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.