CPA Bulletin

www.cpa.uk.net CPA Bulletin > November 2024 17 Machinery with a rated engine power below 56kW Machinery below 56kW is not available at Stage IV. To comply with the minimum standards sites must therefore use emission Stage V machines at these engine sizes. Remember that machines below 37kW do not need to comply, so this only affects machines with a rated engine power between 37kW – 56kW. Generators Diesel generators are not available at Stages IIIB or IV. To comply with the minimum standards sites must therefore use emission Stage V generators. Stage V generators are often not compatible with long periods of low-loading, which can lead to exhaust blockages and asset damage. The Greater London Authority (GLA) expect sites and suppliers to consider power management technologies such as battery, flybrid, and load on demand, to overcome these challenges. Sites can apply for an exemption if they have tried but are unable to source/use a Stage V generator. In those cases sites and suppliers should be prepared to provide detailed justification why use of a Stage V generator is not possible. This will usually include: • What the generator is being used for, and any low loading challenges that apply. • Correspondence evidencing that a Stage V generator has been requested. • A statement from the supplier regarding their investment plans for Stage V and other low emission technologies, dated within the last 6 months. Retrofit Machines that do not meet the minimum standards can be retrofitted with exhaust emission abatement technology as an alternative means of complying with the NRMM LEZ. The retrofit product must be endorsed by the Energy Saving Trust NRMM certification scheme, and must reduce emissions to the equivalent of the required compliant emission Stage. Determining which retrofit product is suitable for your machine can become quite technical. Before purchasing and installing a retrofit, always check with the retrofit supplier what emission Stage the machine’s emission levels will now be equivalent to, and get that confirmed in writing. The retrofit supplier should provide a certificate of installation following fitment, stating what system has been fitted and what the resultant emission compliance levels are. When the machine is registered on the NRMM Register, this certificate must be uploaded alongside it. Labelling It is advisable for suppliers to add bespoke labels to an easily accessible/visible part of the machine, containing the EU Emission Stage and Emissions Type Approval Number. Statutory engine markings can be difficult to find, and do not clearly state the engine’s emission Stage, it is given as a code. Because of this, sites often struggle to assess machines for compliance and can spend a frustrating amount of time on this. Clear supplementary labelling often makes life easier for site and fleet managers, and can reduce the number of NRMM compliance queries you receive. There are some national labelling schemes that you can adopt, for example the CEA ECV labelling ( https://www.cesarscheme.org/ ecv.php ), or you can use your own labelling. Note that the original statutory engine markings must not be removed or obscured. Contact If you have any questions, comments or concerns that you would like to raise regarding the NRMM LEZ, please feel to contact CPA Decarbonisation & Sustainability Manager, Luis Bassett on email: luis @ cpa.uk.net Helpful links: Mayor of London NRMMWebsite & Register - https://www.london.gov.uk/programmes- and-strategies/environment-and-climate- change/pollution-and-air-quality/nrmm Cleaner Machinery (NRMM) Practical Guidance - https://www.london.gov. uk/sites/default/files/2024-05/NRMM- Practical-Guide-Accessible-May2024.pdf Energy Savings Trust Retrofit Accreditation Scheme technical guidance - https:// energysavingtrust.org.uk/service/non- road-mobile-machinery-certification/ DECARBONISATION & SUSTAINABILITY: 2 Exemptions There are currently two types of exemption that can be applied for: