EPUK Statement on the VW emissions scandal

VW recall must be shown to work before 1.2 million untested cars are let loose on UK roads.

As a result of test manipulation, millions of vehicles on roads in the UK and around the world are operating without properly certified on-road emissions controls. Clarification must be sought as to what will be done to address this problem to minimise the health harm to us all.  VW must devise a solution that achieves the NOx standard correctly and minimises CO2 emissions and clearly show that it works in order to restore trust in the vehicle industry and in government oversight.

  • EPUK demands a mandatory recall of all vehicles installed with ‘defeat device’ software and that VW devise a solution that achieves the NOx standard correctly and minimises CO2 emissions.
  • EPUK seeks a statement from the European Commission and the UK Department for Transport that software analysis will form part of the revised testing procedure and clarification on how they will ensure that test manipulation will not be possible and/or tolerated.
  • EPUK recommended that, to achieve this, in addition to the type approval testing, spot-checks of ‘in-use’ vehicle emissions will be required.
  • EPUK consider that there must be an independent investigation of all motor vehicle manufacturers to identify the extent of the use of ‘defeat device’ technology and whether the EU emission tests were subject to the same falsification as in the US, or were simply too lenient.
  • EPUK calls for a joined-up policy approach across government departments, which clearly recognises and actively communicates the public health AND climate change implications of diesel (and petrol) to enable consumers to make a rational and informed decision regarding fuel-type and, indeed, mobility choice.

Millions of vehicles on roads in the UK and around the world may be operating without properly certified on-road emissions controls, as a result of test manipulation. Volkswagen Group UK have announced that they are consulting on an action plan to agree ‘technical solutions and measures’, however it is not yet clear whether this will involve a wholesale recall of the offending vehicles or whether this will be at the discretion of the owners. It is also unclear as to whether the post hoc technical solutions will mean that the emission control systems used to pass the tests will be operationalised for real-world use, at the expense of fuel efficiency and CO2 emissions, or whether some alternative solution is possible that can achieve both goals. A simple ‘software tweak’ that removes the ability of vehicle management systems to detect when they are being tested is not sufficient, if those vehicles are then free to continue to generate higher emissions in the real world.

Although it is accepted that consumers will have purchased these vehicles for differing reasons, fuel efficiency is likely to have been an overriding factor for many. Any solution that results in reducing this aspect is unlikely to be popular and, unless mandatory, will not be taken up by many owners. While emissions reduction may not have been paramount in the minds of all consumers, it is not acceptable that other, potentially more vulnerable, members of the public should continue to be exposed to elevated NOx emissions if the vehicle recall turns out to be optional. EPUK therefore demands a mandatory recall of all vehicles installed with ‘defeat device’ software and that VW devise a solution that achieves the NOx standard correctly and minimises CO2 emissions.

The International Council on Clean Transportation (ICCT) had already shown that on-road emission levels of modern diesel cars are on average about seven times higher than the limit set by the Euro 6 emission standard, and that although NOx emission limits for diesel cars in the EU were lowered by 85% between 2000 (Euro 3) and 2014 (Euro 6), over the same period on-road emission levels decreased only about 40%. The Real Driving Emissions (RDE) Euro 6c test, introducing Portable Emissions Measurement Systems (PEMS), which is proposed to come into force in 2017, should therefore be a welcome, if belated, change in legislation; however, this is contingent on these new tests being reliable. A new era of transparency is required. For public trust to be regained the onus is on all motor manufacturers to demonstrate accuracy and compliance, and on governments to ensure rigour, independence and transparency in the process and results. Competitive advantage and profit margins must not be allowed to take precedence over public health.

To that end, EPUK seeks a statement from the European Commission and the UK Department for Transport that software analysis will form part of the revised testing procedure and clarification on how they will ensure that test manipulation will not be possible and/or tolerated. It is recommended that, to achieve this, in addition to the type approval testing, spot-checks of ‘in-use’ vehicle emissions will be required. Furthermore, there must be an independent investigation of all motor vehicle manufacturers to identify the extent of the use of ‘defeat device’ technology and whether the EU emission tests were subject to the same falsification as in the US, or were simply too lenient.

