E024 - Nick Molden from Emissions Analytics

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So welcome to the Green Element Podcast. Thank you, Nick, for joining us. Well, why don't we start off with if you tell us a bit about your business and what you're trying to achieve through your business, please.

Yes, so my business, I was the— I founded Emissions Analytics back in 2011, and it was— the motivation was observing that most of the official data initially focusing on fuel economy, so MPG, but also emissions were very misleading. They seriously underestimated real-world emissions and overestimated real-world MPG. And rather than just doing a one-off study and publishing an article and leaving it there, what I was interested in is whether you could create a a parallel system, okay, what the official system should have been. So what was it? Was it possible to test lots of vehicles for their real-world emissions and publish them for the general public and fleets and business and even manufacturers to use? And we considered a number of different types of technology for doing measurement and business models to be able to finance it. But we decided in the end on something called PEMS, which is Portable Emissions Measurement System. And it's essentially a— it's a gas analyzer that you strap on a car and you sniff what comes out of the tailpipe. You sniff what comes out very accurately and second by second, which gives you a very detailed picture of the real-world performance as a car drives along on the public highway. In terms of the technology of it, it is very similar to what you find in a laboratory. It's just packaged up into a smallish box which can go inside any type of vehicle. And so we bought some equipment, hired some people, and got testing and decided, you know, the truth's in the data. You know, that's— I'm a great believer in empirical data leads to then good decisions. And my training is as an economist. And, you know, what I was just saying, that the market was failing terribly because of this bad data, and people were buying the wrong cars for their purpose, and manufacturers were building the wrong cars, and this needed to be put right. I did not expect something of the dramatic shape and size of Dieselgate, but essentially that was the point that marked the end for these very convenient but deeply misleading official numbers, and it's really now opened up, you know, the whole field of real-world emissions. And so our business is centered on that, and we're expanding in terms of testing more vehicles, testing more pollutants in more countries, and that's our plan for the coming years.

So how do you choose which vehicles you want to test? Do you just choose the most popular ones that are sold and work down from there, or—

Well, firstly, we try and test as many as we can get our hands on, and we're roughly testing about 300 per year. So it's a very large program. Put it in context, the Environmental Protection Agency in the US runs a real-world program and they test about 150 a year. So, you know, so our numbers are higher, but Our primary sampling method is new vehicles as they're launched. So whether they're big sellers or small sellers, we have a range across that and a range across 35 different manufacturers, I think we've tested so far. But really, we're largely reactive to things being launched. But what that means is that we are testing things as they're brand new and come to the market. So our data is right up to date.

I've got so many questions, I don't even know where to start. I actually looked up my vehicle, and you've actually got it, a VW Transporter. We converted it into a campervan, and it came out as A++. And I noticed that some of them are As and some of them are A+s.

Is that a good sign, or like, what should we be looking for when we go on and look up Can I ask, was that for the NOx emissions on the EQA rating, or was it one of the other ratings?

Oh, now you're asking.

The reason I ask is because I'm assuming that campervan is a diesel?

Yes, it is.

Okay, so now, well, you in a way hit right to the heart of the point, is that Whether or not some— let's assume you're talking about the NOx rating.

Yeah.

At the moment, what you've got is diesel vehicles, which everyone thinks that they're all dirty and would be getting, I don't know, F, G, and H ratings on our scale. Actually, in amongst the dirty ones are hiding some really clean ones. So there's now a at least 30, maybe now 40 diesel vehicles that have got an A rating or better for NOx.

Right.

And that's the significance of, you know, really biggest, most relevant current significance is that at the time that cities are looking to sort of do pretty draconian bans on diesels and governments are certainly setting policies which are, even though they say it's technology neutral, are looking to squeeze diesel out of the market. It's just at the moment the manufacturers are actually bringing forward some very clean diesels, and some of which are cleaner than the equivalent petrol vehicle.

Right.

