preparation of the legal and technical background for a...

Preparation of the legal and technical background for a voluntary EU standard for low emitting combustion engine driven cars

(EULES)

Final Report

Authors:

Leonidas Ntziachristos1, Giannis Papadimitriou1, Giorgos Triantafyllopoulos1

Francisco Lupiáñez-Villanueva2, Ewelina Marek2, Giuseppe Veltri2, Pietro Tornese2

Jens Borken-Kleefeld3

Vicente Franco4, Peter Mock4

1 EMISIA S.A., Thessaloniki, Greece 2 Open Evidence, Barcelona, Spain

3 IIASA, Laxenburg, Austria 4 ICCT Europe gemeinnuetzige GmbH, Berlin, Germany

7 April 2016

Contracting institution European Commission Directorate General Environment DG ENV.SRD.2 B-1049 Brussels Belgium Contract No 070201/2014/693860/FRA/ENV.C.3

Contractor International Institute for Applied Systems Analysis (IIASA) Schlossplatz 1 A-2361 Laxenburg Austria Contact person Markus Amann Phone: +43 2236 807 432 e-mail: [email protected]

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Table of contents

List of abbreviations and acronyms ...................................................................... 5

Executive Summary ................................................................................................. 8

1 Introduction ............................................................................................... 11

1.1 Overview of the project ........................................................................................... 11

1.2 Context and background ........................................................................................ 11

1.3 Structure of this report ............................................................................................ 13

2 Technical model for the introduction of EULES ..................................... 15

2.1 Background: the VW emissions scandal and shortcomings of RDE ....................... 16

2.2 Framework of the technical model .......................................................................... 18

2.3 Determination of conformity factors for EULES ...................................................... 20

2.3.1 Quantitative estimation of CFs ................................................................................. 21

2.3.2 New evidence affecting the initial estimation of CFs ............................................... 24

2.4 Ancillary proposals for EULES................................................................................ 29

2.4.1 Measure A1.1: compliance with both data evaluation methods ............................... 29

2.4.2 Measure A1.2: a priori compliance without the application of data evaluation methods ................................................................................................................ 31

2.4.3 Measure A2: inclusion of cold start emissions ......................................................... 32

2.4.4 Measure A3: ECU-independent testing ................................................................... 33

2.4.5 Measure A4: urban NO2 emission limits .................................................................. 33

2.5 Scalability, compatibility, and future proofing of EULES ......................................... 34

2.5.1 Implications to other regulatory components ........................................................... 35

2.6 Summary and input for recommendations .............................................................. 37

3 Legal approach ......................................................................................... 40

3.1 Background information on type approval for passenger cars................................ 41

3.1.1 Legislation ................................................................................................................ 41

3.1.2 The type approval framework .................................................................................. 42

3.1.3 Types of testing ....................................................................................................... 42

3.1.4 Flowchart of the current EU vehicle type approval process ..................................... 44

3.1.5 Recent development: proposal for changes in type approval framework ................ 45

3.2 Introduction of RDE and EULES integration ........................................................... 46

3.2.1 WLTP+RDE in replacement of NEDC ..................................................................... 46

3.2.2 EULES and RDE/PEMS testing implications ........................................................... 47

3.2.3 Testing and data handling responsibilities ............................................................... 50

3.3 Placement on the market ........................................................................................ 51

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3.3.1 Legal instrument ...................................................................................................... 52

3.3.2 Legal distinction ....................................................................................................... 53

3.3.3 Incentives and benefits ............................................................................................ 53


4 Assessment of likely public response to EULES ................................... 59

4.1 Background ............................................................................................................ 59

4.2 Scope of research .................................................................................................. 59

4.2.1 Objectives and approach ......................................................................................... 59

4.2.2 Research methods ................................................................................................... 60

4.2.3 Fieldwork process .................................................................................................... 68

4.3 Results from the survey .......................................................................................... 69

4.3.1 Decision making: describing the purchase process ................................................. 69

4.3.2 Perceptions and understanding of the health and environmental issues ................ 79

4.3.3 Incentives to influence the purchase process .......................................................... 83

4.3.4 Attitudes and perception towards labels .................................................................. 88

4.4 Results from the experiment ................................................................................... 89

4.4.1 Assessing the impact of labels on consumers’ behaviour ....................................... 89


5 The role of public authorities – attitude and reactions .......................... 94

5.1 Background ............................................................................................................ 94

5.2 Approach ................................................................................................................ 94

5.3 Discussion .............................................................................................................. 94

5.3.1 On differentiated charges for parking ...................................................................... 94

5.3.2 On access charges differentiated by emission performance ................................... 95

5.3.3 Timing issues ........................................................................................................... 96

5.3.4 Parallel national activities ........................................................................................ 96


6 Costs and benefits for the consumer ...................................................... 99

6.1 Objectives and approach ........................................................................................ 99

6.2 Cost-benefit analysis .............................................................................................. 99

6.2.1 Single cost elements .............................................................................................. 100

6.2.2 Interpretation of the lifetime cost calculation .......................................................... 102

6.3 Summary and input for recommendations ............................................................ 104

7 Technical feasibility – emission experimental results ......................... 106

7.1 Objectives and approach ...................................................................................... 106

7.2 Experimental testing ............................................................................................. 106

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7.2.1 PEMS testing of a Euro 6 diesel vehicle ................................................................ 106

7.2.2 RDE test reproduction at engine bench ................................................................. 110

7.2.3 EULES test at engine bench .................................................................................. 114

7.3 Summary and input for recommendations ............................................................ 119

8 Final recommendations .......................................................................... 121

8.1 What is EULES – how it can be implemented? .................................................... 121

8.1.1 Conceptual presentation of EULES ....................................................................... 121

8.1.2 Technical model ..................................................................................................... 122

8.1.3 Legal approach ...................................................................................................... 125

8.2 How to nudge consumers towards a ‘clean’ EULES car?..................................... 128

8.2.1 Summary from the assessment of likely public response ...................................... 128

8.2.2 Summary from the cost-benefit analysis for the consumers .................................. 129

8.3 What is the role of public authorities? ................................................................... 130

8.4 Technology implication for EULES cars ............................................................... 131

References ........................................................................................................... 133

Annex I: Relevant car labelling schemes and ‘eco-friendly’ labels ................. 135

Annex II: Supporting information for section 4 “Assessment of likely public response to EULES” ............................................................................... 139

Questionnaire ..................................................................................................................... 139

Block A. Self-reported purchase process ........................................................................... 139

Block B. Contextual factors ................................................................................................ 142

Block C. Environmental and health impact awareness of car usage ................................. 145

Block D. Awareness, Trust and effect of labels .................................................................. 146

Block E. Socio-demographics ............................................................................................ 148

Fieldwork process ............................................................................................................... 150

Factor analysis: purchase process ..................................................................................... 153

Factor analysis: present-future attitudes ............................................................................. 155

Car labels correlation matrix ............................................................................................... 156

Online experiment effects – Small cars .............................................................................. 157

Online experiment effects – Large cars .............................................................................. 157

Online experiment Effect Likelihood Ratio tests – Small cars ............................................. 157

Online experiment Effect likelihood Ratio tests – Large cars .............................................. 157

Online experiment marginal probabilities small cars ........................................................... 158

Online experiment marginal probabilities large cars ........................................................... 158

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List of abbreviations and acronyms

ADAC

ASC

CARB

CF

CNG

CO

CO2

CoC

CoP

CVS

DG ENV

DOC

DPF

EC

ECE

ECU

EEA

EEV

EGR

ELR

EPA

EU

EUDC

EV

GAINS

GDI

GEN

GHG

GPS

HC

HV

ICCT

ICE

IIASA

I/M

Allgemeiner Deutscher Automobil-Club

Ammonia Slip Catalyst

California Air Resources Board

Conformity Factor

Compressed Natural Gas

Carbon monoxide

Carbon dioxide

Certificate of Conformity

Conformity of Production

Constant Volume Sampling

Directorate-General for the Environment

Diesel Oxidation Catalyst

Diesel Particle Filter

European Commission

Economic Commission for Europe

Electronic Control Unit

European Environment Agency

Enhanced Environmentally-friendly Vehicle

Exhaust Gas Recirculation

European Load Response

Environmental Protection Agency

European Union

Extra Urban Driving Cycle

Electric Vehicle

Greenhouse Gas and Air Pollution Interactions and Synergies

Gasoline Direct Injection

Global Ecolabelling Network

Greenhouse Gas

Global Positioning System

Hydrocarbons

Hybrid Vehicle

International Council on Clean Transportation

Internal Combustion Engine

International Institute for Applied Systems Analysis

Inspection and Maintenance

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ISC

IUPR

LDV

LEV

LNT

LPG

MAW

MIL

MPV

MS

NEDC

NGO

NH3

NMHC

NOx

NTE

O2

OBD

OEM

OTL

PC

PEMS

PM

PN

RDE

SCR

SCRF

SMEs

SSTA

SUV

TA

TAA

TCMV

THC

TS

TSAP

UDC

In-Service Conformity

In-Use Performance Ratio monitoring

Light Duty Vehicle

Low Emission Vehicle

Lean NOx Trap

Liquefied Petroleum Gas

Moving Average Window

Malfunction Indicator Lamp

Multi-purpose Vehicle

Member State

New European Driving Cycle

Non-Governmental Organization

Ammonia

Non-methane hydrocarbons

Nitrogen Oxides

Not To Exceed

Oxygen

On Board Diagnostics

Original Equipment Manufacturer

OBD Threshold Limit

Passenger Car

Portable Emission Measurement System

Particulate Matter

Particle Number

Real-world Driving Emissions

Selective Catalytic Reduction

Selective Catalytic Reduction Filter

Small and Medium-sized Enterprises

Small Series Type Approval

Sport Utility Vehicle

Type Approval

Type Approval Authority

Technical Committee of Motor Vehicles

Total hydrocarbons

Technical Service

Thematic Strategy on Air Pollution

Urban Driving Cycle

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ULEZ

UN

UNECE

US

VW

WHO

WLTC

WLTP

WVTA

ZEV

Ultra Low Emission Zone

United Nations

United Nations Economic Commission for Europe

United States

Volkswagen

World Health Organization

Worldwide harmonized Light duty vehicle Test Cycle

Worldwide harmonized Light duty vehicle Test Procedure

Whole Vehicle Type Approval

Zero Emission Vehicle

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Executive Summary

This is the final report of the EULES project, related to preparing the legal and technical background for proposing a future voluntary EU low emission limit for combustion engine driven cars. The term EULES is used throughout this report, as this is how this is referred to at the time of publishing the report. However, this may well change in the future.

The project has been executed under framework contract No ENV.C.3/FRA/2013/0013, service No 8, EC DG ENV, and the consortium consisted of IIASA (overall framework contract coordinator), EMISIA (technical coordinator), Open Evidence, ICCT, and AVL.

The principal objectives of the project were to provide the background on the potential of a voluntary low emission standard for passenger cars, in order to deliver real-world emission levels below the most stringent current emission limits, as well as to develop the technical and legal background for its implementation.

The usefulness of a EULES scheme can be summarized to the following points:

To guide environmentally conscious customers towards the purchase of vehicles with ‘clean’ emission profiles (low real-world driving emissions).

To provide a benchmark for local or national authorities when developing financial incentives or access and demand policies or establish green procurement rules, to promote clean transportation.

To provide an incentive for manufacturers to produce vehicles that deliver significant and true on-road emission reductions over prior emission control concepts.

The main achievements of the project, presented in detail in the current report, were the following:

Delivering suggestions and options for the technical model and the legal approach that should be followed for a successful introduction of this voluntary scheme.

Assessment of the likely public response (customer acceptance) and the role of public authorities on how to support and promote the scheme with incentives, benefits, etc.

Verification and experimental demonstration of the potential of diesel engine and aftertreatment technology to reach real-drive emissions (RDE) levels which are below the Euro 6 emission limit, using today’s commercial available technology. Our study demonstrates that emission levels corresponding to a conformity factor of as low as 0.5 is technically possible using today’s commercial technology.

Reaching EULES emission levels with diesel cars requires most of the attention as current evidence suggests that Euro 6 diesel cars’ on-road NOx emissions are still much higher than what emission limits call for. As a result of this discrepancy, and in spite of the increasingly stringent emission standards, diesel cars continue to contribute substantially to the urban air pollution in Europe.

EULES is recommended to be based on the already established RDE test procedure, facilitated with portable emission measurement system (PEMS) measurements. It is envisaged as a more stringent version of the Euro 6 + RDE regulatory package, which also ‘patches up’ possible shortcomings of RDE, further controlling the number of exemptions and loopholes.

At the same time, the voluntary nature of the scheme targets to the as fast as possible placement to the market, without time consuming procedures required when introducing a new mandatory standard. This is expected to effectively assist many European cities and regions in

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their efforts to comply with air quality targets (e.g. NO2). A successful example in the past has been the EEV voluntary standard, primarily focused on urban buses. EEV promoted the introduction of natural gas or diesel buses equipped with diesel particulate filters (DPF) already since the beginning of the 2000s, and has significantly assisted local authorities in reducing their urban environment concentrations.

EULES levels (options): In defining the compromise between fast adoption and increased stringency, EULES could be introduced at different stringency levels. More stringent conformity factors than Euro 6 RDE would be level i. Then, introduction of a package of ancillary measures would correspond to level ii. The ancillary measures are proposals to reinforce the implementation of the RDE concept with an additional layer of voluntary provisions. The latter are devised as mild modifications to the current RDE provisions and are expected to increase the stringency or improve the coverage of RDE tests, while imposing only a small additional testing or data processing burden. Finally, level iii would need to be accompanied by additional regulatory components, related to on-board diagnostics thresholds, durability provisions, etc. Such pieces of regulation would lead to making sure that a EULES vehicle remains very clean throughout its lifetime. On the counter side, they could lead to a delay in the EULES limit introduction as they require additional technical and regulatory discussions.

Legal instrument: The legal tool to be used for EULES depends on whether this is introduced as a new standard or just as an enhancement of the Euro 6 RDE regulatory package. For example, if only reduced conformity factors over Euro 6 RDE are foreseen, this could be delivered as guidance to national authorities even with a Communication (COM) document. On the other hand, the adoption of ancillary measures and changes in other regulatory components would require a Regulation in order to successfully address all implications of the voluntary scheme with the existing regulatory framework.

Legal distinction: Concerning the legal distinction of EULES (i.e., usage of label/logo or some other distinction), the assessment of likely public response concluded that European consumers are not too acquainted, hence influenced, by car labels. Displaying logos (EULES, CO2, or a combination of the two) has only a small positive effect for the consumers’ choices. On the other hand, for the public authorities, labels and logos (e.g. sticker or other visible mark) might be beneficial for communication reasons if the vehicles are intended to be showcased or highlighted. However, given the diversity of physical labels (stickers, vignettes) between countries and differences in enforcement (physical sticker or number plate reading), it appears doubtful that an additional EU-wide label still comes in time. Most important is that EULES is clearly identified at vehicle type-approval so that vehicles benefitting from certain policies can be easily highlighted.

Table 1 presents in a summary form the three possible levels of EULES implementation (available options), together with their advantages and disadvantages, legal and technical implications, possible difficulties in implementation, risk for delays, etc.

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Table 1: Summary table of EULES levels (options)

EULES level i) More stringent CF

(no additional testing)

ii) Same as level (i) +

Ancillary measures

iii) Same as level (ii) + Other

regulatory components

Main

characteristics

Builds upon the RDE test

process and, without

additional testing

requirements, lower CF

is required.

Level (i) + adoption of

some ancillary measures.

These are proposals to

reinforce the application

of RDE with an additional

layer of voluntary

provisions.

Level (ii) + Other regulatory

components (e.g. durability,

OBD, etc). Definition of new

thresholds for OBD and/or

changes in durability

requirements may be needed.

Legal

instrument

Possibly even by

communication (COM)

Regulation Regulation

Advantages

Simple and straightforward.

No changes in RDE.

No further processing of the test data.

Increased stringency and/or improved coverage of RDE tests.

Modularity (depending on the ancillary measures adopted) and future proof.

‘Patching up’ possible shortcomings of RDE.

Increased stringency in other regulatory components (e.g. durability, OBD, etc).

Robustness and coherence with the whole regulatory framework.

Cleaner vehicles throughout their lifetime.

Disadvantages

Risk that the vehicle performs well at TA, but then becomes similar to less clean vehicles.

No regulation allows margin for ambiguity in EULES designation.

Imposes a (rather small) additional testing or data processing burden on stakeholders.

Entails delay risks due to technical and regulatory discussions / procedure

Delay in the process of bringing in EULES.

Responsibilities

of the involved

entities

EC to propose EULES level (option) to come forward

TS & TAA will be responsible for checking if conditions of EULES are satisfied.

TAA will be responsible for issuing EULES certificate or EULES indication.

Legal

distinction

Usage of label/logo has only a small positive effect for consumers’ choices.

For the public authorities, labels and logos might be beneficial for communication reasons if the vehicles are intended to be showcased or highlighted.

Given the diversity of physical labels (stickers, vignettes) between countries and differences in enforcement (physical sticker or number plate reading) it appears doubtful that an additional EU-wide label still comes in time.

EULES indication during TA is important so that vehicle is correctly registered in national/international databases.

Incentives and

benefits

Financial incentives (direct subsidies to buyers at the time of purchase, taxation benefits, preferential terms for financing/loans/insurance, toll pricing reductions, etc).

Preferential access (e.g. in designated low emission zones, bus/high occupancy vehicle lanes, lanes along congested streets, etc).

Other benefits (parking places with low fees, specific services and/or rates, etc).

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1 Introduction

1.1 Overview of the project

Under framework contract No ENV.C.3/FRA/2013/0013, EC DG ENV requested an offer for the service No 8 related to preparing the legal and technical background for proposing a future voluntary EU low emission standard for low emitting combustion engine driven cars (EULES). The consortium consisting of IIASA (overall framework contract coordinator), EMISIA (technical coordinator), Open Evidence, ICCT, and AVL, presented its offer and, after its successful evaluation, the project officially started on Dec. 9, 2014.

The principal objective of the project is to develop a first understanding on the potential of such a voluntary emission standard for passenger cars in order to deliver real-world emission levels below the most stringent current emission limits, as well as to develop the technical and legal background for its implementation.

The two main requirements of the project are:

Assess the likely public response and the role of public authorities to such a standard.

Verify and demonstrate whether state-of-the-art Euro 6 cars can reach RDE levels which are below the current emission limit values, by further optimization of their emission control systems, and provide the incentives for this optimization.

The usefulness of such a voluntary scheme is summarized below:

It will guide environmental conscious customers towards the purchase of vehicles with ‘clean’ emission profiles (low real-world driving emissions).

It will provide a benchmark for local or national authorities when developing financial or access and demand policies to promote clean transportation.

It will provide an incentive for manufacturers to produce vehicles that deliver significant emission reductions on the road.

This document is the final report of the project. It summarizes all the work performed and provides final recommendations in order to assist in the successful introduction of such a voluntary scheme. Prior to this final report, there have been presented two interim reports (in April and December 2015, respectively) according to the contractual obligations of the project (Papadimitriou et al., 2015a and Lupiáñez-Villanueva et al., 2015).

1.2 Context and background

The EU is committed to improving air quality in cities and at regional level in order to decrease health, environmental and financial consequences of air pollution. A number of major regulatory initiatives have been taken over the last years, including:

The Thematic Strategy on Air Pollution (TSAP), which provides a comprehensive EU environmental policy framework up to 2020 (COM (2005) 446 final, 21.9.2005).

The Clean Air Policy Package1, adopted by EC in 2013, which sets forward targets for 2020 and 2030.

1 http://ec.europa.eu/environment/air/clean_air_policy.htm

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The Ambient Air Quality Directive 2008/50/EC2, which sets legally binding limits for atmospheric concentrations of key air pollutants.

The National Emissions Ceilings Directive 2001/81/EC, which establishes legally binding limits for total anthropogenic emissions at Member State level.

In order to comply with the above directives, limits and targets, Member States will possibly be obliged to take initiatives to reduce air pollution in hot spots like cities and highly trafficked areas. These initiatives may be fiscal incentives, local access restrictions for all conventionally fuelled vehicles, or can take the form of local environmental zones differentiating vehicle access according to emission classes.

Transport, and in particular road transport, has been identified as a key source of air pollutants in cities with significant contributions especially in NOx, CO, and PM emissions. Specific policies to reduce the environmental footprint of transport are summarised in the 2011 White Paper on Transport3 (COM (2011) 144 final, 28.3.2011). In particular, it is requested that “CO2 and pollutant emissions are reduced under real-world driving conditions”.

Focusing on the sector of passenger cars, in spite of increasingly stringent emission standards, they continue to contribute substantially to the urban air pollution in Europe. Problematic are, in particular, diesel cars that show on the road substantially higher ΝΟx emissions than during type approval tests over the New European Driving Cycle (NEDC).

In the 2011 White Paper on Transport, the EC supports the gradual phasing out of conventionally fuelled vehicles from urban environments by 2050. Thus, while in the longer term access to alternative zero-emission propulsion (e-vehicles, hydrogen, etc.) will be promoted, the conventional internal combustion engine (ICE) will remain important for a considerable time span, as agreed also in CARS21 and CARS20204 processes.

As a response to the above, and among other measures, the EC has deployed a strategy to reduce the so-called Real Drive Emissions (RDE) of passenger cars and light commercial vehicles, focusing primarily on NOx emissions. This has been fuelled by a series of studies and reports which show that in-use NOx emission levels of modern passenger cars exceed type approval levels by several times (Weiss et al., 2011 and Franco et al., 2014).

Quickly reducing NOx emissions from diesel passenger cars is of paramount importance for meeting European air quality targets. In fact, NOx emissions of Euro 6 diesel cars alone can determine the future evolution of air quality in cities, at least in terms of NO2 (GAINS scenarios on the revision of the Thematic Strategy on Air Pollution).

The complementary (to the Euro 6 standard) RDE test procedure is in operation from 1 January 2016, on informing the public and competent authorities on the real world emission performance of all newly introduced cars. The same test procedure will be in force from 1 September 2017 for type approval of all new car models5.

RDE is based upon on-road emissions testing with Portable Emission Measurement Systems (PEMS) over a representative trip and a standard evaluation of the test results, using either a ‘power binning’ concept (with the CLEAR emissions data evaluation tool, developed by the Technical University of Graz) or a moving averaging window (MAW, used by the EMROAD tool developed by JRC) to calculate and report emissions measured by the PEMS. Emission levels

2 http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1455619560547&uri=CELEX:32008L0050 3 http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011DC0144&from=EN 4 http://ec.europa.eu/growth/sectors/automotive/policy-strategy/index_en.htm 5 http://europa.eu/rapid/press-release_IP-15-5945_en.htm

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calculated by the evaluation tools should be lower than the certification limit based on the laboratory test multiplied by a so-called conformity factor (CF).

The Euro 6 RDE regulatory package aims to provide reduced emissions, but challenges still remain on correct functioning of the RDE pollution abatement equipment, especially when cars have driven a considerable mileage. Also, in certain highly trafficked urban hot-spots, restricting access to Euro 6 cars only may still not suffice and stricter emission levels may be needed in order to reach compliant air quality levels.

In addition, the implementation of the RDE requires a multitude of amendments of the Euro 6 legislation and it is a time consuming process which takes many years to complete. Inter alia, due to practical reasons, adoption of a more stringent and obligatory standard (e.g. Euro 7) is not to be expected in the near future. Hence, a specific market challenge exists: in the transition towards zero-emission vehicles, ultralow emission vehicles could show substantially reduced emission levels beyond Euro 6 limits.

As a result from the above discussion, investigating the practicalities involved in setting up a voluntary low emission standard would be desirable. Such a voluntary standard should be based on the established RDE test procedure and target to emission levels lower than Euro 6 limits. The information collected and be made public through PEMS testing offers a unique opportunity to distinguish vehicles with low in-use emission levels from vehicles just exhibiting low emissions over the type approval procedure. Therefore, the EC is considering whether this information can be used to establish a voluntary standard, so that it can be quickly introduced without time-consuming negotiations that would be required for a mandatory standard.

A successful example in the past has been the EEV voluntary standard, primarily focused on urban buses. EEV, although already introduced in 1999, has been the lowest limits standard until the introduction of Euro VI in 2013. EEV promoted the introduction of natural gas or diesel with DPF buses already since the beginning of the 2000s, and has significantly assisted local authorities in meeting their local air quality targets.

1.3 Structure of this report

Apart from this introductory section, the rest of the report consists of the following sections:

Section 2 provides the technical model for the introduction of the voluntary EULES scheme. Main issues covered: conformity factor (CF), ancillary measures to strengthen the existing RDE provisions, and implications to other regulatory components (e.g. durability, OBD, etc).

Section 3 presents the legal approach for EULES. This includes detailed flowcharts for integration into the type approval process with related RDE/PEMS testing implications, testing and data handling responsibilities, and placement on the market (legal tool and distinction, incentives, benefits, etc).

Section 4 assesses the likely public response to EULES, by presenting the results from the online survey and the experiment. Focus is given on the assessment of the impact of labels in consumers’ behaviour and the elements that would nudge the consumer towards an environmentally friendly EULES car.

Section 5 describes the role of public authorities (attitudes and reactions towards a voluntary low emission standard). It provides a discussion on issues like differentiated access charges and charges for parking, timing issues, parallel national activities, etc.

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Section 6 provides an overview of potential costs and benefits for the consumer by performing a cost-benefit analysis. Main cost elements are those related to possible areas of influence for EULES cars and material incentives related to this scheme.

Section 7 is the key technical section of the report, presenting the emission experimental results from PEMS and engine dyno testing. This section reveals the technical feasibility of EULES and justifies the CF finally proposed.

Finally, section 8 is the concluding section of the report, providing final recommendations in order to assist in the successful introduction of the voluntary EULES scheme. It provides direct answers to specific key questions like “what is EULES and how it can be implemented”, “how to nudge consumers towards a clean EULES car”, “what is the role of public authorities”, “what is the technology needed to achieve EULES limits”, etc.

The annexes provided in the end of the report contain additional information, results, or parts of the work performed in the framework of the project.

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2 Technical model for the introduction of EULES

In this section, a detailed proposal of a technical model for EULES is presented. The technical model draws from the recent technical discussions on RDE testing within the RDE-LDV working group chaired by the EC (DG GROW), and it incorporates a discussion of some of the latest developments in vehicle emissions regulation in the EU. Some of these developments were triggered or accelerated by the Volkswagen emissions scandal and ensuing investigations of the issue of high in-use NOx emissions from diesel passenger cars6.

This technical proposal ensures that the required input data are available, and that the proposed calculation steps are practicably feasible within the administrative constraints facing the EC and other actors involved in the type-approval of vehicle emissions from passenger cars in Europe. The proposed technical model was developed in such a way that it could be extended to other pollutants beyond those initially regulated by RDE – i.e., NOx and particle number (PN) emissions – should this be required in the future. Although most of the discussion is heavily dominated by diesel NOx emissions, both the technical model and the legal proposal (see section 3) also take into account gasoline vehicles (for which there is less of a concern regarding real-world NOx emissions exceedances) in order to provide a framework with improved technology neutrality in relation to the baseline Euro 6 standard.

Also within this section, a reasoned proposal for EULES NOx conformity factors (CFs) is made. The key to success is to propose CFs that are: a) technically achievable with state-of-the-art emissions control technology, and b) substantially lower (i.e., more stringent) than the CFs that the current RDE regulation proposes (i.e., 2.1 for 2017-2020, and 1.5 from 2021 onward). The derivation and proposal of these CFs is addressed in subsection 2.3.

A sufficient amount of measured emissions data is available to the research consortium of the project to justify a proposal of NOx CFs for diesel passenger cars, which is the main driver of the first package of RDE regulations. A specific laboratory exercise (documented in section 7) was also carried out to investigate the technical feasibility of a low EULES conformity factor for NOx based on the current state of diesel NOx aftertreatment technology.

A third key output of this task is a list of ancillary proposals made on the basis of the first and second legislative packages of RDE. These were conceived as relatively simple ways to reinforce the application of RDE with an additional layer of voluntary EULES provisions. These provisions address some of the aspects of the RDE regulation proposal that were left open to interpretation, or where increased stringency levels could be achieved. The ancillary proposals cover, among others, aspects such as the trade-offs between the emission levels of different pollutants, the coexistence of two data evaluation methods for RDE tests, the separate evaluation of urban/cold-start emissions, the transparency of reported emission results, and the assurance that the presence of an OBD link does not affect the emissions performance of the vehicle under test. These proposals are detailed in subsection 2.4.

Finally, the issues of compatibility, scalability, and future proofing of the EULES framework are addressed in subsection 2.5. Compatibility in this context refers to the effect of the EULES scheme upon the RDE scheme and how it ties in with the environmental needs of local and regional authorities, whereas scalability and future proofing should be interpreted as options available to the EC to modulate the stringency of EULES before it enters into force, based on the needs of the regulator, as well as during its useful life, to accompany technological development of emissions control technologies.

6 http://www.theicct.org/spotlight/use-nox-emissions

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2.1 Background: the VW emissions scandal and shortcomings of RDE

Since September 2015, new diesel passenger cars registered in the EU must meet the Euro 6 standard, which limits NOx emissions to 80 mg/km. This is down from a 180 mg/km limit under the preceding Euro 5 standard. But these limits apply to an outdated measurement protocol (New European Driving Cycle, NEDC), and they are not supported by on-road compliance and enforcement requirements for in-use vehicles.

As a result, the large majority of passenger cars, certified to the Euro 6 standard, have NOx emission levels several times above the regulated limit when driven under normal conditions. Also, a minority of the latest generation of diesel vehicles become gross polluters as soon as they are tested outside the narrow boundary conditions of the official emissions test, in spite of being equipped with dedicated systems that could control NOx under a broad range of driving conditions.

This problem is specific to diesel cars, which in some cases exhibit a worse NOx emissions behaviour than much larger Euro VI trucks (Figure 1).

Figure 1: Illustration of estimated average real-world NOx emission levels from Euro 6 passenger cars (diesel and gasoline) and Euro VI trucks (diesel)

Source: ICCT

As the RDE regulation was being developed (between the years 2011 and 2015), the addition of a new, semi-random on-road emissions verification test was regarded as one of the greatest challenges facing the European diesel car industry. On September 18, 2015, the United States

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Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) announced that Volkswagen Group (VW) had manufactured and installed defeat devices on 482,000 diesel vehicles sold between 2009 and 2015 in the U.S. market. Subsequently, VW announced that such a defeat device is present in some eleven million diesel vehicles with Type EA 189 engines globally, and the issue of real-world diesel NOx emissions was brought to the forefront of public attention worldwide as a result. This effectively created a much larger challenge for vehicle manufacturers than RDE alone would have.

The VW scandal – or ‘Dieselgate’, if one includes its broader repercussions (e.g., defeat device screening investigations of other manufacturers in the US, EU, and elsewhere) – also put pressure on European authorities as it made apparent some of the shortcomings of the European type-approval framework in general and of RDE in particular. The Volkswagen defeat device scandal related to NOx emissions created a public trust crisis that has led many to question whether "clean diesel" is a misnomer.

Beginning in 2017, the EU type-approval procedure for cars will include a new Real-Driving Emissions (RDE) test conducted using on-board portable emissions measurement systems (PEMS). The RDE regulation is still a key policy to address high real-world NOx emissions from diesel cars, but its success will depend on the ability of regulators to adjust its stringency level to drive changes in emissions control technology and use it as a tool to rebuild trust.

