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Normes "SULEV 2004" Véhicules Propres, pour information !


2. Tailpipe emissions meeting California's "Super Ultra Low Emissions Vehicle" (SULEV) standard.

Even the cleanest and most efficient vehicle on the market today still pollutes the air and otherwise damages the environment. Motor vehicles emit several noxious pollutants which vehicle emissions standards are designed to regulate:

Currently, all new vehicles for sale in the United States (outside of California, New York, and Massachusetts) are certified to meet the Tier 1 Federal emissions standard set by the U.S. Environmental Protection Agency (EPA). Tier 1 limits the amount of HC, CO, NOx, and PM coming from a vehicle's tailpipe and leaking from its fuel system. Vehicles sold in California, New York and Massachusetts must meet more stringent emission standards established by the California Air Resources Board (CARB) and adopted by the other two states.

To continue to improve air quality, tighter standards are needed nationally. CARB has already established stricter standards set to begin in model year 2004. Its Super Ultra-Low Emissions Vehicle (SULEV) standard is the cleanest emission standard that a gasoline vehicle can meet. EPA has proposed a somewhat less stringent program -- Federal Tier 2 standards -- also set to begin in model year 2004. The Tier 2 proposal has an emissions standard almost identical to California's SULEV standard that automakers could begin certifying to as early as MY2001. SULEV represents today's state-of-the-art in emissions control, and is a substantial leap forward compared to the current federal standard. The Clean Car Campaign has therefore adopted the SULEV standard.

The table below compares the SULEV standard to the current Federal Tier 1 standard. It shows that to achieve the Clean Car Campaign's SULEV Standard, vehicle emissions must be reduced by 76 to 97 percent from current levels. This can be achieved through improved engine and catalytic-based control technologies, representing best practice for gasoline vehicle emissions currently available. By applying this standard to vehicles sold nationally, improvements in air quality can be achieved across the country. This Clean Car Standard also applies to both passenger cars and light-trucks.

A COMPARISON OF EMISSIONS STANDARDS
Pollutant Clean Car Campaign
Standard (SULEV)

(grams/mile)
Current Federal
Standard (Tier 1)

(grams/mile)
Reduction
(percent)
Hydrocarbons (HC) 0.01 0.31 97%
Carbon Monoxide (CO) 1.0 4.2 76%
Nitrous Oxides (NOx) 0.02 0.6 97%
Particulate Matter (PM) 0.01 0.10 90%
Notes:
  • Standards for light-duty trucks are less stringent in certain cases under Tier 1 standards. The same Clean Car Campaign-SULEV Standard applies to both passenger cars and light-trucks.
  • Reductions based on a simple comparison of emissions standards for light-duty automobiles. SULEV standards are based on a 120,000 mile lifetime instead of a 100,000 mile lifetime for Tier 1 standards.
  • Achieving the full benefit of SULEV emissions control technologies requires use of low-sulfur fuel, which is required in California but not yet available nationwide. Nevertheless, a vehicle that meets the SULEV standard still will be cleaner than an average vehicle. Since most vehicles stay on the road for many years, its emissions performance will improve as low-sulfur fuel is phased in starting in 2004 under the new fuel quality standards that EPA has proposed under Tier 2.



Modern engine controls and improved catalyst design make these further emission reductions one of the cheapest pollution control options available to society. The technologies to reach the SULEV standard are further refinements to existing technologies. Achieving the full benefit of SULEV emissions control technologies, however, requires the use of low-sulfur fuel. At this time, low-sulfur gasoline is only required in California, and is not yet available nationwide. Nevertheless, substantial emission benefits are expected from SULEV technology even when they are not fueled on relatively clean, lower-sulfur gasoline. Furthermore, SULEV-certified vehicles outside of California will likely be able to take full advantage of their advanced control technologies when lower-sulfur gasoline is required nationally starting in 2004 as part of the EPA's proposed Tier 2 program. However, because the effects of sulfur can vary by design, we also are requesting manufacturers provide the campaign with data demonstrating substantial emissions reductions when operating with average nationwide gasoline.

