TCMV and TAAEG Replies

A 013320 20.12.2016 Committee of Inquiry into Emission Measurements in the Automotive Sector EMIS hearing on 21 June 2016 Replies to the Questionnaire to Commission Representatives on TCMV and TAAEG No Question Reply TCMV 1. Is there a difference between the RDE-LDV expert The Real Driving Emission-Light Duty Vehicle (RDE-LDV) working group is the main group group, the RDE-LDV working group and the RDE set up in January 2011 with the objective to support the development, by the Commission, taskforce? What are these groups exactly, to which of a complementary test procedure that ensures that the emissions of regulated pollutants organisation do they report, who participated in these are appropriately controlled under normal conditions of vehicle use. Two expert groups groups and what role did they play in the process? were set up as sub-groups of the RDE-LDV WG (the so-called "RDE-LDV expert groups") to Could you please provide us with a detailed discuss and develop specific aspects: (1) the Task Force on Data Evaluation set up in composition per grouping, and any of its subgroups November 2013 with the mandate to assess the potential data evaluation methods and to (exact number of members with detailed specification further fine-tune them; and (2) the PEMS procedure drafting group set up in June 2014 per organisation represented)? with the mandate to collect expertise on instrumentation and testing and, based on the initial draft prepared by the JRC, to support the development of the structure of the procedure. The role of these groups is to provide specific advice and expertise to the Commission services with regard to the specific tasks allocated to them. The outcome of the two expert groups is discussed in the RDE-LDV working group. The proposals of the later are then discussed at TCMV level. The group is open for participation to everyone interested in its work and, in fact, experts representing NGOs, academia, equipment manufacturers and automotive industry associations, as well as Member States' authorities and Commission representatives are participating and contributing to its work. The Composition of the participants is balanced and at the same time reflects the specific tasks of the group and the type of expertise required for completing these tasks. All the representatives are participating on equal footing and a no voting system is applied. 1 All the drafts prepared by the two sub-groups are submitted and discussed in the RDE-LDV working group and the results are made public via CIRCABC. There is only one section in the group library to which access is restricted, i.e. the one covering the work of the Task Force on Data Evaluation. Due to the sensitivity of some of the data in this section, access is only given by request and has been provided to various stakeholder groups who are contributing to its work. These include industry, Member States, academia and NGOs. Detailed information on the RDE-LDV working group and its sub-groups is provided in Annex I. All the information concerning the profile of each organisation represented in the RDE-LDV Working Group is publicly available and can be found on the respective organisation's website. 2. At the Commission level the car industry is actively The Commission acts in the general European interest, not in the interests of any specific participating in the work of various "expert groups" group or stakeholder. Stakeholder consultations are integral to well-informed decision- providing "expertise" and technical advice. While it is making and serve to improve the quality of EU law making. In this context, it is natural that clear that the car industry has a lot of useful expertise the Commission closely interacts with a wide range of stakeholders and seeks their views on the subject, which clearly should be taken advantage on how to best design the regulatory framework. This has also been the case in the course of, the influence the industry has on the final version of of preparation of the RDE regulation, where the Commission services regularly consulted proposed legislative measures is rather worrying. Do industry, Member States, research institutions and NGOs. you see any conflict of interest that occurs when those However, stakeholders' input only represents a fraction of the information being assessed being regulated have vital influence on the regulation by the Commission when preparing a legislative proposal, which includes scientific and itself? Should representatives from the car industry only technical publications, results from EU funded research projects, JRC studies, etc. Hence, be consulted at an initial consultative stage of the consulting stakeholders does not prevent the Commission from taking its decisions process and further on any contact should be independently and autonomously. The Commission therefore does not consider prohibited? stakeholder consultation as a potential conflict of interest or as a threat to its integrity. An example of how industry suggestions were treated by the Commission services in the preparation of the RDE is provided in the table attached to Annex I. It shows how the Commission dealt with comments from the European Automobile Manufacturers' Association (ACEA), the main representative of car manufacturers at European level, with regard to key elements of the 2nd Regulation on Real Driving Emissions (RDE), namely the trip definition, boundary conditions and the transfer functions. None of the suggestions to weaken the draft Regulation were taken on board. All the discussions were taking place at 2 the RDE-LDV working group and were led by evidence-based arguments. 3. During the work of the TCMV committee, ACEA made During the deliberations within TCMV, any views, suggestions and recommendations from different several demands which were aimed at weakening the sources (including industry and/or independent experts), can be brought to the attention of the more stringent and therefore more-difficult-to-comply- Committee by any Member State and/or the Commission that are the only members of the TCMV with testing conditions, which, ACEA claimed had unlike the industry which is not represented in the Committee. In addition, Member States are free to request additional technical or scientific expertise from the Commission or any other relevant nothing to do with realistic car use. For instance less external stakeholder, where deemed necessary. time spent testing in towns or on motorways, narrower boundary conditions, exclusion of cold start emissions An example of how the Commission dealt with ACEA comments in the broader context of in the first package, emissions after prolonged stops not the TCMV's work is provided in the response to Question 2 above. counted, no high-speed tests etc. How does the TCMV work when faced with such demands? Do you bring independent experts that can present scientific and technical facts? Or is the work of the technical committee more political than technical? 4. We understand that on 31 January 2011 DG Enterprise The Euro 5 requirements apply from September 2009 to new types of vehicles and from organised the kick-off meeting of the RDE-LDV working January 2011 to all newly produced vehicles. The Euro 6 requirements apply from group whose objective was to develop a September 2014 to new types of vehicles and from September 2015 to all newly produced complementary test procedure that ensures that the vehicles. The provisions of Article 14 of Regulation (EC) 715/2007 make the emission test emissions of regulated pollutants are appropriately procedures conditional to a review of the emissions of Euro 5/6 vehicles. However, an controlled under normal conditions of vehicle use. This assessment could only be completed once a significant number of Euro 5 vehicles were available on the market. In this regard, the outcome of the first study delivered by the JRC took place four years after the adoption of the 2007 in 2011 was needed to provide the necessary scientific evidence and testing data for the Euro 5/6 Regulation, which mandated the Commission development of real driving emission test procedures. to keep the test cycle under review. The RDE-LDV working group looked into four potential approaches to improve the future We understand that between the beginning of 31 real driving emission (RDE) test procedures in the context of type-approval (multi-cycle January 2011 and the end 2012 four candidate testing like in the US, emissions modelling, random driving cycles and on-road emissions procedures were initially discussed in the RDE-LDV testing with PEMS). working group: Approach (i) was very much favoured and claimed to be effective by industry. It was 3 i. multi-cycle test approach like in the US, considered to assess and test an "honest" (i.e. realistic) environment since it would in principle require the optimisation of emission control over a large area of the engine map. ii. emissions modelling, However, it would still leave the possibility for the use of "defeat devices", i.e. cycle sensing iii. random driving cycles, and subsequent adaptation of NOx control. This approach was rejected by the Commission iv. on-road emissions testing with Portable Emissions and national regulators due to the serious concerns regarding the possible use of defeat Measurement Systems (PEMS). devices. An example for this doubt is that it would have been possible for car manufacturers to reduce the level of emission control at temperatures below the lab test After that, only the two latter options were taken temperature or at driving patterns not corresponding to a regulatory cycle. forward for further consideration. Only in October 2013 the work continued with a dedicated RDE task force Approach (ii) was not followed up further because at that time it was not considered as focusing on the last option.

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