the EEC and the European Parliament fixed as the objective for a further more stringent stage with 0.8 g/test for type approval and 1.0 g/test for the control of production conformity. 2.3
- Emission Standards for Small Cars
Finally, MVEG examined the question of definitive European emission standards for the car category below 1.4 litres. The result of the technical work suggested that if the principles of "technical choice" and "reasonable costs" were to be retained, the limit values for the gaseous emissions of the small car category should be equal to those of the medium category i.e. 30gtest for CO and 8gtest for the combined mass of HC and NOx. These limit values were proposed by the Commission in 1987 and were approved in November 1988 as the common position of the Council and the Commission in accordance with the Single Act procedure. The European Parliament, however, with which Council and Commission have to co-operate under this new procedure, was of the opinion that the environmentai situation had becoms dramatic in the EEC, on the one hand, and that the closed loop three-way catalyst technology was now available to the whole European car industry, on the other hand. Consequently, the Parliament requested limit values which are at least as severe as those of the USA for the small car category which represents roughly 60% of the present European car fleet. After some discussions, the Commission followed the Parliament and
38
presented in May 1989 a revised proposal. The majority of the Member States agreed in June 1989 and adopted directive 89/458/EEC with the limit values of 19 gjtest for CO and 5 g/test for HC+NOx (type approval limits) to be applied on 1 July 1992 to new car types and on 31 December 1992 to all new cars. This decision represents another milestone of the motor vehicle emission regulations of the European Community : The principle of the technological choice has been abandonned and replaced by the principle of the best available technology on which the future European standards have to be based. Consistantly, the Council committed the Commission to present a proposal which aligns the limit values of all car categories to those of the small car category and, at the same time, to adapt these standards to the improved test procedure including the extra-urban driving sequences.
2.4
-
The Consolidated Directive
In compliance with these commitments, the previous ones from June and November 1985, and the recent ones from June 1989, the Commission decided to comprehend in one directive the different requirements relating to gaseous and particulate emissions of passenger cars and thus to consolidate the EEC emission standards for this vehicle category. Of course, the proposal is based on the results of the MVEG work described above : the driving cycle completed by the extra urban sequences, the improved particulate sampling method and the specifications for testing the durability of emission control devices and the evaporation of petrol from the fuel system of the cars. The limit values of this proposal for the gaseous emissions constitute a purely technical transposition of the small car standards into the new complete test procedure. The proposed particulate standards correspond to the objective fixed by the Parliament (0.8/1 .O gjtest). For this transposition the appropriate results of the 133 car sample established for the choice of the driving cycle combination has been used i.e. only those cars, both petrol and diesel, whose gaseous emissions were below the limit values of 19 g/test CO and 5 @test HC+NOx. The limit values which resulted from this operation are for the approval of new car types : 2.72 g/km C0.0.97 g/km HC+NOx and 0.19 g/km particles.The corresponding values for the control of production conformity are 3.16g/km CO, 1.13g/km HC+NOx and 0.24g/km particles. It is worth to note that these standards represent approximately 10% of the limit values of the first EEC directive of 1970 (70/220/EEC) relating to emission control. According to international practice, these standards are now expressed in "grams per kilometer" of the new European test procedure combining the urban and the extra-urban driving cycle representing a test distance of 1lkm. In accordance with the directive on small cars these limits are proposed to apply from 1 July 1992 to new car types and from 1 January 1993 to all new cars.
39
The Commission wanted of course to be sure that these limit values comply in fact with the postulate to be at least as severe as the existing US standards. Hence, a study was commissioned to 2 national testing laboratories in order to compare the actual emissions measured with the proposed European test cycle to those measured with the US test procedure FTP'75. The study was carried out with 44 representative European car models- 31 with petrol engines and equipped with closed loop three-way catalysts and 13 with diesel engines - complying with the CO standard of 19g/test and the HC+NOx standard of 5g/test of directive 89/458. This study showed despite an important scatter of the results, a clear trend of the European test procedure to yield generally higher emissions than the US procedure. This trend was most obvious for CO where the European test resulted in average in 45% higher values than the FTP'75 test. For HC+NOx and particulate emissions the average of the results were 15% higher than in FTP'75 test. In terms of limit values, this means, that the proposed European standards for gaseous emissions are indeed more severe - about 12% for CO and 4% for HC+NOx than the US standards. However, for particulate emissions the study showed that the objective fixed by the European Parliament and followed by the Commission has been too lenient : a value corresponding to the present US standard of 0.20gImile would be 0.14gkm In the European test and the corresponding standard for the control of production would be 0.18g/km. The Commission is prepared to correct its proposal in this respect.
