COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Review of Directive 97/68/EC on emissions from engines in non-road mobile machinery in view of establishing a new legislative instrument
Date: 2014-09-25
Institutions: European Commission
Subjects: Community certification, environmental standard, motor vehicle, motor vehicle pollution, reduction of gas emissions, technical specification













EUR-Lex - 52014SC0282 - EN











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52014SC0282

COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Review of Directive 97/68/EC on emissions from engines in non-road mobile machinery in view of establishing a new legislative instrument /* SWD/2014/0282 final */









COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the document
Review of Directive 97/68/EC on
emissions from engines in non-road mobile machinery in view of establishing a
new legislative instrument

Disclaimer:
This report commits only the Commission's services involved in its preparation
and does not prejudge the final form of any decision to be taken by the
Commission.
TABLE OF
CONTENTS
              Executive Summary Sheet  6
1.               Procedural
issues and consultation of interested parties  9
1.1.           Identification  9
1.2.           Organisation
and timing   9
1.3.           Consultation
and expertise  9
1.4.           Scrutiny by the Commission Impact Assessment Board  10
2.               Context  10
3.               Problem
definition  11
3.1.           The
problem that requires action  11
3.2.           Underlying
drivers of the problem   15
3.3.           Who
is affected, in what ways and to what extent?  15
3.4.           Evolution
of the problem   16
3.5.           EU
right to act  16
4.               Objectives  17
4.1.           General
policy objectives  17
4.2.           Specific
policy objectives  17
4.3.           Operational
policy objectives  18
4.4.           Consistency
with other policies and objectives  18
5.               Policy
options  19
6.               Analysis
of impacts  21
7.               Comparing
the options  52
8.               Monitoring
and evaluation  55
List of
abbreviations  56
Annex I:
Specific emission limit values used for the analysis  58
Annex II:
Summary of the open public consultation  61
Annex III: Summary of cost assumptions
for option 3 (chapter  6.3)………………………...65
Annex IV: Summary of cost assumptions
for option 4 (chapter 6.4)………………………...69
              
               Executive Summary Sheet 
 Review of the legislative instrument on emissions from engines in non-road mobile machinery 
 A. Need for action 
 Why? What is the problem being addressed? 
 Non-Road Mobile Machinery (NRMM) covers a large variety of combustion engines installed in machines ranging from small handheld equipment, construction machinery and generator sets, to railcars, locomotives and inland waterway vessels. These engines contribute significantly to air pollution and are accountable for roughly 15% of the nitrogen oxide (NOx) and 5% of the particulate matter (PM) emissions in the EU. The data also indicate that their relative contribution to the total NOx emissions will become bigger over time. The emissions limits for these engines are set in Directive 97/68/EC. This Directive was amended a number of times, but the technical review concluded that the current legislation has shortcomings. The scope is overly restricted, new emission stages were last introduced when the Directive was amended in 2004 and no longer reflect the current state of technology, and there is a mismatch between the emission limits for certain engine categories. 
 What is this initiative expected to achieve? 
 The initiative seeks to protect human health and the environment, and to ensure a good functioning of the internal market for NRMM engines. It also seeks to address competitiveness and compliance aspects. In line with the EU's air quality policy, the objective is to progressively reduce the emissions from new engines being brought on the market. This is expected to result in a very significant emission reduction overall, but the reduction by engine category will vary depending on how stringent the specific requirements already are. The revision is also expected to alleviate the pressure on Member States to take additional regulatory action that could hamper the internal market. Finally, the revision seeks to remove obstacles to external trade by reducing the regulatory barriers that result from diverging emission requirements. 
 What is the value added of action at the EU level? 
 The problem of air pollution has a strong transnational dimension as the effects are rarely confined to the territory of one Member State only. All EU Member States share common EU air quality goals and also have a strong interest in avoiding barriers to intra-community trade. Common rules at the EU level are, therefore, best suited to address the problem. This initiative concerns the revision of existing EU legislation and would not mean that EU legislation is established in a new area. 
 B. Solutions 
 What legislative and non-legislative policy options have been considered? Is there a preferred choice or not? Why? 
 Three main policy options were analysed in detail. Each consists of various sub-options for the engine categories and applications already covered by EU NRMM legislation, and for the ones that could come under its scope in the future. Alongside the no-policy change scenario, these options are: Option 2: Alignment with US standards in scope and limit values Option 3: Step towards road sector ambition levels, for the most relevant emission sources Option 4: Extended level of ambition through enhanced monitoring provisions It was already taken into account in the analytical design that the preferred option might be a combination of elements from different options. The analysis of costs and benefits was carried out in individual modules that allow for regrouping. Non-legislative options (e.g. a voluntary agreement with industry) have been considered, but the initial analysis concluded that they are unsuitable for reaching the initiative's objectives. 
 Who supports which option? 
 The need for a revision is acknowledged by Member States, industry and NGOs alike. However, the preferred level of ambition differs between stakeholders who naturally assign different weight to costs and benefits. Engine and machinery manufacturers would be most directly affected by the cost increase that could result from more stringent emission limits and stress the need for cost-effective reductions and alignment with US EPA limits. Option 2 would require limited research and development efforts from them and could strengthen their export potential, but would still result in important emission reductions. Some Member State authorities and environmental NGOs support a solution that would go one step further and bring NRMM emission legislation closer to the requirements for trucks, by inserting a particulate number (PN) limit in addition to the particulate matter mass limit (PM). Options 3 and 4 answer to this call. End customers, such as railway and inland waterway vessel operators, tend to be most cost-sensitive and stress that the environmental benefits of more stringent emission legislation will only translate into real life reductions if the operators can afford cleaner machinery. 
 C. Impacts of the preferred option 
 What are the benefits of the preferred option (if any, otherwise main ones)?                                  
 Due to the considerable diversity of engines and applications in the NRMM sector, the preferred option is a combination of elements cutting across policy options. The preferred option will lead to a significant reduction of pollutant emissions which have adverse effects on human health and the environment. The focus is on the reduction of diesel particle emissions. In addition, substantial reductions in NOx and HC emissions will be achieved. Overall, the benefit of the preferred option is expected to be in the € 26,100 to 33,300 million range until 2040. A detailed quantification of the benefits is provided for all options and engine categories. Due to the breadth of the NRMM sector and the large variety of engines and machinery covered, it was not possible to capture all relevant aspects in one study at one time. As a result, the data stem from different studies and certain concessions in terms of geographical coverage and base year had to be made to keep them comparable. 
 What are the costs of the preferred option (if any, otherwise main ones)?                               
 A detailed quantification of the costs is provided for all options and engine categories. The cost of the preferred option will mainly be incurred by engine and machinery manufacturers (for development, redesign and production), but also by end-users of machinery (for additional fuel consumption and maintenance). The total cost of the preferred option will be in the range of € 5,200 to 5,800 million until 2040. Overall, the cost-benefit analysis shows important net benefits, but significant investment will be required for certain engine categories and/or sectors. The investment need will be highest in sectors which, until now, have less stringent emission requirements in relative terms; i.e. small diesel engines (19-37 kW) and engines used in the IWT sector. 
 How will businesses, SMEs and micro-enterprises be affected? 
 The result of the public consultation indicates that a large majority of businesses, including SMEs, will at least support more stringent emission limits in-line with the current US legislation. Impacts on SMEs were thoroughly assessed in a dedicated study and it is likely that the costs of more stringent emission requirements are more strongly felt by SMEs. In particular in the IWT sector, where shipbuilders, dealers and end users are often SMEs. 
 Will there be significant impacts on national budgets and administrations? 
 A significant impact on national budgets and administrations is not expected. 
 Will there be other significant impacts? 
 Reducing unequal treatment of engines inside and outside the scope of the Directive, avoids market distortions and unfair competition. Closer alignment with third country requirements emission standards, particular the US, improve cost-efficiency and competitiveness of manufacturers. This is of particular interest with regard to the possible free trade agreement (FTA) between the EU and the US, given that NRMM and their engines make up for a significant part of transatlantic trade. Further regulatory market fragmentation is avoided, with some Member States currently introducing local restrictions in order to comply with EU air quality policy. 
 D. Follow up 
 When will the policy be reviewed? 
 A technical review of the NRMM legislation was carried out in 2008, which triggered the development of the current initiative. Such a review could be repeated a number of years after the entry into force of the revised NRMM legislation once sufficient evidence of the effects can be expected. This could be the case 5 years after the entry into force of new emission requirements. 
              
