Response by the Fédération Internationale de l’ Automobile (FIA) to the Consultation paper of the European Commission on the Preliminary draft proposal for a Regulation of the European Parliament and of the Council relating to emissions of atmospheric pollutants from motor vehicles (Euro 5)
Publication date: 08 September 2005
The FIA is a global federation of touring and motoring organisations. World-wide we represent some 100 million motorists and in the European Union our member clubs have a combined membership in excess of 43 million motorists.
The FIA is pleased to have the opportunity to respond to the European Commission’s Consultation paper. In our opinion, protection of the global environment is vital and thus the impact of motor vehicles on the environment must be minimized. We would
also welcome a speedy implementation of Euro V requirements.
In order to inform motorists better about the environmental impact of their cars, our member club, the ADAC in Germany has research and developed “Eco Test” which was commissioned by the FIA Foundation for the Automobile and Society. Using
“Eco Test”, the emissions and fuel consumption of currently produced cars are measured, calculated and rated. And the results are made available on the Internet.
The position of the FIA as regards the proposals set out in this consultation:
1. An 80% reduction in particulate matter (PM) emissions from diesel cars to 5 mg/km, relative to the limit of 25 mg/km, which has become mandatory for new type approved vehicles from January 2005 under the “Euro IV” emissions standards.
FIA position: OK
2. A 20% reduction in nitrogen oxides (NOx) emissions from diesel cars.
EcoTest results (see figure 1 in the pdf-file) show that cars driving the homologation test cycle (NEDC) easily meet the Euro IV limit values. The reduction of the NOx emissions when actually driving in the real world is however clearly less than the reduction of the limit value of the test cycle.
FIA position: NOx limit: 150 mg/km.
3. A 25% reduction in emissions of both NOx and hydrocarbons (HC) from petrol cars.
Eco Test results confirm that the proposed limit values are currently met by 90% of the Euro IV petrol cars (figure 1 in the pdf-file).
FIA position: However we prefer no NOx reduction for petrol cars at this stage in order to achieve fuel neutral emission limits for cars at a later stage.
4. Introduction of a particulate emission limit for petrol cars using lean-burn direct injection technology (GDI).
A PM health related problem is caused by the so-called Ultra fine particles. These are a relatively minor part of the PM mass however, their number is important. The introduction of a limit value for their number would be a logical step forward.
FIA position: The FIA agrees with the proposed approach of waiting for the results of the UN/ECE Particulate Measurement Programme (PMP) and implementing a number standard through comitology at a later stage.
5. Extension of the durability period over which manufacturers must confirm the operation of emission control devices such as catalytic converters and particulate traps.
FIA position: OK. This corresponds better with the useful life of vehicles.
6. Passenger vehicles with a mass of over 2500 kg, such as SUVs, can no longer use the less ambitious emission standards for light commercial vehicles.
FIA position: OK, because these vehicles are used as passenger cars.
7. An implementation date of 18 months after the entry into force of the regulation for new type approvals and 36 months for all types.
FIA position: OK. FIA would prefer however, that the Commission retain the practice used for the implementation of time limited requirements used in Euro I, II and III. Clear notification to all stakeholders proved effective in avoiding difficult and lengthy discussions.
The FIA welcomes the proposal for the simplification of the emission legislation. However, the proposed repeal of 70/220/EC and its twenty adaptations and rectifications as mentioned in Article 12 can only be welcomed by the FIA once it is clear that all issues (e.g. OBD principles, access to repair information) are sufficiently covered in the new Regulation without loss of existing technical provisions. In this respect the FIA is looking forward to the new comitology proposal of the Commission as a means of speeding up processes. However, there should still be scope for stakeholders to make their view heard.