National Environment Protection (Diesel Vehicle Emissions) Measure
made under subsection 14(1) of the
National Environment Protection (Diesel Vehicle Emissions) Measure
made under subsection 14(1) of the
Contents
Head of Power for Making this Measure
Diesel Vehicle Emissions Policy Framework
6 Strategic context for the management of emissions from diesel vehicles
7 Principles for the management of emissions from diesel vehicles
8 Guidelines for developing compliance programs
Purpose and desired environmental outcome of the Measure
11 Desired environmental outcome
12 In-service Emissions Standards
Guidelines for developing programs for reducing in-service emissions
Schedule A Guidelines for the management of in-service diesel emissions
Schedule A (1) Guideline on smoky vehicle programs
Schedule A (2) Guideline on diesel vehicle emission testing and repair programs
Schedule A (3) Guideline on audited maintenance programs for diesel vehicles
Schedule A (4) Guideline on diesel vehicle retrofit programs
Introductory NoteSection 14 of the National Environment Protection Council Act 1994 and the equivalent provision of the corresponding Act of each participating State and Territory provides for the making of Measures by the NEPC and the matters to which they may relate. This Measure relates to the matters set out in paragraph 14(1)(g).
The Measure is to be implemented by the laws and other arrangements participating jurisdictions consider necessary: see Section 7 of the Commonwealth Act and the equivalent provision of the corresponding Act of each participating State and Territory. |
This Measure may be cited as the National Environment Protection (Diesel Vehicle Emissions) Measure.
This Measure commences on the date of gazettal of this Measure.
This clause defines particular words and expressions used in this Measure. Definitions of other terms that are used in particular guidelines in Schedule A are set out in the relevant guidelines.
In this Measure, unless the contrary intention appears:
ADR means an Australian Design Rule which is a National Standard determined under Section 7 of the Motor Vehicle Standards Act 1989.
Agency means a body or bodies of a participating State or a participating Territory which that State or Territory has nominated for the purposes of this Measure.
Agreement means the Intergovernmental Agreement on the Environment made on 1 May 1992 between the Commonwealth, the States, the Australian Capital Territory, the Northern Territory and the Australian Local Government Association, a copy of which is set out in the Schedule to the Commonwealth Act.
Commonwealth Act means the National Environment Protection Council Act 1994 of the Commonwealth.
Council means the National Environment Protection Council established by section 8 of the Commonwealth Act and the equivalent provisions of the corresponding Acts of each participating States and Territories.
Diesel vehicle means a passenger vehicle, omnibus or goods vehicle powered by a diesel fuelled engine and meeting the criteria for an ‘M’ or ‘N’ category vehicle under the ADRs.
Emissions test means the emissions test procedure for diesel vehicles determined by the Australian Transport Council or successor body.
In-service emissions means exhaust emissions, excluding emissions of noise, from diesel vehicles in use.
In-service Emissions Standards means standards for emissions from in-service diesel vehicles as determined by the Australian Transport Council or successor body.
National environment protection guideline means a guideline that gives guidance on possible means for achieving desired environmental outcomes.
National Environment Protection Measure (Measure) means a Measure made under section 14(1) of the Commonwealth Act and the equivalent provisions of the corresponding Acts of participating States and Territories.
NRTC means the National Road Transport Commission.
Participating jurisdiction means the Commonwealth, a participating State or a participating Territory.
Participating State means a State:
(a) that is a party to the Agreement; and
(b) in which an Act that corresponds to the Commonwealth Act is in force in accordance with the Agreement.
Participating Territory means a Territory:
(a) that is a party to the Agreement; and
(b) in which an Act that corresponds to the Commonwealth Act is in force in accordance with the Agreement.
Head of Power for Making this Measure
This Measure is made pursuant to section 14(1)(g), 14(2)(a) and 14(2)(b) of the Commonwealth Act and the equivalent provisions of corresponding Acts in participating States and Territories.
This Measure forms part of an integrated suite of approaches being implemented by participating jurisdictions to manage emissions from diesel vehicles. Four broad approaches are available to manage vehicle emissions. These are to
It is the purpose of this Measure to provide a framework for the management of in-service emissions from diesel vehicles that complements and protects the emissions improvements obtained from existing regimes. New vehicle emission standards and fuel quality standards are specified in Commonwealth legislation. Strategies to reduce vehicle use are beyond the scope of this Measure.
Diesel Vehicle Emissions Policy Framework
6 Strategic context for the management of emissions from diesel vehicles
Diesel vehicles make a disproportionately high contribution to NOx and particle air pollution from the transport sector. The diesel vehicle proportion of the transport fleet is increasing and this trend is expected to continue. Emissions from diesel vehicles have the potential to cause adverse health effects and detract from urban amenity.
The National Environment Protection (Ambient Air Quality) Measure 1998 provides national air quality standards for six criteria pollutants. The criteria pollutants include PM10 and nitrogen dioxide, of which diesel vehicles are a significant emission source.
Jurisdictions should assess the need for the management of emissions from in-service diesel vehicles as a strategic option for:
7 Principles for the management of emissions from diesel vehicles
Vehicle operators, both owners and drivers, have responsibilities that come with approval to use the road network. They must ensure that their vehicles continue to meet all applicable standards.
Governments, as regulators of on-road vehicles, need to have compliance programs in place that can ensure that operators are meeting these responsibilities. To ensure equivalent protection for the community, compliance systems should implement and achieve nationally consistent standards.
Community expectations and the impact of non-compliance need to be taken into account when assessing the adequacy of current levels of compliance.
8 Guidelines for developing compliance programs
Schedule A of this Measure contains Guidelines to assist jurisdictions to develop programs for reducing emissions from in-service diesel vehicles, in order to achieve compliance with appropriate in-service emissions standards.
Compliance programs may incorporate a combination of the approaches in the Guidelines. Emission management approaches other than those in the guidelines may also be implemented.
Compliance programs
A compliance program may include any or all of the following components:
Communications program
Compliance programs will each require a communications program to inform the target audience/s of their responsibilities, the benefits that may be gained from compliance and the implications, for the operator and the community, of non-compliance.