1.           Procedural issues and consultation of interested
parties 
1.1.        Identification 
Lead DG: ENTR
Other involved DGs: SG, EMPL, MOVE, CLIMA, ENV,
RTD, JRC
Agenda Planning/WP Reference: 2010/ENTR/001
1.2.        Organisation and timing
Work on this impact assessment started in 2008
with a technical review of the NRMM Directive. In the following years, the
review was followed-up with the commissioning of external studies and the
preparation of emission inventories for various engine categories. The impact
assessment report itself was drafted during the year 2013.
1.3.        Consultation and expertise
An open public consultation started on 15
January 2013 and closed on 8 April 2013 (12 weeks duration). For this purpose,
a dedicated consultation web-page[1]
was set up and the Commission services prepared a 15 page consultation
document, outlining key issues, study results and potential courses of action.
69 responses were received in total. A detailed analysis of the results is
included in Annex II of this report and the individual responses can be viewed
on the consultation web-page. Furthermore, a stakeholder hearing attended by
approx. 80 participants took place in Brussels on 14 February 2013. The Group
of Experts on Machinery Emissions (GEME), which brings together industry, NGO, Member State and Commission representatives was regularly informed on the state of the
impact assessment work and actively supported the process. The position of all
stakeholders was duly considered and almost unanimous agreement exists on the
need to further develop NRMM engine emission legislation.
The work on the impact assessment was followed and
informed by an inter-service steering group which met on 25 April, 6 June, 11
September and 17 October 2013. All relevant Commission services were invited to
participate in this group and SG, EMPL, MOVE, CLIMA, ENV, RTD and JRC followed
the invitation. The JRC further supported the analytical work with a research project
on the effects of particulate number (PN) limits for certain engine categories.
The Commission has carried out various studies
and regularly consulted stakeholders, as concerns the feasibility of new limit
values and the need to include new stages for exhaust emissions based on
technical progress. The Impact Assessment builds on the following external studies[2]:
-  
A Technical Review of the Directive, submitted
in two parts, by the JRC, which in part 1 includes an overview of emissions
inventories for NRMM. Part 2, inter alia, focuses on spark ignition engines (small
petrol engines and snowmobile engines) and, among others, analyses emission
inventories and market sales of construction and agricultural machinery.
-  
An Impact Assessment study by ARCADIS N.V.
assesses the impacts of the policy options developed in the Technical Review of
the JRC. A complementary study by the same contractors looked specifically at
the impacts on small and medium sized enterprises (SMEs). In addition to the
social and economic impact the environmental and health impact was also
evaluated in this study. 
-  
A study from Risk & Policy Analysis (RPA)
and Arcadis, evaluates the current contribution of the NRMM sector to greenhouse
gas (GHG) emissions. This study also examines the feasibility of extending the
emission limits for variable speed engines to constant speed engines and
considers the option of aligning the exhaust emission limit values to US values.
-  
The PANTEIA study[3]
commissioned by DG MOVE analysis the situation in the inland navigation sectors
and assesses specific measures for reducing emissions from inland waterway
transport.
1.4.        Scrutiny by the Commission Impact Assessment Board
The Impact Assessment Board of the European
Commission assessed a draft version of the present impact assessment and issued
its opinion on 22/11/2013. The Impact Assessment Board made several
recommendations and, in the light of the latter, the final impact assessment
report:
Clarifies the rationale for expanding the scope
of the Directive and explains more thoroughly how regulatory shortcomings
contribute to internal market distortions and air pollution problems. 
Describes the structure of the NRMM sector by
means of additional graphs and explains the coherence of the planned review of
the NRMM Directive with other air quality related initiatives. Furthermore, it
provides an overview of the positions of both Member States' authorities and
different economic operators, including SMEs in Annex II and throughout the
text.
2.           Context
This Impact Assessment report examines options
for revising Directive 97/68/EC (hereafter NRMM Directive) of 16 December 1997
on the approximation of the laws of the Member States relating to measures
against the emission of gaseous and particulate pollutants from internal
combustion engines to be installed in non-road mobile machinery.
The NRMM Directive establishes the exhaust
emission limits and implementation dates – divided into stages – for the
various engine categories within its scope. The engines covered by the
Directive include spark-ignited (petrol) engines and compression ignited
(diesel) engines, both variable speed and constant speed, which are used in a
wide range of applications ranging from small handheld equipment, construction
and forestry machinery, generators, to railcars, locomotives and inland
waterway vessels. The exhaust emission limits provided for in the Directive get
progressively stricter over time in pre-defined stages, with the latest stage
coming into effect in 2014. The Directive also provides the procedures for
type-approving these engines before they are placed on the market and specifies
the relevant test methods. Furthermore, it stipulates certain exemptions,
derogations and transitional measures. It is important to note that certain
engine categories are not regulated at present. Most notably compression
ignited engines with less than 19kW and more than 560kW, and spark ignited
engines above 19kW. This leaves important regulatory gaps, especially by
comparison to the United States where these engines are regulated and the
overall stringency of NRMM emission legislation is higher. 
The initiative under consideration is situated
in the broader context of the EU’s air quality, occupational health, energy, transport
and climate protection policies. In particular, it relates to the current
review of the EU’s air quality policy and the EU legislation on the prevention
and control of emissions from industrial production processes (IPPC and IED
Directives) and combustion plants (LCP Directive). Furthermore, there is a
close link to the EU's emission legislation for heavy duty motor vehicles (i.e.
trucks and busses) where similar engines and aftertreatment systems are often in
use and which stipulates more stringent emission limits than the NRMM Directive
in its current form. With the entry into force of the Euro VI emission limits
for all new trucks and buses in 2014 this gap will widen. As the initiative
under consideration would be addressed to a number of important economic sectors,
it is also linked to EU industrial policy and Europe 2020, the European
strategy for growth and jobs. 
Since its adoption in 1997 the Directive was
amended several times, with the most relevant amendments being:
-  
Directive 2002/88/EC extended the scope to small
petrol engines (Stage I and II);
-  
Directive 2004/26/EC extended the scope to
constant speed engines as well as to rail and inland marine engines. Stages
IIIA, IIIB and IV were introduced together with certain flexibility provisions;
-  
Directive 2011/88/EU revised the flexibility
percentage for Stage IIIB engines;
-  
Directive 2012/46/EU clarified certain technical
issues on Stage IV engine testing. 
A complete overview of all amendments is
available from this website[4].
Starting from the requirements already set in the amending Directives, the
review will assess further reduction measures taking into account technical and
economic feasibility for the manufacturers of engines and machinery.
3.           Problem definition 
3.1.        The problem that requires
action
Air pollution
Combustion engines installed in NRMM are a significant
source of air pollution and this is the main problem that the Directive itself
and the current review seek to address. At present, many EU Member States
struggle to reach their air quality objectives and a further reduction of emissions
from combustion engines is an important issue in this context. Despite the
limits set by the NRMM Directive and its subsequent amendments, the NRMM sector
has become an increasingly important source of air pollution in relative terms,
especially of nitrogen oxides (NOx) and particulate matter (PM). The NRMM
sector is responsible for around 15% of the total NOx emissions and 5% of the
total PM emission in the EU. While the PM share is expected to decrease, the
NOx share is expected to increase up to nearly 20% in 2020. NOx emissions in
absolute terms, however, will decrease in the same period. This can be
explained by the faster decrease in emissions from the other sectors especially
the road transport sector. The projections below are taken from the 2013 review
of the EU air policy of DG ENV and provide an overview of the NOx and PM
emissions from the non-road sector up to 2050 and constitute a baseline for
this impact assessment. It is worthwhile noting that a number of NRMM sectors,
such as domestic shipping and aircrafts (see dotted lines in the charts below),
are not included in the scope of the NRMM Directive.
In order to address this situation and to further
decrease emissions, subsequent amendments to Directive 97/68/EC, most notably
2004/26/EC introduced further emission reduction stages for existing regulated
engine categories and brought other engines into the scope. The JRC study shows
that these further steps can be expected to provide a significant reduction in
the overall amount of pollutants emitted from NRMM engines over the next
decade. However, as the most stringent emission stage IV requirements foreseen
in the current legislation will enter into force in 2014, it now appears
necessary to ensure that the NRMM sector is put on a long-term emission
reduction trajectory that is aligned to the EU's overall air quality policy and
regulatory requirements in adjacent sectors. Due to the strong export
orientation of the engine and machinery manufactures based in the EU, it is also
of major importance that emission requirements, where relevant, are developed
with a view to the corresponding requirements in the main third-country markets
such as the United States. 
Providing more long-term guidance on emission
requirements than is currently the case would also give more planning certainty
to industry and enable the sector to schedule the necessary investments in
research and development. 
Alongside the impact of NRMM engine exhaust gas
on air quality, NRMM is also accountable for roughly 100 million tons of CO2
equivalent emissions in the EU27 annually which corresponds to 2% of the EU27’s
total greenhouse gas emissions[5]
and, therefore, contributes to global warming. It is, however, important to
keep in mind that the focus of the legislation at hand is on the reduction of
toxic pollutants (NOx, PM, HC, CO). The regulatory approach taken for light
duty vehicles (cars and vans) where toxic pollutants and greenhouse gases are
addressed in separate pieces of legislation follows the same logic.
Regulatory shortcomings
Despite past efforts, the legislation in its
current form has specific shortcomings. Not all categories of NRMM engines are
covered. More specifically, the Directive excludes:
-  
Compression-ignited (CI) engines with less than
19kW and more than 560kW, despite the fact that they alone represent 17% of all
non-road applications and have a significant impact on the environment;
-  
Spark ignited engines above 19kW;
-  
Stationary engines;
-  
Engines installed in all-terrain vehicles;
-  
Engines installed in snowmobiles;
-  
Engines running on alternative fuels such as LNG.
The fact that these engines are currently
unregulated means that important environmental benefits are foregone. They were
excluded because of their overall low contribution at the time of the last
revision in 2004 and have become more important sources of pollution in the
meantime by comparison to the regulated engine categories. 
Furthermore, there is a risk of market
distortion due to the following effects:
-  
For some machinery, the producer has some choice
whether to install an engine currently covered by the Directive or an unregulated
one. In particular a switch from CI to SI engines could be encouraged by the
present regulatory situation depending on the circumstances and fuel
availability. These findings have been confirmed by the feedback received from
stakeholders during the open public consultation.
-  
The current difference in regulatory stringency
between certain categories of CI and SI engines in the Directive, in principle,
also has the potential to result in a distortion of the market.
-  
There is also the possibility that Member
States, regions or municipalities increasingly resort to local regulation
restricting the use of certain NRMM in order to meet air quality requirements
(see section 3.4 for examples).
New emission stages were last introduced when
the Directive was amended in 2004. This means that emission requirements for
certain engine categories are becoming outdated when compared to the state of
the art of technology and recent developments in the road sector. Furthermore,
conclusive evidence[6]
became available in the meantime about the adverse health effects of diesel
exhaust emissions and especially about particulate matter (i.e. diesel soot). One
of the main findings is that the size of the particles is a crucial factor
behind the observed health effects and this can only be addressed by limit
values that are based on a particle number count (i.e. PN limit). Experts
concluded that even the most ambitious levels defined by Stage IV do not
guarantee adequate protection from such pollutants. In line with the
developments in the road sector, the introduction of a new emission stage
(Stage V) targeting particle number limits in addition to particle mass limits,
therefore, needs to be considered for the most relevant engine categories. 
Furthermore, there is a mismatch between
certain engines categories as to the stringency of the currently applicable
emission limits. In particular, the emission limits for engines installed in
inland waterway vessels appear to be insufficiently ambitious and require
reassessment. The NAIADES II Communication[7]
on inland waterway transport identifies a lack of stringency in the current emission
limits as an important issue that needs to be addressed to ensure the long-term
viability of inland navigation as a green mode of transport.
Exhaust emissions from constant speed engines,
which represent a large part of non-road engines are regulated since 2007. The
emission limits for these engines are, however, less stringent than for
variable speed engines, which may encourage manufacturers to move from variable
speed engines to constant speed engines with lower environmental standards. This
situation needs to be reviewed as there is no technical justification for
assigning less stringent limit values to constant speed engines.
Currently, the emission limits for NRMM are
being tested under laboratory conditions when the engine is type approved.
Whilst the Directive does require the emissions control system to correctly
function under real-world conditions, it does not contain any provision to
check that a properly maintained emissions control system is indeed functioning
correctly when in service. It may be useful to provide measures and check
whether engine emissions in-service are fulfilling the requirements set by the
Directive over the prescribed useful engine life, as this is already the case
for heavy duty road vehicles.
3.2.        Underlying drivers of the
problem
As explained in the problem description, some
regulatory shortcomings hinder the effectiveness of EU NRMM emission
legislation. Similarly, current emission limits do not fully reflect technical
progress and public health concerns are insufficiently addressed.
Due to increasingly stringent emission requirements,
NRMM within the scope of the current Directive have become cleaner over time.
However, due to the late introduction of reduction efforts by comparison to the
road sector and the absence of emission requirements for certain categories of
NRMM engines, the resulting emissions trajectory still falls short of what is
needed to deliver on the EU's air quality and occupational health objectives. 
3.3.        Who is affected, in what ways
and to what extent?
A range of different groups are affected by the
problems discussed above:
-  
The population of the European Union is affected
by poor air quality through the acute (i.e. short-term) and chronic (i.e.
long-term) effects on health. Effects can range from minor respiratory
irritation to cardiovascular diseases and premature death. A number of groups
within the population are particularly vulnerable. Especially workers who are directly
exposed to high concentrations of NRMM engine exhaust gas over an extended
period of time are at a heightened risk. Children, elderly people and those
with an existing cardio-respiratory disease are also particularly vulnerable. 
-  
Engine and machinery manufacturers including
component suppliers: More stringent emission limits can be expected to require
adaptation or redesign of engines, machines and their components. This may
entail substantial research and development effort and increased production
cost affecting manufacturers, importers and exporters of engines and non-road
machinery, and their employees. A considerable number of SMEs can be expected
to be affected in client sectors such as construction or inland navigation. For
certain component suppliers, including the makers of after treatment systems,
stricter emission limits could result in higher demand for their products.
-  
Operators of NRMM: An increase in the production
cost of NRMM could be handed on to the operators of NRMM to a certain extent
and stricter regulatory requirements could possibly also result in higher operation
and maintenance costs.
-  
Finally, national public authorities responsible
for type approval and market surveillance could be affected as they play a key
role in enforcing the legislation.
-  
Particular attention is given to the potential
effect on the SMEs amongst the manufacturers, component suppliers and operators.
3.4.        Evolution of the problem
Without additional public intervention at the
EU level, the evolution of the problem would be mainly determined by the legal
requirements already in force, future demand for NRMM and the rate of renewal
of the existing machinery stock. 
In absence of EU action, Member States can also
intervene themselves, as they need to comply with the limits and targets for
various air pollutants set by the EU's Ambient Air Quality[8] and National Ceilings[9] Directives. Some
European cities have already introduced seasonal restrictions on the use of
older construction machinery (e.g. Austria and Sweden) and some public entities
in the EU have tightened their public procurement rules by requiring specific low
emission machinery for public works contracts (e.g. Berlin and Stuttgart). This
already results in a distortion of the internal market and could become a more
important barrier in the future, unless a harmonised basis for such efforts is
provided in form of more stringent EU emission stages. 
Additionally, if no action is taken, the misalignment
with 3rd countries (e.g. US, Switzerland, Japan) would continue or could
even increase. Already now, EU manufacturers have to offer substantially modified
engines and machines in some of these markets to meet the applicable emission
requirements. This leads to reduced scale effects, increased costs for the
manufacturers and technical barriers to trade. 
3.5.        EU right to act
The legal basis of the NRMM Directive 97/68/EC
is Article 114 of the Treaty on the Functioning of the European Union. 
As this concerns amendments to existing EU
legislation, only the EU can effectively address the issues. The subsidiarity
principle is respected, since the policy objectives cannot be sufficiently
achieved by actions of the Member States. European Union action is necessary
because of the need to avoid the emergence of barriers to the single market
notably in the field of NRMM engines, and because of the transnational nature
of air pollution. Even though the effects of the main air pollutants are most
severe close to the source, the effects on air quality are not limited to the
local level and cross-border pollution is a serious environmental problem that can
make national solutions ineffective. In order to solve the problem of air
pollution, concerted action at the EU scale is required.
Setting up emission limits and type approval procedures
at national level would potentially result in a patchwork of 28 different
regimes which would represent a serious obstacle to intra Community trade. Moreover,
it could impose a significant administrative and financial burden on
manufacturers who are active in more than one market. Therefore, the objectives
of the initiative under consideration cannot be achieved without action at the EU
level.
Finally, a harmonised approach at EU level is expected
to represent the most cost-efficient way for manufacturers and end-users to
achieve emission reductions.
4.           Objectives
The primary objective of the NRMM Directive is
to reduce the emission of gaseous and particulate emissions (NOx, HC, PM, CO)
from the engines incorporated in non-road mobile machinery. This is also the
central objective of the review process. More specifically, the initiative
under consideration pursues the following objectives.
Greenhouse gas (GHG) emissions are currently
not included in the scope of the NRMM Directive. This is mainly due to the fact
that the Directive targets at the emission performance of engines rather than of
the machinery in which the engines are installed. Given that the GHG emission
performance is, however, to a great extent influenced by the machinery (e.g.
weight, design,…) as well as its actual operation, the most appropriate
legislative way as to how best address GHG emissions is still to be sought.   For
the considerations of the current review process, GHG emissions, therefore,
remain out of scope. 
4.1.        General policy objectives
-  
Health and environment: Protect human health and the environment through a further
reduction of toxic air pollutant emissions from NRMM engines.
-  
Competitiveness: Ensure
a good functioning of the internal market and provide a reliable, long-term
regulatory outlook for the relevant economic sectors.
4.2.        Specific policy objectives
-  
Health and environment: Contribute to a reduction of toxic air pollutants (NOx, HC, PM,
CO) with a view to the objectives of the EU's air quality policy.
-  
Competitiveness: Reduce
obstacles to internal and external trade and prevent regulatory fragmentation
by reducing the pressure on Member States and other public authorities to impose
restrictions of the use NRMM. Furthermore, promote technical progress by
providing long term guidance on emission limits. The revision also aims at
increasing alignment with regulations established outside of the EU market, and
the United States in particular.
-  
Compliance: Support
Member States in their efforts to comply with the requirements of EU air
quality policy by providing them with a supportive regulatory environment.
4.3.        Operational policy objectives
-  
Health and environment: Ensure that NRMM emission limits and type approval requirements
reflect technical progress and address the regulatory shortcomings that have
been identified. In concrete terms, this means updating the Directive’s scope and
limit values.
-  
Compliance: Support
Member States, regions and cities in addressing compliance problems in the
so-called urban hotspots, where air quality problems have proven to be most
difficult to address.
4.4.        Consistency with other
policies and objectives
The initiative under consideration is aimed at improving
environment and health protection by updating existing emission limits and by
extending their scope where appropriate. At the same time, it is aimed at
ensuring the functioning of the single market, while removing unnecessary
burden on the companies operating in it and internationally. It is, therefore,
entirely consistent with the Europe 2020 strategy and fully aligned to the EU's
Sustainable Development Strategy. 
In this context, the initiative under
consideration ties in with the following more specific policies and objectives:
-  
The EU’s 6th Environmental Action
Programme[10]
which proposed to attain “levels of air quality that do not give rise to
significant negative impacts on, and risks to human health and the environment”.
-  
The Thematic Strategy on Air Pollution[11] which provides a comprehensive
EU policy framework for reducing the adverse impact of air pollution on human
health and environment for the period up to 2020.
-  
The National Ceilings Directive 2001/81/EC which
establishes legally binding limits for the total permissible emissions at Member State level for several air pollutants. According to the official data reported
under this Directive, 12 Member States exceeded these limits in 2010 and,
despite some improvements, compliance problems will likely persist.
-  
The Ambient Air Quality Directive 2008/50/EC which
sets legally binding limits for concentrations in outdoor air of major air
pollutants such as particulate matter and nitrogen dioxide.
-  
The 2011 White Paper on Transport[12], in particular with
regard to cleaner inland waterway and rail transportation. 
More stringent requirements
for combustion engines in NRMM would positively contribute to the objectives of
all of the above policies. In this context, it should be noted that the EU's air
quality policy is currently subject to a comprehensive review as the policy
efforts, at EU and national level, have not fully delivered the expected
results in terms of improved air quality.
-  
The abovementioned review of the EU’s air
quality policy and the present review of NRMM legislation are closely
interlinked. Among other activities, DG ENV announced its intention to carry
out simulation calculations with a view to further quantifying the emission
reduction effects of the preferred option in the context of the air quality
review. 
Furthermore, the
initiative under consideration is situated in the context of:
-  
The Integrated Industrial Policy for the
Globalisation Era[13]
which calls for a strengthening of the single market and the convergence of
rules and standards at the international level. The initiative under
consideration also ties in with the industrial policy update of 2012[14] and could make an
important contribution to technical harmonisation in the context of the EU-US
trade negotiations (TTIP).
5.           Policy options 
Building on the problem description in section
3.1, four policy options will be analysed in detail. It is important to note
that a non-regulatory approach (i.e. self-regulation of industry) is already
being discarded at this stage. Such an approach would mean that it would be up
to industry to decide and implement new emission requirements for NRMM engines.
However, in the light of past experience in other regulatory areas, it is
doubtful if consensus among all relevant manufacturers could be reached on more
ambitious emission limits, substantially exceeding the requirements of the
current Directive. It is also questionable if all manufacturers would respect
such a non-binding agreement in practice, and if a satisfactory level of
environmental and health protection would result from it. Hence, it appears that
emission limits for NRMM engines can only be effective and ensure a level
playing field if they are legally binding. The open public consultation showed
that this also corresponds to the view of the industry stakeholders who mostly
spoke out in favour of the US alignment option (i.e. a regulatory approach).
The effect of variations in implementation
dates has the same effect across options and is therefore not reflected as a
parameter in the design of the individual policy options. However, the need for
sufficiently long lead times for industry to re-design and adapt their engines
and machinery to the new technological requirements is an important
consideration within the overall context of the review. Tools which proofed to
be effective in the current Directive such as, for instance, the granting of a
certain degree of flexibility throughout the transition period between two
emission stages will be maintained and are, therefore, also not included in the
assessment of individual options. 
Option 1: Business as usual – applying the existing
legislation (Baseline)
The NRMM Directive would continue to apply in
its current form and no new emission stage would follow on Stage IV, which enters
into force from 2014 onwards. Engine types outside of the current scope would
continue to be unregulated, unless Member States decide to act themselves.
Option 2: Alignment with US standards in
scope and limit values
The revision would seek to achieve alignment
with US-EPA standards where feasible. As today’s US-EPA standards are generally
stricter than current EU standards, this approach would have the effect of both
extending the scope of regulated engines and introducing stricter emission
limit values. For engine categories where a meaningful correspondence between the
EU and the US limits cannot be established, or where less stringent standards
apply in the US than in the EU, notably for railcars which do not exist as a
distinct category in the US, no alignment would be sought. Instead, an
appropriate level of ambition would be applied with a view to ensuring
consistency across engine categories. It is also important to note that this
option would target particle mass limits rather than particle number limits. 
Option 3: Step towards road sector ambition
levels, for the most relevant emission sources
The Euro VI emission standard for heavy duty
vehicles (i.e. trucks and buses) would be used as the main point of orientation.
This would notably include the issue of particulate matter number limits which
currently do not exist in NRMM legislation. However, the technical and
regulatory differences between heavy duty vehicles and NRMM would be taken into
account when defining limit values. With regard to the definition of limit
values, this option is more ambitious than Option 2 and would seek a coherent
and comparable reduction across the most relevant engine categories. It would
allow for some limited differentiation among the different power classes in
accordance with the results of cost-benefit analyses.
As for engines for the IWV transport sector,
two options are studied: Option 3A being inspired by alignment with future US standards on NOx and HC yet introducing PN emission limits, Option 3B setting in
addition also very ambitious emission reduction targets for NOx and HC. In a
similar manner, two options are being studied for rail applications, i.e. the
introduction of PN emission limits only (Option 3A) respectively PN emission
limits in combination with more stringent NOx/HC limits (Option 3B). 
Option 4: Extended level of ambition through
enhanced monitoring provisions
Under this option, the revision would seek to
combine the more stringent emission limits resulting from Option 2 and/or Option
3 with enhanced monitoring provisions.
These provisions would mainly be aimed at
monitoring the in-service conformity of NRMM engines. In-service conformity
means compliance of the engine with the type approval requirements during the
product’s ‘normal life’. For this reason, legislation has been developed in the
heavy duty sector which is aimed at monitoring, via limited sampling, the
emission performance of engines once installed in vehicles and in service life.
Similar procedures would be introduced for the non-road sector. This could also
serve as a first step towards controlling real world (so-called off-cycle) emissions.

