Explanatory Memorandum to COM(2000)840 - Amendment of Directive 97/68/EC 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 - Main contents
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This page contains a limited version of this dossier in the EU Monitor.
| dossier | COM(2000)840 - Amendment of Directive 97/68/EC on the approximation of the laws of the Member States relating to measures against the ... |
|---|---|
| source | COM(2000)840  |
| date | 18-12-2000 |
The objective of the proposal is to extend the scope of the current Directive on emissions from compression ignition engines to be used in non-road mobile machinery (Directive 97/68/EC) to cover small spark ignition engines also. This will contribute to achieving ambient air quality targets especially concerning formation of ozone.
Contents
- B. Legal basis
- C. Background
- 1. Justification for extending the scope of Directive 97/68/EC
- 1.1. Emissions from non-road SI engines
- 1.2. Environmental needs
- 1.3. Cost
- 1.4. Industry needs
- D. INVOLVEMENT OF INTERESTED PARTIES
- 1. Position of industry
- 2. Position of Member States
- E. CONTENT OF THE PROPOSAL
- 2. Scope of the amendment
- 3. Classification of engines
- Class/category // Displacement (cubic cm)
- Non-handheld engines
- 4. Pollutants to be regulated
- 5. Two-step approach
- 6. Limit values. Compliance with standards
- Compliance with standards
- 7. Phase-in, averaging, banking and trading
- Administrative difficulties
- 8. Small volume manufacturers and small engine families - stage II
- Production of small engine families
- 9. Replacement engines
The amendment is proposed on the basis of Article 95 (ex Article 100a) of the EC Treaty. It forms part of the type-approval system used for engines for non-road machinery and compliance with it will be mandatory for new type approvals to be issued by national authorities. The amendment sets performance standards, leaving the manufacturer the freedom to design products that meet those standards. This legislative approach is fully supported by the operators in the market.
The text is relevant for the EEA.
The current EU Directive on emissions from engines for non-road machinery (Directive 97/68/EC) covers only compression engines with a power output above 18 kW but not more than 560 kW. It includes emission limits for carbon monoxide, oxides of nitrogen, hydrocarbons and particulates. The different limit values are implemented in two stages -stage I coming into force during 1999 and stage II between 2000 and 2003, depending on the engine power output.
Recital 5 of the Directive states that the scope of the Directive could be extended to cover gasoline engines - however without giving any schedule for the extension.
As will be discussed later, the Directive was developed and implemented in very close co-operation with the Environmental Protection Agency of the USA, thus achieving worldwide alignment, including the Japanese legislation. It is therefore of particular interest to study what has already happened and what is in the pipeline in the USA concerning non-road spark ignition engines.
Regulations have been in force federally in the USA since 1997 (adopted in 1995). Those regulations are limited to engines of not more than 19 kilowatts and certain applications are exempted - for instance engines used for marine vessels, underground mining equipment, motorcycles, aircraft and certain recreational vehicles.
A second phase of those regulations was decided upon in March 1999 for 'non-handheld engines' and in June 2000 for 'handheld engines'. This second phase will come into force starting in 2001 for 'non-handheld engines'. Concerning 'handheld engines', the regulations will be implemented between 2002 and 2007.
For engines with a power output above 19 kW there are no regulations in force federally in the USA. At state level the California ARB implemented such rules in October 1998.
To prepare for a possible extension of the scope of Directive 97/68/EC, consultations have been held with experts from the Member States.
In the field of SI engines for non-road mobile machinery the most immediate pollutants to discuss are hydrocarbons and oxides of nitrogen - as ozone precursors. In the longer term particulate emissions, especially from two-stroke engines, and perhaps specific toxic hydrocarbons should also be studied. The latter pollutants are not covered in this proposed amendment but might be covered in future work since further scientific studies have to be carried out before any concrete measures can be justified and proposed.
Statistics on emissions of air pollution have concentrated very much on road traffic and on stationary sources. Thus there is a certain lack of reliable data on the overall emissions from non-road mobile machinery. In preparing Directive 97/68 the Commission launched a study in order to draw up an inventory of the emissions and relative importance of different categories of non-road engines. The data used in this study are from the beginning of the 1990s.
From the study the following information can be extracted:
>TABLE POSITION>
Stage I of Directive 97/68/EC has been implemented resulting in a reduction of emissions from non-road mobile machinery equipped with diesel engines. Concerning light on-road vehicles, three-way catalytic converter technology was introduced at the start of the 1990s resulting in significantly lower emissions of all gaseous pollutants. The standards have been tightened step by step, and a modern light vehicle of today emits less than 10% of what was the case with a vehicle in the late 1980s. A similar development has taken place concerning heavy-duty vehicles although not as effective as for light vehicles.