But if you interviewed 100 people on the street, there would be not very many people who would appreciate this, but it is true. And actually taking it even further than that, so let's say the diesel vehicle has equivalent NOx emissions to a petrol, If you then look at CO2, well, the diesel will have about 18% less CO2 than the petrol. It will have about 3 quarters less particles than the petrol. And it will have lower carbon monoxide than the petrol as well, almost certainly. So we're now in a situation where there are some, and it is a minority, I hasten to add, but there are a good handful now of diesels out there which are probably better in all material respects than the equivalent petrol, yet people have abandoned buying diesels in large numbers and most of them have switched back to buying petrols. So the consequence of Dieselgate and the policy reaction to it has been to make air quality worse and make greenhouse gas emissions worse.

Right.

Worse than they otherwise should be.

So why is it that Joe Public, and I put myself into this category, think diesel is dirtier? Because originally and initially diesel was brought in, it was cheaper because there's less refinery, there's less of a refinery process that goes into it, and therefore It's, in my view, and it sounds like it's wrong, it's dirtier. So what— how is this? Is it because they've been able to change and manipulate the fumes that come out of it and made it less clean or more clean?

Well, yes. So what— so diesel's— the reason diesel was incentivized in the first place is that it is about Like for like, 25% more efficient, so better MPG than petrol, and about 18% less CO2 than petrol. So when the then Labour government was really pushing the climate change agenda, Mm-hmm. a big increase in the penetration of diesel vehicles was seen as a way of rapidly and significantly reducing our CO2 emissions. And actually, that was actually good thinking. It was a good rationale. The problem was the air quality side of it, and diesel, if left— if untreated, will emit significantly more nitrogen oxides than petrol, which is a local air pollutant which leads to health problems. And the European regulations that were meant to guard and make sure that vehicles were low NOx, which are called the Euro stages. So we're currently Euro 6, and Euro 5 before that, which ended in 2015. They were things which were meant to say, right, NOx will be very low and they need to meet this standard. The problem was due to the incestuous way that the regulators and the OEMs are in Europe, they drafted the regulations in such a way as they were full of loopholes.

When you say OEM, do you mean like VW, Ford?

Yeah, the car manufacturers. So they're far, far too close to each other in Europe. And so it created a series of regulations that sounded great on the surface of it, but contained all sorts of perfectly legal loopholes, which meant you could technically meet the Euro standard, but when you drove the car on the road, the NOx emissions were much, much higher. And that's what— that was going on for years and years and years. I mean, we were saying, hey, there's a problem here, but the official— but this carried on until Dieselgate, creating these wonderful-sounding clean vehicles which in practice they just weren't. Now, why did manufacturers do that? They did that essentially to save money, because to put the technology on the car to get the NOx down, is expensive. They can do it, but it's expensive. So if they can avoid doing it by exploiting a loophole, they did it, and they did it. Unlike in America where they didn't have the loopholes and all the diesels were perfectly clean, except the VW ones where they actually broke the law.

Oh, interesting.

Yeah, so I mean, VW, as far as anyone can really tell us, they have not broken the law in Europe in the way that they broke it in the United States.

And so that's the reason why the fine was so much more in the US than it was in Europe.

Yes, and the fine in Europe, to my knowledge, it's not been disclosed what the fine has been for, what wrongdoing the fine has been for. So my take on it is that they've been beaten up behind the bike sheds and told to cough up some money so we governments can say we fined you. But it's either, you know, they haven't published any real details as to what the infraction is meant to have been. I suspect there's probably some technical paperwork infraction that has been found. So maybe there is a technical non-compliance, but it is very, very different from the US, which was a very significant and clear-cut violation, which is why it's cost them almost $30 billion to put right. But they're not actually physically paying a fine.

are they in the US? They're actually being asked to put money into the electrical car infrastructure.

I think a small proportion of it is actually a monetary fine, but you're absolutely right, they're being forced to fund the development of an electricity charging infrastructure, which is what the US does in previous infractions by other people. They get the miscreant to pay up and use that to fund sort of future development of the transportation industry.

