BIC Submission to the draft Regulation Impact Statement (RIS) on its Heavy Vehicle Emission Standards for Cleaner Air [Euro VI]

This BIC submission supports Euro VI (conditional) early implementation dates and equivalent alternative standards.


On 26 February 2021, the BIC provided a submission to the Department of Infrastructure, Transport, Regional Development and Communications on its draft Regulation Impact Statement (RIS) on its Heavy Vehicle Emission Standards for Cleaner Air [Euro VI]. The Department in its draft RIS sought feedback from the heavy vehicle industries on whether and when Australia should adopt more stringent noxious emissions standards. This is not only to achieve a reduction in transport-related air pollution but to make sure that the Australian vehicle market keeps pace with technological developments in the global market and Australian transport operators have access to technology available in other markets.

The key implementation take-outs from the submission include:

  • implementation date for buses and coaches could be as early as 1 July 2023 for new manufactured buses and 1 July 2024 for existing models, but this would need to include an agreed implementation phase. The main issue being that the implementation phase would need to recognise exiting new bus stocks and the delays associated with fitting passenger seats to completed bus bodies.The BIC outlined in its submission that buses and coaches be allowed to be built and pre-plated “without seats”. Once the seats are fitted, the bus could then be fully and correctly planned in accordance with the final seating arrangements. Our submission outlined a number of ‘rules’ in which this could be achieved:
  • it is essential that the Euro VI ADR recognises the equivalent US or Japanese standards as alternatives. Similar to ADR 80/03, ADR 80/04 must also allow for equivalent US or Japanese standards as alternatives to Euro VI. A review of BIC supplier members of Japanese and US chassis and drivelines found that the acceptable alternative standards could be: Japanese: pPNLT OBD II (2017) and USA: US-EPA 13 to 17.
  • The net affect from overall costs when comparing Euro V with Euro VI is cost neutral when considering Euro VI:
    – uses less diesel
    – uses more urea
    – maintenance and replacement costs of DPFs (diesel particulate filters).
  • the supply of Urea or AdBlue is currently not regulated in any form by any government department. This lack of regulation is affecting the quality and consistency of urea supplied to market. Examples of suppliers selling AdBlue that is either watered down or made up of other additives, has been frequently raised by the BIC. The need to regulate the sale of urea is a known issue and although such regulation is needed, it is more likely that the per litre cost of regulated AdBlue will be higher than current market levels.

 

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