RDE is likely to drive technological improvements to the pollution control systems installed in diesel cars, but following the VW scandal it is apparent that certain revisions could be made to the regulation in order to enhance this effect. These modifications concern not just the conformity factors, but also the manner in which on-road tests are conducted, how test vehicles are obtained, and how the test results are disseminated (see Table 2).

EU emissions regulations should reflect the state of the art of the emissions control technology, and be progressively reviewed until all real-world emissions and legal emission limits are in line, as is already the case for most regulated pollutants. The higher flexibility afforded by the voluntary nature of the EULES standard means that it can play a critical role in this sense and be a powerful companion to the RDE regulation.

Table 2: Possible revisions to RDE regulation, highlighted by the VW emissions scandal Source: ICCT, 2015 (adapted)

RDE revision Rationale and relation to EULES

Expand the focus of the RDE regulation from type-approval only (i.e., only testing pre-production specially prepared vehicles, the so-called “golden cars”) to in-use testing for compliance and enforcement purposes.

Vehicles for in-use tests could be obtained at random from private individuals by enforcement agencies, and tests could be conducted throughout the useful life of vehicles to monitor the durability of emission control systems. This is not contemplated by the EULES standard design proposed in this document, but is covered in the proposal for a regulation7.

Revert the conformity factors to the initial technical consensus

The state of the art seems to indicate that a tighter CF is technically possible. The EULES standard would

7 The full text of the proposal and accompanying documents are available at http://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1453996101816&uri=COM:2016:31:FIN

A separate impact assessment of the proposal is available at

http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1453996334099&uri=SWD:2016:9:FIN

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proposal made by the EC to Member States in the TCMV meeting of October 2015: a NOx conformity factor of 1.6 in 2017 and 1.2 for the “final” conformity factor in 2019.

provide a way for best-performing manufacturers to showcase their technology.

Accelerate the technical work to include cold-start emissions in the RDE test results evaluation method, with the intention to set specific, legally binding limits by 2019.

Controlling cold-start emissions is especially relevant for air quality in urban environments. The work to include cold-starts in RDE is already ongoing, but it could be accelerated by EULES.

Monitor and expand the boundaries of the RDE test procedure.

Previous experience has repeatedly shown that driving situations that are not covered by regulations can lead to uncontrolled—yet technically legal—emission behaviours. This is especially true for NOx emissions, which grow exponentially outside of the operating conditions covered by the design of the aftertreatment systems and their control algorithms. To prevent this from happening, the EC could perform additional, independent tests to monitor the performance of vehicles outside of the boundary conditions of RDE (e.g., ambient temperature, altitude, dynamic driving indicators) and expand the limits as necessary to maintain low in-use emissions. EULES could be used to address this aspect, e.g. by monitoring cold-start emissions sooner than the general RDE regulation.

Improve public access to information and provide incentives to foster clean technologies. Information on actual on-road emissions performance should be made easily accessible to the public, so that consumers can make informed buying decisions and manufacturers can track their progress and benchmark their vehicles against the competition.

In addition to including the result of the RDE test in the certificate of conformity and other relevant documents, vehicles that meet the Euro 6 limits during the on-road test could, for example, be granted a “certified clean” label to incentivize both manufacturers and consumers, and help local authorities build their own incentive programs. This is aligned with the objectives of EULES.

2.2 Framework of the technical model

The basis for the technical model of EULES is the RDE amendment to the Euro 6 emissions regulations8. In this section, we present a technical justification for the development of EULES around the RDE regulation as an added (voluntary) layer of increased stringency. The technical model is composed of three modules:

8

http://ec.europa.eu/transparency/regcomitology/index.cfm?do=search.dossierdetail&hdi47H/nymYsbNlXdPttFe3eAOQQ+7kPEZ/3yRiu4PgxdbQ+AI/X9VTTMRqv00VG

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1. Framework of the model: It comprises the technical underpinnings of EULES scheme, which is essentially conceived as a voluntary extension of the provisions of the RDE regulation, which are modified for increased stringency.

2. Conformity factors: A collection of proposed on-road NOx CFs for EULES. These are lower (i.e., more stringent) than the conformity factors proposed in the second package of the RDE regulation. These conformity factors are meant to reflect low, yet achievable with current technology, emission levels.

3. Ancillary proposals: A collection of measures to reinforce the application of the RDE regulation with an additional layer of voluntary EULES provisions. These are devised as simple modifications to the current RDE provisions that are expected to increase the stringency or improve the coverage of RDE tests, while imposing a small additional testing or data processing burden on stakeholders.

The main characteristics of the technical model framework are described below.

Focus on real-world emission reductions and technology neutrality

The main reason to link EULES to RDE relates to the existence of a “real-world” gap for the pollutant emissions of passenger cars. In other words, there is a substantial difference between the emissions recorded at type-approval and the actual on-road emissions. This means that chassis-dynamometer-only testing procedures for conventional pollutants do not fully guarantee that real-world emissions will be reduced in the same proportion as the legal emission limits when more stringent regulatory steps are phased in. Case in point is the issue of NOx from diesel cars, whose on-road emissions (as estimated from comprehensive remote sensing and PEMS measurement campaigns) have only dropped slightly from Euro 3 to Euro 6 (Figure 2).

Figure 2: Illustration of the real-world diesel NOx emissions problem Source: ICCT 2014

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The EULES technical model can play a role in bridging the “real-world emissions gap” by focusing on on-road measurements instead of laboratory results (and therefore incentivizing real-world emissions reductions). Furthermore, EULES conformity factors could be adjusted to achieve technology neutral standards9; by holding all cars to the same effective on-road emission standards regardless of the type of fuel they use, EULES can achieve better technology neutrality than the baseline Euro 6 standard.

Voluntary nature of the standard and support to incentive programmes

EULES is conceived as a voluntary scheme, and as such it needs to present itself as an attractive proposition to stakeholders, including vehicle manufacturers, importers, and technical services. From the side of European Commission, this can be achieved by minimizing the additional administrative, testing and data evaluation burden, and by maximizing the synergies with existing emissions regulations. The voluntary nature of the standard also means that stringency levels can be adjusted in such a way that EULES compliance requires a reduction of pollutants emissions, with additional effort from the side of the manufacturer (i.e., that only the best performers should be able to qualify as a EULES car).

EULES is conceived as a harmonised way to support local and regional incentive programmes. From the point of view of local and regional authorities, a EULES-certified car can be expected to have a low air quality impact, and it should therefore qualify for the most favourable level of incentives foreseen by the applicable programme.

2.3 Determination of conformity factors for EULES

In this subsection we determine what on-road conformity levels would be appropriate for EULES compliance. It is unrealistic to expect that a vehicle certified to a certain emission standard will stay below the certified limits under all driving conditions. Even during type-approval tests, emissions hit several peaks at given points of the driving cycle in which they can be several times above the emission limit. But this does not prevent their average emissions throughout the cycle from meeting the relevant emission limits.

Likewise, it is acceptable for vehicles tested with PEMS to register a moderate number of points at which the emission limits are exceeded – even by a wide margin – but at the same time, their average emissions over long distances (i.e., distances comparably longer to those of type-approval cycles) should be kept under control. The key issue is how close to the laboratory-based values can on-road emissions levels be expected to stay assuming a reasonable coverage of real-world driving situations.

A usual way of comparing on-road emission levels to laboratory-based emission limits is to calculate the so-called conformity factor (CF), which is the ratio of (distance-specific) on-road emissions to a reference (also distance-specific) emission limit. For the purposes of this report, we will speak of CFs of measured emissions to Euro 6 emission limits, although strictly speaking CFs should only apply to regulated tests.

The focus is on the determination of EULES conformity factors for NOx emissions from diesel passenger cars, which is approached in two ways:

An initial, quantitative estimation of appropriate conformity factors on the basis of experimental data available prior to September 2015. This was the approach adopted in

9 Technology neutrality would be (somewhat counter-intuitively) achieved by proposing different CFs for

diesel and gasoline to compensate the original non-neutrality of the Euro 6 emission limits.

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the 1st Interim Report of the project (Papadimitriou et al., 2015a), and it is now summarised in subsection 2.3.1.

A discussion on the qualitative adjustment of the initial proposal, based on the additional information made available to the research consortium of the project after September 2015; notably, the events related to the Volkswagen scandal and the results of the laboratory experiment to explore the technical feasibility of EULES (described in section 7 of this report). This qualitative discussion, along with the information that supports it, is provided in subsection 2.3.2.

2.3.1 Quantitative estimation of CFs

The initial determination of CFs for EULES in the 1st Interim Report of the project (Papadimitriou et al., 2015a) was based on the data-driven analysis of the library of PEMS measurements for Euro 6 cars in possession of ICCT (amounting to more than 140 hours worth of second-by-second data from several sources, covering a combined total of more than 6,400 km driven for 15 test vehicles) which formed the basis for ICCT’s meta-study of on-road emissions from diesel passenger cars (Franco et al., 2014). An overview of the vehicles included in the analysis is provided in Table 3.

Table 3: Overview of vehicles included in the analysis Source: Franco et al., 2014

ID Body type NOX control

Emission standard

Total trips

Data source Make Starting mileage [km]

A SUV SCR+LNT Euro 6b 6 Anonymous 1 M1 22,900

B SUV SCR Tier 2 Bin 5/ ULEV II

8 WVU/ICCT M1 24,200

C Sedan SCR Euro 6 1 Emissions Analytics

M1 4,900

D Station wagon SCR Euro 6 25 Anonymous 2 M2 22,000

E Sedan SCR Euro 6 9 Anonymous 3 M2 63,000

F Sedan SCR Tier 2 Bin 5/ ULEV II

15 WVU/ICCT M2 24,500

G Sedan SCR Euro 6b 6 Anonymous 1 M2 13,500

H Sedan LNT Tier 2 Bin 5/ ULEV II

13 WVU/ICCT M2 7,600

I Sedan EGR + in-cylinder

Euro 6 4 Anonymous 2 M3 7,600

J Station wagon EGR + in-cylinder

Euro 6 1 Emissions Analytics

M3 200

K Sedan EGR + in-cylinder

Euro 6 1 Emissions Analytics

M3 1,600

L Luxury sedan SCR Euro 6 1 Emissions Analytics

M4 1,400

M Minivan SCR Euro 6 1 Emissions Analytics

M5 3,500

N Sedan SCR Euro 6 1 Emissions Analytics

M6 1,500

O Hatchback Dual EGR Euro 6b 5 Anonymous 1 M6 11,000

The PEMS trips analysed come from several different testing campaigns. The cars were therefore driven on different routes, and the relative shares of urban/rural/motorway driving, road gradients, and driving styles all differed as well. In some cases, the vehicles were driven repeatedly over the same route or collection of routes. For some vehicles, only a single PEMS

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trip is available for analysis. This heterogeneity has some disadvantages, because it makes the comparisons of trip averages less meaningful (as they may be distorted by the aforementioned sources of on-road variability). However, a wide variability of driving conditions also has the advantage of allowing us to identify the factors that lead to high (and low) levels of on-road emissions, provided that the data are properly analysed.

The data analysis approach that we followed borrows from both the EMROAD and CLEAR methods, but it is not a complete reproduction of either method, and it uses custom MATLAB scripts developed by ICCT. An analysis using the latest versions of the RDE data evaluation tools was in principle ruled out for this task for two reasons: first and foremost, the scope and depth of the analysis would have been further reduced due to the lack of flexibility of the tools in comparison to the fully customizable scripts. Second, the results may not have been fully representative due to the fact that ICCT’s library of PEMS trips was gathered before the RDE provisions were drafted, and therefore some of the trips do not necessarily comply with them in full, especially in what regards the relative shares or urban/rural/motorway driving. It must also be noted that all of the measured emissions data available for each trip were included in the analysis, and they are initially reported without exclusions. This means, for example, that cold starts or DPF regeneration events were not removed from the data pool.

PEMS tests are performed by driving the instrumented vehicles in real (difficult to predict) traffic and driving conditions. Therefore, it is not possible to follow a standard driving cycle (predetermined time-speed profile). However, it is possible to relate PEMS test results to cycle values by selecting a fixed reference magnitude pertaining to the test cycle and subsequently windowing PEMS data according to this magnitude.

For example, knowing that NEDC covers a fixed distance of 11.02 km (in a fixed time of 1,180 seconds), we could divide a given PEMS dataset in bins (or data windows) to have that same distance (or duration) and compute the total emissions over these windows. Since the windows would then share a common characteristic with a reference cycle, it would be possible to compare windowed emissions to the known cycle results or emission limits and have a meaningful estimation of the influence of real-world driving conditions.

For the purposes of the analysis presented in this report, we have chosen to divide our data into windows using type-approval CO2 emission values as the reference magnitude. By selecting CO2 as a reference, the data window size is not defined in terms of distance or time, but rather by the amount of CO2 emitted over them. All of CO2 windows that could be derived from the available data were pooled together. This resulted in approximately 450,000 CO2 windows (which can be thought of as the on-road fuel equivalent of a type-approval cycle).

If we compute the conformity factors for NOx and CO, as well as the ratio of on-road CO2 to the type-approval CO2 value, we observe the ‘on-road compliance’ situation picture in Figure 3: most of NOx conformity factors are outside of Euro 6 (even Euro 5) conformity (i.e. the CF is higher than 1). The average windowed Euro 6 CF was 7.1 for NOx and 0.32 for CO, whereas the ratio of on-road, distance-specific CO2 to the type-approval value was around 1.4310. This result speaks of a serious on-road compliance issue for diesel NOx emissions for the current crop of Euro 6 passenger cars. If we take a closer look at the CFs for NOx, we can gain further insights into the emissions behaviour of these vehicles.

10 This +43% deviation is consistent with the findings of ICCT’s “From laboratory to road” series of reports,

which further supports the notion that the driving profile of the PEMS dataset falls within the scope of normal “real-world driving”.

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Figure 3: Evaluation of windowed emissions against Euro 5/6 emission limits and type-approval CO2 values (all windows)

In Figure 4 we have sorted all CO2 windows by their corresponding NOx CF (in ascending order). What we see in this figure is that, when NOx are not properly controlled, the CFs rise exponentially to reach values of up to 80. These are relatively rare instances, but their high emissions give them an important weight in the overall emissions behaviour of the vehicle class.

Figure 4: NOx conformity factor for all CO2 windows (sorted in ascending order)

We can see this more clearly in Figure 5 and Table 4, where we compute average NOx CF resulting by including variable percentages of all CO2 windows: if we only include the ‘cleanest’ 20% of windows, we obtain an average CF just above one. Conversely, the inclusion of ‘dirtiest’ 20% of emissions makes the average CF double from 3.63 to 7.21. In other words, the ‘uncontrolled’ NOx sections have a very large impact in the final average NOx emissions behaviour of the vehicle class. Conceivably, a vehicle with a robust NOx aftertreatment system

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(designed to comply with Euro 6c) could eliminate this emissions behaviour and have, at worst, a conformity factor of 3.6. On the other hand, the better performing vehicles of the class would fall within the best 20%, and comply with a CF of 1.0. This would make the CF of 1.0 a suitable baseline proposal for EULES diesel NOx.

Figure 5: Average NOx conformity factor as a function of window coverage

Table 4: Computed average NOx CFs as a function of window coverage

Coverage 10% 20% 30% 40% 50% 60% 70% 80% 90%

CF 0.68 1.03 1.33 1.62 1.96 2.37 2.90 3.63 4.75

2.3.2 New evidence affecting the initial estimation of CFs

For this final report of EULES, a large amount of PEMS data was added to the database (which has now roughly doubled in size). But more importantly, a large amount of additional information regarding the real-world NOx emissions of diesel passenger cars has reached the public domain. In this subsection we discuss this information, as well as its implications in relation to the determination of an appropriate conformity factor for EULES.

2.3.2.1 US EPA’s notice of violation to Volkswagen

Following the publication of US EPA’s notice of violation to Volkswagen, it is now known that the US-market diesel cars tested for the ICCT by the University of West Virginia were two Volkswagens (Jetta and Passat) and one BMW (X5), and that the two Volkswagen vehicles were equipped with defeat devices. As a result, the brand of the other VW and BMW vehicles (anonymised in the original report) was indirectly revealed.

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If we revisit the results of the meta-study and focus on the performance of the vehicles from these two brands (see Figure 6), we can see that the performance of the VW vehicles equipped with the defeat device is markedly worse than that of the rest of vehicles. Interestingly, the best-performing VW is a pre-series vehicle, and also the only vehicle of the meta-study that was sourced directly from the manufacturer. As for the BMW vehicles, the US-market X5 had a relatively good performance. This vehicle was extensively tested and it behaved acceptably, managing to meet the stringent US Tier 2 Bin 5 emission limit for some of the individual trips, despite facing some of the most demanding dynamic driving and road grade situations of all vehicles tested.

Figure 6: On-road emissions performance of BMW- and VW-branded cars (Franco et al., 2014)

It must be noted that all of the measured emissions data available for each trip were included in the analysis, and they are initially reported without exclusions. This means, for example, that cold starts or DPF regeneration events were not removed from the data pool.

For each trip, the emissions were also evaluated after the application of dynamic boundary conditions that exclude the driving situations that would in principle lead to elevated emission levels11 (e.g., high road gradient, strong positive acceleration*velocity)12. These undemanding emission factors are therefore not representative of real-world driving, but they were nonetheless derived to determine “best behaviour” baseline emission levels for the test vehicles under favourable condition13 (called “Undemanding” driving conditions).

In any case, even under “undemanding” driving conditions, some of the vehicles covered in ICCT’s meta-study had emission levels that were more than an order of magnitude higher than the Euro 6 limit (see Table 5).

11 This is the only instance in which data exclusions were performed for the purposes of our analysis. 12 The “All driving conditions” emission factor includes all data points, then the “Undemanding” conditions

have exclusions that are far more generous than those of RDE (e.g., they exclude the instances of a*v higher than the maximum registered over NEDC, and the % of distance excluded is on several instances in exceedance of 50% of total trip distance). Considering cold-start driving is also excluded, we would normally expect on-road compliance with Euro 6 limits after these exclusions.

13 The emission levels resulting from this analysis are only representative of the mild driving conditions that they cover, and they should not be construed as the EULES research consortium’s definition of what constitutes normal driving.

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Table 5: Emission factors of vehicles covered in Franco et al. (2014) Note: vehicles with a defeat device (US market VW passenger cars) marked in red

2.3.2.2 Evidence of poor aftertreatment calibrations for some Euro 6 diesel cars

In Sept. 2015, ICCT published a study (Yang et al., 2015) on the basis of chassis dynamometer emissions data gathered by ADAC (Allgemeiner Deutscher Automobil-Club; Europe’s largest car club), as part of its EcoTest programme. These covered 32 Euro 6 diesel passenger cars: 11 SCR-, 16 LNT- and 5 EGR-equipped. The vehicles were tested over both the NEDC cycle and version 2.0 of the WLTC cycle (hot-started, as it was run right after the cold-start NEDC). This study showed that a minority of vehicles (all equipped with LNT technology) exhibited large conformity factors (in the order of 7 to 15) over the WLTC, whereas they would be in compliance or very close to compliance with the Euro 6 limit when tested over the NEDC (see Figure 7).

Figure 7: Conformity factors over NEDC and WLTC 2.0 for 32 Euro 6 diesel passenger cars Source: Yang et al., 2015

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A follow-up study covering 41 additional Euro 6 vehicles confirmed that LNT-equipped vehicles had an overall performance that was, on average, worse than that of SCR-equipped ones, and that a minority of LNT vehicles (from several different manufacturers) were high emitters outside of the NEDC test. In addition to the experimental emissions data, the same Sept. 2015 ICCT study (Yang et al., 2015) also provided information on the NOx aftertreatment technologies used by the main diesel car manufacturers in the US (Tier 2 Bin 5) and EU (Euro 6) markets in the years 2012-2014 (see Figure 8). These results showed that the US vehicles tended to equip more sophisticated aftertreatment systems (SCR, or combinations of SCR and LNT), while the majority of European vehicles relied on LNT. For the same model denominations, one specific manufacturer (BMW) was found to equip more sophisticated aftertreatment systems in their US offerings. This is an indication that the more stringent US emission regulations are shaping the technological choices made by diesel car manufacturers to control NOx emissions, and that the Euro 6 regulation was not having the same technology-forcing effect.

Figure 8: NOx control technologies used by diesel car manufacturers in US and EU (2012-2014)

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Following the revelations of the VW scandal, the results of other on-road emissions tests that were performed by NGOs and investigative journalists were also made public. Even though these investigations did not provide conclusive evidence of the presence of a defeat device14, they were useful to demonstrate that the Euro 6 standard effectively allowed vehicles with poor NOx aftertreatment calibrations (i.e., with diminished effectiveness under real-world driving conditions) to be type-approved (see Figure 9).

Figure 9: Illustration of the difference between on-road and laboratory NOx emissions for selected diesel vehicles tested by different parties

When asked about these results, the affected manufacturers invoked the exemptions in the European defeat device provisions that allow reducing the emissions of the aftertreatment systems under normal conditions of use when there is a need “justified in terms of protecting the engine against damage or accident and for safe operation of the vehicle”. Some manufacturers have publicly committed to improving the real-world NOx emissions of their Euro 6 diesel cars15,16, implicitly acknowledging that their software calibrations were delivering insufficient real-world performance.

14 Defeat device investigations are carried out by public authorities, and they require extensive testing and

the involvement of the affected vehicle manufacturer. 15 http://www.fcagroup.com/en-

US/media_center/fca_press_release/FiatDocuments/2016/february/FCA_on_Real_Driving_Emissions.pdf 16 http://media.renault.com/global/en-gb/renaultgroup/media/pressrelease.aspx?mediaid=74495

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2.3.2.3 Determination of NOx conformity factors: summary and conclusions

The initial, data-driven determination of the EULES conformity factor for NOx indicated that setting the CF at 1.0 could be appropriate, as approximately 20% of the PEMS data windows available at the time of the analysis fell below this threshold. However, the additional data on the NOx emissions behaviour of Euro 6 diesel passenger cars that was made available to the research consortium of the project after the date of publication of the 1st Interim Report (April 2015) would justify a downward adjustment of this value.

It is apparent from the several reports and the reaction of a number of manufacturers that the calibration of NOx aftertreatment systems from the current crop (pre-RDE) of Euro 6 diesel passenger cars was not optimised for best on-road behaviour. There is evidence that manufacturers have room for improvement on the software side (in the form of new calibrations to be applied in the short term) and the hardware side (through an increased market share of SCR, or combinations of SCR and LNT technology).

Furthermore, the laboratory exercise to investigate the technical feasibility of EULES (see

section 7) supports a NOx conformity factor in the range of 0.5-0.7. Hence, the final recommendation is to set the conformity factor at the levels demonstrated by the laboratory exercise.

2.4 Ancillary proposals for EULES

In this subsection, we make a number of proposals to reinforce the application of the RDE regulation with an additional layer of voluntary EULES provisions. The basic guiding principles for the formulation of these proposals are as follows:

They should increase the stringency of the application of RDE regulations, either by turning optional provisions of RDE into mandatory EULES provisions, or by enforcing the more stringent application of RDE provisions when these are open to interpretation.

They should minimize the additional testing / data processing burden, and at the same time maximize the compatibility with existing RDE provisions and other vehicle emission regulations currently in force.

They should improve the coverage issues that were excluded from the first package of RDE, or insufficiently addressed. Special attention will be paid to the improvement of data transparency and the establishment of safeguards against ‘procedure-beating’ strategies (i.e. aftertreatment management strategies that are oriented towards improving emissions performance during a regulated test, but not during real-world driving).

In the paragraphs that follow, we propose a number of such ancillary measures. At the end of each proposal, and after the explanation of the rationale for the ancillary measure, a table is included with a simple formulation of the measure (as a rewording of the RDE regulation), complemented with a qualitative assessment according to the aforementioned guiding principles (increased stringency, low additional burdens, improved coverage).

2.4.1 Measure A1.1: compliance with both data evaluation methods

Section 9.7 of the first package of the RDE regulation states that “Three years after the dates laid down in the Article 10(5) and in the Article 10(6) of the Regulation (EC) 715/2007 for all new

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vehicle types and all new vehicles respectively, the exhaust emission conformity factors calculated by means of at least one of the data evaluation methods indicated in Appendix 5 and Appendix 6 shall not exceed limits which will be proposed by the Commission in a separate legal act”.

The requirement to demonstrate compliance with only one of two data evaluation methods is the result of a compromise with vehicle manufacturers in view of the difficulties to ensure that both of the proposed methods (EMROAD and CLEAR) were operating in a fully equivalent manner. This is a sound approach, considering that the principles behind either method are substantially different, and no full equivalence can therefore be expected. However, it also poses a risk for the regulator to the extent that previously undiscovered features of either data evaluation model could make it more susceptible to ‘procedure beating’. This can be addressed within EULES by requiring that compliance be demonstrated for both data evaluation methods (see Table 6), effectively providing additional safeguards to the regulator.

Table 6: Measure A1.1: compliance with both data evaluation methods

Formulation of ancillary measure:

The exhaust emission conformity factors calculated by means of both of the data evaluation methods indicated in Appendix 5 and Appendix 6 shall not exceed limits proposed by EULES.

Increased stringency

The ancillary measure increases the stringency in those cases where the compliance of a vehicle with EULES conformity factors would only be attained for one of the two data evaluation methods. The increase in stringency is likely small and difficult to evaluate a priori (at least until the monitoring phase of RDE is completed).

Additional burdens

The additional testing burden is minimal, since the conformity factors must be calculated for both data evaluation methods in any case. RDE-ready PEMS equipment will likely be delivered with accompanying software that performs the data evaluation calculations using both regulated methods. There are no compatibility issues with the RDE procedure associated with the introduction of this ancillary measure. The measure can be easily phased out should one of the two data evaluation methods be dropped upon future amendments of RDE regulation.

Improved coverage

The main benefit of the ancillary measure comes in the form of reduced risk of ‘procedure beating’, i.e., skewed emissions control strategies oriented towards improving the RDE results for either one of the two data evaluation methods instead of focusing on general real-world emissions performance. The measure also leverages the benefit to the regulator derived from retaining two data evaluation methods.

Interaction with other ancillary measures

Incompatible with measure A1.2.

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2.4.2 Measure A1.2: a priori compliance without the application of data evaluation methods

Measure A1.2 proposes a ‘radical’ approach to the issue of coexistence of two data evaluation methods. According to this measure, manufacturers would be required to demonstrate a priori compliance with EULES CFs before the application of either one of the methods. This possibility was repeatedly discussed during the technical discussions of the RDE-LDV Data Evaluation Task Force.

In principle, the establishment of dynamic boundary conditions (e.g. on the basis of an appropriate metric, such as the 95th percentile value of the product of instantaneous acceleration and velocity), along with the environmental boundary conditions imposed by the text of RDE, could mean that a data evaluation method is not strictly necessary because the operating conditions of RDE tests would be sufficiently delimited to ensure ‘normal’ operation. With a method-less concept for emissions data evaluation, the conformity factors would be calculated on the basis of the division of cumulated pollutant mass emissions measured during the RDE test over the cumulated distance driven (i.e., on the basis of ‘raw’ emission factors) (see Table 7).

Table 7: Measure A1.2: a priori compliance without the application of data evaluation methods


The exhaust emission conformity factors calculated by dividing cumulated pollutant mass emissions by cumulated distance driven shall not exceed limits proposed by EULES.


The ancillary measure increases the stringency in those cases where the compliance of a vehicle with EULES conformity factors would only be attained after the application of the data evaluation methods. The increase in stringency is difficult to evaluate a priori. In some cases, there could be no additional stringency arising from the application of this measure (namely, when the driving conditions during the RDE test are so smooth that the effect of the data evaluation tools would be to increase the conformity factor with respect to the ‘raw’ result).

Additional burdens

A small calculation burden is added in the form of a (simple) calculation of ‘raw’ conformity factors. There are no compatibility issues with the RDE procedure.

Improved coverage

As with measure A1.1, the main benefit of the ancillary measure comes in the form of reduced risk of ‘procedure beating’, i.e., skewed emissions control strategies oriented towards improving the RDE results for either one of the two data evaluation methods instead of focusing on general real-world emissions performance.


Incompatible with measure A1.1.

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2.4.3 Measure A2: inclusion of cold start emissions

The current RDE regulation defines boundaries for cold-start events. According to section 4 of Appendix 3, “The cold start period covers the first 5 minutes after initial start of the combustion engine. If the coolant temperature can be reliably determined, the cold start period ends once the coolant has reached 343 K (70°C) for the first time but no later than 5 min after initial engine start”. Until specific requirements for emissions at cold-start are applied17, these will be recorded but excluded from the emissions evaluation.

This compromise was reached during the technical discussions to simplify the data evaluation methodologies. However, this simplification poses a risk to the regulator because it does not provide sufficient incentives for vehicle manufacturers to optimize the thermal management of their aftertreatment systems (which is especially relevant for NOx) during cold-start events. This could have a significant impact on urban emissions, which are most frequently linked to cold-start events. This issue can be addressed within EULES through the inclusion of cold start emissions (see Table 8).

Table 8: Measure A2: inclusion of cold-start emissions


The evaluation of emissions for the purposes of EULES shall cover cold start emissions by including all mass emissions after the initial start of the combustion engine of the vehicle under test.


The ancillary measure positively increases the stringency of EULES beyond that of ordinary RDE tests.

Additional burdens

A significant calculation burden is added, because the inclusion of the cold-start section requires a recalculation of the emissions results for EULES. Once EULES is finalized, and if the ancillary measure is adopted, next-generation PEMS equipment would likely be delivered with accompanying software that performs the data evaluation calculations including and excluding cold-start events. This ancillary measure presents no compatibility issues with the RDE procedure, for which a more sophisticated, separate cold-start evaluation procedure could be developed.

Improved coverage

The main benefit of the ancillary measure comes in the form of reduced risk for the regulator, ensuring that cold-start emissions are at least partially covered. Provides a clear incentive for manufacturers to improve cold-start performance. A successful inclusion of cold-start events within EULES could pave the way for the adoption of a similar approach within the third RDE package.


Incompatible with measure A1.1, compatible with measure A1.2.

17 These are expected to be included as part of the third regulatory package of RDE. Should the cold-start

emissions be addressed by RDE before the EULES standard is finalized, complementary cold-start provisions could be devised for EULES.

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2.4.4 Measure A3: ECU-independent testing

The RDE regulations state that “Vehicles where the collection of ECU data influences the vehicle emissions or performance shall be considered as non-compliant”. On the other hand, the RDE test procedure favours the use of ECU signals (it prohibits the use of ECU signals to derive exhaust mass flow during type-approval RDE tests, but allows the collection of ECU signals such as vehicle speed) and it is likely that a majority of vehicle manufacturers will choose to perform the on-road emissions test with an active data link between the PEMS equipment and the ECU of the vehicle under test. This poses a risk to the regulator, because the presence of the ECU link could effectively ‘alert’ the vehicle that it is being tested and trigger a ‘test mode’18 for the management of the emission control systems. This issue can be addressed within EULES by ECU-independent testing (see Table 9).

Table 9: Measure A3: ECU-independent testing


The evaluation of emissions for the purposes of EULES shall be performed without a data link to the ECU of the vehicle under test.


