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.
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