Developing compliance programs
The factors to be considered in developing a compliance program include:
– the availability and quality of information about operator responsibilities;
– the ‘reasonableness’ of operator responsibilities;
– equity issues; and
– a system’s credibility, efficiency, effectiveness, cost and convenience.
Compliance Program Effectiveness
The effectiveness of programs will be assessed on their ability to achieve the Goal and Desired Environmental Outcome specified in Clause 10 and Clause 11 respectively.
Purpose and desired environmental outcome of the Measure
The scope of this Measure is to provide guidelines for developing programs to minimise the deterioration in exhaust emissions performance, or improve exhaust emissions performance, from diesel vehicles while they are in service.
The Goal of this Measure is to reduce exhaust emissions from diesel vehicles, by facilitating compliance with in-service emissions standards for diesel vehicles.
11 Desired environmental outcome
The desired environmental outcome of this Measure is to reduce pollution from in-service diesel vehicles.
12 In-service Emissions Standards
The assessment of in-service emission performance of the diesel fleet requires a means of objectively assessing the emission performance of vehicles against a benchmark for acceptable emission levels.
Participating jurisdictions will use the in-service vehicle emission standards and test determined by the Australian Transport Council or successor body as the benchmark against which to assess the emission performance of diesel vehicles.
The emission standards have been developed for determining pass/fail limits for the Test and Repair Program and for comparative purposes for the Audited Maintenance Program. However, they can also be used as a benchmark for assessing the effectiveness of the other three strategies.
This Measure recognises the different degrees of impact of diesel exhaust emissions between and within participating jurisdictions. This Measure requires participating jurisdictions to assess the need to manage emissions from in-service diesel vehicles, taking into consideration the following criteria:
Where this assessment demonstrates a need to manage in-service diesel emissions, participating jurisdictions may use the Guidelines in Schedule A to develop compliance programs that are appropriate for their particular circumstances.
Vehicles crossing jurisdictional borders will be subject to the provisions of compliance programs implemented within the jurisdiction to which the vehicle has travelled.
Guidelines for developing programs for reducing in-service emissions
Schedule A provides Guidelines on five approaches for improving the maintenance and operation of in-service diesel vehicles to reduce their emissions and hence their impact on the health and amenity of the community.
Schedule A(1): Guideline on Smoky Vehicle Programs
Schedule A(2): Guideline on Emission Testing and Repair Programs
Schedule A(3): Guideline on Audited Maintenance Programs for Diesel Vehicles
Schedule A(4): Guideline on Diesel Vehicle Retrofit Programs
Schedule A(5): Guideline on Diesel Engine Rebuild Programs.
(1) It is intended that each participating jurisdiction submit a report to the Council on the following matters:
(a) Assessment of the need to take action to manage emissions from the in-service diesel fleet, utilising the criteria specified in clause 13.
(b) Description of actions taken.
A brief description of all programs implemented during the reporting year to manage emissions from in-service diesel vehicles, including any programs implemented that are not covered by the guidelines in Schedule A of this Measure.
This description should take account of:
– the scope of action required to achieve the Goal and Desired Environmental Outcome specified in this Measure; and
– any action taken and progress made to reduce emissions from in-service diesel vehicles prior to the commencement of this Measure (relevant in the first year of reporting).
(c) Assessment of the effectiveness of any actions taken.
Participating jurisdictions must assess their progress in reducing emissions from in-service diesel vehicles identified as significant contributors to air quality problems. This assessment should include:
– an estimation of any change in the proportion of diesel vehicles out of compliance with in-service emissions standards; and
– an estimation of the reduction in diesel vehicle emissions to ambient air.
(2) Participating jurisdictions must submit a report under subclause (1) to the Council by 30 September next following each reporting year. The first reporting year will end 30 June 2002.
(3) In this clause ‘reporting year’ means a year ending 30 June.
This Measure will be subject to review five years from the date of commencement, or within any lesser period determined by the Council, which will consider:
(1) the effectiveness of the Measure in achieving the Goal and Desired Environmental Outcome set out within it;
(2) the resources available for implementing the Measure; and
(3) the need, if any, for amending the Measure (in accordance with the Act), including:
Schedule A Guidelines for the management of in-service diesel emissions
The following Guidelines provide guidance on the possible means for achieving the Goal (Clause 10 of the Measure) and Desired Environmental Outcome (Clause 11 of the Measure) for the management of in-service diesel emissions.
Title of Guideline |
Schedule A (1) Guideline on smoky vehicle programs |
Schedule A (2) Guideline on diesel vehicle emission testing and repair programs |
Schedule A (3) Guideline on audited maintenance programs for diesel vehicles |
Schedule A (4) Guideline on diesel vehicle retrofit programs |
Schedule A (5) Guideline on diesel engine rebuild programs |
Schedule A (1) Guideline on smoky vehicle programs
To improve the emissions performance of in-service diesel vehicles by:
2. Scope
Excessive smoke emissions from diesel vehicles are visually offensive, odorous and potentially a risk to public health. Australian Design Rule 30/00, which was introduced in 1976, required all new vehicles to meet smoke opacity standards. However, deterioration of engine components frequently leads to an increase in smoke emissions, which can be rectified through service or repair.
A smoky vehicle program is intended to provide a means of detecting vehicles that have deteriorated to a point where excessive emissions can be visually observed. Smoky vehicle programs may require the owner to repair the vehicle or may simply encourage owners to make repairs to reduce smoke. Some programs combine both approaches.
Jurisdictions that currently operate smoky vehicle programs apply the “ten second smoke rule” to identify vehicles with excess smoke emissions. That is, smoky vehicles are those detected emitting smoke continuously for a period of ten seconds or more. Studies commissioned by the NEPC indicate that there is no strong correlation between the 10 second smoke rule and measurements of particles in laboratory tests.
A smoky vehicle program which uses the ten second smoke rule cannot ensure detection of vehicles with excess emissions of NOx, hydrocarbons (HC), carbon monoxide (CO) or particles. Other guidelines within this Measure describe emission management approaches which are specifically designed to detect and rectify excessive emissions of these pollutants.
Together with the use of the ten second smoke rule by authorised personnel, smoky vehicle programs normally make provision for the general public to report vehicles they observe to be emitting smoke. Clearly jurisdictions are not able to require owners to repair vehicles on the basis of reports made by the general public. Nevertheless, such reports provide the opportunity to inform the owner that their vehicle is emitting smoke, to educate them about the unacceptability of smoke to the public and the means by which their vehicle may be repaired.