Furthermore, with a view to obtaining a more
accurate picture of the specific greenhouse gas emissions and fuel consumption
of NRMM engines, information on these emissions could be used to label engines
to better inform buyers and users. If deemed necessary at a later point of
time, the results from the monitoring and reporting of the specific greenhouse
gas engine emissions could possibly be used for further measures in the future.
The open public consultation showed that most
industry stakeholders have a strong preference for Option 2, as US alignment would result in reduced emissions without imposing new development costs on industry.
The producers of aftertreatment systems (catalytic converters and particle
filters) are a notable exception to this and expressed a strong preference for
more regulatory ambition. Environmental NGOs and some public authorities also
favour Option 3 and spoke out in favour of close alignment with Euro VI limit
values and procedures. 
6.           Analysis of impacts 
Given the diversity of the non-road sector and
the wide range of engines and applications within the potential scope of the
initiative under consideration, the results of the different studies listed in
section 1.3 had to be combined and adjusted for the purpose of the impact
analysis. The objective was to ensure comparability and to quantify the
expected impacts in monetary terms across engine categories.
Despite far reaching efforts, a number of
limitations remain however. All relevant studies work with EU 15 data and calculations
are mostly based on machinery park and fuel consumption data from 2005. To
address this situation, complementary data and information was obtained from
stakeholders in 2013 which, by and large, confirmed the validity of the study
results. It was also one of the stated objectives of the public consultation to
enable stakeholders to comment on the findings of the background studies and the
feedback received did not indicate that any of the respondents had serious
doubts about their overall validity. 
The types of costs and benefits covered by the
analysis are the following:
-  
Compliance costs are
the development and production costs imposed on the engine manufacturers and
the machinery manufacturers who integrate the engines into their products. They
also include the operational costs imposed on the end user that, for example,
stem from more costly maintenance requirements or the fact that an aftertreatment
system requires consumables, such as urea.
-  
Benefits are analysed
on the basis of the expected reduction of PM and NOx emissions (for snowmobiles
and ATVs also HC), as these are the most important pollutants in the given
context. The total impact of the expected reduction during the period under
review is then monetised by establishing the mass of pollution avoided (in
tonnes) and multiplying it with a specific pollution factor[15] that stands for the
monetary health benefits per unit avoided. In some cases, the underlying
studies have a shorter time horizon than our own calculations which reach to
2040 in Option 2 and 2050 in Option 3. These could not be aligned as the models
used for the studies were no longer accessible. However, this does not have a
discernible effect on the overall trends.
An annual discount rate of 4% was applied to
all costs and benefits in line with the Commission's Impact Assessment
Guidelines. Where different analytical scenarios were assessed for one option,
the relevant range is reproduced in the overview tables (base case, lower
estimate etc.). The concrete limit values for the various engine categories, on
which the analysis of the regulatory options is based, can be found in an
overview table Annex I. 
1.1.                
Option 1: Business as usual – applying
the existing legislation
If the NRMM Directive would continue to apply in
its present form, important benefits would be foregone. In the public
consultation, a large majority of stakeholders acknowledged that the current regulatory
situation is unsatisfactory with a view to its medium- to long term effects. Significant
emission reduction potential that could otherwise be realised would remain
unexploited and a further increase in the adverse environmental impact of non-regulated
machinery would be likely. The data and projections available on air pollution
in Europe and the specific role of NRMM emissions (presented in section 3.1)
support this view.
Maintaining the present regulatory situation would
mean that no long-term regulatory perspective is available for the relevant
economic sectors. The unequal treatment of engines inside and outside the scope
of the Directive could also lead to a distortion of the market and unfair
competition. Furthermore, the chance for closer alignment with third country
requirements would be forgone. It is important to recall at this point that
negotiations on a possible free trade agreement (FTA) between the EU and the US
have started and that NRMM and their engines make up for a significant part of
transatlantic trade. All of the above issues indicate that the problems
described in section 3 of this report will likely persist if no regulatory
action is taken. 
On the positive side, no new regulatory burden
would be imposed on engine and equipment manufacturers at EU level. However, in
absence of EU action, this may happen through Member State legislation.
1.2.                
Option 2: Alignment with US standards
Most engine manufacturers and many equipment
manufacturers are selling their products on the global market and would,
therefore, benefit from harmonised emission limits and test procedures which
would bring down their development, production and certification costs. With
this option, barriers to trade with the United States and a number of other
trading partners that have aligned their legislation to US standards would be
reduced to a minimum. However, the emission limits for certain engine
categories would remain less ambitious than might be technically and
economically feasible. This option would target limit values for particle mass
rather than particle numbers.
In accordance with the description of this
option in section 5, no US alignment would be sought for the engines used in locomotives
and railcars. US emission limits for locomotives are less stringent than the
limits already in force in the EU and the testing procedures differ
considerably. Therefore, the current EU emission limits for railcars and
locomotives would continue to apply under this option.
1.2.1.          
US alignment of CI
engines <19kW
   || Option 2 – US alignment CI < 19 kW 
 Compliance costs ||   ||   
 Development and production costs || € 6.8 m € 6.8 m € 13.6 m 
 Operational costs 
 Total costs 
 Benefits ||   ||   
 Reduction of PM emissions || - 75% 
 Reduction of NOx emissions || - 45% 
 Monetised impact for PM || € 388 m 
 Monetised impact for NOx || € 276 m 
 Total benefits || € 664 m 
 Benefit-cost calculations ||   ||   
 Net impact on society || € 650.4 
 Benefit/cost ratio || 48.8 
 Source: ARCADIS Impact Assessment Study (2009), Reference period: 2005-2030 
1.2.1.1.     Socio-economic impacts
Although diesel engines below 19 kW are
currently not subject to emission regulation in the EU, their emissions are
already regulated in important third-countries, such as the United States and Japan. Due to the overall size of the US market and in the absence of EU regulation,
the US EPA standards have become a global benchmark for this engine category
and all major manufacturers produce compliant engines and machinery. As a
result, the research and development costs for their products to meet identical
limits in the EU can be assumed to border on zero. Additional research and
development costs would occur almost exclusively in the small market segment of
diesel engines with less than 8 kW. These engines exist in the EU market, but
are not present in the US and other third-country markets where this segment is
exclusively populated by petrol engines. As a result, manufactures have not
developed diesel engines and machinery meeting US EPA requirements and would
need to do so if equivalent EU standards were to be introduced. The
introduction of EU limits would also impose certain type approval costs, but
these are likely to be offset by the benefits that internationally harmonised
limits would create for EU manufacturers.
Overall, this option would lead to compliance costs
of roughly 13.6 million euros until 2030. For the purpose of this impact
assessment it is assumed that these costs are equally split between development
and production, and operational costs (6.8 million euro each). From an
international competitiveness perspective the new limits could be beneficial
for European manufacturers. When engines and machines sold in the EU market
have to meet US equivalent standards, more polluting machines designed for unregulated
markets would face higher entry barriers. This could increase the sales of EU
manufacturers in their home market.
The Arcadis background study found that the
number of SMEs manufacturing diesel engines and machinery with less than 19 kW is
limited and that the SMEs active in this market segment would not to be disproportionally
affected by the new emission limits. However, there are many SMEs among the end
users which could be affected by an increase in the price of certain types of machinery.