How forward-thinking is that? I mean, what a forward-thinking way to do things.

Yeah, absolutely, absolutely. I mean, it was made easier by the fact that VW confessed in the US, so it was clear-cut that they'd done something wrong. And that's why actually the settlements happened quite quickly. They were very expensive, but they were quick and clean. And most of the legal action is out of the way in the US. The one that rumbles on more is in Europe because it's all messy and unclear whether they've done anything wrong. But anyway, the point being that the European regulations, due to this incestuous relationship, were created with these loopholes which they then used, which were meaning that the cars on the road were actually dirty despite being legal. And this is not a small problem. If we look at it, there are approximately 40 million of these diesel vehicles that are over-emitting on the roads of Europe, about 8 million of which are in the UK. That is one of the big reasons why cities are missing their air quality targets.

Yeah.

You know, that's a large number of vehicles. It's also the reason that everyone is scared of actually tackling the problem, because putting right 40 million dirty diesel vehicles, which, as you said, have been sold to people in good faith and have been— in fact, they've been positively encouraged to buy them—

Hmm.

But suddenly putting that— having to put that right, it is a big argument as to who should foot the bill. And because the manufacturers are not— have not done anything technically legally wrong, it's proving very hard for the governments to get them to fund it. So there's currently a big battle going on as to who should pay to clean up these 40 million vehicles.

Mm-hmm.

And so, yeah, so that's the nature of the problem. So, but diesels, if you do deploy the aftertreatment system correctly, like happened in the US on BMWs, on Mercedes, on Chevrolets, they can be very, very clean. It comes at a bit of a price. So that is why diesels are slightly more expensive than the equivalent petrol. So to buy, they're slightly more expensive, but then you get the 25% fuel economy advantage. So it pays you back if you do— I think even if you do average mileage, it pays back quite quickly. But why does everyone think all diesels are dirty? Well, it is the it is Dieselgate and the reaction to it from policymakers which has led to this blanket demonization of diesel, when actually the truth of it is, yes, there are a lot of dirty ones out there, but there are some clean ones as well. And don't tarnish a technology for what actually is regulatory failure.

Now, I'm going to ask the next question kind of Having spoken to Emma, who had spoken to you before, but the— I want to go out and buy a hybrid petrol vehicle. What are your thoughts on that? So there's a lot of vehicles out there now that you can— you have all the batteries and you can charge them up and you can drive around the city for 30 miles an hour or until the battery goes down and then you switch over to petrol. Is that a good thing?

So are you specifically talking a plug-in hybrid that you're looking at?

Yeah, plug-in hybrid.

Plug-in hybrid, okay. So plug-in hybrids, so they're one of those things which on the surface of it sound like the best of both worlds, and it is true that they probably are the best of both worlds, but actually for a fairly narrow usage case. They're actually— they turn very rapidly being into the— being the worst of all worlds if you don't— if you use them in a different way. So if you— the problem with the battery is, so it'll only take you 10, 20 miles, something like that, and then after that and you're running on the engine. Firstly, the engine typically is typically a downsized engine, so you'll then have a small little engine trying to power quite a reasonably large car, and that will be fundamentally inefficient. Plus you've got this battery which is heavy, so you're carrying around a dead weight, which makes that even worse. So you go very rapidly from the first 20 miles on battery only, which is virtually emissions-free and efficient, to then something which is much less efficient than if you just got a normal car. So What's crucial is how— what are the pattern of journeys that you drive? If you drive lots of short journeys and you have the opportunity to charge up in between, then it probably is a good option.

Hmm.

If you actually are driving longer journeys and/or you don't have chance to charge it up every time, then it can be actually a lot worse than going for, say, one of these very clean diesel vehicles. And the thing which— the added thing which is a bit of a bizarre observation is that actually many of the people who've bought these plug-in hybrids have been incentivized to deliberately not charge them up. So if you— so it's— so these have been particularly popular on company car fleets because of the low VED.