In developing an effective smoky vehicle program a jurisdiction should ensure its planning covers:
It is important that, Police, Transport and Environment agencies are involved with the development of any smoky vehicle program. It may also be advantageous to invite other government agencies to participate, particularly local government.
3.1. Identify the level at which smoke emissions are unacceptable
ADR 30/00 describes a range of acceptable smoke opacity tests for new vehicles. Given the expectation that there will be some level of deterioration, the ‘10 second smoke rule’ was developed to provide a means for regulating in-service vehicle smoke emissions and has been legislated in several jurisdictions. A legislative model for the 10 second smoke rule has been agreed by transport Ministers and can be found in the schedule to the Road Transport Reform (Vehicle Standards) Regulations 1999.
3.2. Government reporting of offences
To help ensure that only valid sightings of smoky vehicles result in a defect notice or sanction, only reports by authorised officers should result in statutory measures being undertaken. Notices may be issued based on reports from trained government employees including Police, Transport or EPA enforcement officers or local government officers. Jurisdictions should seek to centralise this administration so that only standard notices are issued and the process can be independently audited. A reliable means of gathering evidence such as the use of video cameras should also be considered. These measures will reduce the likelihood of legal challenge.
Notices, or the letters accompanying them, should:
Jurisdictions should consider how they wish to ‘clear’ a notice. A requirement to provide receipts from a qualified repairer is commonly used with existing programs, but jurisdictions that introduce a vehicle testing program (Schedule A(2)) may wish to introduce a requirement that the vehicle must undergo a full emissions test. Alternatively, jurisdictions should consider whether requiring a full roadworthiness test would better encourage compliance.
3.3. Training and authorising authorised officers
As smoky vehicle reports may be received from a number of agencies (eg Police, Transport, EPA) it is important that officers in all relevant agencies are trained to ensure consistency of administration. Draft guidelines for compliance with the 10 second rule are publicly available from the National Road Transport Commission. Vehicle owners and operators may have an expectation of how the rule will be enforced based on the NRTC guidelines.
The means by which officers are authorised will depend on the legal framework in each jurisdiction.
Schemes enabling public reporting of smoky vehicles do not have enforceable compliance requirements and it is difficult to know precisely what impact such programs have on vehicle maintenance. Public reporting does, however, establish a public face to government efforts in reducing pollution while also providing an important outlet for community concern when observing offending vehicles.
Reports by the public should generally require the:
Due to the potential unreliability of public reports, a warning letter only should be sent to the vehicle owner advising that undue smoke is an offence and that they risk penalties under the authorised officer reporting scheme. The letter should seek to educate the person as to why excessive smoke is unacceptable to the community and how smoke emissions can be improved. The letter should not disclose the name or details of the person that made the report, but should state the time and location.
A telephone hotline with the appropriate recorded prompts should be considered as a means of reducing the administrative burden and encouraging the public to participate. An internet reporting facility should also be considered.
3.5. Public Education
It is important that the public is made aware that:
To encourage the use of the public reporting program promotional material should be developed and launches held for the introduction of the public reporting scheme or the telephone hotline. Media coverage of occasional ‘blitzes’ by authorised officers can be used to promote the public reporting program.
3.6. Targeting strategy for reporting
It is important that a strategy for reporting smoky vehicles is developed and regularly reviewed to monitor success. The form of the strategy will depend on the needs of a particular jurisdiction. Elements may include:
In most jurisdictions the vehicle repair industry has a peak body that is supportive of programs that detect poorly maintained vehicles. Jurisdictions are encouraged to liaise with these groups and other groups such as automobile associations and motor traders, to ensure the necessary training is in place and to explain the program so that repairers understand the importance of issuing a receipt with a precise description of the repairs carried out.
Jurisdictions should consider whether there is benefit in introducing an accreditation system for repairers.
Schedule A (2) Guideline on diesel vehicle emission testing and repair programs
To minimise the deterioration in emission performance of diesel vehicles by testing vehicles to identify high emitters and then ensure they are effectively repaired.
2. Scope
A vehicle test and repair program involves:
Because they involve the actual repair of high polluting vehicles, vehicle test and repair programs offer a high degree of certainty that effective emissions reductions will be achieved.
To develop and implement an effective test and repair program a jurisdiction will need to:
Studies commissioned by the National Environment Protection Council have shown that vehicles less than five years old have few faults and therefore small benefits from emission repairs. For vehicles older than five years, there is a poor correlation between vehicle age and pollutant emissions and between vehicle kilometres travelled and pollutant emissions. There is also a poor correlation between visible smoke or opacity and particle emissions.
Jurisdictions should consider one or more of the following means of targeting vehicles from the Australian fleet for testing under a test and repair program:
Frequency of significant emission related faults in the Australian diesel fleet
Vehicle Mass | Vehicles < 5 years old | Vehicle 6-20 years old | ||||
| % with significant emission faults | % with significant emission faults | ||||
| NOx | Particles | Opacity | NOx | Particles | Opacity |
< 3.5 tonnes | 4 | 13 | 4 | 5 | 32 | 10 |
3.5 to 12 tonnes | 2 | 13 | 5 | 5 | 12 | 14 |
12 to 25 tonnes | 0 | 11 | 0 | 3 | 20 | 3 |
> 25 tonnes | 0 | 8 | 0 | 0 | 1 | 1 |
Note: Values based on the percentage of vehicles identified in NEPC Project 7 that have emission levels above the proposed in-service emission standards. Data is current at June 2001. During the conduct of test and repair programs, jurisdictions may obtain information that updates this table.
3.2. Emission Pass/Fail Levels
In implementing a vehicle test and repair program, a jurisdiction should nominate the pollutants it wishes to target. These should include particles and visible smoke measured according to the vehicle emission standards and test determined by the Australian Transport Council or successor body.
A jurisdiction may also choose to target NOx emissions.
The pass/fail levels will be the appropriate in-service emissions standards as specified by the Australian Transport Council or successor body.
