Questionnaire to car manufacturers - European Parliament Reply... · A2 For Nissan the required...
4
NISSAN INTERNATIONAL SA Zone d’Activité La Pièce 12 1180 Rolle Switzerland Phone: +41 21 822 57 00 Fax: +41 21 822 51 21 Questionnaire to car manufacturers No Question Q1 In previous hearings we have heard that the exhaust systems are vulnerable to clogging and corrosion. Can you describe how you as a producer adapted the materials used in order to fulfil warranty requirements, leak-free assembly requirements and customer demands for long service life? A1 The exhaust system is designed based on the required conversion ratio (for pollutants and soot) in life cycle to fulfil engine out performance and reliability requirements. However, if the engine- out emissions change due to unexpected behaviour (malfunction of EGR system for example) then the Exhaust system could be damaged and driver safety could be at risk. This situation is properly controlled by the Engine Control System. Materials are selected during the life cycle to fulfil emission performance and reliability and safety requirements based on available technology in each generation. Q2 What is the effect of the higher temperatures that SCR needs to properly function with the materials used? A2 For Nissan the required temperatures for SCR's urea chemical reactions are not a challenge from a point of view of the materials used. The current exhaust system is built to allow DPF regenerations, which are at a much higher temperature than the required by SCR. Q3 On average, how much does a diesel emissions reduction system cost when purchased and built in? Could you please specify these prices for an exhaust gas recirculation (EGR) system, a NOx storage catalytic converter (NOx trap) and a Selective Catalytic Reduction (SCR) system? And how much would a combination of multiple systems like these costs? In your experience: How many of these costs can be passed on to the buyer? A3 It is difficult to provide a figure for an “average” diesel emission system as there are a large number of variables to take into account. A very hypothetical figure for an "average passenger car" will give an extra cost in the range of €1,200 to change from existing E6b system to Eu6d (w/RDE). This cost will include the enhanced EGR technology and its cooling and SCR after-treatment instead of LNT (or for some application the combination of both SCR & LNT). Each part’s cost depends on system configuration, layout, number of components, raw materials used, etc… Nissan vehicles are not in the luxury sector of the market. Our customers are price sensitive so careful consideration would have to be given to the way that any increase in production costs was passed onto the customer. Q4 Why did car manufacturers focus mostly on the legal testing cycle NEDC if they knew that ¡t was far from reality and had nothing in common with real emissions? Was it not possible to orientate yourself towards real driving emissions (RDE) -like values from the beginning to generate more trust from the costumer? Why did the automobile industry not take the initiative on its own and communicated more realistic exhaust values of their products? A4 The NEDC testing cycle is currently set out in Regulation (EU) 715/2007 that established that NEDC is the mandatory test to fulfil. At the time that these regulations were written and bought into effect they reflected available vehicle and testing technology. The only way to test vehicle performance was in a laboratory under controlled conditions. The purpose of the testing regime was to allow consumers to compare the emissions performance of vehicles on a like for like basis. In recent years technology has advanced which has allowed the on road testing of vehicle emission
Transcript of Questionnaire to car manufacturers - European Parliament Reply... · A2 For Nissan the required...
NISSAN INTERNATIONAL SAZone d’Activité La Pièce 121180 RolleSwitzerlandPhone: +41 21 822 57 00Fax: +41 21 822 51 21
Questionnaire to car manufacturersNo QuestionQ1 In previous hearings we have heard that the exhaust systems are vulnerable to clogging and
corrosion. Can you describe how you as a producer adapted the materials used in order to fulfilwarranty requirements, leak-free assembly requirements and customer demands for longservice life?
A1 The exhaust system is designed based on the required conversion ratio (for pollutants and soot) in lifecycle to fulfil engine out performance and reliability requirements. However, if the engine- out emissionschange due to unexpected behaviour (malfunction of EGR system for example) then the Exhaustsystem could be damaged and driver safety could be at risk. This situation is properly controlled by theEngine Control System.
Materials are selected during the life cycle to fulfil emission performance and reliability and safetyrequirements based on available technology in each generation.
Q2 What is the effect of the higher temperatures that SCR needs to properly function with thematerials used?
A2 For Nissan the required temperatures for SCR's urea chemical reactions are not a challenge from apoint of view of the materials used. The current exhaust system is built to allow DPF regenerations,which are at a much higher temperature than the required by SCR.
Q3 On average, how much does a diesel emissions reduction system cost when purchased andbuilt in? Could you please specify these prices for an exhaust gas recirculation (EGR) system, aNOx storage catalytic converter (NOx trap) and a Selective Catalytic Reduction (SCR) system?And how much would a combination of multiple systems like these costs?In your experience: How many of these costs can be passed on to the buyer?