The ancillary measure has no direct effect upon the stringency of EULES.

Additional burdens

No additional data processing burdens are foreseen from the application of this ancillary measure. The use of an optical / magnetic sensor or a ‘fifth wheel’ may be advisable as a way to record a backup vehicle velocity signal (for situations where the quality of the GPS signal could be diminished, e.g., inside urban canyons). The power signal required for the application of the CLEAR method may have to be gathered from a wheel torque meter.

Improved coverage

EULES-compliant vehicles could be assumed to be free from ECU link influences upon the emissions behaviour. The measure could also worsen the coverage of EULES because some auxiliary signals would not be recorded (e.g., instantaneous pedal position or desired gear, as reported by the gearshift indicator). This trade-off is required to obtain additional assurance that no procedure-beating strategies are being applied.


None foreseen.

2.4.5 Measure A4: urban NO2 emission limits

Due to the large density of population in urban areas, urban emissions are more likely to have a large impact upon human health. On the other hand, NO2 is one of the main constituent gases of NOx. NO2 is a large contributor to the formation of ground-level ozone and secondary particle formation, and it is linked with adverse health effects (such as asthma complications in children

18 This risk is especially high for NOx emissions, which are primarily managed through aftertreatment

systems. Under an (optimized) ‘test mode’, NOx emissions would be kept low thanks to a generous dosing of AdBlue (for SCR systems).

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and elderly people). Euro 6 regulations do not foresee a specific limit for NO2. This issue can be addressed within EULES by urban NO2 emission limits (see Table 10).

Table 10: Measure A4: urban NO2 emission limits


The evaluation of emissions for the purposes of EULES shall include a separate evaluation of NO2 emissions in the urban section of the test.


The ancillary measure increases the stringency of EULES by setting a specific conformity factor for NO2 emissions in the urban environment, which are the likeliest to have an impact upon human health. This measure should be applied in combination with measure A2 (all-inclusive evaluation of cold-starts).

Additional burdens

Minor data processing burdens would arise from the application of this ancillary measure. The measure requires that NO2 emissions be recorded separately by PEMS equipment. The application of this ancillary measure may pose a bigger challenge for EGR-only vehicles.

Improved coverage

The ancillary measure improves the coverage of RDE by focusing on urban emissions. The same rationale could be applied to pollutants other than NO2

(e.g., particulate emissions).


None foreseen.

2.5 Scalability, compatibility, and future proofing of EULES

In this subsection, we identify a number of issues regarding the scalability, compatibility, and future proofing of the technical model for EULES.

A particular challenge exists with respect to the treatment of gasoline and also hybrid-electric vehicles. In principle, EULES should be technology-neutral and should therefore also apply to these technologies. For hybrid-electric vehicles, the Euro 6 RDE procedure is not specified, and thus this vehicle type is not specifically addressed in the considerations of EULES.

For gasoline vehicles, the RDE emission levels of today’s gasoline vehicles are already lower than the envisioned future emission levels of diesel vehicles. This means that there may be vehicles that can be labelled as EULES without substantial further technology improvements. Hence, the EULES label needs to be balanced so that it incentivizes as low as possible real-world emission levels, while maintaining technology neutrality.

The ancillary measures formulated in subsection 2.4 are to be considered by the EC if they will be applied as standalone measures or in combination. The implementation of one or several of these ancillary measures at the discretion of the regulator should allow the EC to modulate the stringency of EULES. Moreover, measures such as these represent an agile way of ‘patching up’ possible shortcomings of RDE, as they are identified throughout the useful life of the regulation, and to ensure that EULES is future proof. An alternative pathway for EULES future proofing would be a periodical revision of conformity factors, but this would likely be met with more resistance from industrial stakeholders.

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In the following paragraphs, we discuss the implications of EULES to other regulatory components currently in place in Europe.

2.5.1 Implications to other regulatory components

EULES is a voluntary emission standard and it needs to be made sure that it will be robust and coherent and build upon the existing regulatory framework. An emission standard package usually contains, further to emission limit values, detailed methodologies and limits regarding the durability of the vehicle, the OBD requirements, low temperature tests, etc. The implications of the previously described technical model on CO2 regulations, OBD, and durability requirements, as these have been agreed for the Euro 6 vehicles, are discussed below.

CO2 regulations

In the framework of RDE, CO2 emissions are recorded since they are needed for the data evaluation process, but it is not yet clear how these CO2 data may be accessed by other parties. In any case, the implementation of EULES should not be to the detriment of CO2 and should focus on conventional pollutants to avoid compatibility issues and political interference with CO2 regulations. A possible compromise to include CO2 in the framework of EULES would be to require that the complete CO2 emissions data of the RDE/EULES test (along with the other pollutants) be reported in full detail to a publically accessible website, but this would require additional data infrastructure investments from the side of the EC.

OBD

The focus of on-board diagnostics at Euro 6 step has been on introducing appropriate OBD threshold limits (OTLs) and the additional requirement for in-use performance ratio monitoring (IUPR). The thresholds are emission levels (expressed as equivalent values over the type approval test), an excess of which should illuminate the malfunction indicator lamp (MIL). In this way the driver is informed that the vehicle emission control is suboptimal and that a service check or maintenance is required. Preliminary (2014) and final (2017) Euro 6 OTLs are shown below.

Preliminary Euro 6 OTLs (2014):

NOx: 0.15 g/km for gasoline, 0.18 for diesel

PM: 0.025 g/km for gasoline and diesel

Final Euro 6 OTLs (2017):



IUPR indicates how often a specific monitor is operating relative to vehicle operation and is given by NumeratorM/DenominatorM, where NumeratorM measures number of times a monitoring function has run and a malfunction could have been detected and DenominatorM measures the number of vehicle driving events taking into account special conditions. In general, the IUPRs are virtual counters that check whether the on-board diagnosis occurs with a minimum acceptable frequency during the vehicle’s operation and guarantee that diagnosis actually occurs at a minimum rate when appropriate operational and environmental conditions are met. This is to eliminate too infrequent diagnosis that would result to too long times to identify excesses. Relaxed OTLs and IUPRs where enforced at a Euro 5 level that later became more stringent at the Euro 6 step. Preliminary (2014) and final (2017) Euro 6 IUPRs are shown below (indicatively, for NOx aftertreatment system and particulate filter).

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Preliminary Euro 6 IUPRs (2014):

NOx aftertreatment system: 0.336 for gasoline, 0.1 for diesel

Particulate filter: 0.336 for diesel (with additional monitoring requirement of total failure or removal)

Final Euro 6 IUPRs (2017):

NOx aftertreatment system: 0.336 g/km for gasoline, 0.26 for diesel

Particulate filter: 0.336 for diesel (with additional monitoring requirement of total failure or removal)

Durability requirements

The whole vehicle durability test represents an ageing test of 160,000 km driven on a test track, on the road, or on a chassis dynamometer. The manufacturer may choose to use a bench ageing durability test. As an alternative to durability testing, a manufacturer may choose to apply the assigned deterioration factors, as follows.

Assigned Euro 5/6 deterioration factors for gasoline:

CO: 1.5 , THC and NMHC: 1.3 , NOx: 1.6 , PM: 1.0

Assigned Euro 5 deterioration factors for diesel (Euro 6 to be determined):

CO: 1.5 , NOx and THC + NOx: 1.1 , PM/PN: 1.0

Available options for EULES regarding OBD and durability

The main options on how to address the issues related to the implications of EULES to other regulatory components are the following:

No changes compared to Euro 6: This option means that no change in the thresholds, durability tests and low temperature values is introduced for EULES in comparison to Euro 6. This option has the advantage of being simple and straightforward, but entails the risk that the vehicle performs very well until a certain mileage but then becomes similar to less clean vehicles because it only has to fulfil the same requirements. For example, if the deterioration factor approach remains for durability conformity, then a EULES car can be made clean for the first kilometres but then fast degrade. Similarly, with OBD threshold limits remaining at the same level, OBD will not be activated until emissions reach the level of a malfunctioning non EULES car.

More stringent limits (e.g. in proportion to the level of EULES limit): This option may lead to cleaner vehicles throughout their lifetime. However, defining new thresholds for OBD or changing the durability requirements entail both technical and legal risks on how to identify and enforce these new limits. In addition, this may also entail long discussions with manufacturers that could delay the process of bringing in EULES.

An intermediate approach: An intermediate approach may require using already established testing procedures but with some slight twists to achieve more stringent lifetime control. With regard to durability, it may be requested that a vehicle with a relatively aged emission control system (e.g. equivalent mileage of 80,000 km) is tested over RDE and should comply with the CF, so that durability concerns are partly covered. Similarly, for OBD, NOx thresholds might be proportionally reduced, assuming that most malfunctions will have a proportional impact to NOx emissions. However, PM and other thresholds could remain on the same levels as Euro 6.

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2.6 Summary and input for recommendations

General

The technical model for EULES is proposed as a voluntary extension that builds upon the RDE regulation, and it is composed of three modules:

Framework of the model: It comprises the technical underpinnings of EULES scheme, which is essentially conceived as a voluntary extension of the provisions of the RDE regulation, which are modified for increased stringency. EULES focuses on real-world emission improvements and brings improved technology neutrality in relation to the baseline Euro 6 standard.

Conformity factors (CFs): A collection of proposed on-road NOx conformity factors for RDE/EULES tests. These are lower (i.e., more stringent) than the conformity factors proposed in the second package of the RDE regulation. These conformity factors are meant to reflect low, yet achievable with current technology, emission levels in real driving conditions.

Ancillary proposals: A collection of measures to reinforce the application of the RDE regulation with an additional layer of voluntary EULES provisions. These proposals are devised as simple modifications to the current RDE provisions and they are expected to increase the stringency or improve the coverage of RDE tests, while imposing a small additional testing or data processing burden on stakeholders. The main idea is to turn optional provisions of RDE into mandatory EULES provisions and/or enforce the more stringent application of RDE provisions when these are open to interpretation.

Voluntary nature of the standard and support to incentive programmes

The voluntary nature of the standard means that stringency levels should be adjusted in such a way that EULES compliance requires a significant additional effort from the side of the manufacturer (i.e., only the best performers should be qualified as EULES cars), although the required effort will inevitably differ across manufacturers. Still, EULES should be an attractive proposition to stakeholders, including manufacturers, importers, and technical services. From the side of EC, this can be achieved by minimizing the additional administrative, testing, and data evaluation burdens, and by maximizing the synergies with existing regulations. EULES is also conceived as a harmonised way to support local and regional incentive programmes.

Appropriate conformity factor for NOx emissions from EULES cars

The main reason to link EULES to RDE relates to the existence of a “real-world” gap for the pollutant emissions of passenger cars. In other words, there is a substantial difference between the emissions recorded at type-approval and the actual, on-road emissions. The issue of on-road NOx emissions from diesel cars, which have only dropped slightly from Euro 3 to Euro 6, remains the key problem for the Euro 6 standard. The key research question is how close to the laboratory-based values can on-road emissions levels be expected to stay assuming a reasonable coverage of real-world driving situations.

The initial determination of CFs for EULES established a value of 1.0 (i.e., Euro 6 compliance for the on-road RDE test) as an appropriate value on the basis of the evaluation of a database of PEMS trips from Euro 6 diesel cars. However, the availability of new information regarding the real-world NOx control strategies employed by some diesel car manufacturers in general, and the question of defeat devices in particular supports a downward adjustment of the

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conformity factor. A conformity factor in the range of 0.5-0.7 is proposed, since this value is in line with the technical feasibility study performed within the scope of the project (see section 7).

Ancillary proposals

Ancillary proposals are measures to reinforce the application of the RDE regulation with an additional layer of voluntary EULES provisions. These proposals increase the stringency of the application of RDE regulations, either by turning optional provisions of RDE into mandatory EULES provisions or by enforcing the more stringent application of RDE provisions when these are open to interpretation. They also minimize the additional testing / data processing burden, and at the same time maximize the compatibility with existing RDE provisions and other vehicle emission regulations currently in force. The ancillary proposals also improve the coverage issues that were excluded from the first package of RDE, or insufficiently addressed. A summary of these proposals is provided in Table 11.

Table 11: Summary of ancillary EULES proposals regarding RDE measurements

Proposed ancillary measure Formulation

A1.1: Conformity for both data evaluation methods

The exhaust emission conformity factors calculated by means of both data evaluation methods indicated in Appendix 5 and Appendix 6 shall not exceed limits proposed by EULES.

A1.2: Conformity of ‘raw’ emission factors (no data evaluation method applied)


A2: Rapid inclusion of cold-start emissions


A3: RDE test performed without a data link to the ECU of the vehicle under test


A4: Separate evaluation of urban NO2 emissions


Implications to other regulatory components

An emission standard package usually contains, further to emission limit values, detailed methodologies and limits regarding the durability of the emission control system, the OBD technical approach and threshold values, and low temperature limits, to name the most important ones. The available options on how to address these issues in relation to EULES are summarized in the following:

No changes compared to Euro 6: This option means that no change in the thresholds, durability tests and low temperature values is introduced for EULES in comparison to Euro 6. This option has the advantage of being simple and straightforward, but entails

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the risk that the vehicle performs very well until a certain mileage but then becomes similar to less clean vehicles because it only has to fulfil the same requirements. For example, if the deterioration factor approach remains for durability conformity, then a EULES car can be made clean for the first kilometres but then fast degrade. Similarly, with OBD threshold limits remaining at the same level, OBD will not be activated until emissions reach the level of a malfunctioning non EULES car.



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3 Legal approach

In this section the legal approach of EULES is presented19. This approach concerns various aspects that should be carefully designed for a successful implementation (regulatory, responsibilities, legal tool and distinction, etc). These aspects are presented in Figure 10 and shortly outlined below; a more detailed presentation is provided in the subsequent paragraphs.

Integration into the type approval process – RDE/PEMS testing implications: The current EU vehicle type approval process is presented and the aspects that will be affected by the introduction of the Euro 6c RDE package, as well as the additional aspects that will be affected by EULES, are clearly illustrated.

Testing and data handling responsibilities: Regarding the collection and use of data, responsibilities within the Commission and between the Commission and Member States, as well as other stakeholders, are clarified. In general, the entities involved are:

o European Commission (EC)

o Type Approval Authorities (TAA)

o Technical Services (TS)

o Original Equipment Manufacturers (OEM)

Placement on the market: This involves the legal instrument to be used (e.g. regulation, directive, other), the legal distinction of compliant vehicles (e.g. label, logo, etc.), and the incentive programmes that can be used for a successful promotion.

Figure 10: Aspects related to EULES legal approach

19 The legal approach presented here is based on preliminary recommendations and discussion made in

the 1st Interim Report of the project (Papadimitriou et al., 2015a), as well as on recent developments on RDE and recent EU proposal to change the vehicle type approval framework (27.1.2016, COM (2016) 31 final, http://ec.europa.eu/growth/sectors/automotive/technical-harmonisation/eu/).

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3.1 Background information on type approval for passenger cars

There are two systems of type approval for passenger cars in Europe20:

i. The first one is based around EC Directives and provides for the approval of whole vehicles, vehicle systems, and separate components.

ii. The second one is based around United Nations (UN) Regulations (formerly known as UNECE Regulations) and provides for approval of vehicle systems and separate components, but not whole vehicles.

Type approval is the confirmation that production samples of a design meet specified performance standards. The specification of the product is recorded and only that specification is approved. Automotive EC Directives and UN Regulations require third party approval – testing, certification and production conformity assessment by an independent body. Each Member State is required to appoint an Approval Authority to issue the approvals and a Technical Service to carry out the testing according to the Directives and Regulations. An approval issued by one Authority is accepted in all the Member States.

In general, there are different potential routes (options) for approval of vehicles, and each one of them has its own advantages and disadvantages21. For example, the EU Whole Vehicle Type Approval (EU-WVTA) is based around EC Directives and provides for the approval of whole vehicles, in addition to vehicle systems and separate components. This certification is accepted throughout the EU without the need for further testing until a standard is updated or the design changes. On the other hand, for low volume/small series manufacturers, full EU-WVTA may not be appropriate; hence, there are a number of other approval routes available, including the Small Series Type Approval (SSTA) or other national schemes with technical and administrative requirements that are more adapted to smaller businesses.

3.1.1 Legislation

Type approval of passenger cars is based around the ‘whole vehicle’ framework Directive 2007/46/EC22 (as amended)23 and this specifies the range of aspects of the vehicle that must be approved to separate technical Directives. The regulatory framework for Euro 5 and Euro 6 light duty vehicles was introduced with the Regulation (EC) No 715/200724. A comprehensive overview with all intermediate stages in the Euro 5 and Euro 6 regulations for light duty vehicles can be found in Ntziachristos and Galassi (2014). Corresponding UNECE regulation for light duty vehicles also exists25; for example, in Regulation No. 83 there are uniform provisions concerning the approval of vehicles (M1 and N1) with regard to the emission of pollutants according to engine fuel requirements.

20 http://www.dft.gov.uk/vca/vehicletype/type-approval-for-ca.asp 21 http://www.transportoffice.gov.uk/crt/repository/CONT077317.pdf 22 Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007 establishing

a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles (Framework Directive).

23 http://ec.europa.eu/growth/sectors/automotive/legislation/motor-vehicles-trailers/directive-2007-46-ec/index_en.htm

24 Regulation (EC) No 715/2007 of the European Parliament and of the Council of 20 June 2007 on type approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information.

25 http://www.unece.org/trans/main/welcwp29.html

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3.1.2 The type approval framework

Emission standard packages and associated framework for type approval are comprehensive pieces of regulation that contain, further to emission limit values, detailed methodologies and limits regarding the durability of vehicle, the OBD requirements, low temperature tests, etc. Figure 11 shows all stages of the type approval framework for passenger cars (Transport and Environment, 2014). These are shortly outlined below and further discussed in more detail in the following paragraphs, with emphasis on EULES integration.

Initial type approval: Regulated pollutant emissions have to meet the applicable limit values. Current NEDC testing cycle to be replaced by WLTP with additional RDE/PEMS vehicle testing.

Conformity of production: Ensures that all products of a type are in compliance with type approval specifications.

Durability requirements: Ensures that emission control devices last at least a predefined number of kilometres through an ageing test or using deterioration factors.

In-service conformity: Ensures that the final products are compliant while they are in use during their normal life.

OBD requirements: The driver is informed that the vehicle emission control is suboptimal and that a service check or maintenance is required.

Figure 11: Overall type approval framework

3.1.3 Types of testing

Emissions are currently tested over the NEDC26 chassis dynamometer procedure (four repetitions of the ECE-15 urban driving cycle - UDC, followed by one extra urban driving cycle - EUDC segment). The emissions are sampled during the cycle according to the constant volume sampling (CVS) technique, analysed, and expressed in g/km for each of the pollutants.

The (revised) urban driving cycle (ECE-15) represents Type I test, as defined by the original ECE-15 emissions procedure. Type II test is a warmed-up idle tailpipe CO test conducted immediately after the fourth cycle of the Type I test. Type III test is a two-mode (idle and 50 km/h) chassis dynamometer procedure for crankcase emission determination. All types of testing for type approval of passenger cars in EU are summarized in Table 12.

26 http://dieselnet.com/standards/cycles/ece_eudc.php

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Table 12: Types of testing for type approval of passenger cars in Europe27

Type

of test Description Requirements and comments

Type I

Tailpipe emissions

after a cold start

(Euro 6 limits)

NOx: 0.06 g/km for gasoline, 0.08 g/km for diesel

PM: 0.0045 g/km for GDIs and diesel

Type II CO emission test at

idling speed Determination of reference value for I/M and CoP

Type III Emissions of

crankcase gases Standard: zero emission

Type IV Evaporative

emissions

A revision of the relevant European legislation is currently underway

(Gary Haq et al., 2013), aiming at improving the control of

evaporative emissions in real world driving conditions. Such an

update is already requested by EC Regulation No 715/2007 and EC

Communication 2008/C 182/0828 (Papadimitriou et al., 2015b).

Type V Durability of anti-

pollution devices

160,000 km

Assigned Euro 5/6 deterioration factors for gasoline:

CO: 1.5 , THC and NMHC: 1.3 , NOx: 1.6 , PM: 1.0

Assigned Euro 5 deterioration factors for diesel (Euro 6 t.b.d.):

CO: 1.5 , NOx and THC + NOx: 1.1 , PM/PN: 1.0

Type VI Low temperature test

(-7oC)

For diesel, demonstration at type approval of:

Performance of NOx aftertreatment device reaching sufficiently high temperature for efficient operation within 400 s after a cold start (-7oC).

Operation strategy of EGR including functioning at low temperature.

Potential introduction of NOx limitation (gasoline and diesel) with Euro 6c (t.b.c.).

A reduction of HC and CO limits with Euro 6c (t.b.c.).

In-service conformity Up to 100,000 km or 5 years

OBD

Identifies malfunctions and deterioration that cause emissions to exceed thresholds, with driver notification upon detection.

Preliminary Euro 6 OTLs (2014):



Final Euro 6 OTLs (2017):



27 Main source of Table 12 data: http://delphi.com/docs/default-source/catalogs/delphi-worldwide-

emissions-standards-pc-ldv-15-16.pdf?sfvrsn=2 28 EC Communication 2008/C 182/08: Communication on the application and future development of

Community legislation concerning vehicle emissions from light-duty vehicles and access to repair and maintenance information (Euro 5 and 6).

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3.1.4 Flowchart of the current EU vehicle type approval process

Figure 12 shows a simplified flowchart of the current EU vehicle type approval process, focusing on the NEDC chassis dynamometer procedure for Type I emission testing (but other types of testing are also presumed in the flowchart). This figure is based on more detailed diagrams that can be found in type approval authorities’ brochures, guides, and other informative packages29.

Figure 12: Simplified flowchart of current EU vehicle type approval process

The main stages of the above process are discussed below30:

29 http://www.dft.gov.uk/vca/additional/files/vehicle-type-approval/related-information/type-approval-

brochure.pdf 30 http://www.dft.gov.uk/vca/additional/files/vehicle-type-approval/vehicle-type-approval/vca004.pdf

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Initial discussions and documents submission: OEM applies to TAA in writing for the work to be done to set the process in motion. Once the application is received, administrative details are designated and OEM submits any technical documentation which is necessary. These documents are used as the basis for the final documents submission in a successful type approval (attached to the approval certificate). OEM also contacts the TS facility or laboratory where the testing will take place.

Definition of vehicle ‘type’ and ‘representative’ vehicle testing: In order to reduce the amount of testing needed, vehicles are grouped to ‘types’, i.e., ranges of vehicles which share a set of fundamental characteristics (described in Directive 2007/46/EC, as amended). A vehicle ‘representative’ of the type to be approved is tested under the NEDC chassis dynamometer procedure (type I and other types of testing). The emissions are sampled during the cycle according to the constant volume sampling (CVS) technique, analysed, and expressed in g/km for each pollutant. The test is carried out by OEM in collaboration with TS and witnessed by TAA.

Test results checking: If emissions are within Euro 6 limits, then the process continues; otherwise, the vehicle must be re-inspected.

Final documents submission: For a successful type approval, further good quality final information documents may need to be supplied by OEM for attachment to the approval certificate. These are based on the initial documents that have been submitted, with appropriate changes wherever necessary.

Conformity of production: CoP is part of the approval process and involves the evaluation of manufacturing processes to ensure that each vehicle is manufactured in accordance with the approved specification. Conformity of production requirements are based around established quality systems principles and it may be necessary for TAA to visit the production facility, hence, it is important to involve the authority at an early stage. The CoP process can run alongside the testing process, in order to avoid delays, and is usually triggered by the application letter to TAA.

Type approval successful – report and certificate issued by TAA: Once all the technical documentation and test reports are complete, and conformity of production clearance has been given, the approval package is completed by TAA issuing an approval certificate. Type approval authorities in other countries are notified of the approval that has been issued. Fees, which have been previously agreed upon, are also paid by OEM at this stage.

3.1.5 Recent development: proposal for changes in type approval framework

In January 2016 the EC released a legislative proposal that will bring a number of changes to the EU vehicle type approval framework31,32. The proposal aims to strengthen the EU oversight over the emission type approval and in-use compliance system.

Under current rules, while the EU sets the legal framework, national authorities are solely and fully responsible for vehicle emission certification and the enforcement of emission regulations. The responsibility to remedy wrongdoings lies with the Member State in which the type approval has been granted – neither other Member States nor the Commission can initiate a recall.

31 https://dieselnet.com/news/2016/01ec.php 32 http://europa.eu/rapid/press-release_IP-16-167_en.htm

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The proposal will make vehicle testing more independent and increase surveillance of cars already in circulation, with a strengthened European oversight. It will also complement efforts to introduce more robust emissions testing (RDE).

The proposal for a Regulation will help to achieve three objectives:

Reinforce the independence and quality of type approval testing: Modification of the remuneration system to avoid financial links between technical services and car manufacturers, which could lead to conflicts of interest and compromise the independence of testing.

Effective market surveillance to control the conformity of cars already in circulation: While the current rules deal mainly with ex-ante controls, in the future Member States and the EC will carry out spot-checks on vehicles already on the market. Safeguard measures against non-compliant vehicles, regular review of the functioning of market surveillance activities and publicly available results.

Reinforce the type approval system with greater European oversight: The EC will have the power to suspend, restrict or withdraw the designation of technical services that are underperforming and too lax in applying the rules. Ex-post verification testing, recalls and financial penalties on manufacturers in case of noncompliance.

Under the proposal, the manufacturer will have to provide access to the car’s software protocols. This measure, which complements the RDE package, includes an obligation for manufacturers to disclose their emissions reduction strategy, as is the case in the US.

In the next step, the draft Regulation will be sent to the European Parliament and Council for adoption. Once adopted, it will repeal and replace Directive 2007/46/EC.

3.2 Introduction of RDE and EULES integration

3.2.1 WLTP+RDE in replacement of NEDC

From Sept. 2017, a new test cycle known as Euro 6c WLTP33 (Worldwide harmonized Light duty vehicle Test Procedure) will be introduced in replacement of NEDC. Additional RDE (Real-world Driving Emissions) monitoring using PEMS (Portable Emission Measurement System) will complement the WLTP test cycle. An overview (roadmap) of latest and near future standards and driving cycles for emission testing of passenger cars in Europe is shown in Figure 13.

Figure 13: Standards and driving cycles for emission testing of passenger cars in Europe

33 https://www.dieselnet.com/standards/cycles/wltp.php

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WLTP test cycle aims to be more representative of real driving conditions; a comparison of the main characteristics between WLTP and NEDC is summarized in Table 13. The new RDE test procedure is an additional on-road test for passenger cars using PEMS. Its aim is to check compliance with regulations under real driving conditions on the road and it is scheduled for introduction in Sept. 2017. The RDE test will have a binding impact on the type approvals issued by the national type approval authorities34.

Table 13: Comparison of WLTP vs. NEDC

Parameter NEDC WLTP

Length (s) 1,180 1,800

Length (km) 11.023 23.26

Idle time (%) 33 13

Vmax (km/h) 120 131.6

Vaverage (km/h) 31.6 46.3

Accelmax (m/sec2) 1 1.6

3.2.2 EULES and RDE/PEMS testing implications

Figure 14 presents a flowchart of the various steps of the RDE test procedure using PEMS and integration of the voluntary EULES scheme. This figure is based on:

Recent developments on RDE legislation35.

The work performed in other parts of this study, especially:

o Technical model (section 2).

o Emission experimental results (section 7).

A more detailed explanation of the various components of this figure is given next.

34 http://europa.eu/rapid/press-release_IP-15-5945_en.htm 35

http://ec.europa.eu/transparency/regcomitology/index.cfm?do=search.dossierdetail&hdi47H/nymYsbNlXdPttFe3eAOQQ+7kPEZ/3yRiu4PgxdbQ+AI/X9VTTMRqv00VG

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Figure 14: Flowchart of the RDE test procedure using PEMS and integration of EULES

RDE test procedure

PEMS test family building and validation: Due to their particular characteristics, PEMS tests are not to be performed for each ‘vehicle emission type’, but several types may be put together by the vehicle manufacturer to form a ‘PEMS test family’. Such a vehicle family is a group of vehicles that differs in certain essential emission characteristics to previously approved types. The definition of family allows for a reduction in the number of

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tests carried out. An existing PEMS test family may be extended by adding new vehicle emission types to it, and this may in particular require the PEMS testing of additional vehicles to validate the extended PEMS test family. OEM is responsible to provide a full description of the PEMS test family with all the technical criteria that are necessary to describe it, and submit this description to TAA.

Representative (plus additional) vehicles for PEMS testing: OEM selects a representative vehicle of the PEMS test family and presents it to the TAA. The vehicle will be tested with PEMS in collaboration with TS to demonstrate compliance with RDE requirements. Additional vehicles for PEMS testing are selected by the authority responsible for issuing the emission type approval to ensure that technical characteristics relevant for pollutant emissions are covered by a PEMS test. With agreement of the TAA, a PEMS test can also be driven by a different operator witnessed by TS, which remains responsible for the proper execution of all PEMS tests.

The testing procedure and the PEMS unit itself should both comply with the RDE legislation. Of particular importance are the determination of boundary conditions36 (vehicle payload and test mass, ambient and dynamic conditions, vehicle condition and operation) and the determination of trip and operational requirements (share of urban/rural/motorway driving, trip duration, etc).

Raw data evaluation, error and quality checking, data processing and normalization: After the test is completed, the recorded PEMS data (raw) are evaluated and processed in order to be used for further emission calculations. If the TAA is not satisfied with the error and quality checking of the data, then the test may be considered as void. This step also includes verification of the normality of dynamic conditions and the windowing data analysis concept used by the EMROAD and CLEAR evaluation methods.

RDE test results checking: For a successful RDE compliance, the emissions determined in accordance to the requirements of the RDE test should not be higher than the following not-to-exceed (NTE) values:

NTEpollutant = CFpollutant x EURO 6,

where EURO 6 is the applicable Euro 6 emission limit and CFpollutant is the conformity factor for the respective pollutant. If this condition is satisfied, i.e. RDE testpollutant < NTEpollutant, then the technical report prepared by OEM and all test data, documents, etc. are collected by the TAA in order to issue the RDE certificate of compliance. For transparency reasons, all this information should be made publicly available.

Integration of the voluntary EULES scheme

Levels (options) of the scheme: The main idea is to propose EULES as a list of available levels (different options that can be implemented) with increased stringency and not as a single solution. This is expected to assist in better evaluation of the advantages and disadvantages of every option and selection of the most appropriate one. There are three available options proposed:

i. More stringent CF (no additional testing): This builds upon the RDE test process as described above and, without additional testing requirements, more stringent CF is used in order to ensure even lower on-road emissions. The selection of the CF is

based on the technical model (section 2) and the emission experimental results

36 Boundary conditions allow for distinguishing between a valid and an invalid test. They are divided

between dynamic boundary conditions related to the drive (such as the load) and ambient boundary conditions (altitude, temperature and humidity).