Diesel light-duty vehicles have received market preference and excise duty incentives due to their fuel efficiency. However, if these results have been influenced by running emission control systems inadequately in real-world use, the viability of the future use of diesel-fuelled vehicles in urban areas needs to be reassessed. As well as emission tests being required to reflect real-world conditions, diesel vehicles must be required to reflect emission test controls in real-world urban conditions. The message that diesel is environmentally superior to petrol must be expunged from the political, public and commercial consciousness – it is no longer acceptable that there should be a trade-off between public health and climate change and entirely unacceptable that government policy should skew this false choice at the expense of public health. Public confusion regarding mixed policy messages from governments over diesel threatens to undermine the profile-raising that the ‘dieselgate scandal’ has achieved for public health. EPUK therefore calls for a joined-up policy approach across government departments, which clearly recognises and actively communicates the public health AND climate change implications of diesel (and petrol) to enable consumers to make a rational and informed decision regarding fuel-type and, indeed, mobility choice.

This manipulation of the testing regime may seem like just another corporate scandal, but it has caused a substantial amount of illness and death. As such it has incurred a massive personal cost to the individuals affected, and to the NHS and the economy as a whole. Even the work of local authorities (and associated costs) to achieve air quality targets was made harder by the vehicle manufacturers’ actions. There may be grounds for legal action to recover some of these costs, and to ensure that further deaths can be avoided.

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Impacts of car pollution

Road transport is one of the biggest sources of pollution in the UK, contributing to poor air quality, noise disturbance, congestion and climate change . Of the 34 million vehicles on our roads, 28 million are cars. Whilst travel by car is often the only practicable option, there are simple steps we can all take to reduce the number of journeys we take and their impact on the environment.

Climate Change

Road transport accounts for 22% of total UK emissions of carbon dioxide (CO2) a major contributor to climate change. The EU has agreements with motor manufacturers that aim to reduce average CO2 emissions from new cars. Colour-coded labels, similar to those used on washing machines and fridges, are now displayed in car showrooms showing how much CO2 new models emit per kilometre. However, as traffic levels are predicted to increase, road transport will continue to be a significant contributor to greenhouse gas emissions.

Air Quality

Air pollutants from transport include nitrogen oxides, particles, carbon monoxide and hydrocarbons. All have a damaging impact on the health of people, animals and vegetation locally. Air quality in the UK is slowly improving, but many areas still fail to meet the health based national air quality objectives and European limit values – particularly for particles and nitrogen dioxide. In town centres and alongside busy roads, vehicles are responsible for most local pollution. Vehicles tend to emit more pollution during the first few miles of journey when their engines are warming up. Although new technology and cleaner fuel formulations will continue to cut emissions of pollutants, the increasing number of vehicles on the road and miles driven is eroding these benefits.

Noise

Noise from road traffic affects 30% of people in the UK. Sources include engine noise, tyre noise, car horns, car stereos, door slamming, and squeaking brakes. Vehicles have been subject to noise standards for many years through EU legislation. The sound of engines is a problem in towns and cities, while in more rural areas tyre noise on busy roads, which increases with speed, is the main source. Low-noise road surfaces, effective noise barriers in sensitive locations, and low noise tyres can all help reduce noise levels. Meanwhile, encouraging people to close car windows when playing loud music, and discouraging the use of ‘boom box’ car stereos would significantly reduce noise impact.

Resource Use

Vehicles have a major impact on the environment through their construction, use and eventual disposal. It is estimated that of the CO2 emissions produced over a car’s lifespan 10% come from its manufacture and 5% from its disposal, with the remaining 85% coming from fuel use and servicing operations. In addition to these emissions of carbon dioxide and other air pollutants, the vehicle and related industries (e.g. fuels) consume large amounts of raw materials, and produce significant quantities of waste.

Local Impacts

Vehicle use affects our whole quality of local life. Traffic can be dangerous and intimidating, dividing communities and making street life unpleasant. Abandoned vehicles cause nuisance, whilst air pollution and traffic noise can make urban living uncomfortable.

What are the Government doing to reduce car pollution?

Climate Change

In addition to the EU’s voluntary agreements with motor manufacturers and the introduction of colour-coded CO2 labels in showrooms, the UK Government has introduced financial measures to favour cars with lower CO2 emissions.