A3 It is difficult to provide a figure for an “average” diesel emission system as there are a large number ofvariables to take into account. A very hypothetical figure for an "average passenger car" will give anextra cost in the range of €1,200 to change from existing E6b system to Eu6d (w/RDE). This cost willinclude the enhanced EGR technology and its cooling and SCR after-treatment instead of LNT (or forsome application the combination of both SCR & LNT).
Each part’s cost depends on system configuration, layout, number of components, raw materials used,etc…
Nissan vehicles are not in the luxury sector of the market. Our customers are price sensitive so carefulconsideration would have to be given to the way that any increase in production costs was passed ontothe customer.
Q4 Why did car manufacturers focus mostly on the legal testing cycle NEDC if they knew that ¡t wasfar from reality and had nothing in common with real emissions? Was it not possible to orientateyourself towards real driving emissions (RDE) -like values from the beginning to generate moretrust from the costumer? Why did the automobile industry not take the initiative on its own andcommunicated more realistic exhaust values of their products?
A4 The NEDC testing cycle is currently set out in Regulation (EU) 715/2007 that established that NEDC isthe mandatory test to fulfil. At the time that these regulations were written and bought into effect theyreflected available vehicle and testing technology. The only way to test vehicle performance was in alaboratory under controlled conditions. The purpose of the testing regime was to allow consumers tocompare the emissions performance of vehicles on a like for like basis.
In recent years technology has advanced which has allowed the on road testing of vehicle emission
NISSAN INTERNATIONAL SAZone d’Activité La Pièce 121180 RolleSwitzerlandPhone: +41 21 822 57 00Fax: +41 21 822 51 21
A4cont
performance. In particular in the last 2 -3 years PEMS have advanced making RDE testing possible formanufacturers and other interested parties. This technology was not available when the majority ofvehicles currently on the road and for sale were in development.
Nissan uses the latest available technology in the development of vehicle emission control systems.Nissan vehicles are developed considering not only NEDC cycle emission system. Emission reductiondevice is activated as much as possible to fulfil reliability and safety requirements.
In terms of communicating “more realistic exhaust values of products”, communication of vehicleemissions data to consumers is regulated by European Regulation and local advertising requirements.In general terms manufacturers are required to give specific information about vehicle performance asset out in the Regulations and may not add to it.
Q5 Article 5(2) of Regulation 715/2007/EC allows for certain derogations to the prohibition of defeatdevices that reduce the effectiveness of emission control systems. Do the vehicles you producemake use of the derogation, and if so could you please describe in detail under what conditionsdo you employ the derogation?Have you indicated and justified the conditions of the operation of such defeat devices to thetype approval authority when applying to type approval? If not, why not? Were you everrequested by the technical services or type-approval authorities to provide clarifications on theuse of derogations under article 5(2)?
A5 Yes, our vehicles make use of that derogation with the exact purpose described in the 715/2007 EUregulation; that is to say for engine protection and safety.
EGR control is protected against:
1.Thermal incident by EGR system breakage in cold and Hot temperature condition
(Ambient and coolant)
2.Engine stall due to water accumulation or iced water at the I/C outlet under cold temperature condition(Ambient )
So far as we are aware we have never been asked to report any derogation of contents by anyHomologation Authority
We are ready to explain contents if Homologation Authority asks and AES / BES dossier is submitted totype approval authorities .
Q6 During recent investigations (e.g. in Germany) manufacturers admitted to using so called“thermo windows” to switch off emission control systems under certain ambient temperaturesin order to protect the engine. It has become clear that there is a broad range of temperaturesused for lower switch-off limits (e.g. below 10°C or 17°C). This suggests that the setting of thesetemperature limits are rather arbitrary. Please explain the discrepancy in temperature limits usedby car manufacturers to justify switching off emission control systems (including EGR). Arethese limits really needed to protect the engine and at which ambient temperatures?
A6 EGR setting have been defined based on reliability evaluation data obtained during the developmentphase study and market problem analysis. This setting depend on engine and vehicle characteristics foreach OEM (Engine room layout, exhaust temperature, cooling performance). As these vehiclecharacteristics are not same among different OEMs the EGR settings will be logically different.
NISSAN INTERNATIONAL SAZone d’Activité La Pièce 121180 RolleSwitzerlandPhone: +41 21 822 57 00Fax: +41 21 822 51 21
Q7 Do you use emissions control systems with different operational limits (e.g. ambienttemperature or engine loads) or quality (design, components or materials used), or of differentdurability when producing vehicles for US and EU markets? Are you aware of such discrepancybetween OEMs on the EU market?
A7 Nissan does not use the same engines for the European and US markets. Technical specifications aredesigned based on the regulations in each market, safety requirements and durability demands.We have no information concerning other OEMs.