1.2.1.2.     Environmental & health impacts
Small diesel engines below 19kW are currently
not subject to NOx and PM emission limits. However, the annual sales for this
category are around 17% of total NRMM sales and the total emissions for this
category are 12 kilo tonne (kt) NOx and 1.7 kt PM. Alignment with US EPA limits
would significantly decrease the emissions of NOx and PM and therefore improve
the air quality in Europe. 
The monetised environmental gains that would
result from this option are estimated at € 388 million from reduced PM
emissions and € 276 million from reduced NOX emissions, leading to
total benefits of € 664 million. Since the compliance costs are only estimated
at 13.6 million euro, the environmental gains clearly outweigh the costs of
including the whole category below 19 kW in the scope of the NRMM emission legislation.
1.2.2.          
EPA alignment of CI engines 19-37kW 
   || Option 2 – US alignment CI 19-37 kW 
 Compliance costs ||   ||   
 Development and production costs || € 153.8 m € 421.6 m € 575.5 m 
 Operational costs 
 Total costs 
 Benefits ||   ||   
 Reduction of PM emissions || - 94% 
 Reduction of NOx emissions || - 37% 
 Monetised impact for PM || € 707 m 
 Monetised impact for NOx || € 440 m 
 Total benefits || € 1147 m 
 Benefit-cost calculations ||   ||   
 Net impact on society || 572 € 
 Benefit/cost ratio || 2.0 
 Source: NOx and PM emissions of machinery on the market per equipment category as per JRC Report - Part II (2008) Reference period: 2015-2040   
1.2.2.1.     Socio-economic impacts
While for the NRMM engine categories between
37-560kW stage IIIB and even stage IV limits were set, the engines between
19-37kW stayed with the IIIA limits that were introduced in 2007. In contrast
to this, new, more stringent emission limits for this category come into force
from 2013 onwards in the US. This situation is evidence that it is technically
feasible to offer similar performing engines in the EU market. Most companies
active in this market segment produce for the European, American and Japanese
markets anyway and would be largely unaffected in terms of R&D effort if
the EU aligned its limits to the US.
              As concerns production
costs, it is expected that the mechanical injection equipment currently used on
stage IIIA engines will be gradually replaced by electronically controlled
injection systems. This kind of equipment has become widely available at
relatively low cost in recent years and enables improved emission performance. The
overall compliance costs of this option are estimated at € 575.5 million. At € 421.6
million, operational costs account for the biggest part of these costs. This is
due to additional fuel, service and maintenance expenditure which is expected
to result from fitting aftertreatment systems 
There are no SMEs among the engine
manufacturers in this segment. Although many machinery manufacturers are SMEs, no
problems are expected given the limited impact on engine prices and presumably
very limited installation challenges. 
1.2.2.2.     Environmental & health impacts
The new limits would lower the NOx and PM
emission and improve the air quality. Estimation showed that this would result
in a 37% decrease in total emissions of NOx and a 94% decrease of the PM
emissions from this engine category. In monetary terms, this corresponds to
benefits of € 856 million.
1.2.3.          
EPA alignment of CI engines >560kW
   || Option 2 – US alignment CI > 560 kW 
   || Base case || Lower estimate 
 Compliance costs ||   ||   
 Development and production costs || € 150 m || € 150 m 
 Operational costs || € 231 m || € 112 m 
 Total costs || € 381 m || € 262 m 
 Benefits ||   ||   
 Reduction of PM emissions || - 94% 
 Reduction of NOx emissions || - 65% 
 Monetised impact for PM || € 1,076 m 
 Monetised impact for NOx || € 1,588 m 
 Total benefits || € 4,664 m 
 Benefit-cost calculations ||   ||   
 Net impact on society || € 4,283 m || € 4,402 m 
 Benefit/cost ratio || 12.2 || 17.8 
 Source: ARCADIS Impact Assessment Study (2009), chapter 3.4 pp. 84, Reference period 2005-2030 
1.2.3.1.     Socio-economic impacts
NRMM engines above 560kW are almost exclusively
used in heavy construction equipment (~440 EU sales annually) and heavy mining
equipment (~220 EU sales annually). The number of engines of this category produced
in the EU is, however, larger. According to industry estimates only 15-20% of
the engines produced stay in the EU while the rest is exported. 
When exporting to the US, EU manufacturers already have to meet EPA emission limits, but in most other export
markets no emission limits for this category exist as yet. Manufacturers
exporting to the US, therefore, already have the technology and capability to
produce engines and machinery complying with these limits. Due to the strong
international presence of the main manufacturers and the overall importance of
the US market, it can be assumed that the bulk of the necessary investment in
R&D has already been made. 
Meeting the new limits may require aftertreatment
systems like a Selective Catalytic Reduction (SCR) system or a Diesel
Particulate Filter (DPF). The SCR reduces the NOx, while the DPF prevents PM
emissions. This leads to a cost increase for each engine where these systems
need to be fitted. Furthermore, these systems may also entail additional
operational costs for the end user. The SCR system requires a supply of urea to
work which needs to be regularly refilled and more complex after treatment
systems may also require more maintenance and can reduce fuel efficiency. Overall,
the costs of aligning with the US are estimated between € 262 and 381 million,
depending on the assumptions made on after treatment system costs.
From an international perspective, the new
limits could put the incumbents in the EU market at an advantage. Market entry
by firms who design their products for sale in unregulated markets could potentially
become harder, since they would require significant and potentially costly
upgrades. Furthermore, alignment with the US standards will reduce barriers to
trade for EU firms that do not export their products to the US market at present due to the difference in emission requirements. 
According to the Arcadis study, no SMEs are
expected to be among the engine or machinery manufactures in this category. However,
some of the end users will be SMEs. They will likely be affected by the new requirements
which can be expected to result in higher machinery prices. According to
industry, this price increase can be expected to be relatively small in
relation to the total machinery price however. Overall, there is no indication
that this price increase would disproportionally affect SMEs.
1.2.3.2.     Environmental & health impacts
The environmental impact is mainly due to the
reduction of NOx and PM emissions and the resulting improvement of the air
quality in the European Union. PM emission from large diesel engines could be
reduced by 94% and NOx emission by 65%. This corresponds to monetised benefits of
€ 4,664 million. One indirect effect of the potential price increase of
machines in this power category, that is not included in the analysis, is the
possible postponement of the purchase of new machines. Older and more polluting
versions could be kept in use longer which could delay the projected emissions
reduction. The potential magnitude of this effect is, however, very difficult to
estimate and not included in the calculation of the environmental and health
benefits as a result.
1.2.4.          
US alignment of CI constant
speed engines
   || Option 2 – US alignment CI CS 
 Compliance costs ||   ||   
 Development and production costs || € 1,417 m (not considered in the study) € 1,417 m 
 Operational costs 
 Total costs 
 Benefits ||   ||   
 Reduction of PM emissions || - 41% 
 Reduction of NOx emissions || - 37% 
 Monetised impact for PM || € 1,065 m 
 Monetised impact for NOx || € 2,085 m 
 Total benefits || € 3,150 m 
 Benefit-cost calculations ||   ||   
 Net impact on society || € 1,733 m 
 Benefit/cost ratio || 2.2 
 Source: RPA & ARCADIS Study in view of the revision of Directive 97/68, Final report - Module 2 (2010), pp.54 Reference period: 2015-2040 
1.2.4.1.     Socio-economic impacts
Constant speed (CS) engines are mainly used in
generators sets. These devices are exclusively powered by this type of engines
and generate electricity from diesel fuel. The power spectrum of generator sets
reaches from small (<19kW) to very large (>560kW). The use of CS engines
in other machine categories is limited to small construction and agricultural
machinery, such as cement mixers. Constant speed engines account for roughly
15% of the land-based engine inventory and contribute significantly to air
pollution.
The NRMM Directive already sets emission limits
for constant speed engines (Stage IIIA). These are, however, less stringent
than the limits for equivalent variable speed engines. There is no obvious technical
reason for this difference because, in principle, it is easier to reach a low
and stable emission performance on a constant speed engine than on an engine
running at variable speeds. 
The background study found that, in the lower
power bands, manufacturers are likely to achieve, or already have achieved the US limits due to their presence in the US market. The potential scale of the costs to be incurred
across all power bands as a result of the US alignment is estimated at € 1,417
million. 
It proofed difficult to find information on the
number of SMEs in this market segment, but after consultation with industry it
can be assumed that a significant number of OEMs are SMEs. It is likely that
the costs of more stringent emission requirements are more strongly felt by SMEs
as their development costs can be spread over fewer machines.
1.2.4.2.     Environmental & health impacts
A reduction of PM and NOx emissions by 41% and
37% respectively is expected from US alignment. The corresponding environmental
gains are estimated at € 3,150 million euro until 2040. 
1.2.5.          
EPA alignment of SI engines <19kW
   || Option 2 – US alignment SI engines <19kW 
 Compliance costs ||   ||   
 Development and production costs || (no cost data available) (no cost data available) € -- m 
 Operational costs 
 Total costs 
 Benefits ||   ||   
 Reduction of HC emissions || - 44% 
 Reduction of NOx emissions || - 44% 
 Monetised impact for HC || € 63.66 m 
 Monetised impact for NOx || € 31.12 m 
 Total benefits || € 94.79 m 
 Benefit-cost calculations ||   ||   
 Net impact on society || € -- m 
 Benefit/cost ratio || -- 
 Sources: JRC report, p 83; data for EU15 in 2005 / ARCADIS Impact Assessment Study (2009), chapter 3.4 pp.84 Reference period: 2020-2040 
1.2.5.1.     Socio-economic impacts
Spark ignited (i.e. petrol) engines below 19kW
are predominantly installed in handheld equipment such as chainsaws and hedge
trimmers, and wheeled applications such as lawn mowers. The emissions of these
engines are already regulated in the NRMM Directive, but the level of
stringency of the EU legislation is lower than in important third country markets
(e.g. US and Japan). It is important to note that the weight and size limitation
of handheld equipment sets limits to installing aftertreatment systems to clean
the exhaust gas. 
As is the case for all SI engines, no reliable
cost data could be obtained for this engine category, but it is clear that
market forces and third-country legislation (US, Japan) have already led to a
shift towards lower emission engines. It can thus be assumed that am alignment
with US EPA limits could be achieved at low cost, as the necessary R&D
activities have already been carried out. Production costs could increase to a
certain extent as engines may need to be fitted with an oxidation catalyst to
meet US EPA standards. This would mostly affect products at the low end of the
market which are predominantly imported from Southeast Asia. There is no
information pointing towards an increase in the operational costs incurred by
the users. Should this option result in additional costs to engine and equipment
manufacturers, these costs are likely to be outweighed by the benefits that
internationally harmonised limits would create for EU manufacturers.
1.2.5.2.     Environmental & health impacts
The total monetised environmental gain resulting
from a decrease in NOx and HC emissions under this option is expected at €
94.79 million euro. It should be noted that PM emissions do not play a
significant role in spark ignited engines in this power band. Instead, focus is
on hydrocarbon emissions (HC) which can reach high levels in this type of
engine.
1.2.6.          
EPA alignment of SI engines >19kW
   || Option 2 – US alignment SI engines >19kW 
 Compliance costs ||   ||   
 Development and production costs || (no cost data available) (no cost data available) € -- m 
 Operational costs 
 Total costs 
 Benefits ||   ||   
 Reduction of HC emissions || - 70% 
 Reduction of NOx emissions || - 70% 
 Monetised impact for HC || € 283.27 m 
 Monetised impact for NOx || € 138.48 m 
 Total benefits || € 421.75 m 
 Benefit-cost calculations ||   ||   
 Net impact on society || € -- m 
 Benefit/cost ratio ||   
 Source: JRC report, p 83; data for EU15 in 2005 as per ARCADIS Impact Assessment Study (2009), chapter 3.4 pp.84 Reference period: 2020-2040 
1.2.6.1.     Socio-economic impacts
Spark ignited engines (i.e. petrol and LPG engines)
above 19kW are currently not regulated by NRMM emission legislation. However,
such engines are used in a number of industrial applications such as forklifts.
The socio-economic impacts of introducing emission requirements would be
relatively limited as this power category is dominated by CI (diesel) engines
and SI engines are mostly imported from abroad. Leaving them unregulated,
however, risks creating an incentive for users to move from regulated CI to unregulated
SI engines and also for manufacturers to move across the 19 kW border to evade
the emission requirements on smaller SI engines.
As most producers of these engines are located
outside the EU, an increase in compliance costs would have limited effect on EU
based engine manufacturers. However, some European car manufacturers also sell
variants of their engines for use in applications such as forklifts. They and
their customers, including the end-users, could be affected by higher production
costs for machines meeting US EPA limits. 
1.2.6.2.     Environmental & health impacts
If calculated on the basis of the current stock
of SI engines above 19kW on the EU market, the environmental impact of this
option would be limited. There are only an estimated 80,000 engines of this
category in operation the EU and more stringent limits would therefore decrease
the HC and NOx emissions from these machines by a relatively small total amount.
The sizeable environmental benefits (€ 421.75 million) that are expected to
result from this option are mostly a consequence of the avoided increase in HC
and NOx emissions that could result from a shift in demand. Such a shift is
expected if new emission limits for CI engines between 19-37kW are introduced
while SI engines in that same power band stay unregulated.
1.2.7.          
EPA alignment of SI engines for ATVs and SbS 
   || Option 2 – US alignment of SI engines for ATVs & SbS 
 Compliance costs ||   ||   
 Development and production costs || (no cost data available) (no cost data available) € -- m 
 Operational costs 
 Total costs 
 Benefits ||   ||   
 Reduction of HC emissions || - 50% 
 Reduction of NOx emissions || - 2% 
 Monetised impact for HC || € 6.86 m 
 Monetised impact for NOx || € 1.59 m 
 Total benefits || € 8.45 m 
 Benefit-cost calculations ||   ||   
 Net impact on society || € -- m 
 Benefit/cost ratio ||   
 Source: Reference period: 2020-2040 
1.2.7.1.     Socio-economic impacts
All-Terrain Vehicles (ATVs) and Side-by-Side
(SbS) vehicles are primarily designed for off-road use for recreational and
utility purposes, including for agriculture and forestry. They are almost
exclusively powered by petrol engines. If used on public roads, these vehicles
are either subject to L-Category (i.e. motorcycle) or T-Category (i.e. agricultural
tractor) rules. While the EU legislation on L-Category vehicles sets emission limits
for ATVs and SbS, the T-Category legislation refers to the NRMM Directive where
these vehicles are currently exempt from emission requirements. ATVs and SbS
also fall into the scope of NRMM legislation if these vehicles are not approved
for use on public roads. This means that ATV and SbS engine emissions are
factually unregulated in the EU unless these vehicles are type-approved as
L-Category vehicles. 
Due to the central importance of the US market for global ATV and SbS sales and the fact that emission limits took effect there in 2006, it
can be assumed that no additional research and development would be necessary
if the EU aligned its legislation to the US. Overall, there is also no
indication that US alignment would lead to significantly higher production or
operational costs.
1.2.7.2.     Environmental & health impacts
Due to the relatively small population of these
vehicles in the EU and assuming that a large share of the ATV and SbS engines
on the EU market are technically identical to the ones sold on the US market,
where US EPA limits already have to be met since the model year 2006, the
environmental effect of US alignment are relatively limited (€ 8.45 million).
However, when assuming that the EU market could increasingly be accessed by low
cost products that do not comply with US EPA standards in the future, the
environmental effects of leaving this engine category unregulated would become
more severe. 
1.2.8.          
EPA alignment of SI engines for snowmobiles
   || Option 2 – US alignment of SI engines for snowmobiles 
   || Least favourable || Most favourable 
 Compliance costs ||   ||   
 Development and production costs || € 0.8 m 
 Operational costs ||   
 Total costs || € 0.8 m 
 Benefits ||   ||   
 Reduction of PM emissions || - 14% || - 40% 
 Reduction of NOx emissions ||   85% ||   42% 
 Reduction of HC emissions || - 14% || - 40% 
 Monetised impact for PM || € 8 m || € 22 m 
 Monetised impact for NOx || € - 8 m || € - 17 m 
 Monetised impact for HC || € 16 m || € 44 m 
 Total benefits || € 16 m || € 49 m 
 Benefit-cost calculations ||   ||   
 Net impact on society || € 15.2 m || € 48.2 m 
 Benefit/cost ratio || 20 || 61.3 
 Source: ARCADIS Impact Assessment Study (2009), chapter 3.2 p.53ff, Reference period 2005-2040 
1.2.8.1.     Socio-economic impacts
Almost all snowmobiles
in the EU/EEA are sold and operated in Sweden, Finland and Norway. They are mainly used for leisure purposes and in the winter season. In contrast to the US – the world's biggest market for snowmobiles –
current EU legislation does not set emission limits for snowmobile engines.
However, the snowmobiles sold on the European market are technically very
similar, if not identical, to the ones sold in the US, where US-EPA emission
limits must be met. 
Still there are two reasons to include
snowmobile engines in the scope of NRMM legislation and to align the relevant
emission limits to the US. Firstly, the current regulatory gap between the EU
and the US poses a certain risk that more polluting and cheaper machines with
basic 2-stroke engine designs could increasingly be put on the European market
in the future if no limits are set. Secondly, Member States in Northern Europe may feel the need to introduce their own legislation in absence of EU
action. This could harm the internal market.
Since most snowmobiles already meet the currently
applicable US limits, alignment is likely to involve little to no R&D
effort and limited additional production costs. The overall costs are,
therefore, estimated below € 1 million.
The snowmobile market is strongly dominated by
North American and Japanese companies and there is no indication that European
SMEs would be negatively affected by introducing emission limits that are
aligned to the US. 
1.2.8.2.     Environmental & health impacts
The number of snowmobiles operated in the EU is
relatively low (roughly 315,000) and their contribution to atmospheric
pollution is limited. Due to their geographical concentration in Northern
Europe, seasonal use and the absence of emission limits, air pollution from
snowmobile engines is nonetheless of concern for some Member States. The
Swedish Ministry of the Environment, for example, explicitly called for
including snowmobile engines in the scope of NRMM emission legislation in its
contribution to the public consultation. 
Most snowmobiles are still powered by
relatively basic 2-stroke engines which tend to have elevated hydrocarbon (HC)
and carbon monoxide (CO) emissions. However, in the last decade several
manufacturers have been successful in designing less polluting 2-stroke engines
in response to US regulation. 
The total environmental benefit of this option
is estimated at € 15.2 – 48.2 million. The projected increase in NOx emissions is
due to the fact that a shift from 2-stroke to 4-stroke technology could
potentially increase NOx emissions, depending on whether a carburettor or
direct injection is used. However, NOx emissions are not the focus of the
environmental concerns surrounding snowmobile emissions. US legislation, for example, does not set NOx emission limits because snowmobiles are
operated in winter when tropospheric ozone formation is not considered a
problem. 
1.2.9.          
US alignment of IWV
engines
 Source: PANTEIA, Reference period: 2012-2050 
1.2.9.1.     Socio-economic impacts
The European IWT sector is concentrated in the Netherlands, France,  Belgium and Germany. 95% of the total fleet is registered in one of these
countries with the Dutch fleet making up for the biggest share. As a result,
the socio-economic impacts will be focussed on these countries.
Since 2007, the engines used in inland waterway
vessels are subject to Stage IIIA emission requirements in the EU. This option
would go one step further and align the EU requirements to the more stringent
emission limits applicable in the US, as described in Annex I. From a
socio-economic standpoint, US alignment would have its merits as the European
market, with sales of around 200 engines a year, is relatively small and most
engine manufacturers are active in both the EU and the US. Going beyond US EPA limits could result in engine manufacturers leaving the EU market
as the expected market size could be too small to justify the necessary R&D
investment to comply with EU limits that exceed US EPA limits.
The marginal investment costs for the IWV
transport sector for aligning the EU to the US limits are expected to be
moderate (€ 211 million) because compliant engines are already available. The
costs of ownership amount to € 296 million. These figures include the
investment costs and the operational costs for the entire sector over a period
of 20 years and assume the use of diesel engines with SCR after-treatment.
Moreover, it is assumed that diesel engines used for complying with standards
under Option 2 have a slightly better fuel consumption performance than the
ones under the BAU scenario, with a relative saving of 2% on fuel consumption. 
SMEs play an important role in the IWT sector.
While most engines are produced by large companies, the shipbuilders, dealers
and end users are often SMEs. Among the end users single vessel enterprises,
where the captain is also the owner, are commonplace. Therefore, it is
important to take into account the ability of end user to invest in new engines
and vessels and, in particular, their access to financing.
However, it is also important to consider that some
Member States may feel forced to take restrictive measures if the emission
requirements at the EU level are not tightened. The access regime of the port of Rotterdam, for example, will only allow Stage IIIA engines to operate in the port
as of 2025. To prevent restrictions that would negatively affect the internal
market by going beyond EU emission limits, the introduction of a new emission
stage for IWV appears necessary. This could either happen by aligning to the US
EPA limits, or by introducing more ambitious limits which will be discussed under
Option 3.
1.2.9.2.     Environmental & health impacts
At present, the atmospheric pollution from
inland shipping is significant with 17 % of the overall non-road emissions. The
main impact of the new more stringent limits is better air quality as a result
of the less polluting engines on the market and the environmental effects will
be most directly felt in the vicinity of the main inland waterways and, in
particular, along the Rhine. Improving the environmental performance of this
transport mode is a priority for EU transport policy. This ambition is formulated
in the NAIADES II package, adopted on 10 September 2013. 
With a view to allowing the direct comparison
of this Option with the more ambitious ones presented under 6.3.4 (Options 3A
and 3B), slightly differing assumptions were made on the underlying shadow
prices for the PM and NOx damage costs, respectively: these were lined up with
the values consistently used throughout the study of Options 3A and 3B, i.e.
104 291 €/t for PM and 11 252 €/t for NOx. Moreover, calculations were carried
out on the basis of the medium damage cost scenario only given that emissions
form IWV transport are expected to happen predominantly in countries and areas
with fairly high population densities, as pointed out above. 
The EPA alignment option for IWVs would bring
down PM emissions by 70% and NOx emissions by 62%. The corresponding
environmental gains are estimated at € 13,451 million in the period up to 2040.
However, the average lifetime of an engine is 10 to 12 years, and with an
overhaul it can be extended to 25 years and more. Therefore, it takes a long
time before all vessels are equipped with new engines and the benefits of more
stringent emission limits for IWV would only become apparent with considerable
time lag after their entry into force. 
1.3.                
Option 3: Step towards road sector
ambition levels
This option takes the most recent limit values
applicable to the road sector (i.e. Euro VI for heavy duty vehicles) as the
point of reference for determining the level of ambition for the non-road
sector. Technical solutions for complying with these limits have been developed
and are now on the market for heavy duty vehicles. However, they would need to
be adapted to the different equipment types in the non-road sector and this can
be expected to lead to additional development and production costs for engine
and equipment manufacturers. For certain types of equipment the use of
technology from the heavy duty motor vehicles may not be economically or
technically feasible. The level of ambition pursued for different engine types
would take this and also past reduction efforts into account.
When proceeding by analogy on the basis of EURO
VI standards for the definition of limit values for NRMM, however, account must
be taken of some fundamental and structural differences that exist between
those two sectors:
-  
Test cycles for type approval: These are different, both for the steady state and transient test
cycles as they are supposed to reflect in a most realistic manner representative
load cycles for HD vehicles and NRMM, respectively 
-  
Power range:
Engines used for HD vehicles are typically in the range between 100 kW to 400
kW, whereas engines for NRMM can typically also be found in smaller power bands
(0-100 KW) and significantly higher power bands (up to 3000kW)
Considering the above and in absence of further
scientific and empiric evidence, limit values for NRMM can certainly not be
defined by literally using identical numerical values as in Euro VI for the
very wide band of power categories in NRMM . 
The approach chosen under the current option is
therefore guided by the following principles:
-  
Including the same pollutant types;
-  
Targeting at limit values that are comparable
yet taking account of NRMM specificities;
-  
Focussing on those power ranges that make the
most relevant contribution to overall emissions from NRMM whilst at the same
time providing sufficient evidence for proceeding by analogy with standards for
EURO VI engines and PN limits in the Swiss legislation.
1.3.1.          
Introducing standards for particulate numbers
(PN)
The introduction of PN limits in the EU
legislation on NRMM will have a number of costs and benefits. In order to
quantify these, the EC JRC Sustainable Transport Unit was asked gather, to the
best extent possible on the basis of information available up-to-date, data
that are needed to carry out a cost-benefit analysis (CBA). Table 6.1 presents
the data sources used for that purpose. 
Table 6.1: Data Sources for the Cost Benefit
Analysis of a introducing a PN limit
 Parameter || Source || Comments 
   Engine Sales ||   Euromot (2005) || No up-to-date engines sales were available. Therefore the Euromot (2005) sales data were used. It was assumed that sales remain constant over time. 
   PM Emission ||   JRC (2008)       ||   The spread sheets used to provide an inventory of emission for the NRMM sector were adapted to estimate PM emissions for each engine category and expected life of engine and hours used.     
   PM Damage Costs       ||   CE Delft – Handbook on estimation of external costs in the transport sector ||   Low and medium EU wide damage cost figures per tonne of PM2.5 emitted were adjusted for inflation (2015 costs) and used to assess the benefits of reductions in PM emissions. 
   DPF technology costs       ||   USEPA (2003) ||   The USEPA costs estimated for the installation of DPF were used. These were adjusted for inflation and converted to Euros. 
As of today, the available and limited
information on cost to society effects resulting from particle sizes is
inadequate to establish a coherent direct damage cost value that is linked to
the number count of particles (PN). As a recent EPA literature review suggests[16], the determination of
causality for adverse health impacts is as of today still best linked to the
mass of particles with a size <2.5 micro-m (PM2.5) for short-term
and long-term exposures.
Against this background, the quantitative
analysis steps put forward here below for assessing the socio-economic and
environmental and health impacts, respectively, in the context of introducing a
PN limit,  are essentially based on considerations and correlations with PM.
1.3.2.          
Determining a limit value for particle numbers
in the NRMM legislation
In order to determine a limit value for
particle number in the NRMM legislation, a literature review of experimental
data for particle numbers measured on engines used in the NRMM sector has been
performed. 
In this context, it is worthwhile mentioning
that as of today available empiric information and data relating to the size
rather than the mass of particles in engine exhaust gases is limited – data
sources for engines that are used in the NRMM sector are even scarcer. 
Therefore, the main data source turned out to
be the set of measurement data from engines that were certified by the Swiss
Federal Office for Environment (FOEN/BAFU)[17] in the context of their type approval procedure (see Annex III,
Table III.1). Indeed, the Swiss legislation is – as of today – the only
legislation that sets a PN limit, namely for construction machinery engines in
the power range from 18 to 560kW.  
The Swiss measurement data are available for
both legislative emission cycles, i.e. the Non-Road Steady State Cycle (NRSC)
and the Non-Road Transient Cycle (NRTC).  A thorough
statistical analysis of these data performed by JRC yielded the following
results:
For the NRSC cycle, it seems reasonable
to propose a PN limit of 1.0·1012 #/kWh for the three
categories of engines (100% of the tested engines within the limit). This will
be in line with the Swiss federal legislation.
For the NRTC cycle, it seems reasonable
to propose a PN limit using the NRTC cycle a value of 8.0·1011 #/kWh
for the three categories of engine (97% of the tested engines within the
limit).
Further data sources have been studied, e.g.
from the Swedish Transport Administration[18] or from AECC[19]. These could, however,
only be used to a limited extent for the purpose of determining a PN limit
value for a wider spectrum of power ranges of NRMM engines.
1.3.3.          
CI engines in general NRMM applications (other
than IWV and rail): Introducing PN limits
The table below shows the monetised impacts of
introducing PN limits for the following engine categories: 19 – 37 kW, 37 – 56
kW and 56 - 560 kW. 
The choice of this categorisation was motivated
by the fact that different standards apply for these three categories under the
current legislation, namely Stage IIIA (19-37 kW), Stage IIIB (37-56 kW) and
Stage IV (56-560 kW). Given that the (incremental) costs for the introduction
of PN standards are directly dependent of 
current ambition levels, cost-benefit effects
for these three categories, respectively, needed to be analysed separately. 
1.3.3.1.     Socio-economic impacts
Referring to today’s state of the art of
available technologies, it is assumed that the introduction of a PN limit of 1.0·1012 #/kWh (see chapter
…) will require the installation of a Diesel Particle
Filter (DPF) for all new engines. 
The economic cost impact of introducing PN
limits in NRMM legislation is therefore calculated on the basis of costs for
implementing the DPF technology for all NRMM power categories concerned. 
In a first step, the unitary incremental costs
for installing and using a DPF in a NRMM were determined. These are, in most
general terms, composed of three cost elements:  
(a)    Costs for the engine manufacturer (material, component, labour)
(b)   Costs for the machinery manufacturer 
(c)    Costs for the end-user (incremental operational costs)
(a) Costs for the engine manufacturer
For the estimation of costs associated with the
installation of the DPF technology at the level of the engine manufacturer,
indicative cost estimates provided by the United States Environmental
Protection Agency (US-EPA) were used. Figures used in this study were adjusted
to 2012 values, converted to Euros and grouped according to NRMM engine categories
(see Annex III, Table III.2).
Further assumptions made:
-
The marginal cost for the manufacturer for
achieving the additional marginal emission reductions resulting from the PN
legislation is assumed to amount, as an average:
o
 100% of the 2012 DPF unit costs in the power
category 19-37 kW (as DPFs currently not used)
o
 20% of the 2012 DPF unit costs for the power
categories 37-560 kW (assuming that DPFs are currently already predominantly
used)
-
The cost of the DPF decreases by 20% every four
years 
(b) Costs for the machinery manufacturer
For the calculation of costs that incur to
machinery manufacturers, it was assumed that these relate mostly to engineering
work for redesign and adaptation so as to fit the new engines and
after-treatment devices to the machinery. These costs were therefore considered
to represent one-off investment costs which, in the calculations, were evenly
spread over the first 4 years following the entry into force of the new
emission standards (regarded as common practice in industry).
Cost assumptions were made for the three power
categories as outlined above, taking notably account of the incremental
technological gap to be overcome with regard to technologies that are used as
of today to comply with existing legislation. 
Against this background, most significant costs
incur for the engine power category 19-37 kW as engines in this category are
assumed not to dispose of DPF after-treatment technologies for complying with
today’s applicable Stage IIIA emission standards and hence require significant
adaptation and redesign. Engines in the power ranges 37-56 kW (predominantly
expected to already dispose of DPF after-treatment technology) and 56-560 kW (predominantly
expected to already dispose of DPF and SCR after-treatment technology to comply
with current Stage IV standards) would only require limited extra efforts for
constant speed engines and, in some cases, adaptation to more stringent PM
limits.  
The cost assumptions were, moreover,
cross-checked with data provided to the Commission most recently by a number
representative industrial stakeholder associations[20], following a survey
which was conducted amongst their member companies, respectively, on the basis
of questionnaires. 
(c) Costs for the end-user (incremental operational
costs)
Additional costs for end-users were assumed to
originate, where applicable, mostly from additional diesel costs resulting from
the use of DPF after-treatment technology. 
Again, this does mostly affect the engine power
category 19-37 kW which is assumed not to dispose of DPF after-treatment
technologies for complying with today’s applicable Stage IIIA emission
standards: these engines are expected to have a 3% higher fuel consumption. 
In a second step, the sales volumes of NRMM
engines for the period 2020 to 2050 needed to be determined. The latest
sufficiently reliable data base was established back in 2005 when the European
engine manufacturer’s association, Euromot, provided sales figures for the EU15
in the context of a major data collection exercise[21]. Ever since, sales
data were not updated so that an assumption needed to be made as regards the
likely future trends of sales figures.
After consultation with a number of
stakeholders and considering the difficulty to provide reliable market forecasts
for a product spectrum that is very wide, it was eventually proposed to carry
out calculations under the assumption of constant sales volumes over the period
2015-2050 for the EU-28, with figures corresponding to the ones of the year
2005. This resulted in assumptions on market data and the market structure as
laid down in Annex III, for NRMM with SI engines (Tables III.3a and III.3b) and
land-based NRMM with CI engines (Tables III.4a and III.4b) respectively. 
A recent study by Integer (see Annex III,
Figure III.5) tends to confirm that sales figures for NRMM declined sharply as
a result of the economic crisis in 2008, with pre-crisis levels (i.e. before
2009) expected to be reached again not before the end of this decade.
The calculations confirm a substantial
potential for PM emission reductions: for the entire power range (19-560 kW),
these would for instance reach an amount of -2 930 t/y in the year 2040
compared to emission under the BAU scenario. A look into the breakdown for the three
power categories shows, in relative terms, the biggest saving potential in the 19-37
kW power range which is due to the fact that this category needs to comply with
Stage IIIA standards only. The contributions of the other categories in which
higher standards apply are, as expected, relatively lower. 
1.3.3.2.     Environmental & health impacts
With a view to assessing the environmental and
health benefits of a PN limit in NRMM legislation, an approach by analogy has
been chosen which compares the effect of PM2.5 emissions avoided
resulting from a PN limit with the base case where PM2.5 emissions
remain unaltered (corresponding to the case where no new PN limits
are introduced). For determining the resulting effect of a PN limit on PM2.5
emissions in the absence of a scientifically substantiated correlation,
the assumption was made that the introduction of a PN limit of 1 x 10-12
will bring down the level of PM2.5 emissions to an actual level of
0.01 g/kWh. This is supported by a recent publication[22] and corresponds to
assumptions already made in the field of legislation for HD vehicles (Euro VI).