Right.

But many of those same companies pay for your fuel, but they don't pay for the extra electricity off your home electricity bill. So when you go home, you have a positive incentive not to charge your plug-in hybrid up.

I've not thought of it like that before.

And the government's well aware of this problem, and they're trying to figure out what to do. And I think that's partly behind why the plug-in tax grant thing was withdrawn recently, to much outcry. But essentially, I mean, is it abuse? I don't know. But it's an unintended consequence of the interaction of the VED with the company car rules. So it led to quite a lot of plug-in hybrids on the road that people deliberately don't charge up. But let's say you're well-behaved and you do charge up at every opportunity you can, then if you're doing lots of short journeys, actually it probably is a good choice.

Right.

You have very low tailpipe emissions. But if you're doing longer journeys, then it is probably— it will be worse on CO2 not CO2, CO, and particles than a diesel. So you need to think carefully. I would certainly say they are not a panacea. They are not some technology that's going to transform the car market. They're going to— I think they will work fine for a narrow market share. Traditional hybrids, non-plug-in hybrids, I think actually are, for generalized driving, is quite a good bet. And it is a viable alternative to the diesel vehicle in terms of comparable fuel economy, and particularly the Toyota Prius. The 4th generation Toyota Prius has really come on a lot in terms of its fuel economy. So you still need to pick quite carefully, but those traditional or full hybrids, as they're called, are quite a good bet if you like that type of vehicle. I mean, it does come with certain driving characteristics. If you like, you know, rapid acceleration and the low-down torque you get with a diesel, then a hybrid is not for you. But if you're not that style of driver, then it's a good choice.

What about— what about the— I used to own a Honda Civic iMA, and the reason why we bought it was we bought it a long time ago, and I now Longer own it, but it was— we bought it because we figured it was the most environmental thing at that time. It was when Toyota Prius were just coming out as well, and we were doing longer distances. So therefore I figured that because we're on the motorway more than doing shorter distances, it made more sense to have electric powering the acceleration as opposed to— and then just charging up as we were cruising. What's your thoughts on that technology?

Well, the one bit that is definitely beneficial is the regenerative braking. The Achilles heel of the internal combustion engine is that it operates at about 35% thermal efficiency, i.e., 2/3 of the heat is wasted, and quite a lot of that's in braking. So if you can recapture some of that energy by regenerative braking and then use that to help accelerate the vehicle, That's a very good approach. Now, we haven't tested that Civic iMA. I think it predates us testing.

Yeah, no, it's more about technology as a whole. I mean, yeah, I was looking at buying a petrol vehicle that was a hybrid. Is that a good way to go into it? That very, very, you know, completely combines both technologies. You're neither on pure electric, neither on pure petrol.

Yeah, I know. Well, that if you have something which is, you know, is effective regenerative braking and is using that for power boosting to keep the internal combustion engine at its most efficient spot, with the electricity then making up the difference when you need a burst, then that actually, that's very, that is very clever. And that's, you know, has now been over the generations of hybrids has been really refined and made better and better. So it is good, but I would caveat that it is— if you compare it to the best diesels on the market, actually the difference is it's not so dramatically different. It probably has now pulled ahead of diesels, but we're not talking twice as good as diesels.

No.

We're talking about incremental improvements. And so one observation to make about hybrids compared to diesels is if you take an average-sized diesel vehicle and drive it really hard, then, then it doesn't increase— that doesn't make your MPG that much worse. Whereas if you go and take a hybrid vehicle and drive it really hard, heavy acceleration up hills, then— the fuel economy will suffer badly. So you've got a sensitivity. So if you're a light-footed driver, then a hybrid would probably be a very good option. But don't then drive aggressively, because then the thing may well be worse than the alternative.

It's really not that black and white, is it, for everything?

