Bortfeld presented EMA’s comments on NOx control and PM Number.

Regarding NOx control measures, it is expected that reagents may be required. EMA considers that without effective control measures frequent tampering can be expected. The draft Regulation has limited requirements, covering only reagent quality, dosing and freezing protection. UN Reg. 96 includes controls on NOx operation, and US Regulations, Euro VI and the amendments to 97/68/EC include comprehensive NOx controls and inducement systems. EMA therefore believes that provisions for the detection of NOx control malfunctions should be added, together with requirements for an inducement system similar to Reg. 96. In the previous meeting, Sweden, with EMA, had been tasked to make a proposal on this but had not yet been able to do so.

Regarding PM Number requirements, there is a requirement for Type I, II and IV REC to provide at least a 97% reduction in PM Number. Nationally, though, only Switzerland has PM Number requirements. It is not, in EMA’s view, possible to transfer those requirements to the REC Regulation as Switzerland uses a steady-state test whereas REC uses a transient cycle said. Wall flow filters would in any case meet this requirement. EMA considered that either the provisions should be deleted or the Swiss LRV should be permitted as an alternative compliance method.

The chairman asked whether EMA and Euromot would be able to come forward with a proposal on NOx control. Stein said that OICA and Euromot (with EMA) could develop such a proposal in consultation with Sweden, but this could not be done rapidly as there would need to be some differences from existing legislation. This is because a) it will need to cover mechanically controlled engines and b) retrofitters are not allowed to tamper with the existing control systems.

He therefore asked that the mandate for the group be extended. The chairman reported that extension of the REC mandate would be on the GRPE agenda tomorrow.

Regarding PM Number, Baarbé reported that the Netherlands and Switzerland are strongly in favour of a PM Number requirement. In their view only this would ensure efficient performance for control of solid particles. Research by AECC has, he said, shown that DPF technology could achieve these requirements on transient cycles. He nevertheless agreed that there should not need to be new tests where existing approvals (VERT, Swiss LRV etc) have shown the performance of such systems.

Williams said that the REC requirements should not go beyond what is required for a new engine.

In particular it should not require that new equipment would then have to be retrofitted to meet additional requirements, even in Environmental Zones. The chairman considered that the intention of the Regulation is to allow retrofitting from one emissions level top a higher one. In the EU this would mean that engines meeting the latest version of the relevant regulation for new engines would have to be acceptable without retrofit. Berger said that Switzerland would not wish to come back from their current requirements and strongly supports the inclusion of PM Number.

In response to concerns on allowing the Swiss LRV as an alternative compliance, the chairman said that this would only be to allow the use of results from existing tests, as for the current proposal on secondary emissions. It was commented that including PM Number requirements would be the best way to avoid local authorities setting additional requirements as well as ensuring efficient DPFs; good wall flow DPFs would meet the requirements on any cycle, so allowing the use of existing data would be a route forward. Stein said that OICA strongly opposes the inclusion of PM Number requirements for engines that do not already have them (i.e. Euro I to V). Euromot supports the EMA proposal, but could accept PM Number in the secondary emissions requirements “without being really mandatory”. He commented that the last PMP meeting had shown that the measurement systems are not very reliable. The UK agreed with Stein that there should be no retrospective limits introduced, but pointed out that the PM Number proposal is not set as a limit but is a percentage efficiency and so should be acceptable. Schulte said that he was in favour of including PM Number in the secondary emission requirements. He considered that this would be a mandatory requirement. Eberhardt supported PM Number to be a mandatory requirement. Nitsche said that the Regulation would not be purely for European use and supported the approach of considering PM Number as a secondary emissions requirement. In response to further comments the chairman noted that there is no intention to include PM Number measurement for the lower efficiency level, but including a PM Number requirement in the higher efficiency level would ensure that such devices maintain the high performance levels needed for public health.

The chairman proposed that the editorial group should draft a PM Number proposal in an annex, treated similarly to that on secondary emissions. This was accepted.