Furthermore additional tightening of the standards has already been decided upon. For light vehicles the next step will be introduced in 2005 and for heavy duty vehicles (HDV) tighter standards will be introduced step by step in October 2000, in 2005 and, for NOx, tentatively also in 2008. In addition a concept of EEV (enhanced environmentally friendly vehicles), to be used by Member States together with economic incentives, has been decided upon for HDVs.
With the introduction of those standards emissions from on-road vehicles will decrease significantly in spite of the increased traffic volumes. According to calculations made in the Auto Oil II programme, emissions of NOx and VOC from the road transport sector will decrease by about 50% by the year 2010 compared with today's situation. The relative importance of emissions from non-road machinery and especially from spark-ignited engines has therefore increased since 1990 and will continue to do so even more in the future.
The intention of the Auto-Oil II programme was to find cost-effective strategies to meet the requirements of the different ambient air quality standards and other air pollution programmes within the EU. Certain results from the programme are of interest when evaluating future emission standards for non-road machinery.
Modelling of the 'base case' forecasts significant reductions in emissions for all conventional pollutants by the year 2010. These reductions, which will be even more significant by the year 2020, will translate into big improvements in air quality but may not always be sufficient to reach the air quality objectives mentioned above.
In particular with regard to tropospheric ozone, it has been suggested that the improvements in ozone levels which can be expected will still leave the Community well short of its objective of no regional-scale exceedences of critical levels. The remaining main air quality challenge will be closing the gap between the Auto-Oil II base case emission projections and the proposed national emission ceilings for NOx and HC. The national emission ceilings for HC emissions, which is one of the main pollutants from small SI engines, are expected to be exceeded in several Member States in 2010.
Another pollutant highlighted in the Auto-Oil II programme is particulate emissions. In this case the cause-effects relationship is still unclear but it is obvious that the number of small particles as well as the content of the particles might be greater than previously thought. Therefore this kind of pollutant is also of future interest concerning spark ignition engines - especially two-stroke engines.
With respect to cost-effectiveness no detailed scenarios for spark ignition engines for non-road machinery were produced in the Auto-Oil II programme. However, the background reports to the US-regulation contain extensive studies on the environmental benefits, the effects of the emissions and the costs for the standards decided upon. Even though those studies cover the US situation, much of the data generated is of a general character and therefore can be used also to estimate the cost-effectiveness under European conditions.
For the phase 1 programme in the USA, the following information on cost-effectiveness has been published (Source: EPA - response to comments on the Notice of Proposed Rulemaking):
-If the total costs for the proposed standards are allocated to HC the cost will be $ 266 per tonne of HC reduced. If equally split between HC and CO the cost will be $ 133 per tonne of HC and CO reduced.
For phase 2 non-handheld engines the following cost has been used (EPA Final Regulatory Impact Analyses):
-When not taking the fuel saving into account $ 852 per tonne HC+NOx saved - noting that by far the biggest reduction is the one in HC - and when taking fuel savings into account $ 507 per tonne. The greatest fuel saving is within the Class II engines but for the Class I engines the cost also decreases to a third when taking the fuel saving into account.
For phase 2 regulations on handheld engines the corresponding estimates are $ 830-1020/ tonne NOx+HC without fuel savings and $ 560-750 with fuel savings.
To gain an idea of the relative cost-effectiveness those figures could be compared with the ones available as a basis for the Commission proposal on a Directive on national emissions ceilings. For hydrocarbons, which are one of the important pollutants when discussing non-road SI machinery, the cost-effectiveness in the different Member States for meeting the requirements in the proposed NEC-Directive typically varies between EUR 1500 and 4000 per tonne reduction in HC.
Assuming that the cost-efficiency used in the US-regulatory process is also typical for European conditions, implementation of an amendment in line with the US regulations/proposed regulations should be well below those figures and should thus be considered cost-effective. Overall the cost implications of introducing standards corresponding to the US standards should be less for European manufacturers. The US estimate was based on the assumption that the legislation was introduced in the USA only. Many European manufacturers are producing engines on a global market and have to develop and produce engines meeting the US standards independently of the EU legislation. A global alignment of the legislation will lower the cost for those manufacturers.