Figure 6.1 presents the resulting effect of
this estimation in terms of total PM2.5 emissions for the
entire NRMM engine stock, with and without a PN limit respectively. For these
calculations, the introduction of a PN limit was assumed to come into effect in
2020. 
Figure 6.1: Total
estimated PM2.5 emissions (in tonnes) with and without the PN limit
(2015-2050)
In order to assess the impact of the above PM2.5
emission reductions, an economic value for the damage cost avoided was
determined on the basis of the CE Delft study[23].
The study shows a significant spread in the damage cost values, depending on
whether emissions occur in urban metropolitan, urban or outside built-up areas.

As it proved difficult to determine the exact
location of the emissions considered, cost-benefit calculations under Option 3
were systematically carried out on the basis of two damage cost values for PM2.5
emissions according to the following scenario assumptions:
·   
‘Low’:  PM2.5 emission damage costs
of 35 000 €/t
·   
‘Medium’:  PM2.5 emission damage
costs of 130 000 €/t
The low damage cost value corresponds to the very
lowest estimate for an average EU-25 value referred to in this study, whereas
the medium damage cost has been determined as a typical EU-25 average value
which is representative for urban areas,  indexed to 2015 prices respectively. The
study mentions, in addition, significantly higher cost damage values for
urban-metropolitan areas[24]
which were however not been used in the current calculations. 
Against this background and considering,
moreover, the fact that direct damage costs based on an PN approach - once such
information will be actually available – would most probably demonstrate by
tendency higher cost impacts than the chosen PM-based approach, it appears reasonable
to consider as of today the ‘medium’ cost assumption as the basis for the most suitable
reference scenario. 
The calculations show that the introduction of
PN limit values implies by far the highest incremental compliance costs for the
smallest engine category (19-37 kW); this holds both for engine and machinery
manufacturers, but also for end users in form of increased fuel consumption.
Market players in this category might face particular difficulties with regard
to financing. The entire segment might therefore be ultimately exposed to the
risk of a serious loss of competitiveness, the latter aspect being of
particular relevance in the light of the possible shift towards spark-ignited
engines which is a genuine alternative in this specific power range.
Though significantly less pronounced, the 37-56
kW power range too has to cope with a considerable financial burden relative to
its size and overall contribution, as reflected by a merely positive net
benefit value for the medium damage cost assumption.
Overall, the calculations yield a positive net
benefit of € 2 349 million over the period 2020-2050 for the medium PM damage
cost scenario and hence confirm the financial viability of Option 3 from a
global perspective. 
Negative values for the net benefits throughout
the three power categories for the low PM damage cost scenario highlight the
dependency of the overall viability of more stringent PM and PN emission limits
on the underlying assumptions for the actual damage costs: Though there are
good reasons to use the medium cost assumption as most suitable reference
scenario as deemed to represent best an ‘EU-wide average population density
pattern’, these results clearly put in evidence that the effectiveness of a
harmonised EU-wide approach varies across the EU according to the actual
repartition of areas with lower and higher population densities. 
1.3.3.3.     CI engines in general NRMM applications (other than IWV and rail):
Complementary introduction of new limit values for NOx and HC
As an additional step beyond the introduction
of PN limits and more stringent PM limits for CI engines in general NRMM
applications as outlined above, the option of adapting NOx and HC limits to
levels corresponding to the ones of Stage IV (i.e. NOx: 0.4 g/kWh, HC: 0,19
g/kWh) was planned to be studied in further detail for the engine power
categories 19-37 kW and 37-56 kW.  Likewise, for engines >560 kW, the option
of a harmonised NOx limit value at the level of the one for generator-sets
(i.e. 0,67 g/kWh) was considered.
For the 19-37 kW and 37-56 kW engine power
categories, the expectation was that cost synergies could be achieved in
conjunction with the introduction of the stringent PN and PM limits (requiring
DPF after-treatment) that were significant enough to justify, in parallel, the
introduction of lower NOx and HC limit values. 
However, the results obtained in chapter
6.3.3.2 as well as further preliminary analyses including careful examination
of further cost data provided by a number of engine and machinery manufacturers
at the request of the Commission, confirmed the in-appropriateness of such a
step so that these options were not being put forward any longer: As a matter
of fact, for the 19-37 kW and 37-56 kW engine power categories, the
introduction of SCR after-treatment technology in order to meet the stringent
NOx and HC limits would have caused further considerable additional operational
and investment costs which – given the need for over-proportionate efforts for
coping with extreme space limitations inherent to these very power categories –
clearly would have proved to be excessive.
As for the >560 kW engine power category,
the very limited number of engines not used for generator-set, rail or inland
waterway vessel applications is far from justifying the significant extra-costs
that the installation (equipment, R&D, redesign) and operation of SCR
after-treatment technology would generate in this very specific engine
segment.   
 
