Mr. Rijnders described the background to the issue of methane in European regulations. The THC limit values (in addition to the NMHC) require NGV system suppliers (OEMs and retrofits) to add expensive catalysts. Also the European regulations are not in conformance to US or Japanese methane regulations. In Europe the issue was only dealt with in 1999 for heavy duty vehicles in the context of the development of the Environmentally Enhanced Vehicle discussion. At that time the THC was changed into a NMHC and a CH4 value for natural gas HD engines and vehicles, but not for LDVs. The topic again has been tabled at the GFV, to argue that methane should not be part of the pollutant emissions. The standards on their own (UNECE) could not be changed without conformity to the EU regulations, which would require Council and European Parliament decision. The Commission is now taking on board in their 2012-2013 working program, which includes a proposal under the legislative procedure for complimentary provisions for Euro 6, to facilitate type approval of NGVs. There will be a co-decision document to give the mandate to the Commission to revise the THC emission regulations for gas vehicles. The Commission has requested Mr. Rijnders, as Chair of GFV to give input on this topic and make a proposal as to how best to incorporate changes into the European legislation.

Mr. Rijnders described the suggested ‘two step’ approach: to make the LDV regulation in line with the HDV, using the same general ratios of NMHC to other emissions. Step one would include creating a methane ‘cap’. A second step, something for future consideration of the European Commission, would be to include methane into other regulations dealing with CO2 and greenhouse gas emissions. Step two suggests that if methane is regulated separately as a global warming gas then the methane cap should be removed.

The draft CHF position paper that was requested of the GFV by the European Commission to support their was sent only one day before the GFV meeting so there has not been substantial time to consider it and make a response. Mr. Rijnders asks if anyone has any general or specific remarks on the document or on the issue and a broad and general discussion followed (see directly below).

Ms. Leifheit (Volkswagen). The higher price of catalysts is not an argument for implementing the legislation. The penalty for the CO2 legislation is more important an issue for the auto industry than the savings on the cost of methane catalysts. There remain many consequences in step 2 for the OEMs. She also noted that any retrofit vehicles would not count toward the OEM fleet requirements to reduce CO2.

Mr. Rijnders pointed out that OEM NGVs will be a benefit to them in reducing their CO2 emissions. Furthermore, the second step is very political and will be a much more difficult discussion. But the GFV is not advocating this nor has any control over an action that is clearly in the hands of the political institutions.

Mr. Seisler (NGV Global) further elaborated that the two step approach satisfies both political concerns about continuing the regulation of methane emissions (via a cap to replace the THC) but does not include methane in the CO2/GWP ‘basket’ which would be a hardship for the OEMs who are concerned about every gram of CO2 reduction (or its equivalent). He also reminds the group that the EU legislation is incorporated into R.115, a global regulation, and this has a worldwide impact on the NGV industry, particularly in markets where OEMs are not substantially present but is driven by the retrofit industry.

Mr. Rijnders added that it seems beneficial to harmonize the methane requirements of LDV regulations with the HDV regulations.

Mr. May (AECC) suggested that the ‘cap’ would be 7 times higher (THC = 100mg; NMHC = 68mg). Mr. Rijnders, however, states that the limit value is only doubled. Mr. Rijnders reminded the group of the discussion in 1999 at the Motor Vehicle Emissions Group (MVEG) that the NMHC and CH4 (300 mg/km) was in general already accepted by the ACEA and all member states (at that time) but the LDV CH4 limit was brought into question at the last moment by one Member state due to one manufacturer’s statement that they could achieve the THC of 100 mg/km with a CNG vehicle. But the fundamental discussion of methane was not done at that time.

There was a give-and-take discussion between VW, TNO, Mr. Rijnders, and Mr. Seisler about why there can be a limit on methane, even if it’s not a pollutant, but as a green house gas (GHG). It is agreed that the OEMs have strong opinions about not adding new elements in the ‘basket’ of global warming gases. But there is another issue for OEMs who claim that they are subject to a more stringent level of emissions regulations than the NGV retrofitters who must comply with R.115, seen as a less rigorous regulation. Mr. Rijnders suggests that regulators must look at the fairness of the pollutants being discussed, either as a pollutant or as a green house gas.

Mr. Piccolo (AEGPL) indicates that there is a CO2 benefit or opportunity to have a CNG car counted in the CO2 regulations.

Mr. Rijnders apologies that the document (GFV 18-06 CH4 Position Paper) was sent late to the GVF and that the discussion should be continued at the next GFV meeting. He asks the members for suggestions and comments on the text and tables

Mr. Renaudin reminds the group that a small group in the GFV have made this proposal and the HDV manufactures did not have time to consider and discuss the document with other members of the International Association of Automobile Manufacturers OICA, who will be concerned about methane regulation. He suggests that this document is not a GFV document.

Mr. Rijnders reminded Mr. Renaudin that he, the GFV Chairman is responding to a request from DG Enterprise. Mr. Rijnders indicates that this is a working document for further discussion and does not necessarily have a consensus on the subject. Mr. Rijnders will provide the request from Mr. Steininger (from the Commission) to the GFV Chairman to deal with this issue. He assures the group that the document would not go to the Commission unless there is some agreement on the content of the document. This is not a ‘normally’ submitted document as other GFV documents since it was motivated as a specific request from the Commission.

Mr. Piccolo suggests that the motivation for creating this document should be clear in the document (and not just in the meeting minutes) either through the use of the standard template for submitting documents or another technique that includes the request from the Commission to create the CH4 rationale.

