The feasibility study carried out by TRL investigating the technical feasibility of Stage IV for narrow tractors (T2, C2 and T4.1) was published just before the Christmas holidays. While the report notes that the introduction of Stage IV comes with many challenges for manufacturers and will have a negative impact on farmers, it nonetheless concludes that it would not be necessary to make any further changes to the current timetable. Without such changes, Stage IV limits for narrow tractors are set to apply as of October 1, 2017.
CEMA strongly disagrees with the report's final conclusion and believes further adjustments to the introduction dates of Stage IV for narrow tractors remain of essential importance.
While the report states it is technically feasible to meet the Stage IV emission requirements, it notes that there will be some penalty for meeting Stage IV requirements. In particular, the report confirms that it will not be possible with future technologies to develop narrow tractors without some sort of penalty. The report believes such a penalty would soon be reduced again because of the competitive pressure on engine manufacturers. However, CEMA believes this penalty is imposed at the expense of farmers and manufacturers and therefore needs to be more carefully re-assessed and adjusted.
In the report, the environmental consequences regarding NOx emission limits are also calculated at great length. While the - admittedly minimal - adverse environemntal effect of a Stage IV delay is noted, other balancing evidence is not considered. Most importantly, the EU itself had noted in its 2014 report on Air Quality in Europe that NOx emissions is not a problem in rural areas (where narrow tractors are nealy exclusively used).
In the coming weeks, CEMA will provide detailed comments and develop an official reaction to the report. Later on, a meeting will be planned with the European Commission to give our feedback on the conclusions of the report and discuss potential next steps.