Since March 2001 the annual Vehicle Excise Duty (VED) rate for new cars has been determined by their theoretical CO2 emission figure and the type of fuel used. This banding is linked to the voluntary colour coded CO2 A – M labelling scheme. VED discounts are available for alternatively fuelled cars, e.g. hybrids, gas and biofuels.

Since 2002 company car drivers have been taxed according to their vehicle’s CO2 emissions and fuel type, again with diesel vehicles paying a tax penalty over petrol vehicles with similar CO2 emissions. Tax discounts are available for drivers choosing bio-fuel and hybrid electric vehicles.

On the fuels side, a Renewable Transport Fuels Obligation has been introduced which requires 5% of road fuels to come from a renewable source by 2013. This may be sold as a separate fuel (e.g. ‘E85’) or blended into normal diesel and petrol at low percentages (5% or less).

The European Union has now agreed a mandatory CO2 target for car manufactures. as cars are responsible for 12% of total EU CO2 emissions. Under this legislation the average emissions of a manufacture’s vehicles sold in Europe will have to be below 130 grams of CO2 per kilometre by 2015, and by 2020 representing a planned reduction of 40%.

Air Quality

The Government set out targets for improving air quality standards, based on health implications, in the UK Air Quality Strategy in 2007. In areas where national objectives for air quality are likely to be exceeded, local authorities must declare an Air Quality Management Area (AQMA) and an action plan must be drawn up and implemented. Your local authority environmental health department should be able to advise you on air quality in your area and any plans for improvement. More information is available at http://www.airquality.co.uk/

In some areas authorised officers of the local authority can check that emissions from road vehicles comply with Construction and Use Regulations and issue fixed penalty notices to those failing the test. In England and Wales, only those local authorities that have declared an AQMA may apply to use this power, but Scottish Regulations enable all local authorities to apply to use them. Drivers who leave their engines running unnecessarily, e.g. while waiting at a level crossing, can also be issued with a fixed penalty notice if they do not turn off their engine when asked by an authorised officer.

EPUK have recently responded to the government’s consultation on whether to introduce a maximum mandatory speed limit on Junctions 28 to 35a of the M1 motorway.

EPUK Response to the Highways Agency’s Consultation on M1 Speed Restriction – 27 February 2014 (PDF)

What are the laws on car pollution?

Emission Standards

All new cars must comply with strict EU vehicle emission standards, known as Euro standards. Four pollutants are covered: carbon monoxide, hydrocarbons, nitrogen oxides, and particulate matter (diesel vehicles only at present). These maximum permitted emissions are gradually being tightened up – Euro IV came in on 1 January 2006 for cars and was followed by Euro V (September 2009) and Euro VI (approved January 2013) for light passenger and commercial vehicles. Second-hand cars will meet earlier standards and the older your car, the more polluting it is likely to be. The current vehicle emission scandal is due to some vehicle manufacturers producing vehicles which meet much more stringent emission standards during the test cycle than in the real world.

As part of the annual MoT test vehicles have to pass an exhaust emissions test, with the standards based on the vehicle’s age and type of engine.

What can I do to reduce car pollution?

Follow the checklist to ensure you minimise your impact:

  • Avoid using cars for short journeys – combine trips or, alternatively, walk, cycle, or take a bus.
  • Care for your vehicle – check tuning, tyre pressure, brakes and fuel consumption – regular servicing helps keep your car efficient and saves fuel.
  • Lighten up – roof racks add drag and other unnecessary weight increases fuel consumption.
  • When your tyres need replacing consider low rolling resistance replacements – ask your tyre fitter for advice.
  • Drive gently – racing starts and sudden stops increase fuel consumption. Use higher gears when traffic conditions allow.
  • Steady you speed – at around 50mph (80 kph) emissions will be lowest, rising dramatically above 70mph (110 kph).
  • Switch off when stationary – if stuck in traffic or stopping more than a minute. Idling engines make sitting in jams even more unpleasant. Do not run the engine unnecessarily – drive off soon after starting (in some areas it may be an offence to leave the engine running).
  • Be considerate of those around you – reduce the volume of your car stereo or close your car window in residential areas, and avoid sounding your horn or revving your engine.
  • Air conditioning and on board electrical devices increase fuel consumption – only use them when really necessary.
  • Share your journeys – go shopping with friends or neighbours, take a colleague to work, or join a car share club or liftshare.
  • Investigate alternatives – If you’re looking for a new car there are a number of different technologies and fuels available; existing cars can also be adapted to give off lower emissions. See “Choosing a Cleaner Vehicle” below.