The first SULEV-certified vehicles are already coming to the market in California. Honda, for example, has announced that they will offer SULEV-certified vehicles in California for MY2000. Toyota has stated that the Prius hybrid car will aslo meet the SULEV standard when it comes to market in mid-2000. Nissan's MY2000 Sentra has been certified as PZEV (Partial credit for Zero Emissions Vehicle), which vehicles (i.e., partial credit for zero emissions vehicle) in California for MY2000. Toyota exceeds the SULEV standard. The Clean Car Standard challenges automakers to offer SULEV-certified vehicles nationally, thus improving air quality and reducing human health risks across the country.



3. Clean manufacturing practices that achieve superior environmental performance in the vehicle's manufacturer and use of non-toxic recyclable materials, to include:

  1. Best-in-class painting/coating practices;
  2. Elimination of heavy metals and other substances of concern; and
  3. Design for recyclability and maximum use of recycled materials.

a. Best-in-class painting/coating practices

A vehicle manufacturer must demonstrate auto body coating practices which achieve the following level of VOC releases: 2 lbs./vehicle, or less.


Painting and coating of automobiles currently results in significant VOC emissions. It is also a highly energy intensive manufacturing process. Coating practices are a useful indicator of manufacturing "greenness" because they have important local health impacts and there is adequate publicly available data to base comparisons between facilities.

Our vehicle standard for coating practices has been developed by surveying the actual environmental performance of existing auto paint shops globally, as well as evaluating the performance of emerging coatings technologies. For example, DaimlerChrysler has established an emission level of approximately 0.5 lbs per vehicle at its Rastatt, Germany plant using an integrated, water-based powder-slurry paint system. For US based plants, emissions of approximately 4 lbs per vehicle is achieved in practice using current technology.

The standard is currently set at a level (2 lbs. VOC/vehicle) which is achievable in the near term, but also requires auto manufacturers to begin utilizing emerging coating technologies that result in significantly lower emissions. This level roughly corresponds to the newly proposed German painting/coating standards, which is currently being achieved or exceeded at several German auto plants. The standard is expressed as volatile organic compound (VOC) releases per vehicle in order to provide a standard which can be used internationally.

b. Elimination of heavy metals and other substances of concern

For a given vehicle, a manufacturer must track and report publicly on its progress in eliminating the following substances of concern, throughout the vehicle's life cycle:
      - great lakes persistent toxics (glpt's)
      - lead
      - mercury
      - cadmium
      - hexavalent chromium
      - PVC
      - CFC's
      - persistent bioaccumulative substances (pbt's)
      - chlorinated solvents
      - asbestos

In addition, for the following components or processes where known and cost-effective alternatives are available, a manufacturer should demonstrate complete elimination:
      - lead-free electrocoat (auto body anti-corrosion coatings)
      - mercury-free lighting/switches
      - PVC-free instrument panels, interiors, and undercoating
      - CFC-free cooling system
      - asbestos-free friction materials and engine gaskets

A number of substances of concern have been targeted for elimination or reduction by auto companies and governments. For example, a voluntary agreement between auto makers and the State of Michigan targeted 65 persistent toxic substances of concern to the Great Lakes. More recently, the European Commission has targeted toxic heavy metals and PVC -- substances that are of concern for "End of Life Vehicles." In a Proposed Directive on environmentally friendly handling of End of Life Vehicles, the Commission has recommended phase-outs of lead, mercury, cadmium and hexavalent chromium from such vehicles, with the possible addition of the plastic PVC. Other important international agreements have also targeted the phase-out of substances such as: CFC's, chlorinated solvents, and asbestos. Many companies are well on their way toward the elimination of such substances from their products and production processes.

In accordance with these international efforts, we have established a vehicle standard that requires the manufacturer to track and report publicly on its progress in eliminating substances of concern from manufacturing processes throughout a vehicle's life cycle. We also require complete elimination of such substances in cases where cost-effective alternatives are available.

c. Design for recyclability and maximize use of recycled materials

Reusability or Recyclability
The manufacturer must demonstrate that the vehicle is 80% by weight reusable or recyclable.


Reusable means that the part is customarily removed from the car before shredding and used as is or remanufactured for reuse.