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(section 7). This option has the advantage of being simple and straightforward, since it is based entirely on the established RDE procedure and the only difference is on the CF used. Hence, there are no changes on the trip requirements and testing conditions and no further processing of the RDE test data is necessary. However, it entails the risk that the vehicle performs very well until a certain mileage, but then becomes similar to less clean vehicles because it only has to fulfil the same requirements.

ii. Same as level (i) + Ancillary measures: This level of the EULES scheme presumes the adoption of some of the ancillary measures proposed in the technical model. These measures are a collection of proposals to reinforce the application of RDE with an additional layer of voluntary provisions. The latter are devised as simple modifications to the current RDE provisions and are expected to increase the stringency or improve the coverage of RDE tests, while imposing a small additional

testing or data processing burden on stakeholders (more details in section 2). The implementation of one or several of these ancillary measures at the discretion of the regulator should allow the EC to modulate the stringency of EULES. Moreover, measures such as these represent an agile way of ‘patching up’ possible shortcomings of RDE and ensure that EULES is future proof.

iii. Same as level (ii) + Other regulatory components: This is the level of EULES that deals with the implications of the voluntary scheme with other regulatory components (see subsections 2.5.1, 3.1.2, and 3.1.3). It ensures robustness and coherence with the whole regulatory framework and, further to lower emissions during RDE test, it contains more stringent methodologies and limits regarding other regulatory components (e.g. durability, OBD, etc). The advantage of this option is that it may lead to cleaner vehicles throughout their lifetime. However, defining for example new thresholds for OBD or changing the durability requirements entail both technical and legal risks, as well as risk for long discussions with manufacturers that could delay the process of bringing in the voluntary EULES scheme.

Checking of conditions in level (x): Depending on the level which is adopted, all conditions related to it should be satisfied in order to have a EULES compliant vehicle. For example, in level (iii) these conditions are:

o RDE testpollutant < more stringent CFpollutant x EURO 6.

o Implementation of some of the ancillary measures.

o More stringent methodologies and limits in other regulatory components (e.g. durability, OBD, etc).

If all the above conditions are satisfied then the vehicle is EULES compliant and has all the advantages and benefits related to this voluntary scheme, i.e., it contributes to better air quality, has higher resale value, access and cost benefits, etc.

3.2.3 Testing and data handling responsibilities

Figure 15 summarizes the responsibilities of the different entities involved in the type approval process of passenger cars focusing on the RDE/PEMS testing procedure and EULES integration. This summary figure is based on the previous discussion and aims to clarify issues related to testing responsibilities, collection and use of data, error and quality checking, data processing, reporting, etc. It also takes into account the recent EU proposal to change the type

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approval framework, see subsection 3.1.5 and COM (2016) 31 final37, 27.1.2016. As discussed earlier, one of the main objectives of this proposal is to reinforce the type approval system with greater European oversight; this is depicted in the figure with the uppermost label entitled “EC: Establishment of a European Authority with oversight of National TAAs and TSs”.

The various responsibilities/actions in Figure 15 are organized per entity involved (EC, TAA, TS, and OEM) and are placed in an indicative timeframe. The green boxes contain the responsibilities that are of most relevance to EULES. These are:

The level (option) of the EULES scheme that will be adopted (to be decided by EC).

Checking if the conditions in EULES level (x) are satisfied (responsibility of TS and TAA).

Issuing of the EULES certificate (responsibility of TAA).

Figure 15: Responsibilities of the entities involved in the RDE test procedure using PEMS and integration of EULES

3.3 Placement on the market

For a successful placement on the market of a EULES compliant vehicle, a number of issues need to be addressed. These involve the legal instrument to be used (e.g. regulation, directive,

37 http://ec.europa.eu/growth/sectors/automotive/technical-harmonisation/eu/

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other), the legal distinction of the compliant vehicles (e.g. label, logo, etc.), and the incentive programmes that can be used for the promotion of the scheme.

3.3.1 Legal instrument

EULES is a voluntary scheme and it is essential to coexist harmonically with the mandatory standards already in place. Hence, it needs to be consistent with existing regulations and not overrule or replace the existing standards. The legal tools that are proposed as most appropriate for EULES are the following (list of options38,39):

Regulation: It is a binding legislative act that must be applied in its entirety across the EU. Member States have no choice in implementation (direct applicability, automatically becomes law in each country on the date specified).

Directive: It is a legislative act that sets out a goal that all EU countries must achieve. However, it is up to the individual countries to decide how (not directly applicable, implementation requires Member States to incorporate directive into national law). It can be considered as an obligation or order given to the Member States to do something.

Communication (COM): It is a preparatory act document. It can be a proposal or other act adopted in the framework of a legislative procedure, a communication, recommendation, report, white paper, or green paper.

Table 14 summarizes the main differences of the above tools.

Table 14: Legal instruments that can be used for EULES

General applicability Direct applicability

Regulation General applicability throughout EU

Direct applicability (no choice in implementation)

Directive Usually addressed to all MS Not directly applicable (requires MS implementation within a deadline)

Communication Not a binding strategy Guidance document, high level of flexibility

The final choice of the legal tool depends on whether EULES will be introduced as an independent standard or just as an enhancement of the Euro 6 (+RDE) standard. This is closely related to the level of the EULES scheme that will be finally adopted (see subsection 3.2.2). Specifically:

Level (i) involves the application of more stringent CFs and nothing more (compared to Euro 6 + RDE). Hence, a Communication (COM) document might even suffice in this case. The technical services and the type approval authorities are informed of the reduced CF levels entailed by EULES and, at the request of the manufacturer, they specify the particular model as “Euro 6 / EULES”.

38 http://europa.eu/eu-law/decision-making/legal-acts/index_en.htm 39 http://eur-lex.europa.eu/content/tools/TableOfSectors/types_of_documents_in_eurlex.html

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Level (ii) implies the adoption of some of the ancillary measures proposed in the technical model (in addition to the more stringent CFs of level (i)). This will require a new Regulation, as already the EULES standard will require extensions over the RDE one.

Level (iii) includes many changes not only on the RDE provisions (ancillary measures), but also on other regulatory components (e.g. durability, OBD, etc). In this case, the legal instrument should be a Regulation in order to successfully address all implications of the voluntary scheme with the existing regulatory framework.

A summary table with all available options presented in an organized manner is provided in subsection 3.4. This table shows all the advantages and disadvantages of each option, as well as issues like technical complications, possible difficulties in implementation, risk for delays, etc.

3.3.2 Legal distinction

The legal distinction of EULES concerns issues like label/logo usage, interaction with other initiatives, etc. Hence, it is closely related to the assessment of likely public response (section 4) and the role of public authorities (section 5).

Regarding the usage of label, logo, etc., some relevant car labelling schemes and indicative examples of ‘eco-friendly’ labels are given in ‘Annex I: Relevant car labelling schemes and ‘eco-friendly’ labels’. However, the assessment of the likely public response concluded that European consumers are not too acquainted with car labels. Many people admit to be “unfamiliar with” existing car labels and do not consider them as “easily recognizable”; moreover, they do not always trust the information displayed. In any case, the element of car labels that mostly attracts the attention of candidate buyers is the message. Specifically, when it comes down to one car purchase decision, consumers are less interested in knowing about clean air, convenient parking, or access fees; they are more likely to buy if – other things equal – they know that the car has lower taxes and lower maintenance costs.

As a conclusion, displaying logos (EULES, CO2, or a combination of the two) has only a small positive effect for the consumers. On the other hand, for the public authorities, labels and logos (e.g. sticker or other visible mark) might be beneficial for communication reasons if the vehicles are intended to be showcased or highlighted. However, given the diversity of physical labels (stickers, vignettes) between countries and differences in enforcement (physical sticker or number plate reading), it appears doubtful that an additional EU-wide label still comes in time.

3.3.3 Incentives and benefits

The incentives that can be used for the promotion of the voluntary EULES scheme are summarized below.

Financial incentives

o direct subsidies to buyers at the time of purchase

o taxation benefits (e.g. lowered annual road tax)

o preferential terms for financing/loans/insurance

o toll pricing reductions

Preferential access, e.g. in

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o designated low emission zones

o bus / high occupancy vehicle lanes

o lanes along congested streets

Other benefits

o parking places with low fees

o specific services and/or rates for EULES cars

In general, the advantages of EULES that should be highlighted in any incentive programme that may be used are the following:

It is expected to guide environmentally conscious customers towards the purchase of vehicles with ‘clean’ real-world emission profiles (low real-world driving emissions).

It will provide a benchmark for local or national authorities when developing financial or access and demand policies to promote clean transportation.

It will provide an incentive for manufacturers to produce vehicles that deliver significant emission reductions on the road.

It will accelerate the development of RDE by pushing the boundaries of currently available technology.

Overall, having EULES in place can be a powerful tool to accelerate clean transportation in Europe, until zero emission vehicles become widespread in long term.


General

The legal approach of EULES concerns various aspects that should be carefully designed for a successful implementation of the voluntary scheme. These are:

Integration into the type approval process.

RDE/PEMS testing implications.

Testing and data handling responsibilities.

Placement on the market (legal instrument, legal distinction, etc.).

Background on type approval for passenger cars

Emission standard packages and associated framework for type approval are comprehensive pieces of regulation that contain, further to emission limit values, detailed methodologies and limits regarding the durability of vehicle, the OBD requirements, low temperature tests, etc.

Emissions are currently tested over the NEDC chassis dynamometer procedure (type I and other types of testing). From Sept. 2017, a new test cycle known as WLTP will be introduced in replacement of NEDC, aiming to be more representative of real driving conditions. The additional RDE on-road test procedure using PEMS will complement the WLTP test cycle and its aim is to check compliance with regulations under real driving conditions on the road.

A recent development (Jan.’16) is that the EC released a legislative proposal that will bring a number of changes to the type approval framework. The proposal aims to strengthen the EU oversight over the emission type approval and in-use compliance system. It will also make vehicle testing more independent and increase surveillance of cars already in circulation.

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Integration of EULES

The main idea is to propose EULES as a list of available levels (different options that can be implemented) with increased stringency and not as a single solution. This is expected to assist in better evaluation of the advantages and disadvantages of every option and selection of the most appropriate one. The three EULES levels are:

i. More stringent CF (no additional testing): This builds upon the RDE test process and, without additional testing requirements, more stringent CF is used to ensure even lower

on-road emissions. The selection of the CF is based on the technical model (section 2)

and experimental results (section 7). This option has the advantage of being simple and straightforward, since it is based on the established RDE process; the only difference is on the CF. Hence, there are no changes on the trip requirements and testing conditions and no further processing of the RDE test data is necessary. However, it entails the risk that the vehicle performs very well until a certain mileage, but then becomes similar to less clean vehicles because it only has to fulfil the same requirements.

ii. Same as level (i) + Ancillary measures: This level of EULES presumes the adoption of some of the ancillary measures proposed in the technical model. These measures are a collection of proposals to reinforce the application of RDE with an additional layer of voluntary provisions. The latter are devised as simple modifications to the current RDE provisions and are expected to increase the stringency or improve the coverage of RDE tests, while imposing a small additional testing or data processing burden on stakeholders. The implementation of some of these ancillary measures at the discretion of the regulator should allow the EC to modulate the stringency of EULES. Moreover, measures such as these represent an agile way of ‘patching up’ possible shortcomings of RDE and ensure that EULES is future proof.

iii. Same as level (ii) + Other regulatory components: This is the level of EULES that deals with the implications of the voluntary scheme with other regulatory components (e.g. durability, OBD, etc., see subsection 2.5.1). It ensures robustness and coherence with the whole regulatory framework and, further to lower emissions during RDE test, it contains more stringent methodologies and limits regarding other regulatory components. The advantage of this option is that it may lead to cleaner vehicles throughout their lifetime. However, defining new thresholds for OBD or changing the durability requirements entail both technical and legal risks, as well as risk for long discussions with manufacturers that could delay the process of bringing in EULES.

Testing and data handling responsibilities

The responsibilities of the different entities involved in the TA process and EULES integration are summarized as follows:

EC will decide and legislate upon EULES level (option) to be adopted.

TS and TAA will be responsible for checking if conditions of EULES level (x) are satisfied.

TAA will be responsible for issuing the EULES certificate.

The whole process will be reinforced with greater European oversight, according to the recent EU proposal to change the type approval framework, COM (2016) 31 final, 27.1.2016.

Placement on the market (legal instrument, legal distinction, incentives and benefits)

For a successful placement on the market of a EULES compliant vehicle, a number of issues need to be addressed. These involve the legal instrument to be used, the legal distinction of the compliant vehicles, and the incentive programmes for the promotion of the scheme.

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Legal instrument: EULES is a voluntary scheme and it is essential to coexist harmonically with the mandatory standards already in place. Hence, it needs to be consistent with existing regulations and not overrule or replace the existing standards. The legal tools that are proposed as most appropriate for EULES are: Regulation, Directive, or even a Communication (COM) document.

The final choice of the legal tool depends on whether EULES will be introduced as an independent standard or just as an enhancement of the Euro 6 (+RDE) standard. This is closely related to the level of the EULES scheme that will be finally adopted. Specifically:




Legal distinction: The legal distinction of EULES concerns issues like label/logo usage, interaction with other initiatives, etc. Hence, it is closely related to the assessment of likely public response (section 4) and the role of public authorities (section 5).

Regarding the usage of label, the assessment of likely public response concluded that European consumers are not too acquainted with car labels. Many people admit to be “unfamiliar with” existing car labels and do not consider them as “easily recognizable”; moreover, they do not always trust the information displayed. In any case, the element of car labels that mostly attracts the attention of candidate buyers is the message. Specifically, when it comes down to one car purchase decision, consumers are less interested in knowing about clean air, convenient parking, or access fees; they are more likely to buy if – other things equal – they know that the car has lower taxes and lower maintenance costs.


Incentives and benefits: The incentives that can be used for the promotion of the voluntary EULES scheme are summarized below.




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Summary table

A summary table with all options presented in an organized manner is provided below. It shows the advantages and disadvantages of each proposed EULES level (option), as well as issues like legal and technical complications, possible difficulties in implementation, risk for delays, etc.





Ancillary measures



Main

characteristics



additional testing


is required.






layer of voluntary

provisions.







Legal

instrument

Possibly even by

communication (COM)


Advantages


No changes in RDE.








Disadvantages






Responsibilities

of the involved

entities




Legal

distinction





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Incentives and

benefits




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4 Assessment of likely public response to EULES

4.1 Background

In Europe, road transportation has been identified as one of the largest sources of CO2 emissions, as well as air pollutants like particulate matter (PM) and nitrogen oxides (NOx) (EEA, 2015). The GHG emissions have significant impact on the environment and, consecutively, on human health. Furthermore, exposure to air pollutants like PM and NOx has been identified as a significant risk factor for a number of health conditions including respiratory infections, heart disease, stroke and lung cancer (WHO, 2014). According to the 2014 WHO report, air pollution in 2012 caused the deaths of around 7 million people worldwide. In Europe, air pollution was estimated to be responsible for more than 430,000 premature deaths in 2014 (EEA, 2015). Furthermore, some 40 million people in the 115 largest cities in the EU were exposed to air exceeding WHO air quality guideline values for at least one pollutant in 2013 (WHO, 2014).

For CO2 emissions of new passenger cars, regulations are proving effective, with the 2015 target of 130 g/km already being achieved in 2013 (EC, 2015). Manufacturers also appear well placed to meet the 2020 to 2021 target of 95 g/km that was established by new legislation approved in February 2014 (EC, 2015). By contrast, the prevalence of air pollutants still raises concerns, particularly for the nitrogen dioxide (NO2) annual limit value. The main cause of high NO2 and particulate concentration in urban areas is linked to the ever-increasing share of diesel vehicles in European cities.

From a consumer perspective, the messages related to GHG emissions seemed to be confusing. On one hand, consumers were told that there is a need to decrease the CO2 emissions; on the other, they were incentivised to purchase air-polluting diesel cars because of discriminatory fuel tax policies favouring diesel as a fuel in most European countries. Furthermore, consumers were informed about the CO2 emission levels via labels but the information about the air pollutants was not available at the point of sale.

In order to help consumers purchase less polluting vehicles, the European Commission is considering a voluntary emission standard, called EULES (European Union Low Emitting carS). The standard could be presented to consumers either in a form of a label, a message, or both. In this study, our research goal was to identify the elements, which would nudge consumers towards an environmentally- and health-friendly EULES car. Our findings should support the European Commission’s decision-making process with respect to the EULES format that should have the greatest impact on consumer purchasing decisions. In addition, we also assessed the likely consumers’ preference between the CO2 label and the EULES label.

4.2 Scope of research

4.2.1 Objectives and approach

The aim of this task was to assess the likely public response to a voluntary EULES standard or label. In addition, the provisional label tested in this study may also provide a basis for the design of a future EULES label, along with the three types of messages that were incorporated into the experimental design.

The following objectives have been established to guide the study:

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By taking into account the literature review, piloting activities, and consultations with the EC, the designs of both the experiment and the survey were slightly modified from the original proposal to better address the above objectives. In this context, the following elements became clear:

A car may have low CO2 emissions but high NOx emissions or vice versa and this may have a confounding effect on consumers, under a scenario of having one single label for both CO2 and NOx. Whereas, CO2 labelling exists already and is present not only in the transportation sector but also widely applied on other products, the EULES label would have to be implemented in parallel (or on top) of the CO2 label.

On the one hand, a brief survey conducted in a small focus group at the beginning of the project revealed that we cannot take for granted that an average European consumer would be fully aware of both CO2 (targeted by the CO2 label) and air pollutants (targeted by the EULES standard).

On the other hand, we found that some respondents thought that all it mattered, including for the air quality in cities, were the CO2 emissions. In other words, people failed to recognise that there was a difference between what matters for the climate change globally (i.e., CO2 emissions) and what brought acute health effects due to the conventional air pollutants, such as NOx (targeted by EULES).

Regarding objective 2, we concluded, in consultation with the EC, to repeal it from this study because there was no specific interest in developing distinct sets of visual stimuli in addition to the EULES label and messages40.

4.2.2 Research methods

Most of the above objectives were tested via two research methods, i.e., an online survey and an online experiment. In general, experiments are powerful instruments to recover causal parameters but are less flexible than surveys and have very stringent randomisation and statistical power requirements that prevent from testing too many conditions. Therefore, these two methods should be perceived as complementary to address the objectives of the study.

40 It is worth mentioning that the study was conducted before the VW case.

Objectives of the assessment of likely public response to EULES

Objective 1. The study shall test and assess the elements of the EULES label (i.e., logo and messages) that would nudge the potential consumer towards an environmentally friendly EULES car.

Objective 2. The study shall further test and assess what kinds of promotional material and visual stimuli would be needed to promote the purchase of EULES cars.

Objective 3. The study shall shed some light on consumers’ expectations towards the EULES car with regard to its look (i.e., the ‘Prius’ look vis-à-vis a more standard car), share the bodywork and looks of the other cars within this model and only differ by powertrain and by emission control components.

Objective 4. The study shall also test and assess if the creation of a physical label for EULES cars would be an advantage and if so, if this label should be combined, or not, with other existing labels (e.g., СO2 label).

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Figure 16 illustrates an overview of the research design. The survey, rather than the experiment, flexibly enabled us to explore and understand attitudes towards low pollutant cars, thereby testing objectives 2 and 3. We retrieved only stated preferences and attitudes via the survey. By contrast, the main advantage of an experiment over a survey is that it allows for eliciting the purchasing process, which is close to the real decisions, when purchasing a car. All four objectives were tested and assessed in the experiment.

Figure 16: Overview of the research design

4.2.2.1 Survey

We decided to explore the level of understanding and the attitude towards EULES related issues with the help of a survey. Furthermore, the psychological, socioeconomic, and personal characteristics of consumers were analysed in relation to their aforementioned understanding and attitudes. Such exploration was only possible via a standard survey and could not be conducted as part of the below-described experiments. The survey was specifically aimed at testing and assessing mainly objectives 1 and 3. We were particularly interested in assessing consumers’ environmental consciousness of air quality and vehicle emissions, attention paid towards fiscal and running costs of a vehicle, as well as urban access and parking facilities in the context of EULES. In the survey, we did not present any particular labels because this was done in the experiments.

In general, the survey encompassed questions on: i) socio-demographic profile, ii) car purchase experience and preferences, iii) general attitudes and values with regard to environmental issues. It was structured as follows:

Block A: Self-reported purchase process. It investigated self-reported steps and factors that consumers take into account in the car purchasing process (class and model; dynamics of purchase process; main attributes considered; information sources).

8 countries N = 6,400

Survey (N= 3,200; 400/country)

To identify general attitudes towards low-polluting cars

Experiment 1: Small cars (N= 1,600; 200/country)

To assess impact of selected car attributes during a purchase decision

Experiment 2: Large cars (N= 1,600; 200/country)

To assess impact of selected car attributes during a purchase decision

Random allocation

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Block B: Contextual factors. It addressed environmental attitudes through consolidated scales, respondents’ faith in the eco-behaviours of others and in the effectiveness of their behaviours as consumers, perceived compromise (i.e., between choosing eco-friendly and performance, air quality). It helped us assess the general attitudes and values with regard to the environmental and health issues.

Block C: Environmental and health impact awareness of car usage. It helped us explore the extent to which consumers were aware of the environmental and health impacts of car usage, and notably its impact on air pollution.

Block D: Awareness, trust, and effect of labels. It helped us evaluate to what extent consumers were aware of and trusted the car labels.

Block E: Socio-demographic profile. It covered standard socio-demographic variables such as sex and age but also questions on possession of a car and its usage.

The questionnaire is fully described in ‘Annex II: Supporting information for section 4 “Assessment of likely public response to EULES”’.

4.2.2.2 Experiment

The experimental design enabled us attaining all objectives of this task. There were two separate experiments: for a small car and a large car. For each of them, subjects were recruited into two samples. In other words, those who participated in the first experiment on the small car did not participate in the second experiment on the large car, and vice versa. By presenting two possible car options we attained objectives 3 and 4.

In each experiment, subjects were asked to choose a preferable option among two identical cars with four different attributes of two car models (i.e., price, EULES label, EULES message, and CO2 label). In order to keep the experimental design within a manageable dimension, we excluded the running costs because this would represent an additional attribute to be tested. By including both, the EULES label and the three types of EULES messages, we addressed objectives 1 and 2.

Both experiments were conducted online, meaning that we did not control for the environment, in which subjects underwent the experimental choices. However, such settings should reflect better to the real purchasing decisions. In a way, one could imagine that a typical consumer usually chooses its vehicle on the basis of a number of attributes at home or during some breaks at work, by browsing the Internet. Subsequently, he (she) visits a car dealer to obtain further details.

The decisions that the participants took in our experiment were simple. They were asked to choose a preferable car among two, on the basis of its attributes. Figure 17 and Figure 18 below illustrate the choice sets for each car type. In Figure 17, the participants had to choose between the small car that should have the EULES label and the CO2 label vis-à-vis an equivalent car that should have no labels. In Figure 18 the subjects chose between a large car with the EULES label and without it; in both cases, the CO2 label was present. In addition, the EULES messages and the prices were different in both choice sets.

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Figure 17: Choice set 2 for a small car

Figure 18: Choice set 1 for a large car

When choosing between several cars, consumers should consider a broad range of attributes prior to a final purchase. Most of them tend to focus on price that is very ‘salient’, whereas other attributes get ‘shrouded’ as they are important but not salient. In this experiment, we conjectured that the price should be the most important attribute but we did not know whether, for example, the EULES label would be more important than the CO2 label for an average consumer.

For this purpose, we applied an experimental design based on the discrete choice models. Discrete choice models statistically relate the choice made by each person to the attributes of the person and the attributes of the alternatives available to the person. For example, the choice of which car a person buys is statistically related to the EULES format and CO2 label as well as

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to price, and other attributes of each available car. The models estimate the probability that a person chooses a particular alternative and provide a response to a question whether one format of presentation is better than another.

The small and large cars differed in terms of prices and the level of CO2 emissions. For the small car, subjects had to pay either 10,000 or 10,700 EUR. For the large car, subjects had a choice between two price levels: 25,000 or 26,200 EUR. The rationale behind this approach lied in the estimated additional cost of introducing the EULES standard (in a range of 700 and 1,200 EUR) that would most likely be passed on consumers. However, it should be noted that this experimental design was not aimed at assessing consumers’ willingness to pay for the EULES standard. In other words, we were not be able to say whether consumers would be willing to pay 700 Euros rather than 1,200 Euros for example, but we looked at price differences separately for a small and a large car.

In addition, the small car was associated with a lower level of CO2 emissions (i.e., in the category B-C) and the large car was associated with a higher level of CO2 emissions (i.e., in the category D). In the experimental design, the label either was present or absent, depending on the choice set. This setting was meant to help us assess the label importance when making the hypothetical car purchases.

In terms of the EULES label, we proposed a few possible options, out of which the EC chose one (i.e., a light-green leaf with a dark-green car). The experimental subjects did not receive any explanation about the meaning of the EULES label and that was supposed to represent the voluntary EU standard. With this approach, we wanted to avoid any experimental biases and priming issues.

Nevertheless, it should be noted that the interviews conducted with the public authorities (see section 5) suggested that the authorities did not have a strong intention to develop a EULES-specific label. Therefore, we also presented proposals for possible messages that could be used instead of or along with the EULES label. In this regard, we identified three main implications of EULES-friendly cars (including health effects, city accessibility, and financial impacts) into three very simple messages to the participants (see Table 16). In the experiments, the messages appeared along with a provisional EULES label, CO2 label, or independently.

Table 16: Messages used in the experiment

About access About health About taxes

Access to low emission zones

Cleaner air in cities Lower taxes

Preferential parking in low emission zones

Protects health Lower annual cost

The above attributes were combined into ten choice sets. Each choice set was presented to the subjects in the order presented in Table 17 and Table 18; the order of choices was not randomised. The rationale behind this was that through the different choices made by the experimental subjects, we were able to single out the attributes that mattered the most in their choice.

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Table 17: Choice sets for small car

Choice Set Price EULES Message EULES Logo CO2 Logo

1 10,000 Message 1 Absent Absent

1 10,700 Message 3 Present Absent

2 10,700 Message 2 Present Present




4 10,000 Message 2 Absent Present














Table 18: Choice sets for large car

Choice Set Price EULES Message EULES Logo CO2 Logo





















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4.2.2.3 Sampling

A random sample of 6,400 individuals was drawn from 8 countries (Germany, Ireland, Italy, the Netherlands, Spain, UK, Czech Republic, Lithuania) and was used to produce two outputs: a full survey (3,200 respondents, 400 per each of the 8 countries) and two online experiments (3,200 subjects, 400 per each of the 8 countries, making 200 subjects for each experiment and country). The randomization was ensured at the country level, meaning that each country was equally represented in the survey (400) and in the experiments (200).

Gathering the data across countries made it possible to ensure the validity and possibility to generalise about awareness, understanding, and attitudes regarding the EULES standard as well as about the relation between EULES and CO2 emissions. The characteristic of the sample used in the survey and in the online experiment is shown in Table 19.

Table 19: Technical specifications of samples for the online survey and experiment

Population General population, aged 18 to 65 years old

Scope

8 EU Member States:

Germany

Ireland

Italy

Netherlands

Spain

UK

Czech Republic

Lithuania

Methodology On-line (quantitative survey) and two on-line experiments

Sample size n=6,400 (n=800 consumers per country); n=3,200 for survey and n=3,200 for experiment

Quotas Country

Gender

Age group

Sampling error

+1.12% for overall data and +3.54% for country-specific data. In all cases, a maximum indeterminate probability (p=q=50), for a confidence level of 95.5% is applicable for each one of the reference populations.

Weighting Weighting by country to be able to interpret the overall data.

Sampling Random with quotas.

The following tables show the sample by age (Table 20), country and gender (Table 21), and education (Table 22).

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Table 20: Target sample by country and age group for survey

Country Age

Total 18 - 24 25 - 54 55 - 65

Germany 47 252 101 400

Ireland 54 282 64 400

Italy 56 273 71 400

Netherland 51 233 116 400

Spain 49 286 65 400

UK 54 244 102 400

Czech Republic 52 263 85 400

Lithuania 72 263 65 400

Total 435 2,096 669 3,200

Table 21: Target sample by country and gender group for survey

Country Gender

Total Female Male

Germany 195 205 400

Ireland 205 195 400

Italy 188 212 400

Netherland 197 203 400

Spain 196 204 400

UK 200 200 400

Czech Republic 196 204 400

Lithuania 212 188 400

Total 1,589 1,611 3,200

Table 22: Target sample by country and education group for survey

Country

What is the highest level of education you have completed (in years)?

0-11 12 (high school

diploma)

Some years of university (not

completed)

University degree

completed

Post-graduate (master, PhD,

other)

Total

Germany

Ireland

Italy

Netherland

Spain

UK

Czech Republic

Lithuania

107 169 27 85 12 400

17 113 103 117 50 400

20 154 78 76 72 400

20 209 59 68 44 400

12 104 69 174 41 400

14 139 68 134 45 400

18 228 47 97 10 400

7 59 64 175 95 400

Total 215 1,175 515 926 369 3,200

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Table 23 shows the study sampling errors (overall and by quotas). They are calculated for a probability no greater than 95.5% and for the least desired context, i.e. a maximum indeterminate probability (p = q = 50%) for the reference population.

Table 23: Sampling errors by country

Country 16-24 25-54 55-65 H M TOTAL

Czech Republic

± 13.87 ± 6.17 ± 10.85 ± 7.00 ± 7.14 ± 5.00

Germany ± 14.59 ± 6.30 ± 9.95 ± 6.98 ± 7.16 ± 5.00

Ireland ± 13.61 ± 5.95 ± 12.50 ± 7.16 ± 6.98 ± 5.00

Spain ± 14.29 ± 5.91 ± 12.40 ± 7.00 ± 7.14 ± 5.00

Italy ± 13.36 ± 6.05 ± 11.87 ± 6.87 ± 7.29 ± 5.00

Lithuania ± 11.79 ± 6.17 ± 12.40 ± 7.29 ± 6.87 ± 5.00

Netherlands ± 14.00 ± 6.55 ± 9.28 ± 7.02 ± 7.12 ± 5.00

UK ± 13.61 ± 6.40 ± 9.90 ± 7.07 ± 7.07 ± 5.00

Total ± 4.79 ± 2.18 ± 3.87 ± 2.49 ± 2.5 ± 1.77

As each country's total population is different, but is sampled in equal measure, weighting was applied to ensure a representative sample for interpretation of the overall data, i.e. for all the selected countries. Table 24 shows the weighting to be applied by country.

Table 24: Weighting factors by country

Country ISCED 0-2

Germany (DE) 2.4340

Spain (ES) 1.9896

Italy (IT) 1.3075

Ireland (IE) 0.1218

Netherlands (NL) 0.5391

Czech Republic (CZ) 0.3052

Lithuania (LT) 0.0737

United Kingdom (UK) 1.9896

4.2.3 Fieldwork process

The car’s survey fieldwork process period ran from 26th February to 24th March 2015. Three consecutive launches were established from the outset:

The first launch took place in the UK (24.2.2015), which was the country in which the pilot study was conducted.

Secondly, and after having included some minor changes, the full launch went ahead in the UK on 26.2.2015.

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Finally, after the translation of the questionnaire in the other languages, a joint launch took place in the remaining countries between 3.3.2015 and 24.3.2015.

Table 25 shows the data collection schedule for the different countries.