There's nothing— in all this, there's nothing— there is no black and white. Even pure battery electric vehicles You have to— the 2 concerns are obviously one is the source of the electricity in the first place. Now, that is actually in pretty much all countries around the world, it's still better to have the EV unless you're doing it 100% on coal, then you will be better. on CO2. But again, the gap is not as big as you think when you take into account that upstream CO2. But the other thing to bear in mind with pure EVs is those vehicles are like-for-like heavier than internal combustion. The battery pack is very heavy, and tire wear is a function of vehicle weight. So you get more tire wear on an EV than you do on a traditional vehicle. And that is linked to this whole microplastics debate. So what happens, you get all this little tiny sort of vulcanized rubber beads or abrasions from the tires, which then gets washed into the drains, which then get washed into the sea and end up inside fish, which is the current worry. So if you've got— so you may have an EV which is, let's say, 20% lower CO2, but it has higher particles. So you probably overall, you could argue that it is still better for the environment in the round, but it's not as, you know, it's not so dramatically different. And I haven't mentioned lithium and cobalt. I don't, in a way, I don't really want to get into that. That's not—

We actually have that on another podcast, funnily enough. We've got a battery manufacturer that talks about that.

Yeah, well, I mean, it's one of those which has become a very emotional and charged debate as to, you know, the right and wrongs of digging up cobalt in the Democratic Republic of Congo. It's not something which is my particular area of specialty, so I'll leave it to others. So, but if you just look at it in the emission sense, so an EV will be better for CO2. But it'll be worse for particles. So choose your poison is my general thing. There's no clear and easy way out of this. This is a long-term thing for the industry to make their cars better and better year on year. And for the consumer, it's a question of informing yourself and making sure you're buying the cleanest vehicle for what you're going to do with it.

Yeah.

And you can make a big difference, you can make a huge difference as a consumer. If you buy the wrong vehicle, you can make a massive difference compared to buying the most suitable vehicle. And that's why it was so tragic that all the official figures turned out to be misleading in Europe, because it was misinforming people. And so people thought they were doing the right thing from an environmental point of view, but often they were doing exactly the wrong thing. And anyway, that's what motivated me in the first place to try and set this right.

Here's something that we could do. We could set up a questionnaire that asks a series of questions and then leads you down to end up with a car that suits you.

Oh yeah, exactly. I mean, that can definitely be done. Yeah, to say, you know, tell us Tell us how you drive, you know, what you need to— how much, you know, how big does your vehicle need to be? What's your driving style? What's the road mix that you run? Do you like running the AC all the time? We have all that sort of data that allows you to effectively— we can ingest— if you put telematics in your vehicle and then send us the details of how you've driven, we can model that through our data and say, actually, for your driving, the most suitable vehicle is X.

Right. Is that a service that you do offer?

We do do a service like that in America, where if you go on the motortrend.com website, you can choose your car and then you can tailor it by telling us about your road mix and driving style and congestion levels, and it'll take the headline MPG number And it'll give you your personalized MPG. It's called Equa MPG.

Right.

So it's only in the US market at the moment, but it works quite effectively. And it illustrates the point of if you change that driving style slider for a hybrid, it hugely affects the MPG. But if you do it on a 2-liter diesel, it has very little effect. So yes, but behind the scenes, you know, it can be done with using detailed telematics data if there's interest.

So if you've got the Audi A4 estates, you've got the VW Transporter 2-liter, you've got a VW Golf 2-liter, and the Škoda, whatever, Škoda Fabia You've got basically all the same engines. Are you going to get the same emissions coming out of the back, or is it absolutely different?

If you're talking about one of the relatively recent versions of those models, within the last 2 years, say, then you will get very similar levels of emissions— pollutant emissions, so NOx, CO, or particles. Very, very similar. They share the same aftertreatment systems. They have particle filters on them which are 99% effective. There'll be virtually no carbon monoxide because diesel generally doesn't produce it anyway. So where it will be different will be on MPG and CO2, but that will be largely a function of the weight of the vehicle.