In addition to the overall cost-effectiveness of an amendment the impact on individual manufacturers must be taken into account. For those European manufacturers who are not operating on a global market and will not be doing so in the future, an amendment will have different consequences than it will for manufacturers who are operating on a global market. The former might have limited resources to carry out technical development and they might also have a limited number of machinery types. Another problem that must be taken into account is the specific European noise requirements that might create the need for extra efforts especially for equipment manufacturers. This kind of problem will, however, occur whichever standards are implemented and should be handled by certain special arrangements, for instance longer implementation periods.
The current situation in Europe, where there is no emission legislation covering spark ignition engines for non-road mobile machinery but obviously an environmental need for it, opens up the possibility of implementation of national and local standards. There are no guaranties that those standards will be similar in the different Member States and if they are not they will definitely create distortion of the single market. Furthermore, from an environmental point of view it is unfortunate if the development resources of the industry are split between a lot of different concepts making it more difficult to get robust solutions at a high environmental level.
Many, though far from all, companies are presently offering their products on a world-wide basis. Those companies will definitely benefit from a limitation in the number of standards, especially if a world-wide alignment is achieved. For those companies not yet on the world market such a development would open up this market too for their products.
The engine manufacturers have been closely involved in the discussions and the development of the proposal. They have been an important contributor and, in general, support the Commission's proposal.
Experts from the Member States have been consulted and informed of the content of the proposal through the Commission's Working Group on Emissions from Non-road Mobile Machinery Engines (GEME) and by mail. A majority of the experts support the proposals.
1. 'World-wide' alignment
When the preparatory work on the current Directive 97/68/EC for CI engines started, no regulations had yet been implemented in the USA or in Japan. They were thus developed in parallel in Europe and the USA. This created a good opportunity to find common solutions and the rules were developed in a spirit of mutual understanding and a willingness to achieve alignment. Later Japan developed legislation aligned on the EU/US legislation.
The situation today concerning spark ignition engines is somewhat different. In the USA regulations are already in place for small engines. For large engines the situation is very much the same as it was for diesel engines when developing Directive 97/68, in that there is no EU legislation and no federal US legislation either.
This means in reality that alignment for small engines is basically a question of evaluation of the current US legislation. However, during the bilateral discussions that have taken place, representatives from the US-EPA have stated a willingness to propose amendments to their legislation if this can be justified and if necessary in order to achieve an alignment.
The European manufacturers have, through the European Association of Internal Combustion Engine Manufacturers (Euromot), expressed a strong wish to achieve world-wide alignment of the legislation concerning SI engines also. In this context they have presented a proposal based mainly on the US legislation - though taking into account some specific European conditions.
From an environmental point of view an alignment is advantageous providing that the standards are on a high level of ambition reflecting the use of best available technology, that they are cost efficient and that they address the relevant environmental problems. The background documents presented by US-EPA clearly indicate that this is the case with the implemented US legislation. In addition aligned requirements will give industry a better chance to concentrate development resources and thus produce more durable technical designs to meet the standards.
Consequently it is beneficial for industry as well as for the environment to align the future EU legislation on the corresponding US legislation as far as possible and to work for world-wide acceptance of those standards. The recent global agreement within the UN-ECE in Geneva creates a possible forum to obtain such world-wide alignment.
Directive 97/68/EC on CI (diesel) engines covers engines with a power output between 18 kW and 560 kW. Those are typical sizes for that kind of engine and consequently the contribution of emissions from CI engines below 18 kW is very small.
SI engines used in non-road equipment are the opposite case. They are normally smaller and the smallest ones make the highest contribution to the overall emissions (NMHC). Typically those below about 20 kW are the biggest contributors, although the contribution from somewhat bigger engines cannot be neglected.
When developing Directive 97/68/EC the Commission carried out an inventory to find out the contributions of the different classes of non-road engines to the emissions.
>TABLE POSITION>
The data from the study clearly indicate that engines below 18 kW are the most important for the overall emissions from SI engines. This does not exclude that there might be cost-effective measures for larger engines as well. However, to be able to draw any conclusions about this, further studies will have to be carried out. Furthermore, if the current policy of achieving a global alignment of the standards is to be maintained, discussions will have to take place on an international level. This process will take a long time. To avoid delaying implementation of standards for the smaller engines, this first amendment of the Directive on SI engines is limited to the segment already regulated in the USA - not more than 19 kW.