1.3.4.          
CI engines in IWV applications: Introducing more
stringent emission limits, including PN limits
With a view to examining the possibility of
introducing emission limit standards in the IWV sector which go beyond the ones
of the US-EPA legislation, reference is made to an exhaustive study[25] - hereafter referred
to as the “PANTEIA study” - which was carried out very recently in the context
of the preparatory work for the Commission’s Communication on NAIADES II[26].
One of the options investigated in this study
is being retained for the purpose of this impact assessment, hereafter referred
to as ‘Option 3B’. This option, denoted as the ‘Innovation Option –Efficiency’
option in the study, sets very ambitious emission reduction targets for the IWV
sector and is based on the principle of a staggered effort profile: very
stringent emission standards for vessels with very big engines (i.e. above 981
kW), less stringent yet still demanding standards for vessels with engines in
the mid-size range (304 – 981 kW) and least stringent standards for engines in
the lowest size range (75 – 304 kW).   
Option 3A examined under this scenario is an
alternative option which does also introduce particle number emission limits
for engines of the IWV sector, yet allowing for NOx and HC emission levels which
are aligned with the ones of future US legislation for engines above 600 kW. 
 Source: PANTEIA, Reference period: 2012-2050 
1.3.4.1.     Socio-economic impacts
Option 3A assumes the continued use of diesel
engines in the IWV sector which then would be expected to require SCR and DPF
after-treatment for the bigger engines (above 600kW), DPF after-treatment only
for engines from 130-600 kW. Given that Option 3A is aligned with after 2017-US
standards as regards NOx and HC limits for the bigger engines, additional
investment costs for research and redesign are fairly limited for this engine
category which represents the bulk of engines in the IWV sector. Additional
investment costs will predominantly incur for the DPF treatment system for
engines in the 130-600 kW power range. 
Operating costs will obviously increase due to
urea (SCR) and higher fuel (DPF) consumption, as well as for the maintenance
and replacement of the after-treatment system components.  This results in
significantly higher costs of ownership for the entire sector.  
Relevant stakeholders such as engine and
after-treatment manufacturers confirmed that the technical feasibility of
Option 3A can be expected to be ensured by 2020.
Option 3B relies on the wide deployment of LNG
engine technology in the IWV sector. Emission limits under this option are most
stringent for the big engines >981 kW which were deliberately chosen to be
identical with those of Euro VI for Heavy Duty road vehicles.  These emission
levels are expected to be achieved as of today only by vessels with LNG engines
(mono-fuel or dual diesel/LNG fuel). Despite the fact that these have lower NOx
and PM/PN “engine-out” pollutant emissions at than diesel engines, these need
nevertheless to be further equipped with SCR and/or DPF filters in order to
fulfil the ambitious emission standards under this option. 
In the mid-size engine power range (304–981
kW), emission standards for this option also require the use of advanced
after-treatment technology, either in combination with diesel engines (SCR and
DPF), dual fuel LNG engines (SCR and DPF) or mono-fuel LNG engines (SCR and
possibly a particle filter). 
The technological shift towards LNG engines
leads to very significant overall investment costs for the IWV sector under
Option 3B. According to the study, however, the operational costs for this
option are significantly lower in comparison to Option 3A which mainly results
from the effect of lower LNG fuel costs (assumed to be 20% lower than diesel at
the point of delivery, which corresponds to today’s price levels) over the
lifetime of a vessel. Overall, the total costs of ownership for the IWV sector
therefore come down to a level which is significantly below the one under
Option 3A.  
Technical feasibility
Regarding the aspect of technical feasibility
of Option 3B, it is worthwhile noting that the PANTEIA study states that the
actual life performance of dual-fuel or mono-fuel LNG engines is not known as
of today in inland waterway transport applications given the lack of real life
data (currently, only one LNG-propelled vessel in operation in the EU). The
study concludes that “the technology has not yet sufficiently matured to
provide a solid basis to make final conclusions on the emission performance of
dual-fuel LNG engines applied in inland water transport”. As regards diesel
engines fulfilling the standards of Option 3B, these would still need to be
developed. It is, however, not certain whether the fairly low engine volumes in
the upper power categories would still attract a sufficient number of engine
manufacturers to engage in this work. 
A technical challenge to overcome for
LNG-fuelled vessels is the impact of methane (CH4) slip. Emission limits need
to be properly defined for this technology in order to prevent an increase of
climate change impact as a result of methane emissions which have a greenhouse
gas warming potential far higher than carbon-dioxide (CO2). Finally, given a
number of structural differences between engines and their operation profile in
road and shipping applications, respectively, the assumption of using identical
numerical limit values as in Euro VI Heavy Duty legislation would require
further technical validation. 
Other aspects
As regards social impacts, the introduction of
more stringent emission standards could generally be expected to have a
positive effect on employment due to a increased demand for products and
services from engine manufacturers, equipment suppliers and wharves. Very
ambitious emission limits, however, bear the risk of ship-owners deciding to
leave the profession if faced with the need of significant new investments.
According to the study, the freight would then need to be carried by other
vessels, by truck or by rail. This may therefore affect the structure of the
inland waterway transport sector, yet probably have a limited overall effect on
employment.
Regarding the aspect of administrative burden,
it may increase with the variety of technologies used for ship propulsion. In
particular, technologies that may give rise to safety considerations
(e.g. LNG) may entail separate certification and information requirements,
resulting in additional administrative costs. Developing general standards
could prevent these costs from becoming too high. 
1.3.4.2.     Environmental & health impacts
Engines used in IWT must currently comply with
Stage IIIA emission standards according to Directive 97/68/EC. By comparison
with the road haulage sector, these emission standards are significantly less
stringent. As a consequence, inland waterway transport reached higher air
pollutant emission levels than road transport per tonne kilometre for certain
vessel types. Also, atmospheric pollution from inland shipping remains
significant with 17% of the overall non-road emissions and with high
concentration levels in certain harbours and cities. It should also be noted
that around 9 out of 10 inland waterway vessels in the EU are registered in Belgium, the Netherlands, Germany and France, where the environmental impacts are more intense, due
to a higher concentration of the population along waterways.
Against this background, the two options
presented under this scenario appear of particular importance given that these
tackle the issue of pollution from particles, an aspect of high environmental
relevance in densely populated areas. In addition, it is worthwhile emphasising
that average lifetimes of engines in inland vessels are very long in comparison
with other applications, resulting in a slower reactivity as regards the
effectiveness of new emission standards. It is therefore even more of the
essence for this very sector to take necessary technological decisions in due
time. 
With a view to assessing the environmental and
health benefits of the two sub-options Option 3A and Option 3B, the same
approach was chosen as for CI engines in general NRMM applications (see chapter
…) with regard the effect of a PN limit on PM2.5 emissions. However,
unlike in the calculations for general NRMM applications in the previous
section or for rail applications, the underlying shadow prices for the PM and
NOx damage costs in the PANTEIA study were consistently chosen to amount to 104
291 €/t for PM and 11 252 €/t for NOx, having their origin in different
simulation algorithms of the programme developed in the PANTEIA study. 
Option 3B reduces, in 2040 for instance, NOx
emissions by 84 800 tonnes and PM by 4 200 tonnes as compared to the BAU
scenario, whereas Option 3A reduces NOx by 63 600 tonnes and PM by 4 100
tonnes.
The PANTEIA study expects Option 3B to provide
a significant stimulus to the switch to LNG engines on inland waterway vessels.
This switch would also involve lower direct emissions of CO2. The
increased use of LNG may, however, also result in methane emissions through
slip effects of methane which is a greenhouse gas with significantly higher
warming potential than CO2. Though this impact could be mitigated by the use of
methane catalysts where engine operating temperatures are sufficiently high
(e.g. lean-burn engines), the environmental impact of CH4 slip would need to be
further studied for engines technologies with lower operating temperatures
which pose a technological challenge for the use of catalysts. 
Overall, the emission reductions would lead to
external cost savings, as compared with the BAU scenario, of € 18,709 billion
for Option 3B and € 15,177 billion  for Option 3A. 
These benefits outweigh, for both options, the
additional investment and operational costs in the longer term (until 2050).  
Option 3B is expected to result in lower
external costs for air pollutants per tonne/km than for heavy-duty road
vehicles by 2030 whilst Option 3A would not reach that level. 
1.3.5.          
CI engines in rail applications: Introducing
more stringent emission limits, including PN limits
Railway diesel engines are niche markets,
representing less than 2% of NRMM. Since 2012, rather ambitious Stage IIIB
standards are in place under the current legislation which distinguishes
between diesel engines for rail cars (commonly also referred to as Diesel
Multiple-Units (DMUs)) and diesel engines for locomotives. Whereas engines for
railcar application are most often derivatives of truck or industrial engines
(typical power ~400kW), engines for locomotive application are derivates from
generator sets, military or ship applications (typical power: shunter
locomotives ~750 kW; hauling locomotives ~2000 kW).    
Option 3A and Option 3B examined under this
scenario represent two alternative possibilities for emission legislation of
engines in rail applications. Option 3A is an sub-option which exclusively
focuses on the issue of particle numbers (NOx and HC emission limits remain
unaltered), whereas Option 3B can be considered as an environmentally very
ambitious approach which would, besides PN, also strive for significantly more
stringent limit values for NOx and HC emissions.    
1.3.5.1.     Socio-economic impacts
The overall trend in the EU is a strong
decreasing diesel locomotive fleet which is expected to continue even beyond
2020 continue. This mainly results from the electrification of most railway
infrastructures, a still on-going trend which makes that railway operators
possess more diesel locomotives than actually required. Also, railcars will
continue to replace locomotives for passenger traffic. 
The diesel locomotive market is therefore
mainly a replacement market in Europe. Optimistic estimates assume that the
total market volume until 2020 is about 175 locomotives/year, but likely to be
smaller in reality (UNIFE). Though reliable estimates for the period beyond
2020 are difficult to provide, it can be expected that the market is probably
going to be reduced even further. 
According to data put forward in the European
CleanER-D project[27]
and forecasts by UNIFE[28],
the railcar fleet is expected to slightly increase until 2020 for the reasons
outlined above, with an estimated sales volume in the range from 150 to 450
railcars/year. Beyond 2020, the diesel railcar fleet is expected to remain
constant and hence also becoming essentially a replacement market.
Any additional costs for introducing new
emission stages that require substantial technology changes must therefore be
seen in the context of the aforementioned particular market characteristics,
i.e. very small market volumes as of today and very limited perspectives in the
future. 
Both for railcars and locomotives, new emission
standards according to Options 3A assume the use of DPF after-treatment,
whereas the ones for Options 3B are expected to require SCR and DPF
after-treatment. 
To meet today’s Stage IIIB standards, rail
engines need either SCR or DPF after-treatment. Therefore, costs taken into
account for Options 3A refer mainly to additional redesign costs for locomotive
and/or railcar manufacturers, whereas Options 3B consider, in addition,
development costs for locomotive engine manufacturers (NB: railcar engine
manufacturers are expected to benefit from available technology from Heavy Duty
road engines), redesign costs (locomotive/railcar manufacturers) and additional
operational costs. 
From the point of view of social impacts, the
introduction of more stringent emission standards could result in increased
fares in public passenger transport (up to 2% for the most ambitious
scenarios), hence negatively impact the mobility especially of socially
disadvantaged groups. For freight, costs might also increase whereas a
pass-through of costs is less likely given the high competition with road and
inland waterways.  SMEs are not directly involved in the production of railway
engines and locomotives. Some of the clients of rail freight operators,
however, can be expected to include SMEs who then could possibly switch to
other transport means (road, inland waterways). 
The use of SCRs in railway diesel engines such
as for Options 3B would require, in addition, investments in the infrastructure
such as for instance for the supply of urea. These do generally not exist as of
today and would need to be separately taken into account. 
Finally, in the light of the specificity of the
diesel railway market, it should be mentioned that more stringent emission
standards bear the risk that operators will maintain existing engines longer
than what would be economically justified, leading ultimately to increased fuel
consumption and higher emissions. Recent developments since entry into force of
Stage IIIB standards in 2012 seem to confirm the existence of such adverse
effects: for instance, less than 80 Stage IIIB locomotives are expected to be
put into service in the first three years, whereas sales usually reach levels
of around 175 locomotives per year. 
1.3.5.2.     Environmental & health impacts
From a global perspective, rail emissions from
diesel locomotives and rail cars account as of today for around 10% of NRMM
emissions. With the stringent emission standards according to Stage IIIB, in
force since 2012, the share in NRMM emissions is expected to decrease by a
factor of 4 or more in 2020. In absolute terms, diesel rail emissions could
even decrease by a factor of 10 by 2020[29].
The phasing-out effect of diesel rail emissions is also confirmed by the
analysis carried out in the EC’s Air Policy review (see graphs, page 8).
With a view to assessing the environmental and
health benefits of the two sub-options Option 3A and Option 3B, the same
approach was chosen as for CI engines in general NRMM applications (see chapter
6.3) with regard the effect of a PN limit on PM2.5 emissions.
Option 3B is expected to reduce, by 2040, NOx
emissions by 2 700 tonnes/y (railcars) and 6 000 tonnes/y (locomotives), PM
emissions by 25 tonnes/y (railcars) and 44 tonnes/y (locomotives) as
compared with the BAU scenario. 
Option 3A would only lead to a reduction of the
PM emissions of the above magnitude, i.e. by 25 tonnes/y (railcars) and 44
tonnes/y (locomotives) by 2040 compared with the BAU scenario. 
These figures illustrate, for both scenarios,
the relatively low potential for emission savings in the railways sector. This
is due on one hand to the effect of relatively stringent emission limits for
the sector as of today (Stage IIIB in force since 2012), on the other hand to
the trend of a strongly decreasing diesel fleet as a whole in the future. 
Overall, the emission reductions would lead to
net benefits[30],
as compared with the BAU scenario over the time period 2020-2050, of 
·   
For railcars: € -56 million/€ -40 million
(low & medium PN damage cost estimate, respectively) for Option 3B, and
€ 2,9 billion/€ 19 billion for Option 3A
·   
For locomotives: € -169 billion/€ -142
billion (low & medium PN damage cost estimate, respectively) for Option 3B,
and € -87 billion/€ -60 billion for Option 3A
More stringent emission legislation seems hence
only justifiable for railcars, where the introduction of a PN limit and
adaptation of the PM limit would lead to a positive net benefit. The particular
situation of the diesel railway sector (i.e. very small market volumes and
moderate sales perspectives up to 2020 and beyond) needs however to be
carefully assessed with regard to the required investment needs for the sector,
in order to still attract sufficient manufacturers and avoid monopolistic
market structures.  
As for locomotives, more stringent emission
standards beyond the ones currently in force (Stage IIB) do not appear
justified so that no change of the existing legislation seems most
recommendable.
1.4.                
Option 4 - Extended level of ambition
through enhanced monitoring provisions
This option aims at complementing the above regulatory
options (i.e. Options 2 and 3) by providing additional assurance that the
emission reduction effects expected from new limit values are actually achieved
in practice. Furthermore, enhanced monitoring paves the way towards gaining
quantitative knowledge on aspects which might potentially become subject to
future regulatory measures, such as e.g. real-life emission behaviour or
fuel-consumption performance. This can be expected to mainly result in higher
administrative costs by comparison to Options 2 and 3. Finally, the negative
effects on human health and the environment could be further minimised.
1.4.1.          
Introducing In-Service Conformity (ISC)
provisions
Current legislation on heavy-duty road vehicles
includes provisions regarding the conformity of vehicles and engines with the
emission limits during the useful life of the engine installed in a vehicle
under normal conditions when properly maintained and used. To verify that, the
vehicle manufacturer has to provide to the type approval authority data on the
performance of a representative sample of vehicles or engines of which the
manufacturer holds the type approval. This procedure is commonly referred to as
“In-Service Conformity” (ISC) testing. 
Considering that obtaining test data from the
engine test bench, as required in the current legislation, is quite costly and
time consuming (i.e. it requires the removal of the engine from the vehicle),
the Commission is developing a new procedure, in cooperation with engine and
measuring equipment manufacturers, type approval authorities and accredited
technical services, to introduce in-service conformity provisions based on the
use of portable emission measuring systems (PEMS).
The technical provisions included the
applicable test conditions, the test protocol (i.e. the PEMS instrumentation
performance requirements and the execution of on-vehicle emissions tests) and
the data evaluation method. 
This approach was studied for non-road engines
as well: A pilot programme for non-road engines conformity testing based on
PEMS was successfully carried out. These basically confirmed the possibility to
apply the ISC method for NRMM engines in the power range 56 – 560 kW with minor
modifications. 
Benefits
The main benefit of ISC testing is that engine
manufacturers are kept responsible for ensuring that their engines maintain
their emission performance during the useful life of the engines as well as
over the entire span of possible operation points. The experience in the road
sector showed indeed that ISC provisions lead engine manufacturers to make
necessary adaptations as early as during the very initial design phase of an
engine. 
As a result, ISC testing can be basically
considered as a means to ensure that projected emission trends over time are
actually kept on track. Currently, emission performance testing only occurs in
the context of the type approval process, i.e. at the very beginning of the
lifetime of an engine family. Any deviations of the actual emission performance
of engines during their useful life are therefore not detected yet ultimately
contribute to higher overall emission levels.
Costs
With regard to the most appropriate method to
be used for ISC testing of an engine installed in NRMM, the following
assumptions can be made:
·   
Engines <19kW: laboratory testing (without
PEMS)
·   
Engines 56-560 kW: PEMS testing on full exhaust
gas flow
·   
Engines >560 kW: PEMS testing on exhaust gas
side-flow
The costs for engine manufacturers of conducting
PEMS based tests as a legislative obligation are expected to include mainly the
following elements:
· 
Purchase, maintenance and periodic renewal of
PEMS equipment
· 
Running costs
o
 Labour costs for preparation of PEMS tests
o
 Labour costs for conducting the PEMS tests
o
 Rental of working equipment and replacement
machinery   
The method of using PEMS on exhaust gas
side-flows for NRMM with engines >560kW, being technically more complex,
would still need to validated by means of a pilot testing programme similar to
the one carried out for the 56-560 kW range. As such, it would be more cost
intensive than ordinary PEMS testing. 
On these grounds and on the basis of further
assumptions as referred to in Annex III, Table IV.1, the calculations predict
likely costs for the implementation of ISC testing on NRMM in the order of
magnitude of about € 60 million for the period 2020-2030. These would mainly
incur to engine manufacturers.
These costs must be seen in the perspective of
potential benefits which could be expected by such as measure: Following the
logic of ‘avoided additional emissions’ as outlined above, these costs would be
offset by avoiding a deviation in the order of magnitude of 0,1% or higher of
the total  projected emissions of the NRMM sector during the period 2020-2030. 
1.4.2.          
Introducing labelling for GHG emissions and fuel
consumption
With the 2012 amendment[31] of the NRMM Directive,
an obligation to also measure and report carbon dioxide (CO2)
emissions was introduced into the engine approval process. The CO2
value provides an indication of the efficiency performance of an engine (i.e. its
fuel consumption). This data is recorded in the test report, together with the
measured values of the toxic pollutants (CO, HC, NOx, PM), which is then submitted
to the type approval authority. However, it is currently not foreseen that information
on the CO2 value is made available to machinery manufacturers or end
users. As a result, it does not have an effect on buying decisions.
On the basis of the reporting obligation in the
2012 amendment, the requirement to include this information in the technical specifications
of an engine that engine manufacturers typically provide to customers (e.g. technical
data sheets, sales prospectus) could be established. This measure is not
expected to result in significant costs for engine manufacturers or type
approval authorities, but could have a positive effect on the energy efficiency
of the NRMM engines sold on the EU market. 
1.4.3.          
Set-up of a public EU database on NRMM engine
emissions
As already described in the previous section, CO,
HC, NOx, PM and CO2 emissions are measured during NRMM engine
approval testing and recorded in a test report. At present, this data is only
used by the type approval authorities who certify that a given engine complies
with the applicable emission stage and can, therefore, be sold on the EU
market. However, this information would potentially also be of value to importers,
distributors and integrators of NRMM engines when making buying decisions. This
information could be complemented with emission data from in-service conformity
(ISC) testing, if such a provision is introduced in NRMM legislation. It can be
expected that the buyers of NRMM engines would try to identify engines with a
reliable emission performance that is also confirmed in ISC testing and avoid
engines that do not perform well if they had direct and convenient access to
this information. However, at present, it is difficult to obtain an overview of
the emission performance of the various engines within a certain power band.
This could be facilitated by setting-up a publicly accessible online database. 
The cost associated to setting up an electronic
database for the exchange of type approval information was already assessed in
a feasibility study[32]
commissioned by the UNECE in June 2006 and for cars, a European Type-Approval
Exchange System (ETAES) already exists in the EU. While the feasibility study
was not done on a publicly available database, it can still be assumed that the
cost assessment provides a valid indication of the costs involved. The study
predicted one off start-up costs in the € 50,000 to € 150,000 range and operating
costs of € 5,000 to € 15,000 per month, depending on the length of the contract
with the service provider. A similar monthly range is provided for operating a help
desk service, if required.
The idea of an EU wide database was clearly
supported by a number of stakeholders during the stakeholder consultation as a
means to provide more transparency, both for manufacturers and end-users:
indeed, a EU database is considered to be an important element on the way
forward towards better market surveillance.   
7.           Comparing the options
To compare the different options, first a table
is presented (Table 7-1 below) that gives an overview on how they score on key
criteria including their environmental benefits in terms of the expected
pollutant reduction and their efficiency put as the ratio (environmental
gains/compliance costs). For ease of reference, the quantitative data on costs
and benefits presented in the individual chapters of the impact analysis has
been translated into a simplified scale (++ / + / 0 / - / --) indicating
relative merit. For criteria that cannot be assessed on the basis of
quantitative data, the scoring is based on a reasoned qualitative judgement.
Assuming that all the criteria for comparison
are given similar weight, Table 7-2 indicates that Option 2 (US alignment) is the preferred choice for all SI engines and the smallest and largest CI
engines. Option 3 (closer alignment with road sector ambition level) would
apply to the CI engines in the middle of the power spectrum, where the bulk of CI
engines is located. Option 3 would also be appropriate for railcars. Here the
analysis points to sub-option 3A. Option 1 (no policy change) only leads to a
satisfactory outcome for the engines of diesel locomotives, a segment of the
NRMM engine market that will have all but disappeared by 2050. 
For inland waterway vessels (IWV), the analysis
reveals merits and drawbacks for Option 2 and Options 3A and 3B, which does not
allow an easy straightforward selection. Considering, however, that Option 2
does not address an issue of high relevance for the EU (i.e. adverse health
impact due to particle sizes), only Option 3A and Option 3B are being retained
at this stage as preferred options.
Finally, the analysis indicates that the
enhancement measures of Option 4 should be applied across the board. 
Based on the scores presented in the table
above, the checked boxes in the table below show the preferred combination of
options by engine category that follows from the impact analysis. 
Due to the considerable diversity of engines
and applications in the NRMM sector, it was already expected that the preferred
option would, in fact, be a combination of elements cutting across all four
policy options. This result is also due to the fact that NRMM engine categories
differ widely as to their expected future importance as a source of emissions,
the technical feasibility of further emission reductions and the level or
regulatory stringency that is already applied to them. The preferred
combination would ensure that these circumstances are duly reflected in NRMM
engine emission legislation in the future and, at the same time, would strengthen
the effectiveness and coherence of the regulatory framework.
Table 7-1: Multicriteria analysis of options
Table 7-2: Overview of the preferred
combination of options by engine category
8.           Monitoring and evaluation 
The European Commission has several tools
available to monitor if the objectives of the initiative under consideration are
being achieved effectively. The most important one is market surveillance by
the relevant authorities of the Member States. Non-compliance will also be
spotted as a result of complaints addressed to the Commission. The emission
data generated by the engine type approval procedure is also valuable for
monitoring and evaluation purposes. In particular, if the database described in
section 6.4.3 is set up. 
A technical review of the NRMM legislation was
carried out in 2008, which triggered the development of the current initiative.
Such a review could be repeated a number of years after the entry into force of
the revised NRMM legislation once sufficient evidence for the effects of the
current initiative can be expected. This could be the case 5 years after the
entry into force of new emission requirements.
              List of abbreviations
ATV               All Terrain Vehicle
CECE             Committee for European Construction Equipment
CEMA            European Agricultural Machinery Industry Association
CI                    Compression Ignition (commonly diesel fuelled)
CLIMA          Commission DG Climate Action
CO                  Carbon Monoxide
DPF                Diesel Particulate Filter
EMPL                        Commission DG Employment, Social Affairs
& Inclusion
ENTR             Enterprise and Industry
ENV               Commission DG Environment
EPA                Environmental Protection Agency (United States)
EUROMOT   European Association of Internal Combustion Engine Manufacturers
GEME            Group of Experts for Machinery Emissions
GHG               Greenhouse Gas
HC                  Hydrocarbons
IASG              Impact Assessment Steering Group
IWT                Inland Waterway Transport
IWV                Inland Waterway Vessel
JRC                Commission Joint Research Centre
LNG               Liquefied Natural Gas
LPG                Liquefied Petroleum Gas
MOVE            Commission DG Mobility and Transport
NGO               Non-Governmental Organisation
NOx                Nitrogen Oxides (NO & NO2)
NRMM           Non-Road Mobile Machinery
OEM               Original Equipment Manufacturer
PM                  Particulate Matter 
PN                   Particulate Number
R&D               Research and Development
RTD               Commission DG Research and Innovation
SANCO          Commission DG Health and Consumer Protection
SbS                 Side-by-Side
SCR                Selective Catalytic Reduction System
SG                   Commission Secretariat-General
SME               Small and Medium sized Enterprises
SI or PI           Spark Ignition or Positive Ignition
(commonly petrol fuelled)
TTIP               Transatlantic Trade and Investment Partnership
UNECE          United Nations Economic Commission for Europe
UNIFE           Association of the European Rail Industry
              Annex
I: Specific emission limit values used for the analysis
              