Table 25: Data collection schedule

Country Sample Completion Launch time Completion

Germany (DE) 800 100% 2.3.2015 18.3.2015

Spain (ES) 800 100% 3.3.2015 19.3.2015

Italy (IT) 800 100% 2.3.2015 24.3.2015

Ireland (IE) 800 100% 3.3.2015 18.3.2015

Netherlands (NL) 800 100% 2.3.2015 24.3.2015

Czech Republic (CZ) 800 100% 2.3.2015 24.3.2015

Lithuania (LT) 800 100% 2.3.2015 22.3.2015

United Kingdom (UK) 800 100% 26.2.2015 18.3.2015

Total 6,400 100%

In ‘Annex II: Supporting information for section 4 “Assessment of likely public response to EULES”’ a detailed description can be found.

4.3 Results from the survey

4.3.1 Decision making: describing the purchase process

In order to gain an indication of the decision-making process behind car purchases, survey respondents were initially asked to report the size of their current car. The most popular car class appears by far to be the small-family car (such as Ford Focus, Volkswagen Golf, Citroën C4) owned by 39% of respondents. About 19% of subjects own at least one large-family car (such as Renault Laguna, Volkswagen Passat, or Ford Mondeo). Supermini cars – Peugeot 208, Volkswagen Polo, Renault Clio - come as a close third having been selected by 17% of respondents. Figure 19 shows a summary of responses.

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Figure 19: Type of car owned, by size Source: Q1 (N=3,200)

In terms of current and future car purchase decisions (Figure 20), it is worth noticing that whereas only few respondents reportedly own environmental-friendly cars, much more of them would buy one in the future. About 18% of the subjects reportedly plan to buy a hybrid car. Cars that run on alternative fuels (CNG and LPG) are targeted by around 14% of the subjects (as opposed to the 3% of current owners). About 11% plan to buy an electric car, currently owned by less than 1% of respondents. These findings are in line with the so-called “attitude-action gap”, that is, a common phenomenon in environmental studies (Kollmuss and Agyeman, 2002) that describes the difference between what individuals say and what they do. Results of this kind should be interpreted cautiously; therefore, to further investigate this gap, we have asked individuals about their present and future attitudes (shown below in this chapter).

Figure 20: Type of car, by engine Source: Q2 and Q4 (N=3,200)

11%

14%

18%

39%

48%

0%

3%

1%

38%

63%

Electric

Alternative fuel

Hybrid

Diesel

Gasoline

Owned Desired

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In terms of car usage, one out of two respondents (47%) reported that drives to work on a daily basis (Figure 21). Almost all subjects drive for shopping, although only 10% do so daily. About 18% drive their children to or back from school every day. Finally, most respondents use their car for weekend getaways (more than 90%) and holidays (more than 80%) at least once a year.

Figure 21: Car usage (%) Note: Respondents were asked to select how often they drive to do certain activities. Lighter colours

indicate more frequent drives. Numbers refer to the share of a ”Daily” response. Source: Q6 (N=3,200)

Individuals were then asked to identify what were the main attributes considered during the purchase decision (Figure 22). As the figure shows, a car’s environmental performance is considered as “very important” by less than one in five respondents (19%). Likewise, local air quality is a very important attribute for only 15% of respondents. On the other hand, about half of the subjects consider price (50%), road safety (47%) and fuel consumption (46%) followed by maintenance cost (40%) and type of engine (28%) as very important attributes. Therefore, after price and road consumption, attributes pertaining to the broadly defined “Fuel Economy” score fairly high in importance.

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Figure 22: Attributes considered in the car purchasing process Note: Respondents were asked to rate each attribute on a 1-7 importance scale. Lighter colours indicate

higher importance. Numbers refer to the percentages of a 7 score (“Very important”).Source: Q7 (N=3,200)

In addition to car’s attributes, individuals were asked to report about the process followed in choosing a car (Figure 23). Similarly, to the previous question, the importance of price and its range was confirmed by the respondents (24% and 39%, respectively). The matter of car’s size and engine were indicated as very important criteria (25% and 26%, respectively). While one third of respondents (32%) are aware that less polluting cars, ceteris paribus, lower the level of pollution, statements on environmental-friendly attitudes in car purchasing yield very low percentages of full agreement. Health consequences would convince only 12% of respondents to select a different class of car (e.g., from sport utility vehicle to midsize car). The environmental effects are also not particularly important when choosing the car’s class (12%). Finally, a mere 11% of the sample is ready to pay more to guarantee an environmental protection for a more environmentally friendly model.

To identify the relationship within these variables, a factor analysis was undertaken41. From the analysis three factors emerged: (1) emphasis on health and the environment (38.41% of variance explained); (2) emphasis on class (15.86% of variance explained); (3) emphasis on cost (8.18% of variance explained).

41 See ‘Annex II: Supporting information for section 4 “Assessment of likely public response to EULES”’,

Factor analysis: purchase process.

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Figure 23: Assessment of statements related to the car purchase process (%) Note: Respondents were asked to rate each attribute on a 1-7 importance scale. Lighter colours indicate


The combination of the responses related to the attribute and purchase process reveals that there is a low percentage of full agreement with statements affirming that environmental and health parameters are important, and quite a high percentage of full agreement with statements affirming that attributes such as price, type of engine, and class of car are already decided before selecting a car model. If this is the case and if consumers decide on type of engine and class of car before selecting a car model, then it seems unlikely that they will fully take into account health and environmental parameters.

To further investigate this gap, individuals were asked about their attitudes towards decision making process in terms of present and future consequences (Figure 24). To examine and

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summarise these broader attitudes a new factor analysis was performed42. From the analysis, two factors emerged: (1) emphasis on the present and costs (34.43% of variance explained); and (2) emphasis on the future and health and environmental (25.58% of variance explained).

Figure 24: Present and Future attitudes (%) Note: Respondents were asked to rate each attribute on a 1-7 importance scale. Lighter colours indicate



Factor analysis: present-future attitudes.

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In order to develop a typology of consumers’ understanding and attitudes towards health and environmental issues in the car purchase process, a Cluster Analysis of K-means was then carried out (Table 26). Cluster one consists of respondents that place a greater emphasis on a car’s price and maintenance cost whose behaviour is likely influenced by the immediate outcomes of their actions, place also more emphasis on the present, and are less likely to sacrifice their current well-being for future gains. This group is thus referred to as representing “Non-sensitive consumers” (57% of respondents). The label is used descriptively in order to capture the sense that, for these respondents, environmental and health issues are not much important. Cluster two is characterised by notably different features to the previous one. The second profile represents those consumers who place a notable emphasis on environmental and health issues – those who are likely to pay more for an environment-friendly car, for example. These respondents place also more emphasis on the future, and are more likely to engage in behaviours with long-term outcomes. Members of cluster two are labelled “Sensitive consumers” (43% of respondents).

Table 26: Profiles of car purchasers

Factor

Cluster

1. Non-sensitive 57%

(n=1,815)

2. Sensitive 43%

(n=1,385)

ANOVA

Emphasis on environmental and health issues - 0.22 0.29 201.52*

Emphasis on cost 0.41 - 0.54 699.54*

Emphasis on the present 0.51 - 0.67 1,106.73*

Emphasis on the future - 0.14 0.19 86.28*

Note: Results of K-means cluster analysis (N=3,200)

There are not statistically significant differences in terms of gender but the results reveal that “sensitive consumers” are more likely to be younger (see Figure 25), higher educated (see Figure 26) and with a slightly higher self-perceived socioeconomic status (see Figure 27) than “non sensitive consumers”.

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Figure 25: Profiles of car purchasers by group of age (%) Source: Cluster and AGE (N=3,200)

Figure 26: Profiles of car purchasers by education level (%) Source: Cluster and Q29 (N=3,200)

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Figure 27: Profiles of car purchasers by self-perceived socioeconomic status (%) Note: Respondents were asked about their status compared to “all other people” in their country on a 1-10

scale, where 1 equals “the worst off” and 10 “the best off”. Source: Cluster and Q33 (N=3,200)

Beyond the traditional socio economic variables, we have characterised these profiles in terms of the importance given to cars’ attributes (see Figure 28). As it could be expected “sensitive consumers” are slightly more oriented towards environmental performance and local air quality than “non-sensitive consumers”. On the contrary, price, maintenance cost and size are considered slightly less important by “sensitive consumers” than “non-sensitive consumers”. This characterisation could be interpreted as these consumers are in favour of paying a slightly highest price/cost for less polluting cars as they value positively the environmental and health consequences of the car selected. However, results also confirm the gap observed in literature between self-reported attitudes/intentions and actual behaviours, health environmental concerns come after many other attributes (price, safety, performance, etc.) in terms of importance in influencing car purchase decisions.

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Figure 28: Profiles of car purchasers by cars’ attributes importance (%) Note: *p<0.05. Source: Cluster and Q7 (N=3,200)

This is confirmed by the fact that “sensitive consumers” are slightly more likely to select their next car from those with alternative fuel or hybrid engines than “non-sensitive consumers” and are less likely to select gasoline engines (Figure 29).

Figure 29: Profiles of car purchasers by next car’s engine (%) Note: *p<0.05. Source: Cluster and Q4 (N=3,200)

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4.3.2 Perceptions and understanding of the health and environmental issues

Beyond the purchase process, individuals were asked about contextual factors (see Figure 30) and about their health attitudes and awareness (see Figure 32). In terms of contextual factors, it is worth mentioning that only 5% of respondents stated that “most people are willing to pay higher prices to protect the environment” and “most people do their parts to protect the environment”. This shows that the faith in the eco-friendly behaviour of others is fairly low, which may reduce the perceived effectiveness of one’s behaviour as consumer and induce ‘keeping up with the Joneses’ attitudes (if other do not care and free ride on the public good ‘environment’ then why should I behave differently?).

The data shows, however, that lack of faith in others does not prevent 61% of respondents from agreeing with the statement “my lifestyle can have an impact on the environment” and 43% from disagreeing with the statement “it’s hard for someone like me to do much about the environment”. So, despite lack of faith in others, respondents do not feel that this exempts them from their individual responsibility. These figures reinforce the ‘attitudes-action gap’, consumers are aware of the environmental impact of cars but this does not translate into their decision making process.

On the other hand, there is quite a widespread perception that less polluting or lower consumption vehicles are associated with higher prices and that to some extent they also compromise performance. So, we also find evidence of the fact that many consumers perceive buying eco-friendly car as entailing loss/sacrifice in terms of other parameters43. To some extent these results show a not complete understanding of the connection between CO2 emissions, fuel efficiency, performance and prices.

43 These results are totally aligned with previous research conducted in (Codagnone et al., 2013).

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Figure 30: Contextual factors (%) Note: Numbers refer to the percentages of a 7 score (“Very much like you”). Source: Q11 (N=3,200)

In this regard, the characterization of the two profiles previously identified reveals that “non-sensitive consumers” are less likely to assume any type of loss/sacrifice in terms of performance or cost as they put more responsibility to the others (“most people…”) than in themselves (“my lifestyle…”) in comparison with “sensitive consumers” (Figure 31).

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Figure 31: Profiles of car purchasers by contextual factors (%) Note: *p<0.05. Source: Cluster and Q11 (N=3,200)

Figure 32 shows the level of health awareness caused by car usage. More than half of the responders (68%) understand that high pollution emissions could make them sick and are concerned about negative future consequences to their health due to their daily choices (50%). Nevertheless, whereas general awareness about the environmental impact of car usage seems fairly high, 43% of the respondents were not afraid of getting sick because of the high levels of pollution. Moreover, when asked a question on information about level of pollution in their cities, just 8% of the respondents totally agree with feeling well informed.

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Figure 32: Health awareness (%) Note: Respondents were asked how much they agree with each of the statements using a 1-7 importance scale. Lighter colours indicate higher agreement. Numbers refer to the percentages of a 7 score (“Totally

agree”). Source: Q11 (N=3,200)

Again, the analysis of the profiles reveals slightly different patterns (see Figure 33). “Sensitive consumers” are generally more aware than “Non-sensitive consumers” about the health consequences of car’s usage, even though they stated that they are less well informed about the level of air pollution. This reveals that “just” information is not enough to nudge consumers.

Figure 33: Profiles of car purchasers by health awareness (%) Note: *p<0.05. Source: Cluster and Q11 (N=3,200)

0 1 2 3 4 5 6 7

I make a link between health and the environment. I understand that high pollution emissions could make

me sick*

I am concerned about negative future consequences to my health due to my daily choices*

I am afraid of getting seriously sick because of the high levels of pollution*

I feel very well informed about the level of air pollution in my city*

Sensitive Non-sensitive

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4.3.3 Incentives to influence the purchase process

In the survey, individuals were asked for their opinion on a number of policy-related issues, including incentives for the environment. As shown in Figure 34, around 30% of subjects believe that providing higher financial incentives (such as tax breaks and subsidies) for low-emitting products would be a very effective strategy to tackle air pollution. The option ranks second only to “applying stricter pollution controls on industrial and energy production activities”, for example by requiring the application of best available technology, selected by 38% of respondents.

Figure 34: Strategies to tackle air-related problems (%) Note: Respondents were asked how much they agree with each of the statements using a 1-7 importance scale. Lighter colours indicate higher agreement. Numbers refer to the percentages of a 7 score (“Totally

agree”). Source: Q17 (N=3,200)

Figure 35 shows to which extent respondents value several policies for low-emitting vehicles. No clear preference for either financial or non-financial incentives emerges. About 29% of the subjects equally consider as “very important” a number of policies as diverse as tax exemptions, schemes for scrapping old vehicles, and charging points for electric cars. On the other hand, cheaper parking options and tax exemptions for low-emitting cars seem to be less appealing (“very important” only by 16% and 15% respectively).

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Figure 35: Respondents who consider “very important” the following policies Note: LEV= Low-emission vehicle. EV= Electric vehicle. HV= Hybrid vehicle. Source: Q13 (N=3,200)

Figure 36 shows how respondents from different countries, on average, value the several policies for low-emitting vehicles. Southern or Mediterranean countries, such as Italy and Spain, show systematically higher values. Conversely, respondents from Netherlands tend to give a systematically lower score to incentives, including those for electric vehicles (EVs). This may be due to the already-abundant supply of these particular vehicles in the Netherlands, which make it Europe’s largest market and the third largest worldwide44.

44 “The Netherlands – 2015-Q4 & Full Year”, EV-Volumes: The Electric Vehicle World Sales Database.

Available at: http://www.ev-volumes.com/country/netherlands/

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Figure 36: Respondents’ reaction to incentives – Country average (1) Note: Respondents were asked how much they consider “important” the different incentives using a 1-7 importance scale. LEV= Low-emission vehicle. EV= Electric vehicle. HV= Hybrid vehicle. Source: Q13

(N=3,200)

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Responses to the eight measures proposed in Figure 35 were later grouped into the two broader categories of “Financial incentives”, which includes tax breaks and subsidies, and “Non-financial incentives”, such as access and parking options. As reported in Table 27, overall respondents tend to consider financial incentives as “more important” (mean = 5.24, using a 1-7 importance scale) than non-financial incentives (mean = 4.71).

Table 27 : Reaction to incentives – descriptive statistics

Source: Q13 (N=3,200)

The impression that access and parking options are not as attractive as tax breaks and subsidies seems to find further evidence with the data shown in Figure 37, in which subjects were asked to react to different non-financial incentives. When put against the scenario of a ban on high-emitting cars from being used during high pollution days, for example, more people stated that they would switch to public transport, bike, or foot (23% of respondents “totally agree”), rather than buy a low-emitting car (18%). Likewise, if low-emitting cars got “substantially cheaper parking places in the city centre”, more respondents would rather commute (18% of full agreement) than buy (14%). The only scenario where subjects would rather buy a low-emitting car, although by a small margin (20% “buy”, 19% “switch”) is the introduction of a low-emission zone in the city centre.

Figure 37: Respondents’ reaction to different incentives Source: Q10, Q20, Q23. (N=3,200)

These results might lead to the conclusion that non-financial incentives (low-emission zones, driving restrictions, cheap parking fees) are ultimately ineffective in moving consumers towards low-emitting cars. Respondents do not seem attracted by the opportunity of cheaper access fees which low-emitting car owners are entitled to. After all, access fees generally make up a

10%

13%

9%

19%

23%

18%20%

18%

14%

Low-emission zone Driving restriction Cheap parking

Stop (park outside) Switch (to public transport, bike, foot) Buy low-emitting car

Value Financial incentives

Non-financial incentives

Mean 5.24 4.71

Median 5.40 4.67

Standard deviation 1.31 1.49

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substantial share of a car’s total running costs. In all three scenarios above, owners of low-emitting cars would be the only ones exempted by the additional financial burden.

On the other hand, it could be that the attractiveness of non-financial incentives differs with the type of consumer. For example, cheaper parking fees are likely to be less attractive for the owners of a residential garage. Similarly, low-emission zones are likely to affect commuters more than city centre residents. In order to account for these differences, we have first recoded our responses according to the new proxy “commuters”. The variable is a dummy that equals 1 for respondents who drive to work on a daily basis, and zero otherwise. The number of respondents who commute daily amounts to nearly half of the total surveyed (47%).

We have then analyzed the reactions to non-financial incentives, this time accounting for

commuters and non-commuters separately (Figure 38). As expected, priorities have changed. Whereas non-commuters are still more likely to switch means of transport in all three scenarios, commuters would rather buy a low-emitting car in presence of low-emission zones (23%) or cheaper parking fees (18%). For commuters, buying (21%) is also almost as popular as switching to public transport (21%) in case of driving restrictions.

Figure 38: Respondents’ reaction to different incentives Source: Q6, Q10, Q20, Q23. (N=3,200)

10%

14%

9%

18%

21%

16%

23% 21%

18%


Commuters only

Stop (park outside) Switch (to public transport, bike, foot) Buy low-emitting car

10% 13%

9%

20%

25%

20%

16% 16%

10%


Non-commuters only

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4.3.4 Attitudes and perception towards labels

In the last part of the survey, respondents were presented with several questions on car labels. Existing car labels do not score particularly well if judged by the level of agreement/disagreement with the statements depicted in Figure 39. As much as 43% of the sample agree with the statement that they are unfamiliar with car labels and almost the same percentage of individuals agree (38%) and disagree (39%) with being familiar with car labels. These percentages of agreement (39%) and disagreement (37%) are similar when individuals were asked about car labels recognition.

Figure 39: Existing car labels awareness and perception Source: Q22 (N=3,200)

Even though the awareness about car labels is split, the percentage of individuals who do not trust the information in car labels (39% agree) is higher than the one for those who trust this information (33%). However, 38% of the sample agree with the statement that car labels are a symbol of a product's trustworthiness (27% disagree) and as much as 37% believe (agree) that information contained in car labels is truthful and 34% that the information is sufficient (32% disagree to both statements). When asked to react to the statement concerning how they use labels when they buy a car 35% of the respondents state (agree) that they base their decision upon a (or several) car labels (on the contrary, 29% disagree).

To disentangle the relationship between labels’ awareness (I’m familiar with car labels) and the rest of the variables, Figure 40 sketches the correlation values45. As it could be expected the


Car labels correlation matrix.

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level of awareness is highly correlated with a label’s recognition and on the contrary is not correlated with the lack of trust. Nevertheless, the correlation between awareness and support to decision-making, truthful and trustworthiness is lower than 0.5. This means than being familiar with labels is not sufficient for individuals.

Figure 40: Perceived utility of car labels Source: Q22 (N=3,200)

4.4 Results from the experiment

4.4.1 Assessing the impact of labels on consumers’ behaviour

In the online experiments, individuals were asked to choose a car between two options. Each option consisted in the picture of a car and a series of additional information. In the first experiment, the same picture of a small car was displayed in both options. In the second experiment, the same picture of a large car was displayed in both options. Additional information was provided as a random combination of the following four attributes:

the car’s price (either 10,000 EUR or 10,700 EUR for small cars, and either 25,000 EUR or 26,200 EUR for large cars);

a label on the car’s CO2 emissions (present/absent);

a hypothetical EULES label (present/absent);

a message on the car’s positive features (in terms of “Taxes”, or lower costs; “Access”, or better accessibility; “Health”, or health benefits).

The result of the statistical analysis for the two experiments is rather unambiguous. All four attributes considered have a significant impact in the participants’ choices. However, the single most important attribute in shaping their choices is the message, particularly the message on financial benefits (“Taxes” message). This is true for both small and large cars. The increase in price does not seem to matter much, although it does more in the scenario of large cars. The presence of logos, be it on EULES or on CO2 emissions, has a very small but significant effect - a finding that is consistent with the literature.

Furthermore, respondents who choose small cars do not think a 700 EUR price increase is important. Likewise, a 1,200 EUR price increase is not considered important by respondents

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of large cars. However small, the “price” effect is slightly more important for those picking between large cars. This comes with little surprise, given the 500 EUR difference between the two increases. Pricing is related to the estimated additional cost of introducing the EULES standard, which ranges from 700 EUR and 1,200 EUR and would most likely be passed on consumers.

The following tables display the output of the statistical analysis. The model used was a conditional logistic regression, also known as “discrete choice” model. For each of the four attributes, the tables show: coefficients, standard errors, and 95% confidence intervals. In discrete choice models, each coefficient is a “part-worth” estimate, or the utility associated with that attribute. In the analysis, the “Taxes” message was used as a reference point for the categorical variable “EULES_Message” and therefore does not appear in the output tables46.

Table 28: Parameter Estimates – Small cars

Term Coefficient Std Error Lower 95% Upper 95%

Price 0.00 0.00 0.00 0.00

EULES Message Access -0.65 0.01 -0.68 -0.62

EULES Message Health 0.12 0.01 0.09 0.15

Absence of EULES Logo -0.13 0.01 -0.15 -0.11

CO2 Logo [NO_CO2_L] -0.13 0.01 -0.15 -0.11

Table 29: Parameter Estimates – Large cars

Term Coefficient Std Error Lower 95% Upper 95%

Price 0.00 0.00 0.00 0.00

EULES_Message[Access] -0.51 0.01 -0.53 -0.48

EULES_Message[Health] 0.11 0.01 0.08 0.14

EULES_Logo[NO_EULES_L] -0.08 0.01 -0.10 -0.06

CO2_Logo[NO_CO2_L] -0.06 0.01 -0.08 -0.04

The relative importance of each attribute alone, and in combination with other factors, is shown in ‘Annex II: Supporting information for section 4 “Assessment of likely public response to EULES”’. Tables showing the likelihood ratio tests for the choice model, with subject effects of each label element and their statistical significance, are also displayed in this Annex.

The following figures help visualize comparisons among the various attributes, and show the variation in total probability for choosing a certain combination of attributes. More specifically, Figure 41 displays the “best combination” for small cars, that is, the one with the highest probability of being chosen (85%): lower price; message on taxes; EULES logo; CO2 logo. The

46 “Taxes” is used as a reference, its part-worth is a structural zero. “Access” yields a negative part-worth

compared to “Taxes”, while “Health” has a positive part-worth. By default, estimates are based on the Firth bias-corrected maximum likelihood estimators (MLEs) and therefore are considered to be more accurate than MLEs without bias correction.

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combination that gets the highest chances of being chosen (77%) is the same for larger cars, as shown in Figure 4247.

Figure 41: Probability profiler – Small cars

47 See also ‘Annex II: Supporting information for section 4 “Assessment of likely public response to

EULES”’, Online experiment marginal probabilities small cars and Online experiment marginal probabilities large cars.

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Figure 42: Probability profiler – Large cars


Perceptions and understanding of the health and environmental issues

Europeans are aware of the health and environmental impact of cars. The survey points to a general understanding of the adverse health effects of pollution. Our research showed that the respondents recognise that there is a link between the environmental protection and human health. They also think that the pollution in their cities or neighbourhoods is rather high. Two-thirds of the respondents (68%) fully agree that high pollution could make them sick. The survey also shows how respondents are aware of the environmental impact of polluting vehicles. More than half of respondents (54%) believe that “cars contribute significantly to the air pollution” in their city or neighbourhood.

Decision making: describing the purchase process

Despite the high environmental awareness, the main factor that subjects take into account when buying a car is price (50% of respondents), followed by road safety (48%) and fuel

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consumption (46%). Most importantly, only one in ten (11%) is ready to pay more for a more environmental-friendly car. These results also confirm the gap between self-reported attitudes/intentions and actual behaviours: health and environmental concerns come only after many other attributes (price, safety, performance, etc.) in terms of importance in influencing car purchase decisions.

In fact, many consumers perceive buying an eco-friendly car as entailing a loss/sacrifice in terms of performance. There is a quite widespread perception that less polluting or lower consumption vehicles are associated with higher prices and that, to some extent, also compromise performance. In this regard, citizens do not clearly understand the difference between air pollution and GHG emissions. Nearly half of the respondents (47%) agree with the statement “Vehicles that produce less pollution consume less fuel”.

Incentives to influence the purchase process

Financial incentives are the most likely to change consumers’ behaviour towards low emission cars. According to 30% of survey respondents, providing higher financial incentives for low emission products would be an effective strategy to tackle air pollution. Financial measures (tax breaks, subsidies) are more likely to nudge consumers towards low emission cars than are non-financial incentives. Among the latter, low emission zones seem more appealing, especially for those consumers who drive to work on a daily basis. Citizens are likely to prefer tax exemptions and subsidies rather than environmental taxes or road pricing. We draw this conclusion from the survey, in which respondents believe they are paying already too much of environmental taxes for their car and are not in favour of applying ‘road pricing’ (e.g., road tax, registration tax) for major metropolitan areas (e.g., cities with over 100,000 inhabitants and their suburbs). At the same time, they welcome proposals in which the government would provide either tax exemptions or subsidies for those purchasing a low-emitting car.

Impact of labels on consumers’ behaviour, attitudes and perception towards labels

European consumers are not too acquainted with car labels. More than 43% of respondents admit to be “unfamiliar with” existing car labels. Around 37% disagree with the statement that labels are “easily recognizable”. As many as 39% do not trust the information displayed, and reportedly the most common use of labels is “to check if what said in the advertisement is true”. Many even misunderstand their purpose: nearly 38% believes that labels symbolize a product’s reliability.

In any case, the element of car labels that most attracts the attention of candidate buyers is the message. To find that out, we ran a series of experiments in which individuals were asked to choose a car between two options. Each option consisted in a label depicting a car and a series of additional elements – logos, price tags, and a series of messages. As the results show, all attributes are significant, and they all contribute to the choice. However, the strongest utility is given by the messages.

Respondents are more likely to choose EULES-friendly cars when they the label shows information on lower costs or lower taxes. When it comes down to one car purchase decision, consumers are less interested in knowing about “Cleaner air in cities”, health-related benefits, convenient parking, or access fees. Other things equal, they are more likely to buy if they know that the car has lower taxes and lower maintenance costs. A minor increase in price has a negligible effect. Finally, combinations of one message with other elements -– EULES logo, CO2 logo, or both – within the same label have a small but positive effect.

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5 The role of public authorities – attitude and reactions

5.1 Background

The NO2 air quality limit is exceeded in many cities in Europe. Road traffic in general and diesel cars in particular are dominant sources of this pollution. That is due to a strongly increased share of diesel cars and them having unexpectedly high NOx/NO2 emissions in real-driving.

Lower NOx/NO2 unit emissions from diesel cars are expected with the introduction of the RDE testing procedure. To accelerate the introduction of vehicles with really low on-road NOx/NO2 emissions, the EC is considering creating a voluntary low emission standard. This is intended to guide consumers when purchasing a new vehicle and provide public authorities with an identifier for low-emitting cars. In the end, when complemented with suitable incentives, this might accelerate the uptake of low-emission vehicles in the market.

Yet, such a standard is unlikely to have an effect on the consumer unless there are material benefits attached to it. Public authorities could offer these benefits e.g. in terms of preferential access, special parking provisions, grants and subsidies, along with own procurement and information dissemination. The reaction of cities will be crucial if this measure shall have any impact. This part of the study elucidates the attitudes and potential reactions of local authorities with respect to the introduction of a EULES label.

5.2 Approach

We reviewed air quality and traffic management plans for a number of major cities across Europe. This literature research provided the background for the specific situation of each city in terms of air quality problems, its local causes, the measures already taken and planned. This was the starting point for the telephone interviews with city representatives of Antwerp, Berlin, London, Madrid, and Milan; despite repeated efforts the City of Paris has unfortunately never responded to our interview request.

The interviews revealed how diverse the situations, legal settings and preparedness are across cities sharing NO2 pollution. Both, diversity, as well as key features summarized below, were further confirmed when put to discussion and commented at a meeting with members of the POLIS working group on Environment & Health, 17 June 2015 in Brussels.

5.3 Discussion

5.3.1 On differentiated charges for parking

Travel demand management is one option for local authorities to influence traffic volume, routing and flow and thus resulting traffic emissions. Parking charges at the destination are known to have a significant influence on the very decision of using a private car for the envisaged trip. The following aspects are considered important.

5.3.1.1 Could authorities consider differentiating parking by emission performance of the cars? Under what conditions?

Hardly a city so far has differentiated parking charges by emission performance, apart from Madrid. Partly, that is because cities do not have legislative authority to levy emission related

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parking charges. Some limited examples of differentiation for private parking spaces (Manchester) as well as for resident’s (2nd car’s) parking permits (Rotterdam), based on emission performance.

5.3.1.2 Reservations or obstacles against a differentiation by emission performance?

See above on legislative incapacity. A widespread application might be difficult in cities with a high share of private parking places.

5.3.1.3 What features of EULES would therefore be important?

Depends on specific form of implementation, e.g. if through license plate reading or through physical label.

The fee scheme in Madrid, for example, depends on the exact Euro level and the streets occupancy level at the time (ratio of occupied to available parking spaces). It seems this detailed scheme is too complicated for the general public, hence not easy for communication.

Nonetheless, it was remarked, that schemes like this could be used for awareness rising towards the emission performance of the car.

5.3.1.4 What costs for implementation & enforcement envisaged?

In Madrid the required change to smart meters was due anyway – costs could not be specified.

5.3.2 On access charges differentiated by emission performance

Access charges if not access restrictions are another way to influence traffic volume and vehicle mix, and thus the resulting pollutant emissions. This has been established as “Low Emission Zones” in many cities or even entire regions across Europe. The question here is whether these schemes can accommodate a EULES designation?

5.3.2.1 Could authorities consider differentiating access by emission performance of the cars? Under what conditions?

Differentiation is standard in all areas that have introduced a low-emission zone. However, hardly any city is planning to exclude large parts of the active diesel fleet, for lack of public support. Also London’s ULEZ will allow uncharged access to ~77% of the passenger cars in 2020.

A EULES car could be treated the same way as a modern gasoline car in terms of access rights, as it is intended to have similarly low pollutant emissions.

However, in some areas, it is up to the region to define the access criteria, and not to the city.

5.3.2.2 Reservations or obstacles against a differentiation by emission performance?

Remark: Positive discrimination, here e.g. granting uncharged access to the inner city, is usually easier to communicate and to receive public acceptance than blaming drivers because of high pollutant emissions of their cars.

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Public support depends also on how fair the measure is perceived (socially balanced) and whether the people have alternative options and means. This might applied e.g. for disfavoured segments of the society who tend to have older cars yet not the means for buying latest (new) technology. (Nonetheless, they might still have sufficient means to buy slightly older gasoline cars, which could qualify also as EULES.)

Another example cited is tradesmen/SMEs, often driving older vans/commercial vehicles. They often claim economic problems to upgrade to the latest diesel vehicle technology, and they can form a vocal group against stringent low-emission criteria.

In general, when a measure is considered technically favourable this does not mean that it is equally favourable/favoured from a political point of view. Implementation often hinges on the political support and the determination of the city’s government.