Recyclable means the material is customarily recycled before or after shredding by separating the material and reprocessing it into usable materials for automotive or other applications. Combustion of a material for energy recovery is NOT considered recycling for purposes of this requirement.


Although a significant portion of the automobile (primarily the metal fraction) is now routinely reused or recycled, the sheer number of vehicles scrapped results in about 2.5 to 3.0 million tons of auto shredder residue (ASR) being disposed of in solid waste landfills each year in the U.S. This residue often contains heavy metals and other toxic chemicals which can leach into ground water or surface water. Furthermore, the disposal of this material, comprised mostly of plastics, rubber, fabric, and glass, represents a tremendous waste of resources. Faced with a shortage of landfill disposal capacity, several European countries, such as Sweden and the Netherlands, have mandated Extended Producer Responsibility for automotive manufacturers for end-of-life vehicles so that they have a strong incentive to increase recycling. The Dutch end-of-life vehicle recycling program claims that it is already achieving recycling rates of 86% by weight of vehicles processed. Automakers have set high goals for vehicle recyclability. Toyota claims that is has already achieved 85% recyclability and plans to increase recyclability to 90% by 2000. General Motors has the goal of 90% recyclability by 2001, and DaimlerChryslers goal is 85% recyclability by 2002. The European Commission has proposed a new directive, which will likely be adopted, which mandates minimum reuse and recycling percentages by certain dates. The first requirement would be for new vehicles to be 80% by weight reusable and recyclable by 2006. Under this draft, recycling does not include incineration of shredder residue. German auto manufacturers, including U.S. companies, have agreed to an 85% goal in Germany to be implemented by 2002, but in Germany incineration with energy recovery can be used to meet the goal. The Japanese government also has an 85% reuse and recycling goal by 2002. Based upon these agreements and goals in the automobile industry, and based upon the technical feasibility of increasing recycling, we have established the interim green vehicle standard of 80% reusability or recyclability.

Recycled Material Content
The manufacturer must demonstrate that the vehicle contains the following levels of recycled content:
      - 20% recycled content for polymer parts
      - 20% recycled content for aluminum
      - 30% recycled content for ferrous metals


For purposes of this requirement recycled content means a combination of post-industrial and post-consumer recycle material. The manufacturer must report on the percentage of recycled content which is post-industrial versus post-consumer.

Using recycled materials in building automobiles is an important means of closing the loop on automobile materials from end-of-life vehicles and also creates markets for recycling materials from other end-of-life products. Using recycled materials also reduces use of raw materials and energy and reduces pollution in the production of materials for automotive use. At least two U.S. companies, Ford and DaimlerChrysler, have set public goals for recycled content of materials used in building their cars. DaimlerChrysler, for instance, will require suppliers to provide 20% recycled content for plastic parts by 2000. The above recycled content levels are comparable to the requirements adopted by these companies.

Producer Responsibility
The manufacturer must demonstrate that it has a program for designing cars to enhance reuse and recycling and that it has produced a disassembly manual which is available to dismantlers and automotive recyclers for the model in question.


Some form of producer responsibility for end-of-life vehicles will be necessary to increase reuse and recycling rates and improve the environmental performance of dismantlers and shredders. European Extended Producer Responsibility legislation and agreements have placed a financial responsibility on producers to ensure that the last owner can turn the vehicle over for reuse and recycling without incurring any cost. In the United States the current level of reuse and recycling has been achieved through a market-based infrastructure which accepts end-of-life vehicles typically without charge to the last owner. Whether higher levels of reuse and recycling and improved environmental performance of dismantlers and shredders can be achieved in the United States without jeopardizing the positive economic value of end-of-life vehicles has yet to be demonstrated. U.S. manufacturers have instituted programs for designing cars to enhance reuse and recycling and have conducted research programs to improve the dismantling of vehicles for reuse and recycling. The proposed European Union Directive would mandate that manufacturers have such programs and that they provide dismantling manuals for each car. These basic elements of producer responsibility form the basis for the standard for producer responsibility.

Contact the Pollution Prevention Alliance at ppa@environmentaldefense.org.

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