EU Adopts HDV CO2 Emissions Regulation with Room for Improvement

| Europe: Brussels

HDGAS imageThe first ever EU legislation on CO2 emissions of new heavy-duty vehicles (HDVs) registered in the EU, formally adopted Jun 25, requires emissions for Categories N2 and N3 and certain other vehicle types to be monitored and reported from 1 January 2019. The VECTO tool is adopted as the measurement tool but does it go far enough?

The Regulation is part of a series of measures to implement the 2016 European strategy on low-emission mobility. It has been broadly welcomed. Lorries, buses and coaches produce about 25% of CO2 emissions from road transport in the EU and around 6% of the EU’s total CO2 emissions. The adopted legislation sets in motion monitoring and reporting on HDVs from the start of 2019, and will later commence same procedures for smaller lorries, buses, coaches and trailers.

Monitoring and reporting measures will provide, as of 2020, the necessary data to set and implement new mandatory CO2 emission reduction targets for manufacturers of heavy duty vehicles. Failure of manufacturers to comply will result in fines being imposed.

The Commission will make the reported data publicly available in an online register managed by the European Environment Agency (EEA) The intention is to increase transparency on the market and will allow transport companies – mostly SMEs – to make significant savings thanks to lower fuel consumption, estimated at €25,000 (USD 29,250) over five years. It will also help to stimulate innovation among manufacturers.

Allocated Responsibilities and Targets

Member States will collect and submit registration data concerning all new HDVs, including trailers, registered in each calendar year. Manufacturers will monitor and report, for each new vehicle, information on CO2 emissions and fuel consumption, determined according to the certification procedure by using the Vehicle Energy Consumption Calculation Tool (VECTO).

This fuel energy efficiency simulation software measures Compressed Natural Gas (CNG) and Liquefied Natural Gas (LNG) as separate fuel types, recognising the higher energy density of LNG (MJ/kg) and its slightly reduced CO2 fuel factor (gCO2/MJ).1

With regard to the average CO2 targets, the proposal from the Commission (published within the so called Third Mobility Package on May 17th) is set as follows:

  • In 2025, 15% lower than in 2019
  • In 2030, at least 30 % lower than in 2019 (subject to review)

These targets are consistent with the EU’s commitments under the Paris Agreement. 2019 will be the first year for which official monitored CO2 emissions data for HDVs will be available.

The 2025 target is described as being based on the deployment of readily available cost-effective technologies for conventional vehicles. In fact, Volvo stated in September 2017 that although natural gas is obviously a fossil fuel, new Volvo trucks will produce 20 per cent lower CO2 emissions than diesel. If biogas is used instead, the climate impact can be cut by up to 100 per cent. IVECO and Scania are also already manufacturing low-emission HDVs.

The 2030 target is aspirational rather than fixed and is subject to a review of progress in 2022, which will then set the mandatory target for 2030; assess the modalities for implementation; and review the scope in order to cover also smaller lorries, as well as buses, coaches and trailers.

Is Tank-to-Wheel Sufficient?

Given the EC is encouraging transport operators to choose wisely, Well-to-Wheel (WTW) figures provide best opportunity to make an informed selection. Yet in the Upgrades to the existing version of VECTO and completion of certification methodology document, updated October 2017, the EC acknowledges “Currently VECTO considers only Tank to Wheel emissions (TTW). Neglecting the Well to Tank (WTT) chain does not correctly rank the real GHG impact of different propulsion technologies.” 2

Whether from fossil-based sources or from harvesting of RNG, there are varying but consistently better outcomes for gas-powered transportation compared to conventional fuels and, in the case of RNG, those outcomes vary from 80% reduction through to carbon-negative (i.e. greater than 100%). The whole fuel chain is therefore important to consider:

Westport Fuel Systems –a transportation technology company and member of NGV Global, on its Westport website discusses the benefits of  both TTW and WTW for natural gas and for renewable gas. It states: “When vehicle efficiency and tailpipe emissions are accounted for, RNG (in this case from landfill gas) can reduce the greenhouse gas emissions of natural gas heavy duty trucks by approximately 75% compared to the level produced from equivalent diesel trucks.” 3

In its 2017 benchmark study Greenhouse Gas Intensity from Natural Gas in Transport 4, Europe’s Natural and Bio Gas Association NGVA Europe reports:

— For passenger cars, on a WtW basis, natural gas reduces GHG emissions by 23% compared with petrol and by 7% compared with diesel.
— In heavy-duty applications, benefits compared to diesel amount to 16% for CNG up to 15% for LNG.
— In maritime applications, the use of LNG provides an overall Well-to-Wake benefit up to 21% compared with conventional HFO (Heavy-Fuel Oil) fuels.

A technical report from Sweden’s Luleå University of Technology notes the following: the WTW GHG reduction for the renewable methane systems analysed, compared with the reference gasoline and diesel systems, amounts to roughly 80% or more when the EU Renewable Energy Directive (RED) calculation methodology is applied. 5

Comparison only by TTW does not capture the whole of a fuel’s journey to the tank and fleet operator’s want to be fully and fairly enabled in their decision-making, especially when policy emphasis appears to favour some alternatives over others, often portrayed through policy-driven incentives.

NGVA Europe Perspective

On release of the draft policy, NGVA Europe pointed out that, considering the time period between the implementation of the VECTO tool for the CO2 emissions monitoring and the first target already in 2025, cost-effective and available solutions will be required, particularly for HDVs given their long development phase. In this respect natural gas technologies, with a high level of maturity and safety, are an immediate and available solution: tailpipe CO2 emissions are reduced from 12% up to 20% compared to diesel according to different engine technologies (cfr.” 6

NGVA Europe believes nominated targets will challenge HDV manufacturers and Member States and is particularly concerned that the EC did not take the opportunity to embrace a more comprehensive approach with regard to carbon neutrality. Not enough attention is given solutions offered by renewable natural gas (biomethane), the association states: “BioCNG and bioLNG are ready today to support the take off and acceleration of the decarbonization process for both HDVs and LDVs, providing, at the same time, an immediate benefit also on local pollutants reduction,” said Andrea Gerini, Secretary General of NGVA Europe.

Spanish transportation company Transportes Monfort is one of many European companies already embracing natural gas fuelled options. “By 2025 we aim to increase up to 50% our share of LNG trucks, currently at 7.4%,” CEO Manual Monfort told ColHD. French carrier Jacky Perrenot will have 550 gas-powered units by the end of 2018 and will target 1,000 units by end 2019.

Renewable Gas – Carbon Neutral

While combustion of biomethane, like natural gas, produces carbon dioxide (CO2), a greenhouse gas, the carbon in biogas comes from plant matter that fixed this carbon from atmospheric CO2.  Thus, biogas production is carbon-neutral and does not add to greenhouse gas emissions.  Further, any consumption of fossil fuels replaced by biogas will lower CO2 emissions. 6

1  VECTO Simulation of LNG Vehicles

2  European Commission draft final reportVECTO tool development: Completion of methodology to simulate Heavy Duty Vehicles’ fuel consumption and CO2 emissions Upgrades to the existing version of VECTO and completion of certification methodology to be incorporated into a Commission legislative proposal.

3  Westport Fuels Systems:

4  NGVA Europe Study:

5  (PDF) Methane as vehicle fuel – a well to wheel analysis (METDRIV)

6  University of Florida

Source: European Commission (and other acknowledged sources)

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