5.3.2.3 What features of the EULES standard would therefore be important?

Depends on specific form of implementation: If implemented e.g. through license plate reading, then the registration data retrieved need to have a EULES entry. No physical label necessary in that case. If implemented through a physical label, then some sort of sticker is required.

A sticker (or other visible mark) at the vehicle might be beneficial for communication reasons if these vehicles are intended to be showcased or highlighted. This could also help e.g. businesses to demonstrate “green” taxis/logistics/delivery/performance, and thus be part of a wider outreach. Likewise, it can be made part of the usual business rules with the local authority.

5.3.2.4 What costs for implementation & enforcement envisaged?

Depends on the specific form. London’s enforcement is based on the camera system installed for the enforcement of the congestion charge area. Setting up a camera-based enforcement for the low emission zone alone would however be prohibitively costly.

On the other hand, controlling physical labels is person-intensive. Therefore anecdotal evidence suggests that enforcement might be poor.

5.3.3 Timing issues

Suppose, a EULES standard would be defined at EU level by 30 June 2016. How long would it take for you to implement the measure in city/region?

At the earliest within 2 years, for several cities possibly within 3 years, but implementation might take up to 5 years if all consultations need to be done from scratch. It will strongly depend on the political leadership.

5.3.4 Parallel national activities

Parallel to a potential EU wide designation there are several national, if not regional and local labelling activities, based in vehicle emission standards.

In Germany access to Low Emission Zones is based in the certification limit of the vehicle, which in turn is indicated through a coloured sticker at the front window. This scheme is going to be developed further to encompass Euro 6/VI emission limits.

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France is introducing a national label for cars with 1 Jan 2016. It is based on the emission certification and allows local authorities to implement access or parking restrictions and incentives.

Likewise, Spain is developing a national label for cars based on the emission certification. This allows local authorities to implement access or parking restrictions and incentives.

(Northern) Italian cities and regions have established congestion charge and low emission zones. The enforcement is linked to registration data accessed via number plate readings.

The Belgium region of Flanders has introduced a discrimination based on the emission certification level. So far, only the city of Antwerp will establish a low emission zone, identifying vehicles based on automated number plate reading.

Stakeholders expressed an interest in a EU-wide labelling scheme, in order to

harmonise criteria,

provide for a complete coverage of the fleet independent of the country of registration,

get inspiration, and

general support from a ‘higher level’.

However, given the diversity of physical labels (stickers, vignettes) between countries and differences in enforcement (physical sticker or number plate reading <-> registration database) it appears doubtful that an additional EU-wide label still comes in time.


EULES is recommended as a voluntary EU-wide low emission standard that coexists harmonically with the mandatory standards already in place. Hence, it needs to be introduced in parallel to (and be consistent with) the existing national, regional, and local initiatives for low emission vehicles (e.g. schemes already implemented in Germany, France, Spain, northern Italian cities, Belgium region of Flanders, and more). The advantages of an EU-wide scheme are: i) harmonisation of criteria, ii) coverage of all vehicles independent of the country of registration, and iii) support from a ‘higher’ (European) level.

Public authorities can assist in the successful introduction of EULES by providing incentives and benefits (e.g. grants and subsidies, preferential access, special parking provisions, etc.), along with own procurement and information dissemination. Especially the attitude and potential reaction of cities can be of particular importance. Air quality and traffic management plans already exist in a number of major cities across Europe, however presenting significant divergence in legal settings, enforcement, specific form of implementation, etc.

The main issues that need to be considered by public authorities are summarized below.

Legislative capacity of cities and local authorities to levy emission related parking and/or access charges, to restrict access in specific areas, and, in general, to provide incentives and benefits for EULES compliant vehicles.

Any scheme for incentives and benefits should not be complicated; otherwise it will not be easy for communication.

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Positive discrimination (e.g. granting uncharged access to the inner city for EULES cars) is usually easier to communicate and to receive public acceptance, rather than blaming drivers of high polluting cars.

Fairness and social balance are also important, together with the provision of alternative options and means for the people. For example, parts of the society who tend to have older cars may not have the means for buying latest (new) diesel technology. Nonetheless, they might still have sufficient means to buy slightly older gasoline cars, which could possibly be EULES compliant (this depends on the final decision about EULES level that will be adopted).

Enforcement parameters must be taken into account. For example, setting up a camera-based enforcement for a low emission zone alone can be prohibitively costly; controlling physical labels is person-intensive, etc.

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6 Costs and benefits for the consumer

The key question of this element of the study is: “Under what conditions is a EULES car economically beneficial to the customer?”

6.1 Objectives and approach

An objective comparison needs to be based on the full lifecycle costs to the consumer, which accounts for purchase and depreciation, running costs, taxes, insurance, etc. and finally the resale value of the car. We consider the following elements:

Table 30: Cost elements considered in the analysis

Cost element Conventional EULES

Purchase price X X

EULES premium - Manufacturer

Financing costs X X

Tax X Public

Insurance X Market

Fuel expenses X Manufacturer

Consumables like tyres, oil, liquids X X

EULES consumables, e.g. AdBlue - Manufacturer

Inspection & maintenance X Manufacturer

Charges like tolls or access charges, parking fees,…

X Public

Benefits/incentives/subsidies - Public

Resale value after 5 years X Market

Some of the cost elements are identical for both a conventional as well as a EULES car: For instance the base vehicle costs and costs for common consumables like tyres and engine oil are identical. Other elements depend on the manufacturer, for instance how the EULES exhaust controls are tuned, e.g. AdBlue dosage on the one hand, and the fuel consumption rate on the other hand in the case of SCR, and on their specific maintenance requirements. Third, the market will determine certain cost elements, notably the insurance rate and the resale value for the used car. Finally, there are cost elements that public authorities can directly influence, notably tax, parking and access charges, as well as possible exemptions and direct subsidies.

The costs under control of public authorities are particularly relevant for the policy recommendations of this task. The key question to be investigated is: “Under what conditions is the purchase and the operation of a EULES car economically beneficial to the customer?” All consumer surveys including ours have shown, that purchase price, fuel and maintenance costs are dominant factors for the purchase decision. Hence any financial benefit for a EULES will make it more attractive for the consumer.

6.2 Cost-benefit analysis

The one-time purchase costs and the resale value are discounted assuming a 5 years holding period of the vehicle. We assume a private discount rate of 10%. These annualised capital

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costs can then be made comparable to the other running expenses occurring during the course of a year.

We compare two cases spanning a range of typical use conditions:

A small car in the price range of 15 000 €, with moderate annual mileage of 12 000 km and (real-world) fuel consumption of 4.5 l per 100 km on average. As it is a smaller car we assume it will be equipped with a LNT that is calibrated for low (NOx) pollutant emissions. No purchase premium is assumed as no additional hardware is required.

A medium to large car in the price range of 30 000 €, with an elevated annual mileage of 25 000 km and (real-world) fuel consumption of 6 l per 100 km on average. As it is a larger car we assume it will be equipped with a SCR that is calibrated for low (NOx) pollutant emissions. Hence we need to account for additional AdBlue consumption as well as extra hardware costs as EULES purchase premium.

In the following we discuss the single cost elements one by one, then they will be considered all together, and the difference between a conventional and a EULES car will be discussed for both cases.

6.2.1 Single cost elements

Purchase price: Here indicative for a small and a medium to large car (similar to the reference cars in the online experiment) Is discounted over the holding period with 10%, reflecting the private perspective.

EULES premium: Assumed only for extra SCR equipment in the larger car due to tighter exhaust NOx emission control technology. Papadimitriou et al. (2015b) suggest manufacturer costs of 350 to 500 Euros for the SCR system. We allocate a high third of these costs to the extra performant SCR for a EULES car (remember, the medium to large conventional car is already equipped with a SCR).

Annual tax and insurance: Indicative only; absolute level irrelevant for the comparison as assumed equal for both cars.

Depreciation rate: Taken from literature in linearized form, higher for the more expensive larger car. Resale premium of 3% for either EULES car indicative to illustrate possible relevance for total cost comparison.

Table 31: Indicative purchase and holding costs for conventional and EULES cars (small / mid-large)

Small car Medium-large car Cost element years Conventional EULES Conventional EULES

Purchase price 5 15’000 € 15’000 € 30’000 € 30’000 €

EULES premium 0 € € 167

Tax 1 150 € 150 € 300 € 300 € Insurance 1 500 € 500 € 1000 € 1000 € Financing costs omitted as identical except for a potential EULES premium

Depreciation per yr 9% 9% 11% 11%

Resale value after 5 years 1 -8250 € -8250 € -13500 € -13500 € Resale premium 3% / -250 € 3% / -400 €

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Fuel expenses: They are based on assumed fuel economy, mileage and fuel costs.

Assumptions: A 2% fuel penalty for the small, LNT equipped car as purification of the trap increases consumption (Papadimitriou et al. 2015b). The SCR equipped EULES car has no fuel penalty based on the experimental evidence of this project (see section 7) but an addition consumption of 3% exhaust fluid (e.g. AdBlue). We allocate half of this penalty to the extra stringent NOx control. The annual vehicle mileage of 12 000 km and 30 000 km respectively reflects different use profiles for smaller and larger cars.

Table 32: Indicative fuel costs for conventional and EULES cars (small / mid-large)


spec. fuel consumption [l/100 km] real

4.5 4.5 6 6

EULES fuel economy benefit/penalty

-2% 0%

ann. mileage [km] 12000 12000 25000 25000

Fuel price [EUR/l] 1.25 € 1.25 € 1.25 € 1.25 €

Fuel expenses 1 675 € 689 € 1875 € 1875 €

Consumables: Indicative only; absolute level irrelevant for the comparison as assumed equal for conventional and EULES cars.

AdBlue consumption: 1.5% of fuel consumption in case of larger car with extra performant SCR technology.

Inspection & maintenance: Indicative only; absolute level irrelevant for the comparison as assumed equal for both cars. Papadimitriou et al. (2015b) estimate about 50 Euros for annual maintenance of an SCR system. We assume that one third of these costs can be attributed to the extra stringent performance of the EULES NOx controls.

Table 33: Indicative running costs for conventional and EULES cars (small / mid-large)


Consumables like tyres, oil, liquids

3 500 € 500 € 900 € 900 €

EULES AdBlue [% of fuel consumption]

not applicable 1.5%

AdBlue price [EUR/l] 0.6 €

1 0 € 13.50 €

Inspection & maintenance 1 165 € 165 € 300 € 300 € EULES consumables premium

1

0 € 17 €

Charges: A wide range of charges is currently applied for hourly parking (e.g. Vienna: € 2 – 8 per hour on public spaces or inner city parking garage) and access (Milan: € 2-5 per access residents / non-residents; London: € 14.50 / £11.50 per day). An average value of 5 € per day for both access and parking costs is assumed here. Such a low value favours conventional cars while a higher value favours EULES cars in case of privileges.

EULES privilege: A reduction of charges (parking/access fees) by 30% is assumed.

No EULES subsidy assumed.

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Table 34: Indicative parking and access costs for conventional and EULES cars (small / mid-large)


daily charge 5 € 5 € 5 € 5 €

days/week (low to high) 1-5 1-5 1-5 1-5Charges for tolls, access, parking,…@ 50 weeks

1 250 - 1250 € 250 - 1250 € 250 - 1250 € 250 - 1250 €

EULES privilege -30% -30%

= -75 to -375 € = -75 to -375 €

Annual costs are summed over five years and added to the purchase costs minus resale price; all cost elements are duly discounted over the 5 year holding period with a private discount rate of 10%. Total costs for the first car owner are summarised in Table 35 for both car variants.

Table 35: Summary of total costs over 5 years holding for conventional and EULES cars (small / mid-large)

Small car Medium-large car

Cost element Convent. EULES Conv. -EULES Convent. EULES

Conv. -EULES

Purchase+holding–resale € 19,483 € 19,210 € 272 € 41,965 € 41,788 € 177

Fuel+AdBlue costs € 3,713 € 3,787 -€ 74 € 10,313 € 10,387 -€ 74

Maintenance costs € 2,017 € 2,017 € 0 € 3,647 € 3,738 -€ 92

parking or access charges

1 day/week @ 5 € € 1,375 € 963 € 413 € 1,375 € 963 € 413

2.5 days/week @ 5 €

or 1 day/week @ 12.5 € € 3,438 € 2,406 € 619 € 3,438 € 2,406 € 619

5 days/week @ 5 €

or 2.5 days/week @ 10 € € 6,875 € 4,813 € 1,031 € 6,875 € 4,813 € 1,031

Total low parking/access charges

€ 26,587 € 25,976 € 611 € 57,299 € 56,876 € 424

Total high parking/access

charges

€ 32,087 € 29,826 € 2,261 € 62,799 € 60,726 € 2,074

6.2.2 Interpretation of the lifetime cost calculation

When the difference is taken between the conventional and an assumed EULES car, all identical cost elements cancel out. In the end, the financial comparison boils down to the trade-off between:

higher purchase and running costs (vehicle maintenance ) versus

potentially lower parking / access charges for a EULES car.

For the smaller car there is a clear financial benefit even without any EULES privilege thanks to reduced parking and/or access fees. That’s because there are no extra capital costs as only a different exhaust after-treatment design is assumed for the Lean NOx Trap. This would

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presumably lead to a higher resale value as the EULES car is assumed unrestricted from local entry fees. This 3% resale premium by far outweighs the slightly higher fuel costs. Any privilege in terms of reduced parking and/or access fees will only increase the financial benefit. Savings to the consumer might be about 120 to 450 Euros annually, increasing with higher charges or more frequent levy (Figure 43).

Small car: Total costs Small car: Cost difference

Figure 43: Illustration of total cost elements and differential costs for conventional and EULES cars (small) over 5 years holding.

The medium to large EULES car has somewhat higher purchase, running and maintenance costs compared to the conventional car. However, already a resale premium of only 3% balances off these extra costs of the more stringent NOx control. Any privilege in terms of reduced parking and/or access fees will only increase the financial benefit. Savings to the consumer might be about 120 to 450 Euros annually (Figure 44).

€ 0

€ 10,000

€ 20,000

€ 30,000

€ 40,000

€ 50,000

€ 60,000

€ 70,000

5 days/week @ 5 €


1 day/week @ 5 € parkinor access charges

Maintenance costs

Fuel costs

Purchase+holding–resale

‐€ 500

€ 0

€ 500

€ 1,000

€ 1,500

€ 2,000

€ 2,500

Conv‐EULES

5 days/week @ 5 €


1 day/week @ 5 € parking oaccess charges

Maintenance costs

Fuel costs


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Medium-large car: Total costs Medium-large car: Cost difference

Figure 44: Illustration of total cost elements and differential costs for conventional and EULES cars (mid-large) over 5 years holding.

Total costs of the car ownership are dominated by the loss in value of the initial capital. However, these are largely the same between the conventional and a EULES car. Therefore, the differential costs between the two car variants are to a large extent determined by possible charges for parking and access. They can quickly become much bigger the any difference in running or maintenance costs between the conventional and a EULES car; this means that cost results are robust in this respect.

We assumed only a very moderate fee of 5 Euros for parking and access per day on average. The financial advantage of a EULES car will be the bigger, the higher this fee is, the more frequently it is levied or the higher the EULES privilege is. Hence, such positive discrimination e.g. by city authorities can constitute a significant incentive to orient car drivers towards a EULES car.


A EULES car is no more expensive than a conventional car as (potentially) higher purchase, running and maintenance costs are offset by as low a resale premium as 3% - or by moderate form of subsidy. If EULES cars receive a discount in parking and access charges this can become a significant financial incentive for its purchase. The savings by a EULES car can reach 1,000 to 2,000 Euros over five years assumed use time, and would increase the higher the charge difference is and the more intensive the use.

This shows that local authorities have a significant, though sometimes also highly contested, price mechanism at their hands, which could influence the purchase and use behaviour of a rational choice homo economicus type of consumer.

€ 0

€ 10,000

€ 20,000

€ 30,000

€ 40,000

€ 50,000

€ 60,000

€ 70,000

5 days/week @ 5 €


1 day/week @ 5 € parkinor access charges

Maintenance costs

Fuel+AdBlue costs


‐€ 500

€ 0

€ 500

€ 1,000

€ 1,500

€ 2,000

€ 2,500

Conv‐EULES

5 days/week @ 5 €


1 day/week @ 5 € parking oaccess charges

Maintenance costs

Fuel+AdBlue costs


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A potential subsidy would only need to be in the order of the purchase premium and, thus, a few hundred Euros, to make up for a potential financial disadvantage of a EULES customer. This might become relevant if the extra performant SCR equipment to be installed in medium to larger cars resulted in significant extra costs.

How much these cost differences or lifetime savings come to the mind of a potential car buyer, and to what extent they are taking into consideration for the purchase decision, is however subject to the investigation of public attitudes. It seems that a difference of a few hundred Euros does indeed not influence significantly the decision making.

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7 Technical feasibility – emission experimental results

7.1 Objectives and approach

The main objective of this task is to experimentally demonstrate, beyond any doubt, that diesel cars can be clean under RDE, using today’s commercial technology. In other words, prove that a CF below 1.0 over Euro 6 is feasible under RDE, by tests on a commercial diesel vehicle.

The approach is totally experimental, using real production Euro 6 vehicle and engine.

First, a Euro 6 diesel commercial vehicle with CF more than 1.5 has been selected. This vehicle has been tested following the RDE specifications. Then, the RDE road test has been reproduced at an engine dyno using an identical engine, ECU, and exhaust aftertreatment system. After that, the test has been repeated, but using a new engine calibration, a new exhaust aftertreatment system, and appropriate tuning targeting at NOx emissions reduction. This new configuration demonstrates a EULES vehicle with a CF less than 1.0.

7.2 Experimental testing

7.2.1 PEMS testing of a Euro 6 diesel vehicle

In the first part of this task, we have selected an appropriate vehicle, designated a well-defined RDE route, and tested the vehicle under RDE.

7.2.1.1 Vehicle specifications

The selected vehicle used to run the experimental testing was a late Euro 6 passenger car with a diesel engine of 1.4 litre displacement. The vehicle was type approved in 2015 and the driven kilometres were 10,000 when the tests began.

No OEM was involved in the selection process; the vehicle was a typical production vehicle.

Following the trend of all Euro 6 diesel vehicles, it was equipped with emission control components, specifically, LNT catalysts, DPF, and EGR.

7.2.1.2 RDE testing route

The route of the RDE test should have specific characteristics, regarding the distance, the average speed, the altitude and the trip duration, which are described by the respective RDE legislation. In compliance with this regulation, a route has been traced in the region of Thessaloniki. This route is shown in Figure 45, where the three distinctive colours represent the three parts of the trip, namely, Urban, Rural, and Motorway. The boundary conditions of this route, as well as the legislation limits, are presented in Table 36.

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Figure 45: RDE test route in Thessaloniki

Table 36: Boundary conditions of Thessaloniki RDE route

Thessaloniki

RDE route Legislation

limits

Trip duration 110 min 90 – 120 min

Stop duration 22% of time > 10% of time

Trip distance 77 km > 46 km

Distance share

Urban 37% 29% – 44%

Rural 29% 23% – 43%

Motorway 34% 23% – 43%

Average speed

Urban 20.9 km/h 15 – 30 km/h

Rural 82.7 km/h 60 – 90 km/h

Motorway 117.6 km/h 100 – 145 km/h

Max altitude 115 m < 700 m

Altitude difference (end – start) -7 m ± 100 m

7.2.1.3 Testing equipment used

The PEMS consists of several units, shown in Figure 46, which were installed on the vehicle. AVL’s48 GAS PEMS iS gas analyzers were used to measure the raw exhaust CO, CO2, NO, NO2 and O2. Altitude, velocity and location coordinates were measured from a GPS unit.

48 https://www.avl.com/

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Ambient temperature, humidity and pressure, along with tailpipe exhaust gas temperature, were measured using respective sensors.

In addition, various engine-related signals were recorded from the OBD port, using RA’s49 Silver Scan-Tool. These are temperature signals, such as engine out temperature, engine coolant temperature, charged air temperature; pressure signals such as boost pressure, DPF pressure drop; load related signals such as accelerator pedal position, absolute throttle position; and other signals such as engine speed, vehicle velocity, Lambda, EGR valve position. Finally, AVL’s MOVE system control unit was used to ensure a simultaneous recording for all signals.

Figure 46: RDE testing equipment

7.2.1.4 Measurement results and discussion

Four RDE test repetitions were conducted with the abovementioned vehicle at Thessaloniki route. All recoded data from the measurement devices were processed according to the respective legislation.

In accordance to the recent legislation addendum, the trip indicators of all four repetitions were calculated in order to verify that each trip was valid. The indicators are the v*a_95 (which is the 95th percentile of the product of vehicle speed per positive acceleration greater than 0.1 m/s2 for urban, rural and motorway shares [m2/s3 or W/kg]) and the RPA (which is the relative positive acceleration for urban, rural and motorway shares [m/s2 or kWs/(kg*km)]). All repetitions were valid in terms of trip indicators, and the analytical results are shown in Table 37.

Table 37 : Trips validity check

Trip validity

Repetition 1 Repetition 2 Repetition 3 Repetition 4 Limits

RPA va_95 RPA va_95 RPA va_95 RPA va_95 lowerRPA

upper v*a95

Urban 0.212 10.4 0.208 10.3 0.218 10.0 0.216 10.2 0.147 16.9

Rural 0.063 13.9 0.057 12.6 0.069 13.3 0.072 16.9 0.052 24.7

Motorway 0.056 15.9 0.062 16.4 0.076 17.1 0.055 13.8 0.025 27.7

49 http://www.rac.de/en/

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For the EMROAD calculations, the value of the type approval WLTP CO2 emission in [g/km] was needed. Since the vehicle was type approved with NEDC, the expected WLTP CO2 emission value was estimated using our WLTP/NEDC experience over various vehicles measured under NEDC and WLTP. Also, the estimated CO2 values of the WLTP sub-cycles (Low High and Extra High) were imported to the EMROAD calculations. These values strongly affect the normality factor of the EMROAD calculations. To eliminate any inaccuracies of the estimation, all normality factors of the EMROAD calculations have been set to 1.

Table 38 contains the results of the EMROAD emissions calculations. The exhaust aftertreatment regeneration events are also shown in this table. LNT regeneration events (periods of engine operation with rich air-fuel mixture) can be identified easily from the lambda sensor reading.

Table 38: Thessaloniki RDE tests, aggregated results

RDE tests CO2

[g/km] NOx

[mg/km] CO

[mg/km] Number of LNT regenerations

DPF regeneration

Repetition 1 113.4 420.9 4.1 9 NO

Repetition 2 114.7 341.0 5.2 11 NO

Repetition 3 134.0 764.5 30.2 8 YES

Repetition 4 118.2 429.5 7.4 9 NO

From the four repetitions, one test had to be selected and later be reproduced at the engine bench.

From the test selection, the first repetition was discarded because a different OBD scanner device was used, which provided a limited amount of engine-related signals.

Also, the third repetition was discarded because DPF regeneration occurred during the Rural and Motorway parts of the trip.

The repetitions 2, 3, and 4 had a significant difference regarding the EGR operation during the Urban part of the trip.

o At the second repetition, the EGR is activated during the whole Urban part.

o At the third repetition, the EGR is deactivated during the whole Urban part.

o Whereas at the fourth repetition, the EGR, which is initially deactivated, activates after the first half of the Urban part (40 minutes).

This EGR non-repeatability causes high fluctuations of the NOx emissions during the Urban parts. All external conditions had no significant differences (similar preconditioning, ambient temperature and road traffic), so internal ECU operations or unknown parameters were affecting the EGR. The EGR activation duration of the 4th test was in-between the 2nd and 3rd, thus, repetition 4 rather represents “average” road behaviour.

For all these reasons the 4th repetition was selected to be reproduced at the engine bench.

The instantaneous vehicle velocity and altitude are shown in Figure 47, whereas the instantaneous CO2 and NOx are shown in Figure 48.

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Figure 47: RDE test vehicle velocity and altitude

Figure 48: RDE test CO2 and NOx emissions

7.2.2 RDE test reproduction at engine bench

The next step of the experimental testing, after the RDE road tests, was to reproduce one RDE test at the laboratory, using an engine bench. This would be the baseline test for further NOx emissions reduction later on.

7.2.2.1 Engine configuration and equipment

The laboratory tests were performed using an identical, with the vehicle, engine, on a transient bench. The test cell was equipped with an active fully transient dyno (AVL Dynoroad 120kW), a dyno control software (Puma Open) and an engine cooling system (AVL Consyscool 200). The ambient temperature of the cell could be controlled.

The setup consisted of the identical Euro 6 engine operated by an open ECU with an identical calibration. Also, exactly the same OEM exhaust aftertreatment system was used, namely the two LNT pieces and the DPF. In addition, a controllable flap was used to adjust the engine out backpressure caused by the exhaust manifold. The whole setup is shown in Figure 49.

Hence, the engine could be conditioned and operated in identical pattern to the one used on the road. Also, bench-measured signals could be matched to several on-road OBD recordings.

The measurements were performed with the same PEMS equipment that was used on the road, avoiding any bias caused by different exhaust gas analyzers.

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Figure 49: Baseline engine configuration

7.2.2.2 Reproduction test, input, and output target

To reproduce the road test, specific road measured parameters (OBD data) were imported as demand values at the engine bench:

Engine speed

Accelerator pedal position

Engine coolant temperature (average value imported as constant demand value)

Charged air temperature (average value imported as constant demand value)

Intake air temperature (average value imported as constant demand value)

LNT regeneration (rich) events start time and duration

To prove the fidelity of the RDE road test reproduction, specific second by second signals should match the respective on-road measured signals. These engine bench output signals are listed in order of importance bellow:

Power (torque)

NOx emissions

CO2 emissions

Various operation parameters (temperatures, etc.)

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7.2.2.3 Results and discussion

The aggregated results of the reproduction test are shown in Table 39, whereas the instantaneous CO2 and NOx emissions are shown in Figure 50 and Figure 51.

Table 39: Aggregated results, reproduction test

Road RDE test Bench reproduction test

RDE test CO2

[g/km] NOx

[mg/km]CO

[mg/km]CO2

[g/km]NOx

[mg/km]CO

[mg/km]

Urban 120.0 728.0 7.5 129.6 731.2 18.3

Rural 110.7 320.7 6.9 112.1 336.2 7.0

Motorway 127.7 330.2 8.1 125.3 319.1 1.3

Total 118.2 429.5 7.4 120.6 433.8 8.2

Figure 50: Reproduction test results, cumulative NOx emissions

Figure 51: Reproduction test results, cumulative CO2 emissions

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The results indicate that the initial target to sufficiently reproduce the RDE road test at the engine bench has been achieved. The CO2 emissions of the bench test are very good matched with the emissions of the road test, but they are a little bit higher; whereas the NOx emissions are almost perfectly matched.

During the initial bench testing, the EGR operation had small deviations from the road, due to its high sensitivity to several parameters. This resulted to a divergence of the NOx emissions (CO2 was perfectly matched). Considering that the project focuses on NOx emissions, a better NOx reproduction was mandatory. For this reason, the intake air flow map of the ECU and the accelerator pedal position were slightly adjusted. This resulted to the small CO2 deviation, but it is on the safe side (bench test CO2 higher than the road test CO2). Also, better calibration would be possible but not relevant to the current study.

Significant parts of the engine operation are the LNT regeneration events, which are reproduced accurately. The instantaneous lambda and CO2 emission are shown in Figure 52.

Figure 52: Reproduction test results, LNT regeneration events

Other instantaneous data proving that the test was reproduced satisfactorily are the DPF pressure drop, shown in Figure 53, and the exhaust gas temperature (measured both at the engine output and LNT output), shown in Figure 54.

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Figure 53: Reproduction test results, DPF pressure drop

Figure 54: Reproduction test results, exhaust gas temperature

7.2.3 EULES test at engine bench

The next step is the ‘low NOx’ test. The target of this test is to lower the NOx emissions as much as possible, but maintain the engine speed and load of the reproduction test.

7.2.3.1 Engine configuration and equipment

In order to achieve NOx reduction, a new exhaust aftertreatment system was installed and calibrated; also, the engine EGR was recalibrated.

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Lower engine out NOx emissions were achieved with EGR recalibration by adjusting the intake air flow map of the open ECU:

EGR was activated for the whole test duration (at the initial RDE road test, the EGR was deactivated for the first 40 minutes of the urban part).

EGR percentage was slightly increased during the urban part.

Adjustments were made to the accelerator pedal position input, in order to compensate the engine load difference for the increased EGR.

The new exhaust aftertreatment system, shown in Figure 55, consists of the following parts:

A DOC (1.5 litre), which was used to convert NO to NO2 and for the catalysis of CO and HC.

An ammonia injection system. Bottled gas ammonia was used, along with a mass flow controller and three injector probes. This system ensures better mixing of the ammonia with the exhaust gas, less space, and no need for urea thermolysis catalyst.

A SCRF (4.1 litre), which is the main component for NOx reduction and PM filtering. The SCRF has copper-zeolite coating and is a combination of a DPF and an SCR, saving space.

A second DOC (1.5litre), which is operating as an ammonia-slip catalyst.

Figure 55: EULES test engine configuration

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The most sensitive part of the NOx reduction test is the ammonia injection. The whole exhaust aftertreatment system was simulated using Exothermia’s50 Axisuite software, targeting low overall NOx and ammonia slip less than 10ppm. The ammonia injection strategy was an offline, model-based, ammonia surface coverage control with constant quantity injection. Also, ammonia injection was stopped below 190°C to avoid salts formation. The ammonia injection strategy is shown in Figure 56.

Figure 56: EULES test results, ammonia injection strategy

Finally, the same laboratory equipment was used (dyno, PEMS analysers), but with an addition of an ammonia analyser which detects any ammonia that slips from the exhaust aftertreatment system.

7.2.3.2 Results and discussion

The aggregated results of the reproduction test are shown in Table 40, whereas the instantaneous NOx and CO2 emissions are shown in Figure 57 and Figure 58. Also the cumulative engine power output is shown in Figure 59.

Table 40: Aggregated results, EULES test

Road RDE test Bench reproduction test Bench EULES test

RDE test CO2

[g/km] NOx

[mg/km] CO

[mg/km]CO2

[g/km]NOx

[mg/km]CO

[mg/km]CO2

[g/km] NOx

[mg/km] CO

[mg/km]

Urban 120.0 728.0 7.5 129.6 731.2 18.3 127.4 49.9 0.2

Rural 110.7 320.7 6.9 112.1 336.2 7.0 108.1 17.2 0.1

Motorway 127.7 330.2 8.1 125.3 319.1 1.3 124.8 60.5 0.0

Total 118.2 429.5 7.4 120.6 433.8 8.2 118.2 38.7 0.1

50 http://www.exothermia.com/home/index.php

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Figure 57: EULES test results, cumulative NOx emissions

Figure 58: EULES test results, cumulative CO2 emissions

Figure 59: EULES test results, cumulative engine power (energy) output

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Table 40 and Figure 57 demonstrate a significant NOx emissions reduction of the EULES test.

The initial target of a CF lower than 1 has been reached; the final result is a CF equal to 0.48.

At the same time, EULES test is identical to the reproduction test in terms of engine behaviour. Figure 59, which shows the engine power output, indicates that the two tests are perfectly matched. In addition to these positive results, a small decrease in the CO2 emissions is also noticed. This is caused by the fact that the EULES test has no LNT and thus no LNT regeneration (rich) events, while the reproduction test has nine LNT regeneration events.