Mr. Rijnders explained the background to the request from the European Commission to provide a rationale paper supporting a change in the total hydrocarbon regulations (Directive 715/2007). The Commission plans to ask Parliament to give them a mandate to change some specific items through what is known as a ‘delegated act’ (within the co-decision process). This THC amendment is part of what is being called by the Commission as the ‘Potpourri Amendments’; six corrections to Euro VI/6 emission regulations, one of which addresses the problem of having an NMHC while still maintaining a THC. To do this a background statement and impact analysis is required (done by the Commission). Mr. Rijnders was asked specifically by the Commission to provide input from the GFV. To this point the ‘CH4 Position Paper’ now in its 12th iteration suggested a ‘two step’ approach: 1) to remove the THC and replace it with a ‘methane cap’ that, 2) at some point in the future might become obsolete if the Commission decides to regulate methane as a greenhouse gas.

Mr. Rijnders reported on the history of the THC/NMHC from 1998 (82, 83 and 84th MVEG in 1999) to note that the discussion at the time included a proposal for a 300 mg/km “methane cap,” proposed by the ACEA. At that time the Commission had the mandate through the Committee for Adaptation of Technical Progress (CATP). However, at the moment of voting the German delegation objected based on a single auto manufacturer who had built an NGV that achieved the THC of 200 mg/km using a methane catalyst.

Mr. Renaudin reminded the group that a great deal of work was done on the heavy duty engines, and in particular the creation of the Enhanced Environment-friendly Vehicle (EEV). Methane eventually was labeled by the Commission as a pollutant but until that time was excluded in engine testing. But including methane as a global warming gas was not done at that time due to the complexity of the issue. Global warming also included secondary particles and NOx (in some circumstances). Methane emissions could be handled through the engine design so it was dealt with at the Commission for Euro IV, V and beyond. Mr. Renaudin clarified that this current action is specifically aimed at light duty vehicles.

Mr. Rijnders indicated at that time the THC prevented natural gas engines from being homologated until there was a separation of NMHC and THC. Today the 100 mg/km THC limit value presents a challenge for light duty vehicles to comply without the use of a methane catalyst.

There was a wide-ranging discussion of different elements concerning the CH4 Position Paper and specifically the recommendation that a new limit value for methane, as a cap once the THC is eliminated (as one of the proposals in the Commission’s Potpourri Amendments). In summary, the concerns expressed and points raised include:

From the auto industry and auto parts/catalyst manufacturers perspective:

• ► There is great concern that, since the global warming impact of methane is 23 times more than CO2 that any added methane threatens to result in a potential increased cost to the auto manufacturers to achieve low CO2 (GHG) limits.

• ► The price of the catalysts quoted in the CH4 Position Paper are too high. Methane catalysts, according to VW, are more in the €50-100 range rather than the €200-400 stated in the paper. (Further investigation of this point will be done, and particularly with AECC.) The argument is that €50 is cheaper than the potential penalties that would be paid by auto manufacturers to include methane as a greenhouse gas added to CO2.

• ► The methane cap proposed in the Position Paper based on the ratios in the Heavy Duty Vehicle standards for the Environmentally Enhanced Vehicle standard (EEV) must be defendable. Using the ratio from HDVs to arrive at 212 mg/km methane actually increases the potential GHG emissions from a vehicle. Even though a light duty NGV reduces GHGs from a petrol LDV by 20-25%, accounting for higher methane limits reduces that potential, all of which is costly to the OEMs in terms of potential penalties they must pay for not achieving low CO2 (or equivalent) levels.

The gaseous fuel system industry advocates expressed alternative views:

• ► By keeping a ‘double limit value’ (NMHC and THC) this effectively regulates methane (i.e. the difference between the THC and NMHC). The conclusion, therefore, is that THC need not be regulated and that the methane cap has been introduced merely to satisfy a perceived political concern about global warming but has no scientific value in terms of emissions from NGVs.

• ► Eliminating the THC and now considering a methane cap is not, in and of itself, the pathway to future regulations on GHG, which could be a new challenge to the auto industry. This is an old argument by the auto industry and that proposing lower emissions for NGVs is a primary motivator that leads to overall tighter emissions regulations. The argument that the ‘first step’ proposed in the Position Paper to remove the THC leads to tighter emissions standards is simply unfounded.

• ► At this point no one is advocating that methane be added to the CO2 requirements facing the auto manufacturers. But if regulators are truly concerned about global warming gases, then the regulations might well include methane, N20, and possibly other emissions/pollutants that GHG limits facing the auto manufacturers. But this is for future consideration by regulators and, at this stage, no one has tabled such a proposal.

• ► The group is asked if anyone, based on scientific logic, can support the continuation of a THC limit so long as the NMHC limit is in place, which addresses ozone formulation. No one is able to justify the THC but the political issue of creating a methane cap still is critical to the discussion even if it is based on ‘politics’ and not science. Thus the issue becomes how to justify whatever limit value is agreed on as a methane cap and this is not answered in the discussion.

Mr. Rijnders suggests that the industry cannot make an argument why not to have NGVs based on global warming impacts. It could be beneficial, in fact, to add methane emissions in the CO2 ‘basket’. If this is not going to be the case, then we should eliminate the THC without establishing a ‘cap’.

Conclusion by Mr. Rijnders: In the June session of GFV we will only briefly deal with the CH4 Rationale document. The goal is to have everyone agree upon a solution inside the GFV. If this is not possible then we approach the Commission that a consensus has not been achieved but some other considerations must be given. After the June GFV session we can continue this dialogue in detail.

There is agreement that, for the moment, we will proceed with considerations to support the Commission’s request for a position paper but that we should confer further with Mr. Steininger about the discussion today and reconsider the ‘two step approach’ initially advocated in the position paper.