According to recital 5 in Directive 97/68/EC the scope of the Directive should be enlarged to include gasoline engines. Even if the expression 'gasoline engines' is used it might be considered whether alternative fuelled engines should also be covered. In the current US regulations a voluntary option on NMHC (non-methane hydrocarbon) is included for 'non- handheld engines' to cover natural gas fuelled engines. Such engines are not expected as 'handheld engines'. However gas fuelling is more common for the bigger engines and is expected to be very exceptional for engines below 20 kW in Europe. The European manufacturers have expressed no wish for a similar voluntary option as in the USA. The discussion on gas fuelled engines therefore will be addressed when discussing SI engines with a power output above 19 kW.
In the current scope of Directive 97/68/EC certain applications are exempted. For natural reasons engines for propelling on-road vehicles are exempted. By limiting the scope of this amendment to engines of not more than 19 kW those are normally exempted anyhow but should still be outside the scope of the Directive also concerning SI engines. Concerning recreational boats work is under way on drafting an amendment to Directive 94/25/EC to cover emissions (and noise). Consequently there is no need to include this application in the amendment of Directive 97/68/EC.
Today constant speed engines (generating sets) are also excluded. This is not the case in the corresponding US legislation. There is no other EU legislation applicable to emissions from those types of engines and they should therefore be covered. For SI engines they will be covered on the same implementation dates as for other types of engines. For CI engines they will be covered from 1 January 2007, giving the manufacturers enough lead time to develop the necessary technology.
Finally 'recreational' vehicles (like snowmobiles) are exempted in the US legislation. Many of those engines are above 19 kW but smaller engines also exist. In certain Member States emissions from snowmobiles are a notable part of overall emissions. However, since the segment proposed for the current amendment only covers a minor part of the engines and since the background studies do not include recreational vehicles those have been excluded from the proposal. The US EPA has announced its intention to develop legislation for emissions from recreational vehicles in the future which creates a good opportunity for bilateral discussions and, if found appropriate, for aligned legislation.
As in the current US regulation, engines are divided into two main categories, depending on the kind of equipment in which they are intended to be used - handheld and non-handheld. This split is also the natural split between the segment totally dominated by 4-stroke engines and the one in which 2-stroke engines are frequent.
Handheld engines are defined as follows:
At least one of the following requirements must be met:
*the engine must be used in a piece of equipment that is carried by the operator throughout the performance of its intended function(s);
*the engine must be used in a piece of equipment that must operate multipositionally, such as upside down or sideways, to complete its intended function(s);
*the engine must be used in a piece of equipment for which the combined engine and equipment dry weight is under 20 kilograms and at least one of the following attributes is also present:
(a) The operator must alternatively provide support or carry the equipment throughout the performance of its function(s);
(b) The operator must provide support or attitudinal control for the equipment throughout the performance of its function(s); and
(c) The engine must be used in a generator or a pump;
Equipment not fulfilling those criteria is consequently defined as non-handheld.
The two categories of engine - handheld/non-handheld - are subdivided into three and four size-classes respectively, depending on the displacement of the engines. This classification is linked to the technical/economic possibilities to reduce emissions.
The engines covered by the extended scope of Directive 97/68/EC are - following the US legislation and the Euromot proposal - divided into different classes and categories:
Main class S: Small engines with a net power „ 19 kW.
Main class S will be divided into two categories:
H: Engines for handheld machinery,
N: Engines for non-handheld machinery.
Handheld engines
Class SH:1 // < 20
Class SH:2 // … 20 to < 50
Class SH:3 // … 50
Class SN:1 // < 66
Class SN:2 // … 66
< 100
Class SN:3 // … 100
< 225
Class SN:4 // … 225
Pollutants normally covered by EU Directives on emissions from engines or vehicles are carbon monoxide (CO), oxides of nitrogen (NOx), hydrocarbons (HC) and particulates (PT) (diesel). As discussed in chapter 1 of this explanatory memorandum, it is obvious that the emission of hydrocarbons is a main issue for this kind of engine. Especially for 2-stroke engines this is the dominant gaseous pollutant and therefore must obviously be addressed in the amendment. In addition the emissions of NOx, as a precursor of ozone, should be considered. The Auto Oil II programme clearly indicated that no further problems are expected with CO in the future and therefore the need to regulate this is less obvious from an environmental point of view. However, for the sake of alignment, it should be included in the set of standards in the amendment. It is noteworthy that the US EPA has drawn similar conclusions on the relative importance of the gaseous pollutants. Thus it should be noted that the standards for CO have not been tightened in phase II - only adjusted to reflect that the phase II standards include durability requirements.
