At the end of 2015, the IAQM submitted evidence to an inquiry of the House of Commons Transport Select Committee, on Vehicle Type Approval. The committee’s inquiry is ongoing, but written submissions have been released online, so we are able to publish our evidence. The IAQM submission made several key points:
- The gap between type approval (TA) and real world NOx emissions has been known by the UK government since at least 2010 and well before then for CO2.
- For CO2 the gap has grown over the last decade and the reported values bear little relationship to reality. This misleads the consumer and fails to achieve climate change mitigation targets.
- The UK government lacks the expertise to effectively regulate a very technical industry. It may also lack the desire, as the industry has significant political influence as a major employer.
- The regulatory framework of many type approval authorities and technical service organisations, with the manufacturers funding the latter directly, is weak. The technology for measuring real driving emissions now exists, and should form a central plank of type approval. There is need for independent in-service surveillance, preferably undertaken by the government.
- An effective enforcement regime is required that withdraws TA from failing vehicles, with suitable compensation for the vehicle owner. Given the complexity of the issues, and the imbalance of knowledge, a strong enforcement system is needed.