Real Driving Emissions is a tough regulation, but also a risky one

Aggressive driving on average increases pollutant emissions by 35% in rural driving and by around five times on the motorway, according to testing of the latest passenger cars by Emissions Analytics on its EQUA Index programme. Even higher “hotspots” have also been identified, where emissions at high speed can peak at more than ten times typical levels of nitrogen oxides (NOx) – the pollutant gas that was at the centre of the #dieselgate scandal.

The need to identify hotspots is becoming vital with the new Real Driving Emissions (RDE) regulations, which is a much tougher regulation of driving in normal conditions. The consequence of this will be that a greater proportion of total emissions may be concentrated in a small number of more unusual or extreme events. Unless those are well understood, the effect of the new regulations may be blunted.

The in-use surveillance requirements set out in the fourth package of RDE are aimed at monitoring vehicle compliance in all normal driving conditions, not just the cycle on which the vehicle was certified. Broadly, a vehicle should pass any RDE test within its useful life, whenever and whoever conducts the test. This is both a significant challenge for manufacturers, and brings with it risk as it is impossible a priori to guarantee compliance on all possible RDE tests.

To help quantify this risk, Emissions Analytics is launching a new evaluation programme that will quantify the risk of excessive emissions for each vehicle tested. Currently, EQUA Index ratings (www.equaindex.com) are published to allow the performance of different vehicles to be compared on a standard, normal cycle. This new programme leaves that rating unchanged, but puts the vehicle through an extended test designed to measure performance in more extreme and unusual driving conditions. The variance between that, the standard EQUA Index and the regulated level will yield a rating for the risk of exceeding the regulated level.

The main factors considered are:
• Higher speeds
• Higher and lower rates of acceleration
• Cold start emissions
• Emissions under regeneration of the diesel particulate filter.

Considering eight diesel cars certified to the new RDE standard (Euro 6d-temp), the effect of driving at speeds up to 160 kph can be shown in the chart below.


In all cases the NOx emissions on the standard cycle – with maximum speeds up to 110 kph – are within the regulated limit of 80 mg/km plus 2.1 times conformity factor, even though certification does not apply this to the motorway section separately. In fact, many of the vehicles are comfortably below this limit. Allowing the maximum speed to rise to 160 kph shows significant proportionate increases on all but one vehicle, with the average percentage increase across all eight vehicles being 552%. All but two of the vehicles remain below the limit despite the increases; however, the worst two vehicles emitted around 650 mg/km.

For reference, under the RDE regulation, the vehicle’s velocity can be driven between 145 and 160 kph for up to 3% of the total motorway driving time. The risk of compliance therefore comes from a vehicle that has a significant emissions uplift at 160 kph and is relatively close to the limit at more moderate speeds.

Under cold start, vehicles 7 and 8 also showed an average increase in emissions of 160% compared to an average of 110% across the other vehicles.

Putting this data together with performance in other parts of the test cycle, it is possible to derive ratings of the risk of excessive emissions on RDE and on RDE-like cycles but with more relaxed boundaries, as shown in the table below.


It is important to note that a red rating does not necessarily imply non-compliance but, rather, it identifies elevated risk of non-compliance using results from the Emissions Analytics’ test, which runs a cycle similar to RDE but that is not strictly compliant.

Considering Euro 6 diesels, whether RDE or prior, the effect of cold start is that NOx emissions are 2.8 times higher on average during the cold start phase compared to the whole warm start cycle. During regeneration of the diesel particulate filter NOx emissions are on average 3.3 times higher than in mixed driving with no regeneration. Therefore, the frequency and geographical location of these events can be critical to the overall real-world vehicle emissions.

These results are important for cities, manufacturers and regulators. For cities, it is vital to know that the latest vehicles do not have emissions hotspots that could undermine their air quality targets. For manufacturers, facing third-party RDE testing to check compliance, it is important to quantify the risk of high emissions being found in unusual driving conditions, where every scenario cannot practically be tested. For regulators, it is important that RDE is seen to function well in order to draw a line under the failed regulation of the past.

Emissions Analytics will continue to test a wide range of the latest vehicles to publish comparable ratings between vehicles, but now with the added quantification of the risk of elevated emissions around the boundaries of normal driving.

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