Obviously particulate emissions from SI engines, especially two-stroke engines, will also be a topic of some urgency in the future. However, there is still a need for further knowledge about the importance from both the health and environmental points of view before relevant regulations can be implemented. There is also a need for further inventory studies on the emission, size distribution and content of those particles.
As described above, the US regulation has been implemented in two phases. The current Directive 97/68/EC also contains two stages of implementation for compression ignition engines. A two-stage approach of this kind has certain advantages. The main advantage is that it gives the industry longer lead-time to develop a reliable and durable technology. A disadvantage is that it might take longer to introduce very strict standards than it would if doing so in one step.
For SI engines a first phase is already in force in the USA. It will be fully implemented by the year 2002. It could therefore be asked whether any European legislation - assuming it is aligned with the US legislation - should go directly for the second phase. Theoretically it could be stated that going directly to step 2 should be less expensive for industry and should also allow earlier implementation than would otherwise be the case. However, if such a strategy were chosen, SI engines for non-road mobile machinery would be unregulated in Europe for at least another 5 years or so. Therefore the proposal includes a two-step approach. The implementation dates are obviously linked to the corresponding implementation in the USA. It should, however, be noted that not all European manufacturers are producing engines for the US market. They therefore need a certain lead time to develop their products even if the basic technology is known. In addition the equipment manufacturers have to adjust their designs for the European market to take into account the stricter EU legislation on noise.
Limit values
The limit values used in the US legislation have been demonstrated to give a good balance between the environmental benefits and the overall economic implications. Using the same limit values (and test procedures) is also the most important element in the alignment procedure. Consequently there is no need to modify them.
It should though be noted that the two classes SN:1 and SN:2 did not exist in phase I of the US legislation and no engines fulfilling those requirements existed. Consequently all existing engines in those classes are developed to meet the phase two standards. Those standards include the deterioration of the engines and to be fully logical the emission limits for stage I should have been strengthened accordingly. However there are no data on how to do this calculation. Therefore the same limit values as in stage II have been used with the certainty that the real emissions will be lower. Furthermore the implementation date proposed for stage II for those engines is to be as early as 1 August 2004.
>TABLE POSITION>
The impact on the environment, of course, depends on the emissions of the engines during real working conditions and taking into account their deterioration by normal use. The US regulation on non-handheld engines, phase II, has therefore implemented standards reflecting in-use emissions. For this purpose a method on how to measure the deterioration factors (DFs) is presented as well as a set of assigned DFs that can be used by small volume manufacturers which have less resources to carry out durability tests.
Implementing such a system in stage 1 already for the European regulations could give some environmental benefits. On the other hand it is difficult to find what standards should be used that correspond to the standards used in the USA for phase I.
The limit values shown in the table are being introduced in the US legislation with a degree of flexibility. For stage one a 'phase-in' procedure is used meaning that only a certain share of a manufacturer's production has to meet the standards in the first year. This share is increased every year until the total production has to meet the standards. This phase-in procedure started in 1996 and by 2002 all the production has to meet the regulations.
Such a phase-in procedure might be beneficial for the environment as well as for the industry. It will make it possible to implement standards for part of the production even though this is not possible for the whole production. At the same time it gives flexibility for industry to develop its production step by step. However since phase I of the US legislation will be fully implemented by 2002, well before the implementation dates in this proposed amendment, there is no need for a similar phase-in programme.
Furthermore, in the corresponding US regulations a system of averaging, banking and trading has been included for the phase II requirements. In brief this means that a manufacturer may produce engine families that are emitting pollutants above the emission limits as long as he is compensating this with other engine families that are emitting below the limit values. As an average the manufacturer has to be below the limit values for his total production. In practice this means that initially he can concentrate on the large engine families and leave the small ones.
To obtain environmental benefits from this system a manufacturer using this option must on average meet progressively tighter standards until the application dates when stage II comes into force. At the implementation date for stage II, of course, the manufacturer has to meet those requirements as an average.
Within the banking system a manufacturer may save credits from one year to another to meet the average emission standards.
The trading system means that a manufacturer might buy or sell credits from or to another manufacturer.
This system, especially the averaging and banking parts, is an important element of the US regulations and thus essential to achieve alignment between the US and EU legislation. The intention therefore has been to build a similar system into this amendment. However, trying to do so raises some issues of concern:
There are some major differences between the US administrative procedures and the EU procedure used in Directive 97/68/EC. The US procedure is based on a certification system leaving much of the responsibilities of testing to the manufacturers. Furthermore it is administered by one and the same authority - EPA. The EU legislation in this field is based on a type-approval system and is administered by, in principle, approval authorities in all the Member States. Those differences make it difficult to transfer the US system into EU legislation without modifications.