              
              
Annex II: Summary of the open public consultation
Public
stakeholder consultation on 
the revision of Directive 97/68/EC on emissions from non-road mobile machinery
engines
Summary
of the contributions received
Author:
P. Troppmann (ENTR B.4)
29
April 2013
Please
note that this summary of the consultation does not express the position of the
Commission.
1.      Introduction
As part of the preparation
of the impact assessment for the revision of the Directive 97/68/EC on
emissions from non-road mobile machinery engines, hereafter referred to as “NRMM
Directive”, the Commission ran an internet public consultation for 12 weeks
from 15 January until 8 April 2013. 
This consultation sought
opinions from stakeholders and experts in the field of non-road mobile
machinery with a view to receiving additional information on a number of policy
options identified as a result of an exhaustive preparatory work by the GEME
expert group[33]
as well as several studies. All European citizens, organised stakeholders,
industries, institutions, NGOs and public authorities of EU countries were
invited to contribute to this consultation.
This consultation was
supplemented by a stakeholder hearing on 14 February 2013 in Brussels which was
attended by about 70 participants, mainly from industry, national or regional
authorities, European associations and NGOs.  
2.     
Structure of the questionnaire
The questionnaire used
open questions on pre-identified policy options describing the possible content
of the revision. Answers were not mandatory.  It was explicitly highlighted
that the pre-identified policy options are supposed to describe only major
possible changes to the Directive which have been prepared solely for
consultative purposes without prejudging the form and content of any future
proposal by the European Commission. 
3.      Characterisation of
the respondents
In total, 69 contributions
were received through the functional email box for NRMM activities (ENTR-NRMM-EXHAUST-EMISSIONS@ec.europa.eu). 
According to the figure below, the most represented contributors were
professional associations (38%), followed by industrial companies (22%), EU
national and regional authorities (10%, respectively), non-governmental
organisations (7%) and social partners (6%); the remaining part of
contributions (7%) was introduced by end-users, one citizen and Switzerland as
non-EU authority.
It is noted that some
ship-owners or ship-operators associations were registered as non-governmental
associations and some ports were registered as public authorities. The table
below gives an overview of the contributors, grouped in accordance to their
field of competency:
   || Number || % of total 
 Ship-owners* || 36 || 26% 
 Charterers/ Ship operators* || 13 || 9% 
Key contributors were
(sorted by affiliation):

 Professional
     associations: Finnish Biogas, EBU
     (European Barge Union), Intl. Snowmobile Association, UK Railfreight
     Group, CEFIC (chemicals), AECC (emission control), CECE (construction
     equipment), VDMA, NGVA (Natural & bio gas vehicles), EUROPGEN
     (gensets), ESO-OIB (EU Skippers’ Organisation), GIGREL (gensets), CEMA
     (agricultural machinery), EUROMOT (internal combustion engines), FEM
     (handling machinery), INE (Inland Navigation Europe), CER (railway &
     infrastructure companies), EURELECTRIC (electric industries), UEPG
     (aggregates), ATVEA (all-terrain vehicles), EGEA (garage equipment),
     Energy UK, VCD (Verkehrsclub Deutschland), UNIFE (rail industries), EGMF
     (garden machinery), TRANSFRIGOROUTE (temp-controlled road transport). 
 Industries:
     WELL AUTOMOTIVE (Technology Service), NISSAN Forklift,  RANSOMES JACOBSEN
     (turf care equipment), LIEBHERR (cranes), SDMO Energy Ltd, SDMO Industries
     (generator sets), VALTRA (tractors), VOLVO Penta, FIAT Industrial, EnBW
     Energie, EDF Energy, EMINOX (Emission reduction technologies), WESTPORT
     INNOVATION (Technology provider), THERMOKING – INGERSOLL RAND (transport
     refrigeration units) + 1 Anonymous.
 EU National
     Authorities: Belgium, Denmark, Italy, Netherlands, Portugal, Sweden, United Kingdom.
 EU Regional
     Authorities:  Salzburg,
     Steiermark, Wien (AT); Flanders (BE); Nordrhine-Westfalia, Baden-Württemberg
     (DE); Greater London (UK).
 Non-EU Authorities:
     Switzerland
 NGOs:
     Deutsche Umwelthilfe (DUH) & Bund für Naturschutz (BUND),
     Naturschutzbund Deutschland (NABU), AirCLIM (air pollution & climate
     secretariat, Sweden), EEB (European Environmental Bureau), T&E -
     Transport & Environment.
 Social partners:
     IG Bau (Industriegewerkschaft Bauen-Agrar-Umwelt, Germany), Bundesarbeitskammer Österreich, EFBWW (European Federation of Building & Woodworkers),
     BAT-Kartellet (Danish Federation of Building & Woodworkers).
 Others: 
     Endusers - Vienna Intl. Airport, SNCF,
     VTT (Vereiniging Verticaal Transport); Citizen (1)