The emissions standards are specified in mass of pollutant emitted per kilometre travelled per vehicle mass, ie in grams per kilometre per tonne. Vehicle test results should therefore be reported in grams per kilometre per tonne and grams per kilometre (for use in calculating emissions inventories).
3.3. Obliging Vehicles to be Tested
3.4. Testing Regime and Infrastructure
3.4.1 In-service Emissions Test
The in-service emissions test to be employed in a diesel vehicle test and repair program is the test determined by the Australian Transport Council or successor body. At the date of commencement of this Measure, this is the DT80 transient short test for which the drive cycle is illustrated below. The protocol for conducting the test is determined by the Australian Transport Council or successor body. Vehicles should be tested using the fuel present in the vehicle tank when it is submitted for testing.
Set dynamometer inertia load to (Tare+GVM)/2 Sample over complete cycle. | ||
Phase | Action | Duration |
A – B: A – B: | Idle. Select low gear. | 60 secs |
B – C: | Rapidly accelerate through gears to 80 km/h. |
|
C – D: | Brake to stop. |
|
D – E: | Idle, select low gear. | 10 secs |
E – F: | Rapidly accelerate through gears to 80 km/h. |
|
F – G | Brake to stop. |
|
G – H | Idle, select low gear. | 10 secs |
H – I | Rapidly accelerate through gears to 80 km/h. |
|
I – J | Maintain 80 km/h. | 60 secs |
At J | Test complete. Return vehicle to stop with engine at idle. |
|
3.4.2 In-service Emissions Test Equipment
Required equipment specifications are detailed in the in-service vehicle emission standards and test determined by the Australian Transport Council or successor body. In summary, the DT80 test should be undertaken and emissions measured with the following equipment:
Purpose | Equipment/Requirement |
Conduct test | - Chassis dynamometer with transient inertia simulation capability during acceleration, on/off ramps, vehicle restraints and axle pull-down system. - Dynamometer control system (computer software) with the capability to run an unlimited number of user-defined driving cycles, communications between control computer and emissions analysis equipment. - Safety barriers. |
Exhaust handling and analysis | - Appropriate humidity, ambient temperature and barometric measurement devices. - Exhaust handling equipment that will not contaminate the gases and which will enable particulate matter to be measured at a temperature below 51.7C. - A total mass flow measurement system capable of ensuring that the total mass flow of exhaust at the point of emission sampling is controlled so as to maintain the equipment's nominated volumetric flow rate to within an accuracy of ±3.0%. - A sample filtration system capable of trapping 97% of all particulates and aerosols 5 microns or larger from entering the gaseous analysers. - A water trap capable of removing exhaust sample water from vehicles fuelled with diesel, and any other desired fuels. |
Gaseous emissions | Gas analyser(s) with the range and capacity specified in the test protocol given in the in-service vehicle emission standards and test determined by the Australian Transport Council or successor body. |
PM measurement | Laser light scattering photometry device. |
Smoke measurement | An opacity meter which is a partial-flow device, meeting the performance requirements of ISO 11614, and which interfaces seamlessly with the analyser software via an RS232C or Universal Serial Bus (USB) port. |
The target pollutants may not be the only emissions measured during a test and repair program. Measurements of carbon dioxide and oxygen are required for quality control reasons. Jurisdictions may also choose to measure other emissions for inventory purposes. The emissions to be measured could include:
Oxides of nitrogen should be calculated from the measured NO concentration using sample condition corrections and USEPA specified formulae.
The DT80 transient short test has been found to be a good test for identifying high polluting vehicles. For emissions inventory purposes results should be measured in g/sec on the DT80 and converted to CUEDC measurements using the correlation coefficient determined in NEPC Project 2.2. The CUEDC scores can than be used for inventory purposes as they reflect a better estimation of real world driving patterns.
All equipment should be calibrated and calibration gases regularly checked in accordance with the in-service vehicle emission standards and test determined by the Australian Transport Council or successor body.
3.4.3 In-service Emissions Test Stations – Vehicle Throughput
Jurisdictions will need to establish test stations (either fixed or mobile) that cater to the characteristics of the target vehicle group.
3.4.4 Test/Repair Procedure
Testing of vehicles will involve the following steps.
1. Conduct a safety check of the vehicle to determine its suitability for testing. Faults to be considered include underinflated or unsafe tyres, fuel or fluid leaks, overheated engines and excessive smoke. Vehicles that are unsafe for testing should be referred for repairs and re-testing.
2. Record vehicle details including vehicle identification number, fuel type, model year, model year, make, model, vehicle type, gross vehicle mass, tare weight, vehicle ADR category, engine displacement, number of cylinders, turbocharger, fuel system, odometer reading, testing hazards identified if any. Depending on the computer software design and network linkages, much of this information may be automatically retrieved from registration records.
3. Test the vehicle.
4. Print a vehicle inspection report. The vehicle inspection report should include maximum allowable emissions values, results for the test vehicle, a pass/fail determination and emissions values that are considered good for that age and make of vehicle.
5. If the vehicle has failed, refer it for repair.
6. The repair facility should issue the client with a repair report detailing the type and cost of repairs carried out.
7. Re-test the vehicle.*
8. Repeat steps 4 – 7 until the vehicle passes or is granted a qualified waiver (see below).
* A jurisdiction may choose to accept evidence of vehicle repair other than re-testing such as a statement of repair from an accredited repairer. This may be necessary in cases where a vehicle is identified as not meeting the standard in a jurisdiction other than its jurisdiction of registration.
3.4.5 Repair Requirements
Any vehicle that fails to meet the in-service standard will be required to be repaired, and provide evidence of that repair. The Australian Transport Council or successor body may prescribe an acceptable level of evidence to show that the repairs have been undertaken. For reasons of practicality it is desirable in a test and repair program to place a limit on the scope of effort expended on repairs. Such provisions mean that once the limit is reached, vehicles are granted a waiver of the test requirement in that instance. Such a waiver does not preclude the vehicle from being targeted for testing in the future according to a jurisdiction’s vehicle testing schedule (eg yearly, 2 yearly testing).
A national approach to waivers or exemptions may be set by the Australian Transport Council or successor body. The national approach may reflect the following criteria.