Yeah, yeah, that makes sense. That's great. So what got you into this? How did you become— go from being an economist into understanding the emissions of vehicles?

Well, I see actually the lineage is quite close in that it is market failure, and that's what a lot of economics studies. But in practical terms, I mean, I was— I've done a lot of work in automotive data, in pricing, and over the years, and it was simply— it was a question which kept being raised by associates and friends saying, I just bought a car, the brochure said it was going to do 60 miles a gallon, I don't know what I'm doing wrong, I'm only getting 45, is it broken? Should I take it back to the garage? And when, you know, enough people had asked me this, I thought, I mean, there's something going on here, they can't all be broken. And also, whenever they took their car back to the garage, these friends would be fobbed off, or something cosmetic would be done to it. The car would be handed back and told there's nothing wrong with it, and they'd still be getting 45. So I smelt an issue there and thought— I tried to find data, tried to find data in the public domain, and very, very little. And so the only way to really bottom this out is to go and collect some primary data ourselves. very rapidly uncovered, you know, at the time it was 20-odd percent average difference on MPG, which then every year we were testing, that grew every year. It's now about 35% gap. But we measured NOx at the same time. And I mean, you know, we weren't expecting it. We weren't really focused on NOx. We didn't expect an issue. But when we started looking at our data, we found that the— 5 times exceedances on average. And then Dieselgate happened, which, you know, meant that those who tried to explain away the findings that we were getting and say, oh, this, you know, it's all perfectly explainable, nothing to see here, it's because how you drive, or it's because it's a bit cold, was proven to be actually it was industrial-scale legal cheating that was causing it. So yeah, so from that You know, why can't I get the MPG in the brochure? Led one step at a time to unearthing what was going on behind Dieselgate.

So when did you start doing what you're doing?

So we launched in— we started our first test in the summer of 2011.

Okay, so you've been going for quite a while now.

Yeah, and we've tested over 2,000 cars, vans, diggers, cranes, trucks. tractors, generators, barges. We've tested pretty much, pretty much anything that burns fossil fuel. We've stuck our equipment on and we built possibly the— I think it is the largest commercially available database worldwide of real-world emissions.

And you are largely in the US, or are you half and half US, It is—

in terms of our activity, I would say it's roughly a third, a third, a third. A third UK, a third Europe, and a third US. We have also just launched a joint venture in Korea as well, which is at a nascent stage. But yeah, UK was our original center, and then we branched out into Germany and the US.

And how do you get your funding?

Well, it's entirely privately funded through private shareholders, and we put all the data we gather into a database, and people can pay to subscribe. So if you want to know the detail behind our public ratings, you subscribe and pay money for that. You can also commission us to do testing. So those 2 revenue streams are what fund fund the EQUA program.

So who would you say tends to buy your data? What sort of companies would be ones who buy it?

Well, it's a wide range, actually. I mean, car manufacturers. I mean, so you do get sometimes the absurd thing that their PR departments are criticizing us publicly at the same time as their engineers are subscribing. But rationality is overrated. So manufacturers, governments, regulators have bought it. Some of the tier 1 suppliers have, but also interestingly financial institutions as well. So I mean, there's obviously a lot of money riding on what's the future of diesel as a technology, and should a whatever sovereign wealth fund, should they be keeping their investments in BMW or whoever it is, or should they be getting out because their profitability is going to fall. So actually, ours gives a sort of leading indicator of the share price performance of these companies that are exposed.

Just stay in, by the sounds of it. Keep buying those EV shares.

Well, yeah, well, there's a massive difference between the best and the worst manufacturers. So some of them are really clean on average, but others are still very dirty. Even today. And I mean, and it may come as a surprise, but one of the very cleanest manufacturers for their diesel vehicles in practice is Volkswagen.

Yeah, that doesn't— personally, that doesn't surprise me.

