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.