Repairs may include but are not limited to:
3.5. Repair Industry
The success of a vehicle test and repair program in terms of reducing emissions is dependent on the ability of the repair industry to diagnose and repair vehicle faults. The cost effectiveness of the program will be affected by the industry’s ability to repair vehicles efficiently and effectively, thereby minimising instances of successive failure of vehicles.
It is therefore essential that jurisdictions plan for and assist the repair industry to be effectively trained and equipped prior to the introduction of a test and repair program. Jurisdictions may wish to consider the desirability of certifying the industry for repair of high polluting vehicles.
An effective training program would include:
A successful vehicle test and repair program requires the support and cooperation of vehicle owners covered by the program and repairers. A communications program will be an essential first step in promoting their acceptance of the program. The communications program should help the target group of vehicle owners to understand why vehicle testing is needed and how to comply with the program requirements.
The communications program should include:
The information provided about the program should include but not be limited to:
In order to assess the emissions benefit from programs, it is critical that data is collected and reported at the beginning, during and end of the program. The data will enable participants to assess and report the emissions reductions from their operations and will also assist regulatory authorities in assessing the impacts on emissions and air quality overall.
The data collected should include:
3.8. Quality Control and Audit
Effective quality control and audit procedures are essential to ensure that appropriate levels of customer service are maintained and that the owners of vehicles tested under the program have confidence in its integrity. A preventive maintenance and quality control program should be implemented to ensure:
A quality control program should include:
All test and repair program facilities should be accredited by the National Association of Testing Authorities.
Schedule A (3) Guideline on audited maintenance programs for diesel vehicles
To improve the emissions performance of in-service diesel vehicles by ensuring they are maintained in a manner that can be shown to minimise excess emissions.
2. Scope
A vehicle that has not been modified from manufacturer’s specifications and which has been maintained to the specifications of the manufacturer should not become a polluting vehicle (ie its emissions should not exceed the limits specified in the standard established by the NRTC).
There are strategically different approaches to maintenance that can be equally valid if used correctly. For example regularly scheduled maintenance is one approach, but increasingly large fleets utilise ‘on condition’ maintenance that puts in place methods to detect the need for maintenance, for example measuring sump oil quality at regular intervals.
Evidence of good maintenance could therefore be presented by operators as proof that their vehicles continue to comply with emission standards. Other operators and the public would require some audit of the maintenance regime to ensure the credibility of the program.
Operators may choose to enter an audited maintenance program for a number of reasons. They may wish to:
An audited maintenance program is a quality system approach to the management of emissions from diesel vehicles. Such programs can make use of standards and infrastructure that have already been established to administer quality management programs for the transport industry.
Audited maintenance programs offer vehicle operators an alternative to Government regulatory provisions hence their classification as alternative compliance programs. In the case of regulation relating to vehicle emissions, participation in an audited maintenance program may mean exemption from regular emissions testing. Participation in audited maintenance programs is open to operators regardless of the number of vehicles they have.
In developing an effective audited maintenance program a jurisdiction would need to ensure that a such a program is capable of:
Arrangements for financing the program would need to be determined and a system for its administration established. A regulatory and/or market strategy would need to be developed to ensure adequate adoption of the program.
4.1. Program Coverage
The National Environment Protection (Ambient Air Quality) Measure set standards for ambient air quality. Airsheds of major cities are in general the only regions likely not to meet standards. Localised pockets within a region may also have air quality problems because of traffic volumes and local geography. Amenity issues may arise when fumes and smoke from a vehicle cause nuisance and visual pollution.
Research and experience has shown that the emissions most likely to be affected by repairs or maintenance of a diesel vehicle are particulates and smoke. NOx is generally a function of the engine design and varies little in current engines which do not have dedicated NOx emission controls. In future generations of engines with NOx control emissions may be considerably influenced by tampering or poor maintenance.
The quantity of emissions from diesel vehicles are a function of the distance travelled multiplied by emissions per kilometre. For a well maintained vehicle, emissions per kilometre are generally related to the age of the vehicle and the ADR with which it had to comply with when new. Excessive pollution from new vehicles is likely to be due to tampering and from older vehicles because of wear or poor maintenance.
Audited maintenance programs therefore should focus on:
4.2. Program Operation
The responsible parties in the program will be the regulator, the administrator, the operator, the emissions tester and the auditor. Where relevant, industry associations may also be involved in the design and administration of programs for operators in their industry.
Program Regulator
The program regulator is responsible for:
Administrator
Program administration of many of the existing alternate compliance programs in the transport industry is undertaken by industry associations. Alternatively, the regulator may also administer the program. In determining where the administration function for an audited maintenance program should be located, consideration should be given to ensuring that there is adequate capability to:
Operators
Operators are the owners of vehicles who chose to participate in the audited maintenance scheme. It is the responsibility of operators to define and document the maintenance arrangements (organisational structure, procedures, processes and resources) by which control of the factors affecting emissions is ensured. The documentation on maintenance arrangements should be at least the minimum required to minimise cost and maximise the likelihood of compliance. If a company already has a quality system in place for vehicle maintenance the audited maintenance program should complement this. Documentation systems that are already in place for financial control and other purposes may also be used to provide documentation for the maintenance program and reduce the need for duplication.
Auditors
The quality auditor undertakes systematic and independent audits on behalf of the administrator to determine whether an operator’s maintenance program complies with approved arrangements and whether these arrangements have been implemented effectively and that the results of the program match the intended outcomes. The regulator may also commission special audits in response to complaints or evidence of non-compliance (eg infringing the 10 second smoke rule).
Emissions tester
Emissions testers are engaged by operators to conduct initial emissions testing of the fleet to establish the effectiveness of the existing maintenance regime. They may also conduct testing for auditors or for the regulator. Those undertaking emissions testing should be accredited by the National Association of Testing Authorities.
Emission testing systems (which include test equipment, documented test procedures and the skills and training of staff ) should also be accredited by the National Association of Testing Authorities.
4.3. Operator Maintenance Program
Each operator in the audited maintenance program must have maintenance arrangements in place which have the goal of ensuring the factors which affect the level of emissions from vehicles are managed so that emissions are minimised.
The operator’s maintenance program should be designed so that it enables:
When the administrator is evaluating an operator’s maintenance program the following criteria need to be met:
It is the responsibility of operators to establish and/or refine their maintenance programs to meet these criteria.