Q8 At a meeting of transport ministers in Luxembourg on 7 June 2016, the following wording onwhen the ban on defeat devices should not apply was proposed: “even if the best availabletechnologies are included, no other technology is available to protect the engine againstdamage or accident and for safe operation of the vehicle”. In this regard, what is yourunderstanding of “the best available technologies”? Can you provide us with a list of currently“best available technologies” for lowering NOx and CO2 emissions?
A8 In our opinion, it is reasonable to say that the best Technology for Eu6d, including real drive emissionsregulation, is an SCR system and LP + HP EGR system. An additional after treatment system for (LNT)could be used for low temperature conditions.
Alternatively the best Technology for Eu6d could be said to be EGR for engine out emissions. Tocompensate CO2 the best is lean combustion by boost system.Remaining NOx can be reduced by SCR system and additional after-treatment system could berequired also for low temperature condition.
EGR has been and will continue to be one of the key technologies (for almost 20 years). In the currentEU6b environment this strategy is still able to reduce 70-80% the engine out NOx emissions. RemainingNOx to EU6b legal level can be reduced either by the use of LNT or SCR. These two technologies arecomplementary of EGR and used almost 50/50 among different OEMs in Europe.
Q9 With emissions norms progressively tightening, the introduction of the WLTP testing in 2017and new emissions measurement procedures better reflecting real-driving conditions (RDE),what is, according to your own research and experience, the optimal combination of the bestavailable technologies in order to comply with NOx and CO2 standards? Are the requiredtechnologies currently available for mass production or do they need more research anddevelopment before they can deliver the expected results? Do certain best availabletechnologies damage the engine?If yes, why?
A9 EGR systems will remain the main NOx reducer in combination with improved after-treatment systemssuch SCR or LNT, sometimes both. This after-treatment combination will be able to fulfill the newregulatory requirements (WLTP & RDE). These technologies are available for development and willfulfill reliability and safety requirements
Q10 Do you agree with the statement that the engine control unit (ECU) is a black box, without type-approval obligation and without external supervision on how it is configured or how itfunctions? Would you be in favour of the introduction of a type-approving provision for this unitwith, for instance, the possibility for the certificating authority of accessing the software and itscode, and request detailed information on the use of the software, in order to avoid anyunwanted software modifications, including unwanted modifications after type approval andbefore true production? What benefits or risks would you identify in such a procedure?
A10 Software is an important part of the emission system, so it should not remain excluded from type-approval. However, recent software is very complex and difficult to inspect as it involves many parties,not just the OEM but also the EFIE supplier and other subsystem suppliers. In our view, a real driveemission regulation together with the requirement that the AES/BES (Auxiliary Emission Strategy /base Emission Strategy) dossier should be submitted to type approval authorities, describing emission
NISSAN INTERNATIONAL SAZone d’Activité La Pièce 121180 RolleSwitzerlandPhone: +41 21 822 57 00Fax: +41 21 822 51 21
control strategies, would be a more effective solution to prevent unwanted software implementation.
Q11 From the manufacturers point of view, what kind of role other aspects such as increase engineefficiency play in the emission reduction? What kind of research is carried out, other than thepipe-end technologies, to reduce the emissions?
A11 Engine efficiency is being improved continually by Multi-injection, rail pressure up to 2500bar moreover, nozzle improvement for spray, friction etc.…
Q12 According to the JRC, exemption for the use of devices interfering with pollution controlsystems, as provided for in Article 5(2) of Regulation (EC)715/2007, are not justified from atechnical point of view as the same results (i.e. protecting the engine from damages) can beobtained in many different ways. Do you agree with this assumption? If not can you explain indetail why?
A12 We need more data from JRC to understand their view and discuss their statement in detail.
Q13 The EU law (Regulation 715/2007/EC Article 5(1)) requires manufacturers to equip vehicles so asto enable the vehicle to comply with the emission limit values contained in the Regulation “innormal use”. How do you explain the conclusions of the German Federal Motor TransportAuthority (Kraftfahrt-Bundesamt) investigation that on average the Emission ControlTechnologies are off or turned down around 75-80% of the time? Please describe in detail forwhich “normal use” conditions (temperature, altitude, engine load, etc.) your engines aredesigned to operate in Europe?
A13 We can say that all Nissan vehicles meet the regulations EU 715/2007 and EU 692/2008. "Normal use"is not defined but Nissan follows the detailed testing regime set out in the Regulation so that theemission control system works when the vehicle is in use other than in conditions where some form ofengine management is required and this is then in accordance with Article 5(2).
EU 715/2007 also recognises in Article 5(2) that there will be justification for management of theemission control system for engine protection and safe operation of the vehicle.