3
-
ASSESSMENT OF THE PROPOSAL FOR A CONSOLIDATED EMISSION DIRECTIVE AND ITS POSSIBLE INDUSTRIAL EFFECTS
The main characteristics of the proposal are, on the one hand, the strict respect, by the Commission, of the previous agreements and commitments which are mentionned in the first part of this paper. The Commission believes in the continuity of the EC policy on vehicle emission standards because of its economic importance, in general, and of its bearing on the European automotive industry, in particular. On the other hand, this proposal is caracterized by the determination of the Commission to find a genuine European solution to the environmental problems caused by road traffic, a solution which is most adapted to the European conditions in respect of both its car fleet and its driving patterns. It needs to be said that the proposal which was presented to the Council of Ministers on 5 January 1990 and to the European Parliament on 22 February 1990 has not received a unanimous approval from these institutions. The majority of the European Ministers who discussed it at their meetings of 22 March and of 7 June 1990 declared it nevertheless to be a good basis for a rapid decision and confirmed their interest in a genuine European solution. The problems which have been identified so far appear to be more of a technical nature than fundamental. The European Parliament, at least its
40
Environmental Committee, appears, however, convinced that, in principle, the best for Europe would be to copy the American emission regulations. In the forthcoming dicussions, the Commission has decided to stand firm concerning its proposals and the following months will show what eventually, will be the solution which rallys the majorities of the European institutions. In any case, whatever the solution will be, from an industrial point of view, it appears clearly that from January 1993 on all cars produced for the market of the EEC in big series will be, independent of their engine capacity equipped with closed loop three-way catalysts if they are powered by petrol engines. As far as diesel powered cars are concerned, the proposed standards both for gaseous and particulate emissions, do not assume the use of catalysts or trap oxydizers. The reason for this is that expert consultations did not allow the Commission to assess neither the potential of these techniques, nor the time of their availability, with sufficient accuracy. The Commission will, of course, follow their development and, if possible, adapt the standards to their potential, in order to generalize their fitting to the concerned vehicles. 4
- OUTLOOK INTO THE NEXT FUTURE
The Commission is aware that catalysts deteriorate within a certain period of usage. The regulatory durability tests available now including the US - 50 000 miles- test which has been also included into the directive proposal do not offer a safe means to determine the moment when catalysts are no longer efficient and have to be replaced. The Commission believes that only a Community-wide system of periodic inspections of the cars in use is appropriate for this purpose and allows eventually to take the full environmental benefit of this technology. Consequently, the Commission is actively working on a directive proposal in this respect which it deems necessary to complete its present proposal relating to vehicle construction. Another complementary measure which the Commission will present in a few months, concerns the emission standards for all vehicles covered by the scope of this directive and not being passenger cars. Such vehicles, generally being light commercial vehicles of category N1 but also heavy passenger cars having more than six seats and/or a total mass exceeding 2.5 tomes, are presently governed by transitional provisions which submit them to more lenient standards than passenger cars. The reason for this is essentially that such vehicles have a power-to-weight ratio considerably inferior to that of typical passenger cars. Consequently, these vehicles have higher emissions than passenger cars under identical test conditions. At present, we are studying, a system of standards which is adapted to the technical conditions of these vehicles but represents the same level of severity as the proposed passenger car standards. Consequently, it can be foreseen that after the mid-nineties all motor vehicles driven by petrol engines will have to be equipped with closed loop three-way catalysts.