Determining effectiveness in meeting the goal may require operators to undertake some emissions testing to establish the sensitivity of emissions to various factors. Audited maintenance programs minimise the need for exhaust emission testing. However, they will not necessarily eliminate all testing. In particular a program of testing will be required to benchmark the emissions performance of a fleet and to establish the adequacy of the proposed maintenance regime. Some additional testing may then be conducted to complement the audits which need to be conducted to ensure the program goal continues to be met.
4.4. Operator Assessment
The assessment of operators would be undertaken by the audited maintenance program administrator, or assessed independently. The assessment would include a review of the operator’s incentives for program participation, incentives to cheat on the program, and their capacity to meet program objectives. A low incentive level is likely to lead to poor compliance as is an obvious incapacity to effectively implement a quality system.
There are sometimes incentives to alter an engine from the manufacturer’s specifications (eg increased power or improved driveability) and adherence to maintenance schedules is a cost that some operators do not believe is warranted (or can afford) and will attempt to avoid.
There are also incentives for operators to correctly maintain vehicles. These include improved reliability, improved fuel consumption and a better resale value.
To establish if an operator is suitable for inclusion in an audited maintenance program the program administrator should collect and evaluate data on the following:
5. Program Marketing and Funding
The regulator will need to develop policy (and regulations if necessary) to establish incentives for operators, to cover the operation of the scheme and to gain acceptance for the scheme from stakeholders.
5.1. Incentives
It will be the responsibility of the regulator to ensure appropriate incentives are in place to warrant the cost of participation to an operator and to ensure a participating operator is not disadvantaged commercially. These incentives may be developed nationally, for a jurisdiction or a local area and may require consultation with transport associations, the Commonwealth government, local government or major transport users (eg, supermarkets, government).
5.2. Marketing
The administrator of the scheme will market the scheme to potential participants. This may entail the provision of brochures and publications, the provision of an internet site, a telephone enquiry line and presentations to industry and others.
5.3. Financing
In order to ensure the sustainability of an audited maintenance program, the regulator should:
The program costs can be allocated to each of the responsible parties according to the tasks that they undertake.
It is expected that administrative costs will be financed by fees from operators. Administrative costs include those associated with dealing with enquiries from prospective operators, providing an information/application package, review of applications, the maintenance of a register of operator status (eg. applicant, approved operator, under review because of complaints received), and implementation of a system to manage audits and apply sanctions if necessary. Operators will also be responsible for financing their own costs for implementing and operating their own maintenance program. Audit and emission testing is to be financed on a fee for service basis by those who commission them – operator, auditor or regulator. The marketing function for the program is to be financed by operators.
Schedule A (4) Guideline on diesel vehicle retrofit programs
To improve the emissions performance of in-service diesel vehicles by the fitment of exhaust after-treatment devices.
2. Scope
There are a large number of vehicles in the diesel fleet which have no emissions control technology, except to limit smoke. There is a capacity to reduce harmful emissions from vehicles certified to pre-2002 standards (when new emissions ADRs take effect) by retrofitting exhaust system components.
There are a range of emission reduction technologies which could be considered for a retrofit program. Factors to consider in selecting suitable technologies include:
The principal after-treatment technologies currently in use in retrofit programs are diesel oxidation catalysts and various types of particle traps/filters.
Particle traps/filters can deliver large PM emission reductions in specific applications. To be effective they need to be carefully tailored to particular engines and in-service use patterns. Fuel sulfur levels must be < 500ppm, with some trap technologies requiring very low sulfur levels (around 50ppm) to be effective.
Diesel oxidation catalysts (DOC) are well proven technology, commercially available and are currently used in retrofit programs in the US and Europe. DOCs are effective in reducing HC, CO and PM emissions, but usually have no significant impact on NOx emissions. DOCs are also effective in reducing odours from diesel exhaust.
DOCs are the cheapest after-treatment technology, require no maintenance and are very durable (one estimate of catalyst life is 600,000km).
It is recommended that retrofit programs focus on the use of diesel oxidation catalysts in the medium term. While the costs and other complexities with the use of particle traps tend to limit their adoption at this stage, they have the capacity to deliver substantial reductions in PM emissions, and may be a viable option where the particular fuel and engine operating conditions can be achieved.
Original equipment manufacturers should be consulted before undertaking any retrofit activity.
There are three parts to this guideline:
All diesel vehicles are potential candidates for retrofit programs.
The criteria for selection are a matter for the jurisdiction, and may be based purely on a cost/effectiveness assessment or involve other broader government objectives. This guideline sets out a range of possible criteria that jurisdictions may use in considering the introduction of a retrofit program.
3.1.1 General Principles
There are some general principles which apply, regardless of the target groups.
1. The emissions benefits are proportionally greater for earlier technology vehicles such as those provided to the Australian market before ADR70/00 (ie largely unregulated or ‘Euro 0’, late 1980’s US), but there are still significant benefits from retrofitting vehicles meeting Euro 1/Euro 2, and US 91/US 94 standards.
2. There is little value in retrofitting vehicles that meet the new emission standards in ADR80/00 and ADR79/00 as the emission benefits will be marginal.
3. The vehicle engine must be in reasonable condition. Engines in a poor state of repair may lead to catalyst damage and increased smoke and odours from oil etc entering the exhaust system and reacting with the catalyst.
4. Emissions reductions are likely to be greatest when the catalyst is tailored to the engine (in accordance with advice from the engine manufacturer) and the maximum commercial fuel sulfur levels are known and controlled.
5. DOCs have widespread application.
3.1.2 Target Vehicle Criteria
Taking the above factors into account, possible criteria for selecting vehicles for retrofitting are outlined below:
More than one criterion may need to be met in order for a jurisdiction to consider implementing a program for a particular fleet.
3.1.3 Implementation
As indicated above, DOCs can potentially be applied to the full range of diesel vehicles, and their benefits can be significant. However, DOCs come at a cost, so regulation, incentives, or Government/corporate policy commitments are required. Jurisdictions will need to make their own decisions about target fleets based on the criteria detailed above.
