The document discusses the need for an alternative approach to Clean Air Zones to effectively tackle vehicle emissions and improve air quality. It notes that while new engine technologies have reduced NOx emissions, the large number of older, more polluting vehicles on roads means air quality issues will continue unless these vehicles are addressed. Measuring in-cabin pollution shows drivers face significant exposure, especially when behind older diesel vehicles. The document proposes using an independent AIR Index rating system based on on-road testing to identify highly polluting vehicles, which could help create more effective and fair policies to improve air quality and public health.

1. Hidden pollution exposure
inside the vehicle cabin
Why an alternative approach to Clean Air Zones is
required to achieve good air quality
Nick Molden, Co-Founder AIR
IAQM Routes to Clean Air 17 September 2019

2. Perceptions in September 2019 include…
 New engine technology and RDE fixed NOx
 City policy actions are quickly resolving air quality breaches
 Citizens and politicians will continue to support these policies
 We can move on to other things
…but is this correct?

3. But the installed base of dirty vehicles is exposing drivers…
 Ambient particle number in the Europe is typically 3x Los Angeles
 PN concentrations in the cabin can be double outside or more
 Tends to correlate with NO2 exposures
 Peak exposures are when driving behind older diesel
 Vehicle ventilation systems are unregulated and often give little protection
…unless this is tackled the health effects will continue

4. Pollution In-cabin Measurement System…
…PN (15nm), CO2, CO, NO2

5. The health and legal background…
• “…each increase of 10 micrograms per cubic meter in annual exposure to PM2.5 … was
associated with an increase in all-cause mortality of 7.3%...” – New England Journal of
Medicine, 2017
• “…ultrafine PM which comprises the smallest fraction of fine PM … may be
disproportionately toxic…” – Atmospheric Environment, 2014
• Background CO2 ~400ppm; measured background around roads 450-500ppm
• Cognitive impairment starts around 1000ppm
• CO2 emitted as “greenhouse gas” becomes noxious pollutant in confined space
• Many vehicles count as workplaces and are subject to legal or regulatory criteria
•

6. Particle infiltration…
0
50000
100000
150000
200000
250000
1
71
141
211
281
351
421
491
561
631
701
771
841
911
981
1051
1121
1191
1261
1331
1401
1471
1541
1611
1681
1751
1821
1891
1961
2031
2101
2171
2241
2311
2381
2451
2521
2591
2661
2731
2801
2871
2941
3011
3081
3151
3221
3291
3361
3431
3501
3571
3641
3711
3781
3851
3921
3991
4061
Particlenumberconcentration,#/cm3
Time, seconds
Inside vehicle Outside vehicle
Recirculationon Recirculationoff

7. Carbon dioxide build-up…
0
500
1000
1500
2000
2500
3000
1
106
211
316
421
526
631
736
841
946
1051
1156
1261
1366
1471
1576
1681
1786
1891
1996
2101
2206
2311
2416
2521
2626
2731
2836
2941
3046
3151
3256
3361
3466
3571
3676
3781
3886
3991
4096
4201
4306
4411
4516
In-cabinCO2concentration,ppm
Time, seconds
Recirculationon Recirculationoff
Cognitive impairment

8. New engine technology and RDE fixed for NOx?
EC and car makers have successfully introduced RDE making on-road emissions clean...
BUT car buyers remain unsure about diesel and are buying higher CO2-emitting gasoline
cars. Average CO2 emissions from new car sales have risen 2.4 g/km since 2017
44%
36% 32%
0
10
20
30
40
50
2017 2018 Q1 2019
Diesel Share (EU 27)*
* Sources: JATO and ACEA

9. RDE has arrived but there is a huge EU parc of 270 million vehicles to cleanse.
Progress will be too slow because RDE can’t replace older technology quickly enough
City policy actions are quickly resolving air quality breaches?
Sources: ACEA, EC (GEAR), Euronext, NHTSA and analysis
+ 14
- 6
270 278
5%
RDE
2025
parc
2020
parc
2019
parc
new
RDE
ELV 318
25%
RDE
• After 10 years only ~30% of cars are
scrapped (End of Life Vehicles, ELV)
• ~70% stay on the road
• 2016 ~14 million Euro 6 registered
• 2026 ~10 million still in use…

10. The German experience: Banning Euro 4 & Euro 5 diesel cars
AIR Index could be used EU-wide under CWA17379
• Court imposed Euro 4 & 5 bans (2019)
• Effective solution using on-road NOx
emissions <270 mg/km
• Proof required by independent vehicle
testing (also enables retrofit policy)
• Euro 6 excluded
The Guardian
City policy actions are quickly resolving air quality breaches?