35
THE EVOLUTION OF THE EEC REGULATIONS ON VEHICLE EMISSIONS H. Henssler, Commission of the European Communities
1 - INTRODUCTION This paper deals mainly with the evolution of the regulations of the European Communities relating to the control of exhaust emissions from motor cars since the first CAPOC-seminar in 1986. As an introduction the main principles of the so called "Luxemburg Compromise" of June 1985, are briefly recalled as they represent the key for understanding the further evolution of the European emission standards. These principles were : (a) to set up European standards which in their effect on the environment were equivalent to the emission standards of the USA, however, taking into account the specific conditions of Europe concerning its car fleet and traffic patterns. (b) to allow for a choice of technologies to comply with the future European standards, these technologies being essentially the closed loop three-way catalyst and, as an alternative supposed to be cheaper, lean burn engine concepts, if necessary, fitted with simple oxidation catalysts. The realisation of these principles have led to a regulation containing 3 distinct sets of limit values according to 3 categories of engine capacities : 2 litres and more, 1.4 to 2 litres and less than 1.4 litres. In correspondance with the assumed availability of the concerned technologies also distinct implementation dates have been fixed : - For the category above 2 litres : 1 October 1988 for new car types, 1 October 1989 for the registration of new cars, - For the category between 2 litres and 1.4 litres : 1 October 1991 for new types and 1 October 1993 for all new cars and - For the category below 1.4 litres : 1 October 1990 for new types and 1 October 1991 for all new cars. The standards of the Luxemburg compromise are based on the existing European test procedure, the so-called urban driving cycle, but allowing, as a transitional measure, the alternative use of the US - FTP 75 driving cycle. These standards also require all spark ignition engines to be adapted to the use of lead-free petrol of 95 RON. They are equally applicable to diesel engines, however, engines with more than 2 litres being submitted to the standards of
36
the medium category. The Luxembourg compromise had to wait until 3 December 1987 to become an EEC Directive thanks to the European Single Act of February 1986, which introduced the possibility of decisions by a qualified majority, thus overcoming the Danish and Greek vetos. This Directive with the reference 88/76/EEC represents the 5th amendement to Directive 70/220/EEC which had established in 1970 the basic emission standards of the European Community. For the sake of completeness it may be added that the United Nations' Economic Commission for Europe translated in 1988 this latest EEC Directive into a new ECE Regulation no 83 intended to replace their traditional regulation no 15 covering motor car emissions.
-
2 FURTHER EVOLUTION The further evolution of the European emission standards since 1985 has been largely determined by a number of commitments which were part of the Luxemburg compromise or have been taken in connection with the adoption of Directive 88/76 : These commitments concerned : - the substitution of the interim standards for the car category below 1.4 litres by more severe European standards - the completion of the existing urban test procedure by sequences representing driving conditions on highways and motorways - the setting of standards for the emission of particulate matter by diesel powered cars - the introduction of requirements concerning the durability of emission control devices and the evaporation of fuel.
2.1 - The Extra-Urban Driving Cycle Immediately after the Luxemburg Council the Commission charged its well established expert group on vehicle emissions known under the abbreviation MVEG with the technical work resulting from these commitments. This group is composed of the experts of the interested national administrations, of the motor and petrol industry and of consumer and environmental organizations. Its work in relation to the future European extra-urban driving cycle started on the basis of studies of typical highway and motorway driving patterns in Germany and the United Kingdom and by the Committee of Common Market Constructors. The results of these studies were put together and resulted in a synthesized driving cycle which was presented in March 1988 as the European Extra Urban Driving Cycle "EUDC", caracterized by a relatively simple driving pattern and presenting a peak speed of 120 km/h and an average speed of 62.6 kmh. MVEG then examined the possible combination of this cycle with the
31
existing urban driving cycle with the help of tests carried out on a representative sample of 133 cars of different types and featuring different emission control systems. Eventually, the group agreed on a combination where the urban cycle precedes the extra-urban cycle, a combination which became known as "MVEGA" and which preserves the potential of the urban cycle to measure emissions at a cold start.