4.      Results of the
on-line consultation
The
individual contributions received in response to the public stakeholder
consultation are available at:
http://ec.europa.eu/enterprise/sectors/automotive/documents/consultations/2012-emissions-nrmm/index_en.htm
The
following chapters summarise the replies received from the respondents.
Obviously, respondents did not always address all pre-identified policy options
proposed in the consultation document. For this reason, the number of total
replies received is indicated for each policy option, respectively. 
The
figure below provides a global overview on the number of replies received on
the suggested policy options, each of which is being discussed in further
detail in the sections hereafter.
                      Support                                conditional
support                         not conclusive                   disapproval
4.1.Extension of the scope
4.1.1.      Including compression-ignited (CI) engines
<19kW
(29
replies – 28 supportive, 1 conditionally supportive)
– The inclusion of smaller CI engines is clearly supported by the vast majority
of responses received on this measure. Most respondents support the limit
values contained in the consultation document which are aligned with those of
the corresponding US Tier 4 power class. The creation of two power classes,
namely <8KW and 8-19kW, is suggested by some of the respondents. The case of
conditional support refers to engines in transportable refrigeration units
(TRUs) for which longer lead times are requested due to the additional
technical complexity resulting from dimensional constraints of such units.
4.1.2.     
Including CI
engines >560kW
 (34
replies – all supportive) - The inclusion of CI
engines >560kW is clearly supported. The proposed limit values for variable
speed engines which correspond to the US Tier 4 ‘non-genset’ power class
standard are largely supported, while others favour application of the limit
for the 130-560kW power class. Also, the US approach of dividing these engines
class according to ‘genset’ and ‘non-genset’ applications receives some
support. 
4.1.3.      Including stationary engines
(32
replies – 24 supportive, 3 conditionally supportive, 5 disapproving)
– The inclusion of stationary engines is supported by most of the responses
received on the matter. However, there is also critical feedback on this
measure, mainly with regard to the risk of potential double legislation with
the ‘Industrial Emission Directive’ (IED) which regulates stationary engines
> 50MWth and which requires the Commission 
·        
to review the need to establish union wide
emission limit values for diesel engines and report by 31 Dec 2013 (review
currently in progress, by DG ENV)
·        
To carry out a review to determine whether
there is a need to control emissions from installations <50 MWth and report
by 31 Dec 2012 (review currently in progress)
As
regards limit values, the approach of using identical values as for mobile
engines in each power class, respectively, is mostly supported for engines
operating for longer periods (“non-emergency engines”). For “emergency
engines”, less demanding limit values are favoured (typically Stage IIIA that
does not require after treatment measures) whilst at the same time insisting on
a clear and comprehensive definition of the term “emergency engine”. 
4.1.4.      Including spark-ignited (SI) engines
>19kW
(24
replies – 23 supportive, 1 non-conclusive) –
The inclusion of larger spark-ignited engines appears to be an uncontroversial
measure too. A restriction to a power range from 19 to 56kW is suggested by
some respondents. As for the limit values, some respondents claim for alignment
with US standards whilst disapproving the proposed (stricter) values  put
forward in the consultation document.  One respondent requested further
clarification as to whether or not LPG and CNG engines would also be included. 
It’s
worthwhile mentioning that this measure is also supported for all-terrain and
side-by-side vehicles by its European association (ATVEA), whilst pleading for
a clear distinction between variable speed and constant speed engines with
regard to limit values and test procedures.  
4.1.5.      Including snowmobile engines
(12
replies – all supportive) – The inclusion of
snowmobiles is unanimously supported by respondents who provided feedback on
this measure. One respondent suggests Stage IV limit values, whilst the others
appear to support the proposed ones which are based on the US standards.
4.2.Introduction of new stages
4.2.1.      Constant speed engines
(16
replies – 13 supportive, 3 conditionally supportive)
– The approach of applying same limit values as for non-constant speed engines
and hence introducing Stage IV standards to constant speed engines is generally
supported. However, alignment with US standards in all power classes favoured
by a majority of respondents which notably requires the proposed limits for the
19-37kW class to be adapted.
4.2.2.      Inland Waterways Vessels (IWV): Stage IV /
Stage V
(20
replies – all supportive) – Whilst the introduction
of Stage IV emission limits for IWV (i.e. alignment with US standards) is
broadly supported, a number of respondents favour stricter NOx limits in the
130-600kW class (as per IMO standards), the inclusion of standards for
gaseous-fuelled (e.g. LNG) engines as well as the coverage of the full engine
(i.e. including any after-treatment system) by the Directive. One respondent
explicitly asks for a Stage V standard with a stringent NOx and particulate
number (PN) standard. 
4.2.3.      Engine class 19-37kW: Stage IV
(20
replies – 16 supportive, 4 conditionally supportive)
– Whilst this measure is broadly supported, most respondents express their
preference for alignment with the US standard also on the PM limit rather than
supporting the stricter one proposed by the Commission in the consultation
document (some respondents make their support conditional on this). 
4.2.4.      New emission limits: Stage V
(36
replies – 26 supportive, 10 conditionally supportive)
–The need for addressing particulate numbers (PN) in addition to particulate
mass (PM) is largely acknowledged by the respondents. However, some request a
comprehensive cost-benefit analysis before any further decision is taken. This
includes also clarification of the question whether such standards should be
limited to certain engines power categories (typically 56-560kW, possibly with
a staggered introduction and sufficiently long lead times). 
As
for possible limit values on PN, the reference to EURO VI for standards &
approach is generally preferred. Also, further aspects such as for instance
availability of engines/technology, the use of NRMM-appropriate test cycles and
the benefits of a joint approach with other important third markets (e.g. US, Japan) are highlighted.
4.2.5.      In-service conformity
(31
replies – 20 supportive, 4 conditionally supportive, 4 non-conclusive, 3
disapproving) –Whilst the principle of
in-service conformity (ISC) is supported by a significant number of
stakeholders, there are also critical views on this measure: These mainly refer
to concerns on possible implications in case of non-conformity and/or the lack
of further information in this regard (conditionally supportive responses and
non-conclusive responses). Opponents of ISC measures raised concerns as to the
inaccuracy and replication difficulties of portable measurement systems for the
wide variety of non-road applications; the rail sector, in addition, raised
serious safety concerns in case of coupling ISCs with automatic engine stop
features.
4.3.Specific transitional measures
4.3.1.      Flexibility scheme
(19
replies – 15 supportive, 2 conditionally supportive, 2 non-conclusive)
– Whilst the benefits of the flexibility scheme are generally acknowledged and
its retention supported by the respondents, some mention the need to make this
scheme more transparent and easier to enforce, monitor and control.  In this
context, the request to clearly designate the Legal Entity that is authorised
to make the request under the flexibility scheme is put forward. Generally,
there appears to be a preference for a more restrictive use of this instrument.

4.3.2.      Other transitional measures 
While
the retention of the Sell-off
of stock provisions (Art 9(4a)) is mostly
supported in its current form – only one respondent explicitly claims the
deletion of this provision due to significant additional administrative efforts
and the incentivising effect for manufacturers to produce for stocks – the
deletion of the End of
series provision (Art 10(2)) is
unanimously supported by the respondents, given that nearly no use is made of
it.
As
regards Time limits for
derogations, a period of 2 years as suggested in
the Commission consultation paper is widely supported for engines under the
sell-off provision. As for the Flexibility Scheme, some stakeholders advocate a
period of 5 years rather than the suggested 3 years, whilst others suggest
alignment of the time limits for engines under the sell-off and flexibility
provisions with limitation to 2 years. The rail sector argues to be a
particular case in this regard, claiming that the NRMM Directive should not
deal with any time limit given the conflict with the procedures established in
the relevant TSIs (Technical Specifications for Interoperability).
4.4.Other measures
4.4.1.      Alternative fuels
(25
replies – all supportive) - The extension of the
NRMM to alternative fuel engines as outlined in the consultation document is
unanimously supported by the respondents, along the principle of a fuel-neutral
approach. 
For
LNG-fuelled engines, some respondents draw to attention to the need for
avoiding methane leakage. 
Some
respondents raised concerns as to the fact that the inclusion of alternative
fuels of any kind might represent a significant effort for this legislative
act, so that it is suggested to include in the first instance only gaseous
fuels.  
4.4.2.      Legislation
(18
replies – all supportive) - The choice of a
Regulation as form of legal act is unanimously supported by the respondents,
mainly for its facilitated and faster transpositions as well as its uniform
application. 
4.4.3.      International harmonisation
(10
replies – all supportive) - The use of the UNECE
process as a means of simplifying procedures and ensuring widest-possible
harmonisation of standards is unanimously supported by the respondents. 
4.4.4.      Administration
The proposal of Better labelling of
engines received broad support by a number of respondents: this mainly includes
the marking on the engine of the actual production date (month & year), the
Stage to which it complies and whether it is intended for use outside of the EU
(export only). 
A
number of respondents also requested the introduction of more effective
measures for Market
Surveillance along the principles of the New
Legislative Framework, as a means to avoiding the placing on the EU market of
machinery that is not in conformity with EU legislation. 
4.5.Further comments from stakeholders
The
following aspects were mentioned as additional comments which some of the
respondents made at their own initiative. These should therefore be interpreted
as specific and singular remarks that cannot be statistically assessed with
regard to their representativeness.  
·        
Specific test cycles for transport refrigeration
units (TRUs)- A specific test cycle aligned with
the one in US legislation is suggested for TRUs which replicates their specific
in-use operating modes. 
·        
EU database –
A EU-wide publicly accessible database is recommended that ensures transparency
by mandatory publication of engine emissions performance 
·        
Separate shipment of after-treatment
systems – Against the background that
anti-pollution devices are often produced in a different facility than the
engine leading to separate shipping of these devices, the inclusion of
clarification on separate shipment in the legal act is recommended, along the
lines of a proposal by the GEME Working Group.
·        
Field-testing equipment
– the inclusion of a derogation for regularising the practice of field-testing of
engines during their development and prior to their type-approval is
recommended. 
·        
ATEX –
A derogation clause is proposed for equipment used in potentially explosive
atmospheres (ATEX), in the light of technical difficulties with engines
operating under such circumstances. This would allow such engines to comply
only with Stage IIIA standards. 
·        
Measuring of GHG emissions
– In analogy to Euro VI standards, it is suggested to measure greenhouse gases
(mainly CO2 and CH4) under any new emission standard, with a view to giving
industries and public authorities the possibility to make the best-informed
decision possible.
5.      General conclusions
With
a total of 69 responses received, the public stakeholder consultation had a
very satisfactory and sufficiently representative reply rate. This holds also
for the distribution of the respondent’s affiliation which can be qualified as
balanced with – expectedly – most significant participation from associations
and industry stakeholders; but also (national and regional) public authorities
and NGOs were well represented.
Overall,
the consultation process went pretty smoothly, without any particular problems
rising during the period of its publication. The stakeholder hearing event
organised as an accompanying measure on 14 February 2013 in Brussels was well
attended (about 70 participants) and very much welcomed by stakeholders as an
opportunity for providing the Commission with first orientations and positions
on the subject.  In this context, it is worthwhile mentioning that four major
industry associations (EUROMOT, CECE, CEMA & FEM) agreed on a common
position and came up with a consolidated presentation at this event. 
As
regards the written contributions received on the public consultation, the
revision of Directive 97/68/EC on NRMM along the proposed policy options
appears by and large broadly accepted and well supported by all stakeholders.
This holds for the proposed extension of scope, introduction and/or adaptation
of new emission limits and a range of further operational and administrative
measures.
An
alignment with US standards – which intrinsically implies both an extension of
scope and adaptation of (some) emission limit values – appears generally to be
the preferred way forward for most industrial stakeholders. As opposed to
these, public authorities and NGOs do generally tend to be supporting a more
ambitious approach, with stricter and widest-possible coverage of harmonised
emission limit values across categories. There is, however, a general consensus
between nearly all respondents that the issue of particulate numbers, an aspect
which is not addressed in current US legislation, needs to be addressed in
forthcoming legislation. On this issue, a number of respondents, mostly
representing industries, calls for a more cautious approach, notably building
upon detailed cost-benefit analyses, the possibility of restricted application
and further research into the issue, whilst other respondents advocate
ambitious targets in direct reference to Euro VI road standards.    
As
for the transitional measures, and here more particularly the flexibility
scheme, their general benefits in the past are mostly acknowledged. Unlike
industrial representatives who claim the retention of this system in its
current form, public authorities and NGOs however advocate a generally more
restrictive and limited use of this instrument. 
Finally,
there appears to be unanimous support from all responding stakeholders to the
use of the UNECE process as well as the use of a Regulation instead of a
Directive as new legislative instrument.
The
results of the public stakeholder consultation will be duly considered as input
to the Commission’s impact assessment work which currently is being carried
out.
              Annex III: Summary of
cost assumptions for option 3 (chapter  6.3) 
Table III.1: Particle Number (PN) data for
NRMM engines (FOEN/BAFU). 
Table III.2: US-EPA DPF Costs per unit,
adjusted for inflation and converted to € 
 EURO || 19-37 kW || 37-56 kW || 56-75 kW || 75-130 kW ||   130-560 kW 
 Kilowatt || 24 || 56 || 110 || 184 || 370 || 485 
 Material and Component Costs ||   ||   ||   ||   ||   ||   
 Filter volume (Litre) || 2.25 || 5.88 || 7.05 || 11.46 || 27 || 30.45 
 Filter trap || 244 || 640 || 766 || 1,246 || 2,938 || 3,311 
 Washcoating and canning || 90 || 237 || 285 || € 463 || 1,089 || 1,229 
 Platinium || 72 || 186 || 222 || 362 || 683 || 961 
 Filter can housing || 12 || 12 || 12 || 19 || 26 || 26 
 Diferential Pressure Sensor || 82 || 82 || 82 || 82 || 82 || 164 
 Direct Labour Costs ||   ||   ||   ||   ||   ||   
 Esitmated labour hours || 2 || 2 || 2 || 2 || 2 || 4 
 Labour rate ($/hr) || 48 || 48 || 48 || 48 || 48 || 48 
 Labour cost || 96 || 96 || 96 || 96 || 96 || 191 
 Labour overhead @40% || 38 || 38 || 38 || 38 || 38 || 76 
 Total Direct Costs to Mtfr (corrected 2012/Euro)   || 634     || 1,291     || 1,501     || 2,305     || 4,951     || 5,958     
Source: USEPA (2003)
              
Table III.3a: SI
engines: Market data1 of small SI engine machinery (overall: 44 Million; 2005, EU15)
Table III.3b: Market structure of small
SI engine machinery 
Table III.4a: CI
engines (except rail and IWV): Total number of machinery on the market per
equipment category and power class (overall: 6.7 Million; 2005, EU15) 
Table III.4b: CI
engines (except rail and IWV): Market structure of CI
engine land-based machinery
Table III.5: EU’s NRMM
annual sales from 2008 (Integer Focus Report).
              Annex IV: Summary of
cost assumptions for option 4 (chapter 6.4)
Table IV.1: Underlying assumptions for the NPV
calculation of costs for ISC implementation
[1]http://ec.europa.eu/enterprise/sectors/automotive/documents/consultations/2012-emissions-nrmm/index_en.htm 
[2]http://ec.europa.eu/enterprise/sectors/mechanical/non-road-mobile-machinery/publications-studies/index_en.htm

[3] http://ec.europa.eu/transport/modes/inland/studies/inland_waterways_en.htm

[4] http://ec.europa.eu/enterprise/sectors/mechanical/documents/legislation/emissions-non-road/

[5] Arcadis (2010) Study in View of the Revision of Directive 97/68/EC
on NRMM, Module1
[6] In 2012, the WHO classified diesel exhaust as carcinogenic to
humans (Group 1) based on sufficient evidence that exposure is associated with
an increased risk for lung cancer.
[7] COM(2013)623 of 10 September 2013
[8] 2008/50/EC
[9] 2001/81/EC
[10] Decision No 1600/2002/EC of 22 July 2002
[11] COM(2005)446 of 21 September 2005
[12] COM(2011)144 of 28 March 2011
[13] COM(2010)614 of 28 October 2010
[14] COM(2012)582 of 10 October 2012
[15] CE Delft (2008) Handbook on estimation of external costs in the
transport sector.
[16] EPA
(2009). Integrated
Science Assessment for Particulate Matter (Final Report). U.S.
Environmental Protection Agency, Washington, DC, EPA/600/R-08/139F, 2009. 
[17] In its most recent update, smaller engines with an output ranging
from 19 to 37 kW that meet the limit of 1×1012 particles/kWh have
been included for the first time. The first engine families listed in this
range are equipped with a DOC and DPF. www.bafu.admin.ch/partikelfilterliste/11647/index.html?lang=en
[18] http://www.trafikverket.se/PageFiles/65300/delrapport_emissionsmatning_arbetsmaskiner.pdf
[19] www.aecc.eu/content/NRMM_Seminar/09%20%20AECC%20Raimund%20Mueller.pdf
[20] Replies received from the following European manufacturer’s
associations: CEME, CECE, FEM
[21] JRC: 2007 Technical Review of the NRMM Directive 97/68/EC – Part II
(2008) 
[22] B. Giechaslkiel et
al (2012): Measurement of Automotive Nonvolatile Particle Number Emissions
within the European Legislative Framework: A Review
[23] CE Delft (2008) Handbook on estimation of external costs in the
transport sector
[24] Urban metropolitan: cities with > 0.5 million inhabitants
[25] PANTEIA, 2013: Contribution to impact assessment of measures for
reducing emissions of inland navigation, http://ec.europa.eu/transport/modes/inland/studies/doc/2013-06-03-contribution-to-impact-assessment-of-measures-for-reducing-emissions-of-inland-navigation.pdf
[26] European Commission, September 2013: The
NAIADES II package "Towards quality inland waterway transport". http://ec.europa.eu/transport/modes/inland/promotion/naiades2_en.htm
[27] http://www.cleaner-d.eu/
[28] UNIFE - Association
of the European Rail Industry
[29] Arcadis 2009: Impact Assessment study, reviewing Directive
97/68/EC. Final report, page 182 ff.
[30] NB: a negative amount indicates a net loss
[31] Directive 2012/46/EU of 6 December 2012
[32] T-Systems 2006, Database for the Exchange of Type Approval
Documentation (DETA) Feasibility Study.
[33] GEME – Group of Experts for Machinery Emissions