ACEA releases Euro 7/VII position paper
9 December 2020
The European Automobile Manufacturers’ Association (ACEA) released a position paper on the future Euro 7/VII emission regulations that are being developed by the European Commission (EC) and its Advisory Group on Vehicle Emission Standards (AGVES). The paper summarizes ACEA’s considerations on the Euro 7/VII developments at the AGVES meeting on October 27, where the EC’s CLOVE consortium of consultants presented more concrete proposals and scenarios for Euro 7/VII emission limits and testing procedures.
In the position paper, ACEA strongly criticizes the Euro 7 proposals presented by CLOVE, and describes them as, “to the greatest extent, technically infeasible for vehicles with combustion engines”.
The key issues raised by ACEA include:
- Testing procedures—While the current requirements for on‐road testing (RDE for light‐duty and PEMS‐ISC for heavy‐duty vehicles) have been shown to be robust and are delivering excellent results, CLOVE has presented drastic changes without any proper demonstration of the flaws of the existing on‐road testing provisions in EU Regulations. For instance, the Euro 7/VII on‐road test would contain no minimum average speed and no “sensible limitations” of positive elevation gain or maximum altitude. “The proposal basically aims to impose absolute emission controls under any possible driving event, however infrequent and at whatever cost,” ACEA said.
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Emission limits—The COVE proposals include two scenarios (A and B) for light‐duty vehicles and two scenarios for heavy‐duty vehicles, which ACEA considers “technically infeasible”. The heavy vehicle proposal, for example, has a massive weighting of emissions to the cold‐start phase that would be beyond reality compared to the normal use cases of commercial vehicles for goods or passenger transport, which would lead to a negative impact on fuel consumption and CO2 emissions. Even with a more realistic concept for RDE testing, scenarios B for both LD and HD vehicles are “completely infeasible for the entire fleet”. The proposed limits would not be achievable using the best available diesel engine and aftertreatment technology, as demonstrated last year by AECC [4220], Figure 1.
Figure 1. NOx emissions from AECC demonstrator vs CLOVE LD scenarios (Source: ACEA)
- Measurement uncertainty—Current portable emissions measurement systems (PEMS) devices show an absolute measurement uncertainty that is of the same order of magnitude as the proposed emissions limits. On the basis of today’s knowledge, such emission limits could not be legally assessed with the necessary level of certainty during on‐road testing.
- Competitiveness of the EU industry—Today, emission legislations and technical requirements are harmonized within the United Nations Economic Commission for Europe (UN‐ECE) for all contracting parties to the so‐called 1958 and 1998 Agreements. While any change in EU regulations needs to be mirrored at UN level, too drastic disproportionate changes to such regulations that could endanger the economic viability of internal combustion engines in order to promote electro‐mobility may isolate EU regulations globally as contracting parties deciding otherwise would simply stop following EU legislations. This could be severely detrimental to EU industry that would have to design EU‐specific products that would not be fit for any other market.
The CLOVE scenarios also introduce limits for greenhouse gases including N2O and CH4, while CO2 would not be limited for an individual vehicle. The new proposal also sets limits for particles (PN) based on SPN10 (particles sizes down to 10 nm).
The ACEA position paper includes a number of specific, technical comments on the proposed emission limits and the aftertreatment architectures that would be necessary to meet the proposed requirements.
The proposals presented by the CLOVE consortium in AGVES do not necessarily represent the final EC proposal for Euro 7/VII, which is expected to be released in 2021.
Source: ACEA