2.2
-
Diesel Particulate Standards
In parallel, MVEG worked on the future European standards for the emissions of particulate matter of cars powered by diesel engines on the basis of an investigation of the actual emissions from present European diesel car models. As sampling and analyzing method that of the present US regulation was retained and efforts were made to adapt it to the European test procedure. In June 1988 this work resulted in the adoption of Directive 88/436/EEC. Because of the lack of precision of the sampling method and the resulting relatively high limit values (1.1 dtest for type approval and 1.4 g/test for the control of production conformity), it was understood that this Directive could only represent a first stage of the particulate control in the EEC and the European Parliament fixed as the objective for a further more stringent stage with 0.8 g/test for type approval and 1.0 g/test for the control of production conformity. 2.3
- Emission Standards for Small Cars
Finally, MVEG examined the question of definitive European emission standards for the car category below 1.4 litres. The result of the technical work suggested that if the principles of "technical choice" and "reasonable costs" were to be retained, the limit values for the gaseous emissions of the small car category should be equal to those of the medium category i.e. 30gtest for CO and 8gtest for the combined mass of HC and NOx. These limit values were proposed by the Commission in 1987 and were approved in November 1988 as the common position of the Council and the Commission in accordance with the Single Act procedure. The European Parliament, however, with which Council and Commission have to co-operate under this new procedure, was of the opinion that the environmentai situation had becoms dramatic in the EEC, on the one hand, and that the closed loop three-way catalyst technology was now available to the whole European car industry, on the other hand. Consequently, the Parliament requested limit values which are at least as severe as those of the USA for the small car category which represents roughly 60% of the present European car fleet. After some discussions, the Commission followed the Parliament and
38
presented in May 1989 a revised proposal. The majority of the Member States agreed in June 1989 and adopted directive 89/458/EEC with the limit values of 19 gjtest for CO and 5 g/test for HC+NOx (type approval limits) to be applied on 1 July 1992 to new car types and on 31 December 1992 to all new cars. This decision represents another milestone of the motor vehicle emission regulations of the European Community : The principle of the technological choice has been abandonned and replaced by the principle of the best available technology on which the future European standards have to be based. Consistantly, the Council committed the Commission to present a proposal which aligns the limit values of all car categories to those of the small car category and, at the same time, to adapt these standards to the improved test procedure including the extra-urban driving sequences.
2.4
-
The Consolidated Directive
In compliance with these commitments, the previous ones from June and November 1985, and the recent ones from June 1989, the Commission decided to comprehend in one directive the different requirements relating to gaseous and particulate emissions of passenger cars and thus to consolidate the EEC emission standards for this vehicle category. Of course, the proposal is based on the results of the MVEG work described above : the driving cycle completed by the extra urban sequences, the improved particulate sampling method and the specifications for testing the durability of emission control devices and the evaporation of petrol from the fuel system of the cars. The limit values of this proposal for the gaseous emissions constitute a purely technical transposition of the small car standards into the new complete test procedure. The proposed particulate standards correspond to the objective fixed by the Parliament (0.8/1 .O gjtest). For this transposition the appropriate results of the 133 car sample established for the choice of the driving cycle combination has been used i.e. only those cars, both petrol and diesel, whose gaseous emissions were below the limit values of 19 g/test CO and 5 @test HC+NOx. The limit values which resulted from this operation are for the approval of new car types : 2.72 g/km C0.0.97 g/km HC+NOx and 0.19 g/km particles.The corresponding values for the control of production conformity are 3.16g/km CO, 1.13g/km HC+NOx and 0.24g/km particles. It is worth to note that these standards represent approximately 10% of the limit values of the first EEC directive of 1970 (70/220/EEC) relating to emission control. According to international practice, these standards are now expressed in "grams per kilometer" of the new European test procedure combining the urban and the extra-urban driving cycle representing a test distance of 1lkm. In accordance with the directive on small cars these limits are proposed to apply from 1 July 1992 to new car types and from 1 January 1993 to all new cars.