Key factors to consider are:
– Reduced registration charges;
– Rebates on vehicle inspection fees;
– Exemption from participation in mandatory Testing and Repair programs for a specified period after retrofit;
– Use of electronic tolling to restrict or charge non-retrofitted vehicles for access to specified areas in the urban environment; and
– Rebates or other subsidies on approved retrofit technology.
3.2. Technology Assessment Guideline
Retrofit devices need to be objectively evaluated for their:
Demonstration of compliance with these requirements is a pre-requisite for acceptance of particular appliances in retrofit programs. This section is based on DOCs but could be adapted for other devices which comply with the requirements.
3.2.1 Performance Requirements
To be considered for use in a retrofit program, a DOC must meet the following requirements:
(1) The DOC is:
(a) approved by the US EPA under the Urban Bus Rebuild/Retrofit Program;
(b) approved under the London Bus Retrofit Program; or
(c) emission tested under the relevant Composite Urban Emissions Drive Cycle, UN ECE Type I emission test under ECE R83/04 or later (or equivalent EC Directive), the UN ECE 13 mode steady state test under ECE R49/02 or later (or equivalent EC Directive), or the US CFR 40 Part 86 EPA Federal Test Procedure.
(2) When tested in accordance with one of the options under (1), the DOC reduces odour and reduces emissions from the test vehicle(s)/engine(s) by at least the proportion (%) specified in the following table:
Engine / Vehicle Category | Minimum Reduction in Emissions (%) | |
PM | HC | |
Pre ADR70/00 | 40 | 50 |
ADR70/00 – minimum (Euro 1, US 91, Japan 93-4) | 30 | 50 |
Euro 2, US 94 | 25 | 50 |
(3) The DOC is demonstrated (by means of specific testing or engineering analysis) to deliver the percentage reductions in (2) for the size and type of engines used in the target vehicles.
(4) The DOC is demonstrated to deliver the reductions in (2) on diesel fuel with sulfur levels typical of the fuel used by the target vehicles in normal use.
(5) The DOC is demonstrated (by means of an acceptable durability test or in-service testing) to remain effective over the life of the vehicle.
(6) The DOC does not significantly increase vehicle noise in the target vehicles when tested in accordance with the requirements of ADR28/01.
(7) The DOC does not significantly increase exhaust back pressure in the target vehicles to a level outside the manufacturer’s specification.
It is the DOC supplier/manufacturer’s responsibility to demonstrate that their DOC comply with the above requirements. Testing shall be conducted by independent organisations with appropriate expertise in the field.
3.3. Program Evaluation Guideline
The evaluation of a retrofit program serves two main purposes:
(1) To support the vehicle selection process in section 3.1 for a proposed program; and
(2) To provide a means of assessing and reviewing the effectiveness of a program in operation.
(1) To Support Target Vehicle Selection
As indicated in section 3.1, one of the criteria in selecting target vehicles is the cost effectiveness of any proposed program for the target group. Determining the cost effectiveness of particular approaches enables the objective comparison of different measures and the consideration of the need for further incentives.
One basic formula for such an estimation is as follows:
Cost Effectiveness ($/kg Emissions) = (Cost) / (Emission Reduction) |
Where:
Cost($) | = | (no. vehicles fitted)*(DOC unit cost)/(DOC unit life years) |
Emission Reduction | = | (emissions/fleet/year)*(DOC emission reduction factor) |
Emissions/fleet/year | = | (emission/vehicle/year)*(fleet size)*(fleet suitability)*(fleet penetration) |
Emission/vehicle/year | = | (emission rate)*(annual vehicle kilometres travelled) |
Notes:
Fleet suitability Refers to the estimate of the proportion of the fleet that will actually be suitable for retrofit. For example, it may be determined that 15% of a particular fleet is too old to warrant the cost of retrofit, or conversely 10% of the fleet meets ADR80/00 (Euro 3) and would not benefit significantly from retrofit.
Fleet penetration Refers to the rate at which the fleet is retrofitted over the period of the program. For example, in a five year program, the target may be to retrofit all the pre-ADR70 vehicles in the first year and the balance over the next four years. Where there is phased implementation, the emission reduction calculation will need to be adjusted in the early years of the implementation period to reflect the number of vehicles retrofitted each year.
(2) Program Assessment
Once it is decided to proceed with a particular retrofit program, it is important to collect key data, so that the worth of the program can be properly assessed and lessons can be learned for any future programs.
For an effective assessment, it is desirable that data are collected at the beginning, during and end of any retrofit program. The data will enable participants to assess and report the emissions reductions from their operations (which may be important to support government/corporate commitments) and will also assist regulatory authorities in assessing the impacts on emissions and air quality overall.
The level and detail of data collected will obviously be subject to available budget, but ideally the following data should be collected:
The above data may be integrated with other data collected on the target fleet, such as public complaints about smoky vehicles.
Participants in a retrofit program should be required to keep records of the above tests which must be made available on request to the regulatory authority. The regulatory authority could assist by developing standard reporting formats. In jurisdictions which operate Testing and Repair programs Schedule A(2), the emission testing for the retrofit program could be integrated with the Testing and Repair program.
Schedule A (5) Guideline on diesel engine rebuild programs
To improve the emissions performance of in-service diesel vehicles by the fitment of low emission engine upgrade kits at time of engine rebuild.
2. Scope
There are a large number of vehicles in the diesel fleet which have no emissions control technology, except to limit smoke. Catalysts and other advanced exhaust control technology will not be fitted to most diesel vehicles until the introduction of ADR79/00 and ADR80/00 in 2002.
There is a capacity to reduce harmful emissions from vehicles certified to pre-2002 standards by fitting low emission engine rebuild kits when an engine is undergoing a major overhaul. Such rebuild kits are currently available for a limited number of US sourced engines. These are principally aimed at reducing PM emissions from urban bus engines. New low NOx rebuild kits will be developed in the US following a 1998 agreement between the US EPA and engine manufacturers.
Where kits are available, they give a vehicle operator the ability to extend the life of a vehicle, while improving its emissions performance to a level better than the original specification. Where they are available they are marginally more expensive than a standard rebuild kit.
The operation of a rebuild program has many similarities to a retrofit program, with the key difference being that many retrofit technologies have generic application, whereas rebuild programs are developed for specific engines or engine families.