Competition between 'small' and 'large' manufacturers
Only manufacturers producing more than one engine family can use an averaging and banking system. The more engine families produced the more beneficial the system is. This might lead to a situation where a large manufacturer with a large number of engine families in its range could continue to produce engine types with emissions above the limit values by compensating this with production of an engine family with emissions below the limit values. At the same time a small manufacturer with perhaps a similar engine as the only one in its range has to meet the standards.
Those two issues have been addressed in the proposed amendment. One alternative is of course not to include averaging and banking. If doing so and still trying to offer a possibility for the engine manufacturers to use the same engine designs world-wide, the limit values would have needed to be higher or implemented later. This would have opened the way for imports onto the EU market of engines with lower technical standards from an emission point of view.
Consequently a system of averaging and banking is included in the proposal. This system is optional for the manufacturer who might choose to use the traditional method of type approving all his engine families separately to meet the limit values instead. To avoid any extra administrative burden on the approval authorities, all requirements that might follow as a consequence of the system have to be covered by the manufacturers. To meet the competition between manufacturers who cannot use the system of averaging and banking and those who can, an exemption is proposed for 'small engine families', as is the case in the US legislation (see below).
An averaging and banking system has never been used in EU legislation before. Some doubts therefore were raised during the discussions with Member States and industry whether the details of the proposed system were the most appropriate. At the same time experts from the Member States expressed the need for quick introduction of the amendment and implementation as early as possible. In order to meet both those requests the Commission, instead of delaying implementation, will launch a study to look at the details of the proposed system in greater depth and, if found appropriate, propose amendments before the averaging and banking option comes into force (stage II).
Small volume manufacturers
Small volume manufacturers will have greater difficulties in addressing the requirements than manufacturers producing larger volumes. They have more limited development resources and thus need extra time to adjust their production. In the US legislation too this problem has been addressed by a later implementation date for those manufacturers.
During the discussion with industry a request for a later implementation date for stage II was made. An application date three years later has therefore been proposed for small volume engine manufacturers, defined as those with a total production of the engines covered by the proposal of less than 25 000 units per year.
Costs for developing the technology necessary to meet the standards could of course be covered more easily with big engine families than with smaller ones. For some niche products it might be difficult to cover the cost needed to meet the standards, at least in the short term. These products need extra time for technical development or to find solutions that can replace the engines. This need is similar for small engine manufacturers and for large engine manufacturers.
In the US legislation this is approached by an exemption for small engine families. However, such a solution might - taking into account the structure of grouping into engine families in the EU legislation - result in a manufacturer dividing his production into a large number of small engine families to prevent introduction of the standards. To avoid this the criteria on how to group the engine families must be changed. The engine family concept was introduced to limit the burden of testing for the manufacturer. Consequently it has been left to the manufacturer to a great extent to decide how to create the engine families, just concentrating on the 'worst case' in the engine family. A change of those provisions would limit this advantage for the manufacturer without presenting the necessary advantages from other points of view. Instead, to simplify the system, the problem with small engine families has been addressed by looking at the production of a certain class of engines. Such a simplification would take care of the small engine family problem in a reasonable way for small manufacturers who are unable to use the averaging system. For manufacturers using the averaging and banking system this will solve the corresponding problem on an equitable basis from a competition point of view.
The proposal therefore delays implementation for three years for any manufacturer who can show a production volume of a certain class of engines below 5 000 units per year. The delay of course only covers that specific class of engines.
For smaller engines (SI engines) the value of the engine as such represents the main value of the equipment. Therefore there is no need to address the issue of replacement engines. Subsequently there are no specific arrangements in the US legislation for this type of engine.
For larger engines, where the total value of the equipment is considerably higher than the value of the engine as such, special arrangements for replacement engines might be relevant. The current requirement in Directive 97/68/EC is that a replacement engine must meet the emission limits in force at the time. It might, however, be difficult to find a fitting engine meeting those emission standards.
In the current Directive 97/68/EC this topic of replacement engines has not been dealt with separately. So far it has created no problems since stage I of the Directive came into force very recently. However, if not addressed it will create problems in the future. Therefore separate requirements are proposed for replacement CI engines making it possible to replace an engine with one meeting the same requirements that the original engine had to meet.