So, you know, it's how this can be is maybe a story for another day, but it is true. So really, you know, you could argue, right, you go long in the ones that are clean and you go short in the ones that are dirty, but then you've also got the overriding thing is actually diesel as a technology, is it going to be in practice outlawed by government and city regulations? That's— yeah, so there's a lot of— there's a lot of money riding on it, and so we provide data which allows then people to refine their investment decisions.

And do you— are you finding that the environment and sustainability as a whole is driving a lot of maybe subscriptions to your service or wanting to have a knowledge of what it is you're doing and understanding cars, or do you think it's purely financially driven?

I think the people who are using our ratings, the EQA Index ratings, are doing it for that motivation. So it's either private individuals or fleets wanting to do the right thing, wanting to take an environmental position.

Right.

From the subscriber side, I think it doesn't work quite like that. It's— the primary thing you're generally responding to is the regulations. So you want to see, you know, what our view of how compliant people's cars are. They want to know how good their technology is compared to their rivals' technology. They want, you know, they want to know if they've got a car which is a bit risky, a bit marginal for compliance, those sorts of things. So it doesn't— Whether or not in the background in their minds they have an environmental motivation, I don't know, but the primary motivation is to produce compliant cars that sell well, and that's what our data can help them with.

So what could our listeners do? They want to— if they want to buy a new car, where would you suggest they go? What would What sort of things should they think about? I mean, could they go to the American website and have a look at it, and will that give them an idea of the type of vehicle for the UK, or if you're not in the US as a listener?

So, well, we've got local sites in a lot of countries now. So if you're in the US, you go to usa.equindex.com, and you have all the ratings based on our US test program. If you go to just the regular www.equindex.com, you'll get to the UK data. But equally, there's fr.equindex.com for France. Italy has one. Spain, the Netherlands, Belgium, Poland all have localized in the local language version of our ratings. So I think from a buyer's point of view, whether you're a business buyer or a private buyer, go and do the research when you're doing. Do not trust the label that says Euro 6. When you see that in the brochure, think, actually, I really need to look it up on equindex.com to see what the reality is. It's been totally debased as a rating, Euro 6, and you should not trust it. You need to find out the real world. Go to our site and then you can get the real-world NOx, CO, and fuel economy and CO2, and gives you everything you need.

I wonder if Brexit happens, or when Brexit happens, depending on, you know, whatever, the legislation will change because we won't be governed by the EU. We will not be governed by the euro. emissions then?

Well, I think the answer is yes and no. I think the— I cannot believe that we will not suddenly create our own certification system, and we will not change from the European system to, say, the American system. It's not going to happen. So we will still use the European system for certification. Where it might diverge is in what's called surveillance. So governments are meant to basically do spot checking like America does to make sure no one's cheating. So random selection of vehicles every year, and then you test the vehicles and just make sure everyone's behaving themselves. Now, the European regulations set down a requirement for surveillance. If we're outside of that, Even if we— the cars are type approved, it's called the compliance, it's called type approved, type approved to the European system, we could take a different approach to surveillance. That might mean we, we do more surveillance or less surveillance. We might have a whole different framework of fines for people who are found cheating. That's, that's where the divergence will— may well come, but we're not going to diverge from the original certification. That would be— Okay, brilliant.

Well, Nick, thank you so much for your time today.

Pleasure.

It's been brilliant learning more about what cars to buy and, yeah, the whole thing about emissions and how it's not black and white.

Yeah, but also every individual can make a material difference if they buy well. That's, that's, and that's, that's a good thing. So people are not powerless. And through this information, you can then make a better decision and make a genuine impact on the environment. So I think that's something that everyone can go away and bear in mind when they're going shopping for their next car. But no, thank you very much for inviting me. It's been an interesting discussion. Thank you. 3 years after Dieselgate and the thing has very much not gone away and I'm expecting this issue to rumble for years and years to come.

Keep up the good work. Thank you so much for doing everything you're doing. No problem. Thank you.

Thank you. All right, great.

Cheers, Nick.

Okay, thanks all. Good to meet you. Okay, bye-bye.

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