Air pollution standards for non-road engines

This paper is a response from Transport & Environment to the ‘Consultation on the revision of Directive 97/68 on emissions from non-road mobile machinery engines’ by the European Commission. 

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Our key points are:
• Given serious persistent air quality problems in Europe, Euro VI levels for heavy duty onroad engines should serve as a benchmark for new standards for NRMM. We are concerned with the much lower ambition levels hinted at in the consultation document.
• In particular there is a need to solve the problem of diesel particles, and related black carbon, once and for all by introducing Euro VI equivalent standards for particle number count for all engines covered;
• The scope of the legislation should be extended to also cover engines below 37kW and above 560 kW, and by also including stationary applications (e.g. diesel generators, air conditioning engines);
• Following developments in standards for the on-road sector, we would prefer moving towards a regulation instead of a directive;
• Standards should be fuel-neutral.
• Greenhouse gas emissions (CO2 and CH4) should be measured and reported;
• Exemptions, flexibilities etc. should be cut drastically so that it is impossible to sell machinery equipped engines complying with an old standard a limited time after entry into force of the standard;
• In-service emissions need to be a top priority. As a minimum, relevant provisions of Euro VI legislation should be copied to also cover non-road engines;
• Emissions from existing engines need to be addressed;
• Transparency should be ensured by mandatory public