The CO2 benefit of the EULES test is around 2.4 g/km (2%).

This is calculated by summing up the extra CO2 of every LNT regeneration event (Figure 60).

Figure 60: EULES test results, CO2 benefit due to removing the LNT regeneration events

During the EULES test, an ammonia analyser was installed in the exhaust. Since ammonia was injected to the exhaust manifold, it was necessary to monitor the ammonia slip. Figure 61 shows that the initial target of ammonia slip less than 10ppm has been reached.

Figure 61: EULES test results, ammonia slip

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The total ammonia that was injected during the EULES test was 14.5 g. This quantity can be converted to equivalent AdBlue, which is widely used in SCR systems. Considering an AdBlue to gas ammonia conversion efficiency of 1, then the calculated equivalent AdBlue that was used for the EULES test is 75 ml.

This means that the AdBlue consumption is 0.98 lt per 1,000 km or 18.2 ml per fuel litre (2%).

An additional test with lower ammonia injection (-25%) was conducted, in order to investigate the NOx emissions sensitivity. The results are shown in Table 41.

Table 41: NOx emissions result of test with less ammonia injection

NOx [mg/km]

Bench EULES test

Bench test with -25% ammonia amount

Urban 49.9 90.5

Rural 17.2 42.8

Motorway 60.5 59.0

Total 38.7 60.1


The feasibility exercise demonstrated that a CF around 0.5 in NOx is technically possible using today’s emission control technology and using latest RDE testing specifications. However, other issues such as durability, OBD or other packaging commercialization implications at these emission levels were not examined in our study, as this was not the intention.

The aftertreatment components that were used in our approach are relatively large (not so unrealistically). Again, our approach was not to optimize the packaging for the particular engine but use typical, off the shelf, components that could be used to reduce emissions. Further optimization may be possible either for components size reduction or further NOx reduction. The optimization could also relate to ammonia (urea) injection strategy, the SCRF positioning could be closer to the engine to benefit from even higher temperatures, and the second DOC would definitely be smaller in size, probably zoned within SCRF.

A potential point of concern in our approach is the injection of ammonia instead of urea. In terms of basic SCR reactions, this should not have an effect. However, ammonia injection may have better cold-start performance (not relevant in our study) and does not need a thermolysis catalyst. In our case, we used ammonia injection to retain an overall simpler system. Gas ammonia injection and safe gas ammonia storage systems are becoming commercial, so the technology that was used is within the range of the commercial applications.

It is our understanding that AdBlue injection would bring the same NOx reduction, but would require more components. The equivalent AdBlue consumption is relatively low; only 2% of corresponding fuel consumption. The strategy for ammonia injection was to keep a saturated SCRF in ammonia using a predefined mapping. In fact, this was not achieved for parts of the motorway part; hence, in principle further reductions could be possible. Also, more

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efficient ammonia use may still be possible by using a closed loop SCR ammonia injection system, e.g. using NOx sensors to adjust the quantity of ammonia to be injected in real-time.

The achieved NOx reduction did not lead to any extra fuel consumption and CO2 emission; instead, a small reduction is achieved by not having the need for LNT regeneration events that were present in the original configurations.

Another important recommendation about the proposed legislation is that the ammonia slip should be monitored during the RDE testing. The test results indicate that without a proper ammonia injection strategy, or without the use of a post SCRF ammonia slip catalyst, high amounts of harmful ammonia could slip from the exhaust aftertreatment system.

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8 Final recommendations

This is the concluding section of the report, aiming at providing useful recommendations for the successful introduction of the voluntary EULES scheme. It provides direct answers to specific key questions like “what is EULES and how it can be implemented”, “how to nudge consumers towards a clean EULES car”, “what is the role of public authorities”, “what is the technology needed to achieve EULES limits”, etc.

It is repeated here that the term EULES is only temporary and it is expected to be modified in the course of implementing the final approach.

The recommendations presented here are derived by synthesizing the work performed in the framework of the different tasks of the project and presented in the previous sections of the report. For further details and more analytical information per topic, the reader should refer to the relevant section (e.g. technical model, legal approach, assessment of likely public response, experimental testing, etc.).

8.1 What is EULES – how it can be implemented?

8.1.1 Conceptual presentation of EULES

EULES can be a voluntary EU scheme for promoting the placement in the market of truly low emitting combustion engine driven cars. Its principal objective is to place to the market cars with real-world emission levels below the most stringent current emission limits. A first understanding on the potential of such a voluntary emission scheme has been developed in the framework of this project, together with the proposal for the technical and legal background for its successful implementation.

The main characteristics of EULES are summarized below:

1. All key pollutants addressed: EULES should address all regulated pollutants, which constitute a significant problem, especially in urban hot spots like highly trafficked areas. This includes NOx, PM, PN, HC, CO and NH3. The immediate objective is to address the issue of high NOx emissions of diesel cars, which still exhibit on the road (real-world driving conditions) substantially higher levels than during type approval. As a result of this discrepancy, and in spite of the increasingly stringent emission standards, diesel cars continue to substantially contribute to the urban air pollution in Europe.

2. Technology neutrality: EULES is by definition technology neutral. It is based on limit values and not technology enforcement. Any car equipped with an internal combustion engine (petrol, diesel, hybrid, alternative fuel, etc.) can be characterized as EULES compliant, if meeting the emission criteria to be finally decided. Some of the vehicle technologies available today may exhibit RDE emission levels which are already below emission limits (e.g. late technology port fuel injection gasoline vehicles). This means that there may be vehicles that could already be labelled as EULES without substantial further technology improvements. In other cases, like for most of the diesel cars, improved emission control is required to achieve the EULES levels.

3. Link to RDE procedure: EULES will be based on the RDE test procedure. The intention is not to create a new testing procedure that will take long to develop from scratch. Hence, EULES is envisaged as a more stringent version of the Euro 6 RDE regulatory package, with reduced emission limits. It is understood that RDE testing may further develop in the future by possible inclusion of cold-start emissions and, even, a

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more extensive operation coverage. It is envisaged that EULES will be compliant with the specific RDE procedure in place at any time. Provisions extending to current RDE may need to be foreseen for some pollutants, e.g. NH3.

4. Voluntary character: Legislation based on RDE has been proven a time consuming process which started in 2011 and is expected to end by the end of 2016 (or early 2017). In general, enforcing yet a new mandatory emission limit may take several years due to practical reasons, involving long discussions in the technical and political fronts. However, urgent action is needed in urban environments to meet air quality obligations (e.g. NO2) and, because of this, vehicles that can be already today lead to low emission levels need to be labelled. The quick introduction of EULES as a voluntary scheme can answer to this market challenge with success. A successful example in the past has been the EEV voluntary standard, primarily focused on urban buses. EEV promoted the introduction of natural gas or diesel with DPF buses already since the beginning of the 2000s, and has significantly assisted local authorities in meeting their air quality targets. This does not preclude EULES being placed as a mandatory Euro 7 standard.

5. Usefulness: EULES is expected to i) guide environmental conscious customers towards the purchase of vehicles with ‘clean’ emission profiles (low real-world driving emissions), ii) provide a benchmark for local/national authorities when developing financial or access and demand incentives to promote clean transportation, and iii) provide an incentive for manufacturers to produce vehicles that deliver significant emission reductions on the road.

6. No impact to CO2 – fuel economy: Implementation of EULES should not be to the detriment of CO2. This means that no change to the CO2 regulations should be required to provide any flexibilities for EULES. EULES-compliant cars will be counted towards market-average CO2 in a similar way as non-compliant vehicles. Actually, a successful implementation of EULES as an environment-conscious badge can only be made by respecting stringent CO2 targets. Hence, additional limitations on max CO2 emissions or CO2 labelling category on which a EULES car can belong to may be enforced.

8.1.2 Technical model

General

The technical model for EULES is proposed as a voluntary extension that builds upon the RDE regulation, and it is composed of three modules:

Framework of the model: It comprises the technical underpinnings of EULES scheme, which is essentially conceived as a voluntary extension of the provisions of the RDE regulation, which are modified for increased stringency. EULES focuses on real-world emission improvements and brings improved technology neutrality in relation to the baseline Euro 6 standard.

Conformity factors (CFs): Lower on-road NOx conformity factors are proposed for EULES compared to those of the second package of RDE. The proposed conformity factors are meant to reflect low, yet achievable with current technology, emission levels in real driving conditions.

Ancillary proposals: These are measures aiming to reinforce the application of the RDE regulation with an additional layer of voluntary EULES provisions. They are devised as simple modifications to the current RDE provisions and are expected to increase the

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stringency or improve the coverage of RDE tests, while imposing only a small additional testing or data processing burden. The main idea is to turn optional provisions of RDE into mandatory EULES provisions and/or enforce the more stringent application of RDE provisions when these are open to interpretation.

Framework of the model

The voluntary nature of EULES means that stringency levels should be adjusted in such a way that compliance with the standard requires a significant additional effort from the side of manufacturers (i.e., only the best performers should be qualified as EULES cars). Still, EULES should be an attractive proposition to stakeholders, including manufacturers, importers, and technical services. From the side of EC, this can be achieved by minimizing the additional administrative, testing, and data evaluation burdens, and by maximizing the synergies with existing regulations.

Conformity factors for NOx emissions

As a starting point, a NOx conformity factor at a value of 1.0 (i.e., Euro 6 limit compliance for the on-road RDE test) seems as the minimum requirement to place to the market clean vehicles that may assist towards achieving air quality targets in the EU (Borken-Kleefeld and Ntziachristos, 2012). Also, the potential to reach this target has been verified by analysing the ICCT database of PEMS trips from Euro 6 diesel cars.

However, even a CF of 1 for diesel cars (80 mg/km) appears high compared to petrol vehicles that can achieve RDE NOx with CF below 1, according to petrol limits (60 mg/km). Moreover, latest PEMS data and an experimental technical feasibility study conducted in the framework of the current work revealed that lower than CF=1 is possible even for diesel vehicles.

Therefore, a NOx conformity factor in the range of 0.5-0.7 (based on diesel limits) seems technically possible using today’s emission control technology and using latest RDE testing specifications.

Ancillary proposals

These are measures to reinforce the application of the RDE regulation with an additional layer of voluntary EULES provisions and are summarized in Table 42. These can further increase the stringency of EULES without requiring substantial additional technical or regulatory burden.

Table 42: Summary of ancillary EULES proposals regarding RDE measurements

Proposed ancillary measure Formulation

A1.1: Conformity for both data evaluation methods (EMROAD and CLEAR)

The exhaust emission conformity factors calculated by means of both data evaluation methods (EMROAD and CLEAR) shall not exceed limits proposed by EULES.

A1.2: Conformity of ‘raw’ emission factors (no data evaluation method applied)


A2: Rapid inclusion of cold-start emissions


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A3: RDE test performed without a data link to the ECU of the vehicle under test


A4: Separate evaluation of urban NO2 emissions


Implications to other regulatory components

An emission standard package usually contains, further to emission limit values, detailed methodologies and limits regarding the durability of the emission control system, the OBD technical approach and threshold values, and low temperature limits, to name the most important ones. The available options on how to address these issues in relation to EULES are summarized in the following:

No changes compared to Euro 6: This option means that no change in the thresholds, durability tests and low temperature values is introduced for EULES in comparison to Euro 6. This option has the advantage of being simple and straightforward, but entails the risk that the vehicle performs very well until a certain mileage but then becomes similar to less clean vehicles because it only has to fulfil the same requirements. For example, if the deterioration factor approach remains for durability conformity, then a EULES car can be made clean for the first kilometres but then fast degrade. Similarly, with OBD threshold limits remaining at the same level, OBD will not be activated until emissions reach the level of a malfunctioning non EULES car.



Some new components may also need to be added to EULES to close potential loopholes:

For vehicles equipped with a reagent system, they should not be allowed to operate without reagent. With the new type approval procedure proposed by the European Commission, the technical service will have to right to check the emission control algorithms. Provisions to make sure that the vehicle is derated when no reagent is in place can be therefore checked.

For vehicles equipped with an ammonia-based reagent, it is mandatory that ammonia levels at the tailpipe do not exceed a certain level. This is mostly to avoid environmental implications of the toxic ammonia but also to protect the equipment used for measuring the emission levels. Since developing a new technical guideline for measuring NH3

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levels with PEMS equipment may be time consuming, an alternative approach may be that the manufacturer declares that ammonia control has been actively implemented, this implying the existence of an ammonia slip catalyst and/or the existence of an ammonia responsive sensor in the tailpipe.

8.1.3 Legal approach

The legal approach of EULES concerns various aspects that should be carefully designed for a successful implementation of the voluntary scheme. These are:

Integration into the type approval process.

RDE/PEMS testing implications.

Testing and data handling responsibilities.

Placement on the market (legal instrument, legal distinction, etc.).

Integration of EULES into the type approval process and connection with RDE

The main idea is to propose EULES as a list of available levels (different options that can be implemented) with increased stringency and not as a single solution. This is expected to assist in better evaluation of the advantages and disadvantages of every option and selection of the most appropriate one. The three EULES levels are:

i. More stringent CF (no additional testing): This builds upon the RDE test process and, without additional testing requirements, more stringent CF is used to ensure even lower on-road emissions. The selection of the CF is based on the technical model and experimental results. This option has the advantage of being simple and straightforward, since it is based on the established RDE process; the only difference is on the CF. Hence, there are no changes on the trip requirements and testing conditions and no further processing of the RDE test data is necessary. However, it entails the risk that the vehicle performs very well until a certain mileage, but then becomes similar to less clean vehicles because it only has to fulfil the same requirements.

ii. Same as level (i) + Ancillary measures: This level of EULES presumes the adoption of some of the ancillary measures proposed in the technical model. These measures are a collection of proposals to reinforce the application of RDE with an additional layer of voluntary provisions. The latter are devised as simple modifications to the current RDE provisions and are expected to increase the stringency or improve the coverage of RDE tests, while imposing a small additional testing or data processing burden on stakeholders. The implementation of some of these ancillary measures at the discretion of the regulator should allow the EC to modulate the stringency of EULES. Moreover, measures such as these represent an agile way of ‘patching up’ possible shortcomings of RDE and ensure that EULES is future proof.

iii. Same as level (ii) + Other regulatory components: This is the level of EULES that deals with the implications of the voluntary scheme with other regulatory components (e.g. durability, OBD, etc). It ensures robustness and coherence with the whole regulatory framework and, further to lower emissions during RDE test, it contains more stringent methodologies and limits regarding other regulatory components. The advantage of this option is that it may lead to cleaner vehicles throughout their

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lifetime. However, defining new thresholds for OBD or changing the durability requirements entail both technical and legal risks, as well as risk for long discussions with manufacturers that could delay the process of bringing in EULES.

Testing and data handling responsibilities

The responsibilities of the different entities involved in the type approval process and EULES integration are summarized as follows:

EC will decide and legislate upon EULES level (option) to be adopted.

TS and TAA will be responsible for checking if conditions of EULES level (x) are satisfied.

TAA will be responsible for issuing the EULES certificate.

The whole process will be reinforced with greater European oversight, according to the recent EU proposal to change the type approval framework, COM (2016) 31 final, 27.1.2016.

Placement on the market (legal instrument, legal distinction, incentives and benefits)

For a successful placement on the market of a EULES compliant vehicle, a number of issues need to be addressed. These involve the legal instrument to be used, the legal distinction of the compliant vehicles, and the incentive programmes for the promotion of the scheme.

Legal instrument: EULES is a voluntary scheme and it is essential to coexist harmonically with the mandatory standards already in place. Hence, it needs to be consistent with existing regulations and not overrule or replace the existing standards. The legal tools that are proposed as most appropriate for EULES are: Regulation, Directive, or Communication (COM).

The final choice of the legal tool depends on whether EULES will be introduced as an independent standard or just as an enhancement of the Euro 6 (+RDE) standard. This is closely related to the level of the EULES scheme that will be finally adopted. Specifically:




Legal distinction: The legal distinction of EULES concerns issues like label/logo usage, interaction with other initiatives, etc. Hence, it is closely related to the assessment of likely public response and the role of public authorities.

Regarding the usage of label, the assessment of likely public response concluded that European consumers are not too acquainted with car labels. Many people admit to be “unfamiliar with” existing car labels and do not consider them as “easily recognizable”; moreover, they do not always trust the information displayed. In any case, the element of car labels that mostly attracts the attention of candidate buyers is the message. Specifically, when it

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comes down to one car purchase decision, consumers are less interested in knowing about clean air, convenient parking, or access fees; they are more likely to buy if – other things equal – they know that the car has lower taxes and lower maintenance costs.


Incentives and benefits: The incentives that can be used for the promotion of the voluntary EULES scheme are summarized below (shown ordered according to customer acceptance).




Summary table

A summary table with all options presented in an organized manner is provided below. It shows the advantages and disadvantages of each proposed EULES level (option), as well as issues like legal and technical complications, possible difficulties in implementation, risk for delays, etc.





Ancillary measures



Main

characteristics



additional testing


is required.






layer of voluntary

provisions.







Legal

instrument

Possibly even by

communication (COM)


Advantages


No changes in RDE.








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Disadvantages






Responsibilities

of the involved

entities




Legal

distinction





Incentives and

benefits




8.2 How to nudge consumers towards a ‘clean’ EULES car?

8.2.1 Summary from the assessment of likely public response

Perceptions and understanding of the health and environmental issues

Europeans are aware of the health and environmental impact of cars. The survey (performed for the assessment of likely public response) points to a general understanding of the adverse health effects of pollution. Moreover, respondents recognise that there is a link between the environmental protection and human health. They also think that the pollution in their cities or neighbourhoods is rather high. Two-thirds of the respondents (68%) fully agree that high pollution could make them sick. The survey also shows how respondents are aware of the environmental impact of polluting vehicles. More than half of respondents (54%) believe that “cars contribute significantly to the air pollution” in their city or neighbourhood.

Decision making: describing the purchase process

Despite the high environmental awareness, the main factor that subjects take into account when buying a car is price (50% of respondents), followed by road safety (48%) and fuel consumption (46%). Most importantly, only one in ten (11%) is ready to pay more for a more environmental-friendly car. These results also confirm the gap between self-reported attitudes/intentions and actual behaviours: health and environmental concerns come only after many other attributes (price, safety, performance, etc.) in terms of importance in influencing car purchase decisions.

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In fact, many consumers perceive buying an eco-friendly car as entailing a loss/sacrifice in terms of performance. There is a quite widespread perception that less polluting or lower consumption vehicles are associated with higher prices and that, to some extent, also compromise performance. In this regard, citizens do not clearly understand the difference between air pollution and GHG emissions. Nearly half of the respondents (47%) agree with the statement “Vehicles that produce less pollution consume less fuel”.

Incentives to influence the purchase process

Financial incentives are the most likely to change consumers’ behaviour towards low emission cars. According to 30% of survey respondents, providing higher financial incentives for low emission products would be an effective strategy to tackle air pollution. Financial measures (tax breaks, subsidies) are more likely to nudge consumers towards low emission cars than are non-financial incentives. Among the latter, low emission zones seem more appealing, especially for those consumers who drive to work on a daily basis. Citizens are likely to prefer tax exemptions and subsidies rather than environmental taxes or road pricing. We draw this conclusion from the survey, in which respondents believe they are paying already too much of environmental taxes for their car and are not in favour of applying ‘road pricing’ (e.g., road tax, registration tax) for major metropolitan areas (e.g., cities with over 100,000 inhabitants and their suburbs). At the same time, they welcome proposals in which the government would provide either tax exemptions or subsidies for those purchasing a low-emitting car.

Impact of labels on consumers’ behaviour, attitudes and perception towards labels

European consumers are not too acquainted with car labels. More than 43% of respondents admit to be “unfamiliar with” existing car labels. Around 37% disagree with the statement that labels are “easily recognizable”. As many as 39% do not trust the information displayed, and reportedly the most common use of labels is “to check if what said in the advertisement is true”. Many even misunderstand their purpose: nearly 38% believes that labels symbolize a product’s reliability.

In any case, the element of car labels that most attracts the attention of candidate buyers is the message. To find that out, we ran a series of experiments in which individuals were asked to choose a car between two options. Each option consisted in a label depicting a car and a series of additional elements – logos, price tags, and a series of messages. As the results show, all attributes are significant, and they all contribute to the choice. However, the strongest utility is given by the messages.

Respondents are more likely to choose EULES-friendly cars when they the label shows information on lower costs or lower taxes. When it comes down to one car purchase decision, consumers are less interested in knowing about “Cleaner air in cities”, health-related benefits, convenient parking, or access fees. Other things equal, they are more likely to buy if they know that the car has lower taxes and lower maintenance costs. A minor increase in price has a negligible effect. Finally, combinations of one message with other elements -– EULES logo, CO2 logo, or both – within the same label have a small but positive effect.

8.2.2 Summary from the cost-benefit analysis for the consumers

Parking and access charges can make up a substantial share of the total costs of a car, depending on the frequency and rate of charges. Already at the level of current moderate parking fees and assuming only 30% discount for EULES cars, the resulting charges can make all the difference in a strictly financial comparison with a conventional car. The savings by a

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EULES car can reach 1,000 Euros over five years assumed use time, and would increase the higher the charge difference is and the more intensive the use. This shows that local authorities have a significant, though sometimes also highly contested, price mechanism at their hands, which could influence the purchase and use behaviour of a rational choice homo economicus type of consumer.

A potential subsidy would only need to be in the order of the purchase premium and, thus, a few hundred Euros, to make up for a potential financial disadvantage of a EULES customer. How much these cost differences or lifetime savings come to the mind of a potential car buyer, and to what extent they are being taken into consideration for the purchase decision, is subject to the investigation of public attitudes. In any case, the assessment of likely public response has shown that a difference of a few hundred Euros does indeed not influence significantly the decision making.

8.3 What is the role of public authorities?

EULES is recommended as a voluntary EU-wide low emission standard that coexists harmonically with the mandatory standards already in place. Hence, it needs to be introduced in parallel to (and be consistent with) the existing national, regional, and local initiatives for low emission vehicles (e.g. schemes already implemented in Germany, France, Spain, northern Italian cities, Belgium region of Flanders, and more). The advantages of an EU-wide scheme are: i) harmonisation of criteria, ii) coverage of all vehicles independent of the country of registration, and iii) support from a ‘higher’ (European) level.

Public authorities can assist in the successful introduction of EULES by providing incentives and benefits (e.g. grants and subsidies, preferential access, special parking provisions, etc.), along with own procurement and information dissemination. Especially the attitude and potential reaction of cities can be of particular importance. Air quality and traffic management plans already exist in a number of major cities across Europe, however presenting significant divergence in legal settings, enforcement, specific form of implementation, etc.

The main issues that need to be considered by public authorities are summarized below.

Legislative capacity of cities and local authorities to levy emission related parking and/or access charges, to restrict access in specific areas, and, in general, to provide incentives and benefits for EULES compliant vehicles.

Any scheme for incentives and benefits should not be complicated; otherwise it will not be easy for communication.

Positive discrimination (e.g. granting uncharged access to the inner city for EULES cars) is usually easier to communicate and to receive public acceptance, rather than blaming drivers of high polluting cars.

Fairness and social balance are also important, together with the provision of alternative options and means for the people. For example, parts of the society who tend to have older cars may not have the means for buying latest (new) diesel technology. Nonetheless, they might still have sufficient means to buy slightly older gasoline cars, which could possibly be EULES compliant (this depends on the final decision about EULES level that will be adopted).

Enforcement parameters must be taken into account. For example, setting up a camera-based enforcement for a low emission zone alone can be prohibitively costly; controlling physical labels is person-intensive, etc.

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8.4 Technology implication for EULES cars

EULES is technology neutral; any combustion engine driven car (petrol, diesel, hybrid or alternative fuel) can be characterized as EULES compliant by meeting the criteria that have been set. Diesel passenger cars appear as the most difficult to reach low NOx emissions and may require advanced emission control technology to achieve the low limits.

The feasibility exercise demonstrated that a CF around 0.5 in diesel NOx is technically possible using today’s emission control technology and using latest RDE testing specifications. However, other issues such as durability requirement, OBD monitoring and other packaging and commercialization implications at these low levels were not examined in the study, as this was not the intention. We may expect that a relaxation of the CF (e.g. 0.7) may be required to comply with these additional requirements.

In our exercise, using a production Euro 6 engine, CF of 0.5 was made possible to achieve using the following components:

EGR: Enhanced EGR compared to stock engine by covering a wider area of engine map and recirculating more exhaust gas mass.

First diesel oxidation catalyst (DOC1): To increase the temperature upstream of the SCRF and to reduce emissions of oxidable exhaust components.

Ammonia injector: Directly injecting gaseous ammonia in the exhaust line. The ammonia injection strategy was to keep the SCRF always saturated in ammonia.

SCRF: Performs the main SCR reactions and filters PM

Second diesel oxidation catalyst (DOC2): Operating as an ammonia slip catalyst

Our approach has been a possible solution, however this is not to exclude alternative solutions which can be equal or more efficient. It should be mentioned that the emission control configuration selected achieved those NOx reductions without a fuel consumption penalty. In fact, the lower efficiency by the enhanced EGR was counterbalanced by the absence of fuel rich periods required for LNT regeneration in the stock vehicle configuration.

The aftertreatment components that were used in our approach were relatively large in size, but not unrealistically so. In any case, our approach was not to optimize the packaging for the particular engine but use typical, off the shelf, components that could be used to reduce emissions. Further optimization may be possible either for components size reduction or further NOx reduction. The optimization could also relate to ammonia (urea) injection strategy, the SCRF positioning could be closer to the engine to benefit from even higher temperatures, and the second DOC would definitely be smaller in size, probably zoned within SCRF.

A potential point of concern in our approach is the injection of ammonia instead of urea. In terms of basic SCR reactions, this should not have an effect. However, ammonia injection may have better cold-start performance (not relevant in our study) and does not need a thermolysis catalyst. In our case, we used ammonia injection to retain an overall simpler system. Gas ammonia injection and safe gas ammonia storage systems are becoming commercial, so the technology that was used is within the range of the commercial applications.

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It is our understanding that AdBlue injection would bring the same NOx reduction, but would require more components to achieve this (dispenser, flow mixer, thermolysis catalyst). The equivalent AdBlue consumption is relatively low; only 2% of corresponding fuel consumption. Even more efficient ammonia use may still be possible by using a closed loop SCR ammonia injection system, e.g. using NOx sensors to adjust the quantity of ammonia to be injected in real-time.

Another important recommendation about the proposed legislation is that the ammonia slip should be monitored during the RDE testing. The test results indicate that without a proper ammonia injection strategy, or without the use of a post SCRF ammonia slip catalyst, high amounts of harmful ammonia could slip from the exhaust aftertreatment system.

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Papadimitriou G., Markaki V., Gouliarou E., Borken-Kleefeld J., Ntziachristos L. (2015b), Best Available Techniques for Mobile Sources in support of a Guidance Document to the

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Annex I: Relevant car labelling schemes and ‘eco-friendly’ labels

Car labelling and ‘eco-friendly’ labels

The most common use of labels in order to help consumers in selecting environmental friendly cars is related to low fuel consumption and indicators on CO2 emissions in g/km (OECD, 2014). Car labelling is mandatory in EU Member States as a result of the transposition of the Directive 1999/94/EC51 and related acts52. Variations of such a labelling system exist in different countries. A relevant Directive is 2009/33/EC53 for the promotion of clean and energy-efficient road transport vehicles. Car manufacturers use different names to indicate that a specific vehicle satisfies CO2 or other ‘eco-friendly’ criteria54. A systematic review on CO2 / car labelling options has been undertaken in a study delivered for EC DG CLIMA (Codagnone et al., 2013). Another study on designing effective environmental labels for passenger cars (in US) can be found in Teisl et al. (2004).

The EU Ecolabel scheme

The EU Ecolabel is a voluntary environmental labelling system, a commitment to environmental sustainability55. The scheme enables consumers to recognize high quality eco-friendly products and the label may be awarded to products and services that have a lower environmental impact than other products in the same group. The award criteria are devised using scientific data on the whole of a product’s life cycle, from product development to disposal, and customers can rely on the logo (Figure 62) because every product is checked by independent experts. Currently, no award criteria exist for passenger cars and the time needed for (possible lengthy) consultations required to decide on the criteria must be taken into consideration. The most relevant legislation for Ecolabel is included in Regulation (EC) No 66/201056. The EU Ecolabel programme is member of the Global Ecolabelling Network (GEN)57.

Figure 62: The EU Ecolabel logo

51 Directive 1999/94/EC of the European Parliament and of the Council of 13 December 1999 relating to

the availability of consumer information on fuel economy and CO2 emissions in respect of the marketing of new passenger cars.

52 http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1423128762914&uri=URISERV:l32034 53 Directive 2009/33/EC of the European Parliament and of the Council of 23 April 2009 on the promotion

of clean and energy-efficient road transport vehicles. 54 http://www.autonews.com/assets/PDF/CA3605916.PDF 55 http://ec.europa.eu/environment/ecolabel/index_en.htm 56 Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on

the EU Ecolabel. 57 http://www.globalecolabelling.net/

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Other national or regional specific examples

Germany: From 1 December 2011 all new cars in Germany must be labelled with an energy efficiency label, issued by the Deutsche Energie-Agentur GmbH (DENA) – the German Energy Agency58,59. Similar to those used for household appliances such as washing machines, this ‘ecolabel’ shows vehicle costs and emissions at a glance (Figure 63)60. The colour scale gives information about the carbon efficiency of passenger cars (CO2 efficiency classes). The classification ranges from A (green, very efficient) to G (red, little efficiency). The black arrow shows the respective car belongs to which efficiency class. These classes specify whether a vehicle emits much or little CO2 in relation to its weight. This labelling scheme facilitates comparisons with other vehicles by the consumer and has contributed to lower fuel consumption and CO2 emissions61.

Figure 63: DENA emissions label (Germany)

German low-NOx environmental badge from NGO Deutsche Umwelthilfe62: This is a further development of the environmental zone framework to reduce air pollution by nitrogen oxides. In order to give municipalities the ability to exclude vehicles with high emissions of NOx from polluted areas, the adoption of this legal framework for a Blue environmental badge, as a continuation of the current environmental zone control, aims at combating the continuing high NOx burden in many cities. The Blue Badge is a logical development of the successful environmental zone framework and will help to alleviate the burden of diesel vehicles without effective emission control. A blue badge should apply to all vehicles that comply with the emission limit values for NO2 of Euro 6/VI (Figure 64). With this measure, it is expected that there will be a development of retrofit technologies for vehicles without corresponding emissions standard, analogous to retrofit with diesel particulate filters63.

58 http://www.ngvglobal.com/ngvs-in-germany-officially-green-says-dena-eco-label-1201 59 http://www.dena.de/en/projects/transport/implementation-platform-for-car-ecolabels.html 60 http://www.pkw-label.de/pkw-label/auf-einen-blick.html 61 http://www.dena.de/en/press-releases/pressemitteilungen/share-of-co2-efficient-new-registrations-on-

the-rise.html 62 http://www.duh.de/home.html 63 http://www.aecc.eu/en/content/pdf/AECC%20Newsletter%20July-August%202014.pdf

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Figure 64: German low-NOx blue environmental badge

UK: The Low Carbon Vehicle Partnership’s64 voluntary label (fuel economy label) shows how much of the greenhouse gas carbon dioxide a vehicle emits and relates that figure to the vehicle tax that must be paid. Conformity with the label’s standard is verified by the company or organization applying for the label (first party)65. The fuel economy label (Figure 65) illustrates to car buyers – at the point of sale – the running costs and fuel efficiency of new cars. The label clearly shows that choosing a car with lower CO2 emissions means lower running costs and lower tax66.

