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CLEPA Statement Real Driving Emissions – Light-Duty Vehicles (RDE-LDV) – 3rd regulatory package

CLEPA has continuously supported the development and introduction of the Real Driving Emissions – Light-Duty Vehicles (RDE-LDV) test in order to complement the current test-cycle type approval. This commitment of the European Automotive Supplier Industry is confirmed for the future development of the test and the ongoing discussions on the 3rd regulatory package (main aspects particle number control and inclusion of cold start). Engine and aftertreatment technologies for air quality benefits are available on the market.

 

CLEPA respects the political objective to mandate particle number control and cold start provisions upon implementation of RDE-LDV step 1 on 1 September 2017. Whereas a swift regulation can generally be supported, the European Automotive Supplier Industry wants to draw the political attention to lead-time considerations. CLEPA suggests considering the following argumentation in order to ensure an effective regulation that does not impair the ongoing vehicle production.

 

Cold start for NOx: CLEPA is supportive of the integration of cold start in RDE-LDV step 1 as long as the requirements do not exceed an equivalent transfer from test-cycle to real-world. The driving distance over which the cold start is assessed and a realistic correction factor require careful investigations.

 

Particle number: CLEPA believes that a thorough preparation of the automotive industry has so far not been possible given that satisfactory portable emission measurement equipments for particle number have only become available in recent months. This is also reflected in the regulatory approach towards in-service conformity for particle emissions from heavy-duty vehicles. In addition, a number of relevant RDE-LDV decisions have either been taken only last year (real-world test procedure without cold start requirements, conformity factor for RDE-LDV urban) or will be taken in the future (cold start requirements and particle filter regeneration). While CLEPA generally supports a timely and comparable regulation of diesel as well as gasoline vehicles, the European automotive supplier industry calls upon RDE-LDV decision-makers to study the necessary lead-time and a realistic introduction scenario carefully, as engines and aftertreatment systems will have to be adapted.

 

The already agreed introduction timing for RDE-LDV is ambitious and the remaining lead-time should therefore not be affected by other generally positive regulatory developments, such as the introduction of WLTP in European legislation. European automotive suppliers are concerned that the change in test cycle in 9/2018 (all new vehicles) leads to new vehicle types, which will have to comply with RDE step 1 regardless of the agreed RDE introduction in 9/2019 (all new vehicles).

 

Similar timing concerns exist for the regulation of evaporative emissions (EVAP). Therefore we strongly recommend to respect the TCMV-decision of the 12th of May with an EVAP-introduction date of 9/2019.

 

For a pdf version, please click here.

 

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    In: CLEPA News, Environment & Energy, Real Driving Emissions
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