39
The Commission wanted of course to be sure that these limit values comply in fact with the postulate to be at least as severe as the existing US standards. Hence, a study was commissioned to 2 national testing laboratories in order to compare the actual emissions measured with the proposed European test cycle to those measured with the US test procedure FTP'75. The study was carried out with 44 representative European car models- 31 with petrol engines and equipped with closed loop three-way catalysts and 13 with diesel engines - complying with the CO standard of 19g/test and the HC+NOx standard of 5g/test of directive 89/458. This study showed despite an important scatter of the results, a clear trend of the European test procedure to yield generally higher emissions than the US procedure. This trend was most obvious for CO where the European test resulted in average in 45% higher values than the FTP'75 test. For HC+NOx and particulate emissions the average of the results were 15% higher than in FTP'75 test. In terms of limit values, this means, that the proposed European standards for gaseous emissions are indeed more severe - about 12% for CO and 4% for HC+NOx than the US standards. However, for particulate emissions the study showed that the objective fixed by the European Parliament and followed by the Commission has been too lenient : a value corresponding to the present US standard of 0.20gImile would be 0.14gkm In the European test and the corresponding standard for the control of production would be 0.18g/km. The Commission is prepared to correct its proposal in this respect.
3
-
ASSESSMENT OF THE PROPOSAL FOR A CONSOLIDATED EMISSION DIRECTIVE AND ITS POSSIBLE INDUSTRIAL EFFECTS
The main characteristics of the proposal are, on the one hand, the strict respect, by the Commission, of the previous agreements and commitments which are mentionned in the first part of this paper. The Commission believes in the continuity of the EC policy on vehicle emission standards because of its economic importance, in general, and of its bearing on the European automotive industry, in particular. On the other hand, this proposal is caracterized by the determination of the Commission to find a genuine European solution to the environmental problems caused by road traffic, a solution which is most adapted to the European conditions in respect of both its car fleet and its driving patterns. It needs to be said that the proposal which was presented to the Council of Ministers on 5 January 1990 and to the European Parliament on 22 February 1990 has not received a unanimous approval from these institutions. The majority of the European Ministers who discussed it at their meetings of 22 March and of 7 June 1990 declared it nevertheless to be a good basis for a rapid decision and confirmed their interest in a genuine European solution. The problems which have been identified so far appear to be more of a technical nature than fundamental. The European Parliament, at least its
40
Environmental Committee, appears, however, convinced that, in principle, the best for Europe would be to copy the American emission regulations. In the forthcoming dicussions, the Commission has decided to stand firm concerning its proposals and the following months will show what eventually, will be the solution which rallys the majorities of the European institutions. In any case, whatever the solution will be, from an industrial point of view, it appears clearly that from January 1993 on all cars produced for the market of the EEC in big series will be, independent of their engine capacity equipped with closed loop three-way catalysts if they are powered by petrol engines. As far as diesel powered cars are concerned, the proposed standards both for gaseous and particulate emissions, do not assume the use of catalysts or trap oxydizers. The reason for this is that expert consultations did not allow the Commission to assess neither the potential of these techniques, nor the time of their availability, with sufficient accuracy. The Commission will, of course, follow their development and, if possible, adapt the standards to their potential, in order to generalize their fitting to the concerned vehicles. 4
- OUTLOOK INTO THE NEXT FUTURE
The Commission is aware that catalysts deteriorate within a certain period of usage. The regulatory durability tests available now including the US - 50 000 miles- test which has been also included into the directive proposal do not offer a safe means to determine the moment when catalysts are no longer efficient and have to be replaced. The Commission believes that only a Community-wide system of periodic inspections of the cars in use is appropriate for this purpose and allows eventually to take the full environmental benefit of this technology. Consequently, the Commission is actively working on a directive proposal in this respect which it deems necessary to complete its present proposal relating to vehicle construction. Another complementary measure which the Commission will present in a few months, concerns the emission standards for all vehicles covered by the scope of this directive and not being passenger cars. Such vehicles, generally being light commercial vehicles of category N1 but also heavy passenger cars having more than six seats and/or a total mass exceeding 2.5 tomes, are presently governed by transitional provisions which submit them to more lenient standards than passenger cars. The reason for this is essentially that such vehicles have a power-to-weight ratio considerably inferior to that of typical passenger cars. Consequently, these vehicles have higher emissions than passenger cars under identical test conditions. At present, we are studying, a system of standards which is adapted to the technical conditions of these vehicles but represents the same level of severity as the proposed passenger car standards. Consequently, it can be foreseen that after the mid-nineties all motor vehicles driven by petrol engines will have to be equipped with closed loop three-way catalysts.