What can I do to reduce car pollution at work?

Travel Plans

A travel plan is a range of practical measures to reduce car use for journeys to and from work and for business travel. Measures can include encouraging colleagues to use public transport or providing a dedicated bus service, improving cycling facilities, or car sharing clubs. By setting up a travel plan, your company, school or university can help reduce its impact on the environment, save money and improve its relationship with the neighbouring community. A plan can also help improve accessibility for everyone, not just car drivers.

Green Fleets

If your company has a fleet of vehicles it makes environmental and financial sense to ensure these are adequately maintained, and that drivers are given guidance on how to reduce their environmental impact. Cleaner fuels and technologies can also be considered, as well as working to reduce overall mileage of the fleet and improving fuel efficiency, in order to reduce emissions. The Energy Saving Trust gives free green fleet reviews to companies with fleets of over 50 vehicles, or over 20 in Scotland.

Taxation

In addition to the Company Car Tax rules there are several other tax breaks available. If a company offers free or subsidised work buses, subsidies to public bus services, cycles and safety equipment for employees, or workplace parking for cycles and motorcycles, employees are not required to pay tax for the benefit.

Choosing a cleaner car

In the UK 2 million new cars and 8 million used cars are sold annually. 1.2 million of the new cars sold are to company fleets. When buying a car for use at home or work consider choosing the option with the lowest environmental impact.

New Cars

Diesel and petrol cars dominate new car sales, but gas (e.g. LPG), biofuel and hybrid vehicles are also available. Diesels emit slightly less CO2 in their exhaust than petrol vehicles, but more local pollutants which are harmful to health. Hybrids give maximum benefit if your journeys involve lots of urban driving. You can check the carbon dioxide emissions and fuel consumption of new cars in the VCA guide. Advertisements for new cars give the CO2 emissions and this information is available at the showroom.

Vehicles that run on alternative fuels include LPG (liquid petroleum gas), electric or hybrid vehicles. Cleaner fuels are becoming more widely available and they may save you money and reduce pollution.

Used Cars

When buying a used car you have similar choices on size, fuel type, etc than you do when buying a new one. Remember that the newer the vehicle is, the cleaner it is likely to be. However, regular maintenance is also important and a full service history will help to ensure the vehicle is running clean and well. For vehicles produced after March 2001 you’ll be able to find CO2 and fuel economy figures in the VCA guide.

Cleaner Car Tips

  • Downsize – a smaller car will save you money and reduce pollution. Many small cars now have ‘big car’ features and levels of comfort.
  • Think fuel – if most of your driving is on motorways and trunk roads a diesel car could offer the lowest CO2 emissions. If most of your driving is urban a petrol, or better still a hybrid, has lower emissions of local pollutants harmful to health.
  • Check the figures – if you’re after a new car, or a used one produced after March 2001, check the VED database for its CO2 emissions and Euro standard. Aim for a low CO2 figure and a Euro IV rating. and Euro V and VI for commercial vehicles.
  • Look at the history – when shopping for a used car look for one with a good service history to ensure it has been well maintained.
  • Turn it off – remember that air conditioning and electrical gadgets can increase fuel use significantly.
  • Why idle? – Many vehicles now are available with stop-start technology that automatically stops the engine when the car is stationary, and starts it again very quickly when you’re ready to move off. This saves fuel, and reduces both emissions and noise.
  • Look to the future – commercial that meet the Euro VI standard will start appearing in the new market during 2013, ask the dealers if the model you are interested in complies.

Which fuel?

Different fuels have different environmental advantages.

Diesel

Diesel vehicles emit higher levels of NOx and particulates than new petrol vehicles. They generally have lower CO2 exhaust emissions compared to petrol, because of the higher efficiency of diesel engines. However the overall climate change benefit may be negligible once refinery emissions and emissions of other climate change pollutants, such as black carbon, are taken into account.

