Høringssvar fra Det Økologiske Råd til EU-Kommissions forslag til en forordning om CO2 emissioner fra lette varebiler og minibusser
Klima- og Energiministeriet
Att. Lars Hasselager Olsen
1256 København K
The Danish Ecological Council find the proposal from the Commission unsatisfying, as it fails to deliver substantial short term as well as long term goals for CO2 reduction from LCVs.
A central point of this proposal is the postponement of full compliance of the 175 g/km from manufacturers. This has been postponed from 2012 to 2016 primarily because of demands from the car industry, at the expense of the main aim of the legislation, which are the 20%-30 % CO2 reduction targets in 2020.
The potential for long and short term reduction of CO2 emissions are far greater if the target year for full compliance, is set at 2013 rather than 2016. Postponing the targets for LCVs will be a step in the wrong direction and could potentially upset the long term reduction targets. No arguments for the opposite have been presented in the Commission’s proposal. The impact of postponing the 175 g/km to 2016 has not been assessed by the Commission in the proposal’s impact assessment.
The original long term target of 135 g CO2/km is not clearly stated as a part of this proposal. The uncertainty around the long term target, as stated in the proposal this target now varies from 125-160 g/km, means this legislation does not provide conditions for long term planning for car manufacturers. To avoid further uncertainties about the CO2 reduction targets it is very important that the final legislation contains legally binding proposals for a 175 g/km target for 2012, and a 125 g/km or at the very most 135 g/km long term target for 2020.
There is a lot of uncertainty surrounding the omission of N2 vehicles, in accordance with “Council Directive 70/156/EEC of 6 February 1970”. This could mean that a large number of minibuses (with more than 8 seats) would not be included in this proposal, the extent of the actual number of vehicles in the N2 category is not clear. It is very important to have reliable knowledge about how many vehicles that are left out of this proposal as a result of omitting the N2 category, as this could mean that an undesirable large number of minibuses wouldn’t face CO2 reduction demands.
The most cost-effective short term reduction potential lies with limiting the speed of LCVs. The Commission has previously stated that this is an important issue, and the speed limiter would contribute to CO2 reduction as well as road safety. This means that LCVs should be on level terms with other commercial vehicles, such as lorries, which have a legal speed limit. Adding a speed limit to the proposal would strengthen the CO2 reduction potential substantially, as well as contributing to road safety.
This leads to four main points when assessing the proposal:
The choice to follow the car manufacturer’s demands should not be at the expense of EU’s CO2 reduction targets
The final legislation must contain clear and legally binding short term and long term targets, for 2012 and 2020
The consequences of omitting N2 vehicles from the proposal must be determined
Speed limits should be introduced as a part of the effort to reduce CO2 from LCVs