11. Citizens and politicians will continue to support these policies?
If (when) air quality fails to improve with Euro-based policies, then a high risk of..
City authorities (and voters) may take draconian action when air quality fails to improve
• ICE technology bans in cities
• ICE vehicle owners left with cars they
cannot use – vehicle values collapse
• Voter anger and second loss of trust
(after Dieselgate) could be final straw
Reuters

12. Citizens and politicians will continue to support these policies?
Independent, trusted information can inform effective policies (many solutions)...
The AIR index provides standardisation and simplicity
• Clean Air Zones/Low
Emission Zones
(CAZ/ULEZ)
• Data-based policy using
on-road emissions
• Scrappage schemes
• Retrofit programmes Fleet Europe Reuters
What Car?

13. We can move on to other things?
We cannot ignore the actual emissions from modern (pre-RDE) cars on our streets…
The AIR Index differentiates where Euro standards do not
Make Model Year Fuel Type
Official NOx
limit
Actual NOx
Emissions
AIR Index
Rating
Land Rover Discovery 3.0 TD6 2018 Diesel 80 mg/km 33 mg/km A
Nissan Qashqai 1.2 DiG-T 2017 Petrol 60 mg/km 137 mg/km B
MINI Cooper S 3dr 2.0 d 2015 Diesel 80 mg/km 231 mg/km C
Dacia Duster 1.5 DCI 2018 Diesel 80 mg/km 422 mg/km D
Ford Focus 1.5 TDCI 2017 Diesel 80 mg/km 429 mg/km D
Renault Clio 1.5 DCI 2017 Diesel 80 mg/km 651 mg/km E

14. Policy: Euro standards
Restrictions: Can still pay to enter
NOx Reduction: 27% v pre-ULEZ1
ULEZ, London: free for Euro 4 (petrol) and Euro 6 (diesel) cars: 120,000/day
Today Enhancement with the AIR Index
Results will be slow and disappointing; massive boost using AIR Index
CEN CWA17379
Restrict access for ‘D’ and ‘E’
89% v pre-ULEZ1
1 Emissions Analytics estimate
City policy actions are quickly resolving air quality breaches?

15. We can move on to other things?
The NOx issue is not going away for the industry or policy makers
Things will only move on when trust returns
Bloomberg BBCForbes

16. Without the AIR Index, a plausible scenario is...
 CAZs are not sufficient to achieve air quality compliance
 Client Earth and other NGOs persist
 Drip-drip of further “cheat” revelations
 Consumer class-action lawsuits
 Cities tighten restrictions further: at least all pre-RDE diesels, if not more
…AIR Index draws an independent and credible line

17. To be politically palatable the solution must be fair…
 Ambient air pollution disproportionately affects the less well off
 They are more likely to have a high-emitting vehicle
 Are least likely to be able to afford to upgrade, especially to an electric vehicle
 Any taxpayer help can be concentrated on a smaller group of people in need of help
…AIR Index makes this possible

18. AIR Index is also protection from an unattractive outcome…
 Cities do not have to restrict mobility any more than is necessary
 Car makers do not take a hit on genuinely clean diesels
 Consumers can stop worrying
… And finally the Dieselgate spiral can end

19. Allow Independent Road-testing (AIR)’s core mission
‘To help reduce the negative impacts of vehicle emissions
in the short and long term.’
Our initial focus is to enable NOx solutions for today and into the future
Implementation commenced:
1. Comparative, realistic and repeatable CO2 data to prevent ‘Petrolgate’
2. Cabin air quality and health exposure ratings that can be trusted

20. Nick Molden
Chief Executive Officer
Emissions Analytics Ltd
nick@emissionsanalytics.com
+44 (0) 20 7193 0489
+44 (0) 7765 105902