Petrol

Petrol vehicles produce less local air pollution with their lower NOx and particulate emissions. Some new petrol technologies now coming onto the market offer significant improvements in fuel efficiency. Compare fuel economy and CO2 figures for petrol and diesel models to see what the differences are.

Biofuels

Biofuels are produced from oil of crops such as oilseed rape, sunflowers and soybeans, and from waste cooking oils. They are usually sold in blends of up to 5% with petrol or diesel and although they are not completely carbon neutral (because of the energy used to grow and process them) they offer significant carbon savings over petrol and diesel and are compatible with most vehicles. You should check with your vehicle’s manufacturer to be sure.

Biodiesel is more widely available than bioethanol and some higher blends of biodiesel can also be used in some vehicles. Some vehicles, known as “flex fuel vehicles” can run on a blend of up to 85% bioethanol and 15% petrol, known as E85, as well as just petrol. Availability of these vehicles is currently limited but improving.

LPG and CNG

LPG (Liquid Petroleum Gas) has proved popular thanks to Government tax incentives that makes fuel relatively cheap. However, the Government has started to reduce the tax differential between LPG and conventional fuels and will continue to do so over coming years. Vehicles using LPG tend to be dual-fuel and can run on either petrol or LPG. On local emissions LPG vehicles tend to have cleaner exhausts than petrol vehicles, and diesel like emissions of CO2.

CNG (Compressed Natural Gas) offers even lower CO2 emissions than LPG, and very low particulate emissions. CNG vehicles can also run on biomethane, offering even lower CO2 emissions.

LPG and CNG cars are generally converted from petrol fuelled cars, either by the original manufacturer or by a specialist converter. Some manufacturers now offer ‘dedicated’ cars, which have been specially designed to run on gaseous fuels. These are likely to give the best performance.

Electric Vehicles

A number of Electric Vehicles (EVs) are available. They are cheap to run and have virtually no emissions at the point of use, although when the batteries are charged emissions are created at power stations. The drawbacks are that battery technology, although improving, remains heavy and expensive. EVs have a limited range – typically 100 miles – and can take several hours to recharge, but are worth considering as an urban runabout suitable for shorter journeys.

Hybrid Vehicles

Hybrid vehicles use a conventional petrol engine in conjunction with an electric motor and a battery. The extra power of the electric motor allows a smaller petrol engine to be used and for it to be loaded more efficiently. This can reduce CO2 and local pollutant emissions. Some hybrids operate on their electric motor alone for short periods of time at low speeds.

There are now several hybrid models available in the UK. The hybrid drive can be used to reduce emissions or alternatively to improve performance over models with a similar sized petrol engine. These can be battery operated hybrids or plug-in hybrids, which can be recharged externally. In addition to ‘full’ hybrids, ‘micro’ hybrids are also available. In these models the electric motor does not provide power to propel the vehicle, but allows the petrol engine to stop when the vehicle comes to a halt. These cars are usually cheaper than ‘full’ hybrids, and in urban areas produce significantly less CO2, local air pollution and noise.

Fuel Cell and Other Vehicles

Fuel cell vehicles combine hydrogen fuel with oxygen from the air to produce electricity. This is then used to propel the vehicle, the only exhaust emissions being water. Emissions are produced in the production of the hydrogen fuel; at present most hydrogen comes from reforming natural gas. Although fuel cell vehicles are clean and quiet they are currently in the early stages of development, and it will be some years before they become common on our roads.

Further contacts

Department for Transport
Tel: 0300 330 3000
Contact form

Office for Low Emissions Vehicles
Email: olev.enquiries@olev.gsi.gov.uk

Campaign for Better Transport
Tel: 020 7566 6480
Email: info@bettertransport.org.uk

Vehicle Certification Agency
Tel: 0300 330 5797
Email: fuel@vca.gov.uk

Low Carbon Vehicle Partnership
Tel: 020 7304 6880
E-mail: secretariat@lowcvp.org.uk

Environmental Transport Association
Tel: 0845 389 1010
Email: eta@eta.co.uk

Liftshare
Tel: 01603 389321
E-mail: info@liftshare.com

Carplus
Tel: 0113 234 9299
Contact form

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