There are three parts to this guideline:
The criteria for vehicle/engine selection are a matter for the jurisdiction, and may be purely on a cost/effectiveness assessment or involve other broader government objectives. This guideline sets out a range of criteria that a jurisdiction may use in considering the introduction of a low emission engine rebuild program.
3.1.1 General Principles
There are general principles that apply, regardless of the target groups.
1. Low emission engine rebuild kits are specifically designed to work with particular engines or engine families, as they rely on modifications to pistons, camshafts and other engine components.
2. Rebuilds are only likely to be undertaken on heavy duty truck and bus engines where the cost of the rebuild is warranted because of the long service life of the vehicle and the higher capital cost of replacing the whole vehicle. Many light duty vehicles are likely to be scrapped rather than have their engines rebuilt.
3. In most cases, low emission rebuild kits can only be developed by the original engine manufacturers.
4. Manufacturers are only likely to develop rebuild kits where there is a specific demand (eg. as a result of a Government directive or incentive applying to vehicles fitted with the particular engines).
5. To be cost-effective, there should be a significant volume of vehicles operating in the Australian fleet which have engines for which rebuild kits are available.
3.1.2 Target Vehicle Criteria
Taking the above factors into account, possible criteria for selecting vehicles for a low emission engine rebuild program are outlined below. More than one criterion may need to be met in order for a jurisdiction to consider implementing a program for a particular fleet.
Leadership in the improvement of urban air quality could be demonstrated by instituting a low emission engine rebuild program for fleets.
3.1.3 Implementation
As indicated above, low emission rebuild kits can potentially be applied to a wide range of diesel vehicles, but are only likely to be cost effective in larger engines in significant volumes. The kits add a marginal cost to engine rebuilds so regulation, incentives, or Government/corporate policy commitments are required. Jurisdictions will need to make their own decisions about appropriate target fleets based on the criteria detailed above.
Key factors to consider are:
– Reduced registration charges;
– Rebates on vehicle inspection fees;
– Exemption from participation in any mandatory Testing and Repair programs for a specified period after retrofit;
– Use of electronic tolling to restrict or charge for access to specified areas in the urban environment, where the vehicle is not built to current standards and it does not meet the rebuild requirements (or the retrofit requirements); and
– Rebates or other subsidies on approved retrofit technology.
3.2. Technology Assessment Guideline
Low emission engine rebuild kits need to be objectively evaluated for their:
Demonstration of compliance with these requirements is a pre-requisite for acceptance of particular kit in rebuild programs.
3.2.1 Performance Requirements
To be considered for use in a retrofit program, a low emission rebuild kit must meet the following requirements:
(1) The kit is:
(a) approved by the US EPA under the Urban Bus Rebuild/Retrofit Program; or
(b) emission tested under the relevant Composite Urban Emissions Drive Cycle, UN ECE Type I emission test under ECE R83/04 or later (or equivalent EC Directive), the UN ECE 13 mode steady state test under ECE R49/02 or later (or equivalent EC Directive), or the US CFR 40 Part 86 EPA Federal Test Procedure.
(2) When tested in accordance with one of the options under (1), the kit reduces PM or NOx emissions from the test vehicle(s)/engine(s) by at least 25%.
(3) The kit is demonstrated to deliver the reductions in (2) on diesel fuel with sulfur levels typical of the fuel used by the target vehicles in normal use.
(4) The kit is demonstrated (by means of an acceptable durability test or in-service testing) to deliver emission reductions over the life of the vehicle (recognising that the magnitude of the reductions may diminish over time through normal engine wear).
(5) The kit does not significantly increase vehicle noise in the target vehicles when tested in accordance with the requirements of ADR28/01.
It is the rebuild kit supplier/manufacturer’s responsibility to demonstrate that their kits comply with the above requirements. Testing shall be conducted by independent organisations with appropriate expertise in the field and acceptable to the jurisdiction.
3.3. Program Evaluation Guideline
The evaluation of a low emission engine rebuild program serves two main purposes:
(1) To support the vehicle selection process in section 3.1 for a proposed program; and
(2) To provide a means of assessing and reviewing the effectiveness of a program in operation.
(1) Target Vehicle Selection
As indicated in section 3.1, one of the criteria in selecting target vehicles is the cost effectiveness of any proposed program for the target group. Determining the cost effectiveness of particular approaches enables the objective comparison of different measures and the consideration of the need for further incentives etc.
One basic formula for such an estimation is as follows:
Cost Effectiveness ($/kg Emissions) = (Cost) / (Emission Reduction) |
Where:
Cost($) | = | (no. vehicles fitted)*(kit unit cost)/(kit unit life years) |
Emission Reduction | = | (emissions/fleet/year)*(kit emission reduction factor) |
Emissions/fleet/year | = | (emission/vehicle/year)*(fleet size)*(fleet suitability)*(fleet penetration) |
Emission/vehicle/year | = | (emission rate)*(annual vehicle kilometres travelled) |
Notes:
Kit emission reduction factor | The percentage reduction applicable to the kit. There may have to be a deterioration value factored in, as the initial percentage reduction may not be maintained over the life of the engine. |
Fleet suitability | Refers to the estimate of the proportion of the fleet that will actually be suitable for rebuild (ie have done enough kilometres and still be of sufficient value to warrant the cost of rebuild) |
Fleet penetration | Refers to the rate at which the fleet is rebuilt with the kits over the period of the program eg in 5 year program, it may be anticipated that 10% of vehicles will come up for rebuild. |
(2) Program Assessment
Once it is decided to proceed with a particular rebuild program, it is important to collect key data, so that the worth of the program can be properly assessed and lessons can be learned for any future programs.
For an effective assessment, it is desirable that data are collected at the beginning, during and end of any program. The data will enable participants to assess and report the emissions reductions from their operations (which may be important to support government/corporate commitments) and will also assist regulatory authorities in assessing the impacts on emissions and air quality overall.
The level and detail of data collected will obviously be subject to available budget, but ideally the following data should be collected:
Participants in a rebuild program should be required to keep records of the above tests which must be made available on request to the regulatory authority. The regulatory authority could assist by developing standard reporting formats. In jurisdictions which operate Testing and Repair programs (Schedule A(2), the emissions testing for the rebuild program could be integrated with the Testing and Repair program.