Figure 65: UK Fuel Economy Label

Metropolitan area of Barcelona: The ‘ecolabel’ for vehicle fleets and environmental policies in the metropolitan area of Barcelona is shown in Figure 66. It is a regional ecolabel, awarded by the Catalan Government, and recognizes products and services that comply with defined environmental quality requirements67,68. The objectives are: i) to minimize environmental impacts and to promote sustainable development going further the current regulations, ii) to reduce PM10 and NOx emissions from transport, iii) to reduce greenhouse gas emissions from transport and increase competitiveness thanks to the reduction of energy costs, and iv) to

64 http://www.lowcvp.org.uk/ 65 http://www.ecolabelindex.com/ecolabel/uk-fuel-economy-label 66 http://www.dft.gov.uk/vca/fcb/fuel-consumption-labelling.asp 67 http://www.ecolabelindex.com/ecolabel/emblem-of-guarantee-of-environmental-quality-catalonia 68 http://www.clean-fleets.eu/news/news-archive/july-2013/

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promote eco-efficiency and energy savings in the planning, design, and management of the transport system.

Figure 66: The Catalan ecolabel: the emblem of guarantee of environmental quality

The EEV standard

The EEV (Enhanced Environmentally-friendly Vehicle) has been a successful example of voluntary standard in the past, primarily focused on urban buses and coaches. Although already introduced in 1999 with Directive 1999/96/EC69, it has been the lowest limits standard until the introduction of Euro VI in 201370. In addition to conventional diesel technologies that made it into EEV (with engine measures and/or advanced exhaust aftertreatment), natural gas and biogas, ethanol fuelled, and even diesel-hybrid buses became popular in several European cities. The emission reductions of EEV compared to Euro V are as follows.

Carbon monoxide (CO) reduced by 25% in transient cycles (city, metropolitan start-stop operations).

Particulate matter (PM) or soot emission reduced by 33% in transient cycles.

Hydrocarbons (HC) reduced by 46% in steady cycles (highway, constant speed operations).

Smoke (ELR) reduced by 70%.

EEV promoted the introduction of compliant vehicles already since the beginning of 2000s and has significantly assisted local authorities in meeting their local air quality targets. The rationale with its introduction was to provide a possibility for local governments facing tough environmental pressures to provide incentives for the introduction of super clean vehicles in their controlled captive fleets (Ntziachristos and Galassi, 2014). Appropriate logos have been used by fleet operators, manufacturers, etc. to indicate vehicle compliance with this voluntary standard71,72,73,74. The main benefits from EEVs for the operators were free (or low cost) access in low emission zones and reduced tolls in motorways.

69 Directive 1999/96/EC of the European Parliament and of the Council of 13 December 1999 on the

approximation of the laws of the Member States relating to measures to be taken against the emission of gaseous and particulate pollutants from compression ignition engines for use in vehicles, and the emission of gaseous pollutants from positive ignition engines fuelled with natural gas or liquefied petroleum gas for use in vehicles and amending Council Directive 88/77/EEC.

70 http://dieselnet.com/standards/eu/hd.php 71 http://www.smidl.cz/userfiles/image/o-nas/eev-logo.png 72 http://img.masiniverzi.ro/2009/12/screen-capture-13.png 73 http://www.birminghamselfstorage.co.uk/images/Slide-eev.jpg 74 http://www.cvdealer.co.uk/images/iveco%20EcoDaily2small.jpg

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Annex II: Supporting information for section 4 “Assessment of likely public response to EULES”

Questionnaire

Block A. Self-reported purchase process

Class and models

Q1. Which of the following classes does your car belong to? (more than one answers only if you or your family possess more than one car) Micro-car (e.g., Smart ForTwo, Fiat Panda) Supermini (e.g., Peugeot 208, Volkswagen Polo, Renault Clio) Small family car (e.g., Ford Focus, Volkswagen Golf, Citroën C4) Large family car (e.g., Renault Laguna, Volkswagen Passat, Ford Mondeo) Executive car (e.g., BMW 5 series, Mercedes E-Class, Audi A6) Roadster/Sport car (e.g., Mazda Miata, Audi TT, Porsche Cayman) Sport Utility Vehicle (SUV) (e.g., BMW X1, Toyota RAV4, Hyundai Santa Fe) Small Multi Purpose Vehicle (MPV) (e.g., Opel Meriva, Renault Scénic, Ford B

Max) Large Multi Purpose Vehicle (MPV) (e.g. Renault Espace, Ford S-Max,

Volkswagen Sharan) I can’t tell/do not understand: please indicate what car(s) do you have

………………………… I do not have a car (to be used for filter and skip indication) I have never bought a car (to be used for filter and skip indication)

Q2. What type of engine is used in your car(s)? (more than one answers only if you or your family possess more than one car) Diesel Gasoline Alternative fuel (e.g., bio fuel, CNG, LPG) Hybrid

Gasoline Diesel

Electric I can’t tell/do not understand: please indicate what engine is used in your

car(s)……………

Q3. How old is your car? One year or less More than one - up to three years More than three – up to six years More than six – up to nine years ago More than nine years ago

Q4. From which of the following engine car(s) would you select your next car, if you

were going to buy one? (Maximum three answers) Diesel Gasoline Alternative fuel (e.g., bio fuel, CNG, LPG) Hybrid

o Gasoline o Diesel Electric I can’t tell/do not understand

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Dynamics of purchase process

Q5. How do you intend to purchase your next car? From a car dealer From a second-hand occasion (e.g., from another person) I will receive a car from the company, for which I work.

Q6. How often do you use your car for the following activities?

Daily Several times a week

Once a week

Several times a month

Once a month

Several times a

year

Never

Commuting to work

Transferring kids to/from school

Shopping

Holidays

Weekend getaways

Main attributes/factors considered

Q7. Please think about the attributes of a car that are important when you consider which car to buy. Please state how much you agree with each of the statements presented below using a scale from 1 to 7 concerning the importance/awareness of several attributes and factors influencing your car purchase decision (1= very important and/or I am very aware of it; 7= not important and/or I am not aware of it)

Not

important at all 1

2 3 4 5 6 Very

important 7

Price Daily habits Size Fuel consumption Maintenance costs Performance (acceleration, top speed, etc.) Road safety Class/model specific taxation and/or incentives

Type of engine (e.g., diesel, gasoline, electric)

Social status Impact that the car has on local air quality Customization of the car (e.g., comfort, equipment, number of seats, reliability)

Environmental performance: CO2 and/or other emissions

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Q8. I would like you to think carefully about the process followed in choosing a car. Please state how much do you agree to each of the statements presented below using a scale from 1 to 7.

Totally Disagree 1

2 3 4 5 6 Totally Agree 7

The main criterion of choice is price I am ready to pay more to guarantee environmental protection for a more environmentally-friendly model

I am ready to pay more for a more fuel efficient model

I select the car among those belonging to a size class (e.g., mini, family car, sport utility vehicle, etc.)

I select the car among those belonging to a certain class, defined according to type of engine (e.g., diesel, gasoline, electric)

Environmental effects (emissions) are the main factor in defining the current class of cars

Health effects (e.g., respiratory disease) may convince me to select a different class of car (e.g., from sport utility vehicle to midsize car)

I am aware that by choosing a less polluting car, I can help lower the levels of air pollution

I believe that by choosing a less-polluting car, I contribute to reducing the burden of certain diseases (like stroke, asthma or lung cancer)

Before choosing my car, I have already decided on its size

Before choosing the car, I have already decided on its engine type (e.g., gasoline, diesel, hybrid, etc.)

Before choosing my car, I have already decided on the price range

Before choosing my car, I have already decided on the range of the maintenance costs

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Block B. Contextual factors

Present - future attitudes

Q9. For each of the statements below, please indicate whether or not the statement is characteristic of you. If the statement is extremely uncharacteristic of you (not at all like you) please fill-in a "1" on the answer sheet; if the statement is extremely characteristic of you (very much like you) please fill-in a "5" on the answer sheet. You can also use the numbers in the middle if you fall between the extremes.

___1. I consider how things might be in the future, and try to influence those things with my day-to-day behaviour.

___2. Often I engage in a particular behaviour in order to achieve outcomes that may not result for many years.

___3. My behaviour is only influenced by the immediate (i.e., a matter of days or weeks) outcomes of my actions.

___4. My convenience is a big factor in the decisions I make or the actions I take. ___5. I am willing to sacrifice my immediate happiness or well-being in order to achieve future

outcomes. ___6. I think it is important to take warnings about negative outcomes seriously even if the

negative outcome will not occur for many years. ___7. I generally ignore warnings about possible future problems because I think the problems

will be resolved before they reach crisis level. ___8. I think that sacrificing now is usually unnecessary since future outcomes can be dealt

with at a later time. ___9. I only act to satisfy immediate concerns, figuring that I will take care of future problems

that may occur at a later date.

___10. Since my day to day work has specific outcomes, it is more important to me than behaviour that has distant outcomes.

Q10. Suppose, from next year onwards, only low-emitting cars would be allowed to

access into the city centre. On a scale from 1 to 7, would you...

Very likely 7 6 5 4 3 2 Not likely at all 1 Stop at the fringe of the city centre Pay the higher access fee for the higher emitting car

Switch to public transport, walk or bike for the trip

Buy a low-emitting car I'm not affected

143

Health attitudes

Q11. For each of the statements below, please indicate whether or not the statement is characteristic of you. If the statement is extremely uncharacteristic of you (not at all like you) please fill-in a "1" on the answer sheet; if the statement is extremely characteristic of you (very much like you) please fill-in a "7" on the answer sheet. You can also use the numbers in the middle if you fall between the extremes.

___1. I make a link between health and the environment. I understand that high pollution emissions could make me sick.

___2. I am concerned about negative future consequences to my health due to my daily choices.

___3. I am afraid of getting seriously sick because of the high levels of pollution.

___4. I feel very well informed about the level of air pollution in my city.

Faith in others, perceived consumer effectiveness, perceived compromise

Q12. Please state how much you agree with each of the statements presented below using a scale from 1 to 7.

Totally Disagree 1


Most people are willing to pay higher prices to protect the environment

Most people do their part to protect the environment

My lifestyle can have an impact on the environment

It is too hard for someone like me to do much about the environment

Vehicles that produce less pollution are probably more expensive to buy

Vehicles that produce less pollution consume less fuel

Vehicles that produce less pollution probably have lower performance

Most people are aware of the link between the environment and health

My lifestyle can have an impact on my health as well as on that of others

144

Q13. Some authorities have already adopted policies (e.g., lower taxes and other incentives) to increase the number of cars with less environmental impact. Could you tell how important the following items are when selecting a car and/or calculating its full costs?

Very important 7

6 5 4 3 2 Not important at all 1

Road tax based upon emissions tests Subsidy for purchase of less polluting car

Subsidy for scrapping old car Subsidy for purchasing an electric or hybrid car

Total or partial exemption to registration and road taxes for electric and hybrid vehicles

Access fees to the city based upon emission tests

Reduced parking fees based upon emission tests

Preferential access to electric charging points

I don’t know, I’m not aware of any policies in favour to reduce air pollution from the passenger cars

Yes / No

Q14. Please state to what extent you agree with each of the statements presented below using a scale from 1 to 7.

Totally Disagree 1


The price of my vehicle is highly affected by environmental tax (e.g., carbon tax)

I agree that my governments may charge me, via the road and registration tax, in proportion to the environmental burden produced by my car

I agree with policies that exempt electric vehicles from [certain] taxes

The government should support the purchase of environmentally-friendly (e.g., electric, hybrid, bi-fuel) vehicles by providing more incentives for them

I believe that governments should apply ‘road pricing’ (e.g., road tax, registration tax) for major metropolitan areas (e.g., cities with over 100 000 inhabitants and their suburbs)

I already pay too much in environmental taxes on my car

145

Block C. Environmental and health impact awareness of car usage

Q15. In your opinion, what is the level of air pollution in your city/neighbourhood?

Very low 1 2 3 4 5 6 Very high 7

Q16. How do you think that the level of air pollution changed over the past ten years?

Improved Deteriorated Stayed the same I do not know

Q17. In your opinion, which of the following would be the most effective way of

tackling air-related problems?

Totally Disagree 1


Applying stricter pollution controls on industrial and energy production activities (e.g., by requiring the application of best available technology)

Providing higher financial incentives (e.g., tax breaks, subsidies) for low-emitting products

Providing more information to the public on the health and environmental protection

Ensuring better enforcement of existing air quality legislation

Introducing stricter air quality legislation Increasing taxation on air-polluting activities

Q18. Please state how much you agree with each of the statements below, using a

scale from 1 (Totally disagree) to 7 (Totally agree).

Totally Disagree 1


Cars contribute significantly to the air pollution in my city/ neighbourhood

Cars’ pollution is not the main cause of the deterioration of the environment

Cars’ pollution is not the main cause of the deterioration of human health

Q19. Please indicate your preference in your daily way of travelling between driving your car or each of the options listed below.

Low preference for private car 1

2 3 4 5 6 Strong preference for private car 7

Train Metro, tram and bus

Car pooling Walking and bicycle

146

Q20. Imagine that soon older cars could be banned from driving in the city at large

during episodes of high air pollution. Would you...

Very likely 7

6 5 4 3 2 Not likely at all 1

Park at the outskirts of the city Switch to public transport, walk or bike for the trip

Buy a low-emitting car I'm not affected

Q21. Generally speaking, please state how satisfied are you with the following issues

in your city?

Totally unsatisfied 1

2 3 4 5 6 Totally satisfied 7

Road infrastructure Public transportation infrastructure Parking zones Cost of public transportation Creation of low-emission zones Access to electric charges for electric vehicles

Block D. Awareness, Trust and effect of labels

Awareness and trust

Q22. Please state to what extent do you agree with each of the statements presented below using a scale from 1 Totally disagree to 7 Totally agree.

Totally agree 7

6 5 4 3 2 Totally disagree 1

I am familiar with car labels Car labels are easily recognizable for me I am unfamiliar with car labels Car labels are a symbol of a product’s trustworthiness

I believe that information contained in car labels is truthful

I believe that information contained in car labels is sufficient

I don’t trust the information in car labels I base my decision upon a (or several) car labels

147

Q23. Suppose that you have a higher-emitting car and learn that from next year onwards, low-emitting cars would get substantially cheaper parking places in the city centre. Would you...

Very likely 7 6 5 4 3 2 Not likely at all 1 Park at the fringe of the city centre Pay the higher parking fee for the higher emitting car

Switch to public transport, walk or bike for the trip

Buy a low-emitting car I don't care, I'm not affected

Q24. People may have different reasons to look at environmental label when they buy

a car. Please state to what extent you agree with each of the statements presented below regarding why other people look at environmental and health variables using a scale from 1 to 7.

Totally agree 7


To check if what said in advertisement is actually true

To check the features of a brand To compare different classes of vehicles To get a general idea of the product To have an idea about fuel consumption To see if they can get a tax exemption, tax credit, or any other benefit from the municipalities, like free access to parking space

Q25. People state that that they do not look at an environmental label related to emissions and air quality when buying a car. Please state to what extent you agree with each of the reasons presented below for not looking at the information from an air pollution label, using a scale from 1 to 7.

Totally agree 7


Because all cars pollute more or less the same Because these labels are not clear Because it is hard to understand what they mean in terms of environmental impact and savings on gas consumption

Because it is hard to understand what they mean in terms of health impact

Because these people only care about the price of the car

Because they choose according to other parameters

Because, once they have selected a car’s class (e.g., mini, family car, sport utility vehicle, etc.), buying one model or another does not make a lot of difference

148

Q26. Imagine how WOULD you make use of the information on an air pollution label. Please state to what extent you agree with each of the statements presented below using a scale from 1 to 7.

Totally agree 7


I would check if what it says is actually true I would compare different brands of vehicles I would compare different classes of vehicles (e.g., mini, family car, sport utility vehicle, etc.)

I would get a general idea of the product from the label

I would get info on whether I could get a tax exemption from the label

I would get info on whether I could get any other benefit from the municipalities, like free parking place or free access

Block E. Socio-demographics

Q27. Gender Female Male

Q28. Age

____ years old

Q29. What is the highest level of education you have completed? [SINGLE ANSWER]

0-11 years of education 12 years of education (high school diploma) Some years of university (not completed) University degree completed Post-graduate (master, PhD, other)

Q30. Marital status

Single Married or equivalent

Q31. Do you have children living with you at home?

Yes No

Q32. What is your current occupation?

a. Farmer, forester, fisherman

b. Owner of a shop, craftsperson

c. Liberal professional/ independent expert (lawyer, medical doctor, accountant, architect…)

d. Manager of a company

e. General management, director or top management

f. Middle management

g. Civil servant

h. Office clerk

i. Other employee (salesperson, nurse, etc...)

149

j. Specialised manual worker

k. Supervisor/foreman (team manager, etc…)

l. Manual worker

m. Unspecialised manual worker

n. Other

Q33. Think of this ladder as representing where people stand in your country. At the top of the ladder are the people who are the best off – those who have the most money, the most education and the most respected jobs. At the bottom are the people who are the worst off – who have the least money, the least education, and the least respected jobs or no job. The higher up you are on this ladder, the closer you are to the people at the very top; the lower you are, the closer you are to the people at the very bottom. If you consider your current situation and compare it with all other people in your country, where would you place yourself on this ladder?75

Q34. In your household, which best describes your role in purchasing cars?

I am the person who makes all the purchases I share purchasing responsibility with others in the household I never make these purchases Other – please specify________________________

Q35. When did your family buy your last car?

We never bought a car Less than three years ago Between three and five years ago Between five and ten years ago More than ten years ago

75 Adler N.E. and Stewart J. (2007), The MacArthur scale of subjective social status. Available at

http://www.macses.ucsf.edu/research/psychosocial/subjective.php.

150

Fieldwork process

Table 44 summarises the interview distribution by overall data and country within the fieldwork process:

8,500 of 19,796 received responses were deleted, mainly because they did not fall into the required quotas (5,420) or they have been rejected by target (2,130) or they have been rejected by quality control (950). The criteria for rejecting a response were incompleteness, duration and/or poor consistency of responses.

To achieve 6,400 responses, it was necessary to send 77,381 invitations to the panel, from which, 19,796 responses were received.

In the majority of countries, the panel had information on parent status and young children; only the Dutch panel did not have this information. For this reason we have differences between the Netherlands and other countries in number of invitations, rejected, etc.

It explains also why we have needed additional time to achieve the number of interviews required.

Not all panels with information had the same type of information about the age of the children. On account of this, there are differences between panels in terms of invitations, screenout or timeout.

Table 44: Indicators of the fieldwork process

Country Invitations Non

responses Responses Screenout

Out of

quota

Time

out Rejected Sample

Germany (DE) 9,696 7,757 1,939 486 171 381 101 800

Spain (ES) 3,318 1,577 1,741 192 385 221 143 800

Italy (IT) 2,656 846 1,810 434 90 339 147 800

Ireland (IE) 3,502 1,583 1,919 371 188 479 81 800

Netherlands

(NL) 28,073 22,776 5,297 2,422 226 1,705 144 800

Czech

Republic (CZ) 7,489 5,803 1,686 177 325 268 116 800

Lithuania (LT) 19,026 15,944 3,082 897 270 996 119 800

United

Kingdom (UK) 6,610 4,288 2,322 441 475 507 99 800

Total 77,381 57,585 19,796 5,420 2,130 4,896 950 6,400

Lastly, the average interview length was 23 minutes, with considerably homogenous results per country, varying between 21 and 26 minutes. Table 45 summarises the average interview length data per country:

151

Table 45: Interviews length

Country Interview length

Germany (DE) 23 min

Spain (ES) 22 min

Italy (IT) 21 min

Ireland (IE) 23 min

Netherlands (NL) 23 min

Czech Republic (CZ) 26 min

Lithuania (LT) 24 min

United Kingdom (UK) 21 min

Average 23 min

Table 46 shows the car’s experiment data collection schedule for the different countries.

Table 46: Data collection schedule

Country Sample Launch date Completion

Large 1,600 03.12.2015 15.12.2015

Germany (DE) 200 04.12.2015 15.12.2015

Spain (ES) 200 03.12.2015 15.12.2015

Ireland (IE) 200 03.12.2015 15.12.2015

Italy (IT) 200 03.12.2015 13.12.2015

Netherlands (NL) 200 04.12.2015 11.12.2015

Czech Republic (CZ) 200 04.12.2015 10.12.2015

Lithuania (LT) 200 03.12.2015 15.12.2015

United Kingdom (UK) 200 04.12.2015 15.12.2015

Small 1,600 03.12.2015 15.12.2015

Germany (DE) 200 03.12.2015 15.12.2015

Spain (ES) 200 04.12.2015 15.12.2015

Ireland (IE) 200 04.12.2015 15.12.2015

Italy (IT) 200 04.12.2015 15.12.2015

Netherlands (NL) 200 03.12.2015 15.12.2015

Czech Republic (CZ) 200 03.12.2015 14.12.2015

Lithuania (LT) 200 04.12.2015 15.12.2015

United Kingdom (UK) 200 03.12.2015 15.12.2015

Total 3,200

152

Table 47 summarises the interview distribution by overall data and country within the fieldwork process.

Table 47: Indicators of the fieldwork process

Country Invitations Non

responsesReponses Screenout

Out of quota

Time out

Rejected Sample

Large 5,658 3,134 2,524 14 746 49 115 1,600

Germany 823 330 493 1 263 10 19 200

Spain 583 316 267 0 40 11 16 200

Ireland 936 652 284 1 70 5 8 200

Italy 409 182 227 4 12 5 6 200

Netherlands 749 406 343 1 105 8 29 200

Czech Republic

665 446 219 1 12 0 6 200

Lithuania 633 274 359 5 139 1 14 200

United Kingdom

860 528 332 1 105 9 17 200

Small 6,166 3,948 2,218 23 429 68 98 1,600

Germany 805 563 242 0 18 12 12 200

Spain 482 242 240 4 17 12 7 200

Ireland 974 655 319 0 83 15 21 200

Italy 460 230 230 4 8 11 7 200

Netherlands 816 580 236 2 19 4 11 200

Czech Republic

585 340 245 1 35 2 7 200

Lithuania 549 305 244 7 27 1 9 200

United Kingdom

1,495 1,033 462 5 222 11 24 200

Total 11,824 7,082 4,742 37 1,175 117 213 3,200

153

Factor analysis: purchase process

Table 48: Purchase process (Q8) factor analysis – Correlation matrix

Statement 1 2 3 4 5 6 7 8 9 10 11 12 13 The main criterion of choice is price I am ready to pay more to guarantee environmental protection for a more environmentally-friendly model

.022


.063**

.641**

I select the car among those belonging to a size class (e.g.. mini. family car. SUV. etc.)

.219**

.239**

.324**

I select the car among those belonging to a certain class. defined according to type of engine (e.g.. diesel. gasoline. electric)

.194**

.299**

.380**

.498**


.122** .664** .443** .268** .389**

Health effects (e.g.. respiratory disease) may convince me to select a different class of car (e.g.. from SUV to midsize car)

.073** .624** .419** .230** .312** .692**

I am aware that by choosing a less polluting car. I can help lower the levels of air pollution

.131** .379** .350** .258** .314** .468** .425**

I believe that by choosing a less-polluting car. I contribute to reducing the burden of certain diseases (like stroke. asthma or lung cancer)

.118** .544** .443** .245** .297** .587** .607** .605**

Before choosing my car. I have already decided on its size

.226** .183** .253** .474** .391** .196** .183** .301** .265**

Before choosing the car. I have already decided on its engine type (e.g.. gasoline. diesel. hybrid. etc.)

.170** .221** .229** .354** .554** .304** .250** .274** .254** .494**

Before choosing my car. I have already decided on the price range

.444** .057** .141** .355** .308** .123** .097** .317** .165** .459** .395**

Before choosing my car. I have already decided on the range of the maintenance costs

.388** .260** .234** .299** .340** .356** .320** .250** .268** .388** .402** .506**

Note: Extraction Method: Principal Component Analysis. Rotation Method: Varimax with Kaiser Normalization.

154

Table 49: Purchase process (Q8) factor analysis – Varimax rotated factor matrix

Variable Factor 1

(Health and Environment)

Factor 2 (Class)

Factor 3 (Cost)

I am ready to pay more to guarantee environmental protection for a more environmentally-friendly model

0.83 0.16 0.07


0.83 0.15 0.11

Health effects (e.g., respiratory disease) may convince me to select a different class of car (e.g., from SUV to midsize car)

0.82 0.09 0.09

I believe that by choosing a less-polluting car, I contribute to reducing the burden of certain diseases (like stroke, asthma or lung cancer)

0.79 0.11 0.16


0.63 0.35 - 0.09

I am aware that by choosing a less polluting car, I can help lower the levels of air pollution

0.60 0.18 0.27

I select the car among those belonging to a certain class, defined according to type of engine (e.g., diesel, gasoline, electric)

0.28 0.75 0.07

Before choosing the car, I have already decided on its engine type (e.g., gasoline, diesel, hybrid, etc.)

0.16 0.72 0.20

I select the car among those belonging to a size class (e.g., mini, family car, SUV, etc.)

0.17 0.72 0.13

Before choosing my car, I have already decided on its size

0.10 0.70 0.31

The main criterion of choice is price 0.02 0.04 0.81

Before choosing my car, I have already decided on the price range

0.01 0.40 0.73

Before choosing my car, I have already decided on the range of the maintenance costs

0.27 0.30 0.65


155

Factor analysis: present-future attitudes

Table 50: Present-future attitude (Q9) factor analysis – Correlation matrix

Statement 1 2 3 4 5 6 7 8 9 I consider how things might be in the future, and try to influence those things with my day-to-day behaviour.

Often I engage in a particular behaviour in order to achieve outcomes that may not result for many years.

.592**

My behaviour is only influenced by the immediate (i.e., a matter of days or weeks) outcomes of my actions

.025 .118**

I am willing to sacrifice my immediate happiness or well-being in order to achieve future outcomes

.407** .444** .144**

I think it is important to take warnings about negative outcomes seriously even if the negative outcome will not occur for many years.

.478** .389** -.014 .374**

I generally ignore warnings about possible future problems because I think the problems will be resolved before they reach crisis level.

-.019 .080** .442** .154** -.141**

I think that sacrificing now is usually unnecessary since future outcomes can be dealt with at a later time.

.010 .074** .425** .085** -.120** .610**

I only act to satisfy immediate concerns, figuring that I will take care of future problems that may occur at a later date.

.023 .079** .486** .128** -.088** .549** .594**

Since my day to day work has specific outcomes, it is more important to me than behaviour that has distant outcomes.

.193** .242** .403** .229** .090** .393** .439** .490

156

Table 51: Present-future attitude (Q9) factor analysis – Varimax rotated factor matrix

Variable Factor 1 (Present)

Factor 2 (Future)

I only act to satisfy immediate concerns, figuring that I will take care of future problems that may occur at a later date.

0.82 - 0.00

I think that sacrificing now is usually unnecessary since future outcomes can be dealt with at a later time.

0.81 - 0.04

I generally ignore warnings about possible future problems because I think the problems will be resolved before they reach crisis level.

0.80 - 0.04

My behaviour is only influenced by the immediate (i.e., a matter of days or weeks) outcomes of my actions

0.70 0.06

Since my day to day work has specific outcomes, it is more important to me than behaviour that has distant outcomes.

0.67 0.27

I consider how things might be in the future, and try to influence those things with my day-to-day behaviour.

0.00 0.82

Often I engage in a particular behaviour in order to achieve outcomes that may not result for many years.

0.12 0.79

I think it is important to take warnings about negative outcomes seriously even if the negative outcome will not occur for many years.

- 0.16 0.74

I am willing to sacrifice my immediate happiness or well-being in order to achieve future outcomes

0.18 0.69


Car labels correlation matrix

Table 52: Car labels – Correlation matrix

Statement 1 2 3 4 5 6 7 8 I am familiar with car labels

Car labels are easily recognizable for me

.829**

I am unfamiliar with car labels

-.428** -.406**

Car labels are a symbol of a product's trustworthiness

.326** .369** .044*

I believe that information contained in car labels is truthful

.329** .361** .014 .636**

I believe that information contained in car labels is sufficient

.351** .380** .025 .532** .697**

I don't trust the information in car labels

.056** .034 .213** -.097** -.280** -.157**

I base my decision upon a (or several) car labels

.446** .457** -.035* .483** .453** .457** .101**

Note: p<0.001 Source: Q22 (N=3200)

157

Online experiment effects – Small cars

Online experiment effects – Large cars

Online experiment Effect Likelihood Ratio tests – Small cars

Online experiment Effect likelihood Ratio tests – Large cars

Column Main Ef fect Main Ef fect SE Total Ef fect Total Ef fect SE

EULES_Message 0.746 0.006 0.865 0.01

CO2_Logo 0.033 0.002 0.065 0.002

EULES_Logo 0.032 0.002 0.064 0.002

Price 0.018 0.001 0.037 0.001

Column Main Ef fect Main Ef fect SE Total Ef fect Total Ef fect SE

EULES_Message 0.65 0.007 0.775 0.01

Price 0.106 0.004 0.186 0.004

EULES_Logo 0.02 0.001 0.042 0.002

CO2_Logo 0.012 0.001 0.026 0.001

Source L-R ChiSquare DF Prob>ChiSq

Price 251.796 1 <.0001*

EULES_Message 2169.130 2 <.0001*

EULES_Logo 167.296 1 <.0001*

CO2_Logo 203.018 1 <.0001*

Source L-R ChiSquare DF Prob>ChiSq

Price 1286.676 1 <.0001*

EULES_Message 1555.362 2 <.0001*

EULES_Logo 73.718 1 <.0001*

CO2_Logo 39.794 1 <.0001*

158

Online experiment marginal probabilities small cars

Online experiment marginal probabilities large cars

Marginal Probability Marginal Utility Price

0.5801 0.16156 10000

0.4199 ‐0.16156 10700

Marginal Probability Marginal Utility EULES_Message

0.1559 ‐0.65014 Access

0.3372 0.12114 Health

0.5069 0.52900 Taxes

Marginal Probability Marginal Utility EULES_Logo

0.4353 ‐0.13022 NO_EULES_L

0.5647 0.13022 YES_EULES_L

Marginal Probability Marginal Utility CO2_Logo

0.4344 ‐0.13191 NO_CO2_L

0.5656 0.13191 YES_CO2_L

Marginal Probability Marginal Utility Price

0.6576 0.32639 25000

0.3424 ‐0.32639 26200

Marginal Probability Marginal Utility EULES_Message

0.1876 ‐0.50757 Access

0.3465 0.10578 Health

0.4659 0.40180 Taxes

Marginal Probability Marginal Utility EULES_Logo

0.4598 ‐0.08063 NO_EULES_L

0.5402 0.08063 YES_EULES_L

Marginal Probability Marginal Utility CO2_Logo

0.4709 ‐0.05835 NO_CO2_L

0.5291 0.05835 YES_CO2_L