Energi- Forsynings- og Klimaudvalget 2017-18
EFK Alm.del Bilag 137
Offentligt
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Impact Assessment on Heavy Duty Vehicles (HDV) CO
2
emission standards
Fields marked with * are mandatory.
Impact Assessment on Heavy Duty Vehicles (HDV) CO
2
emission
standards
The July 2016 Commission's strategy for low-emission mobility recalls that mobility is an essential
component of the shift to the low-carbon, circular economy needed for Europe to stay competitive and be
able to cater to the mobility needs of people and goods. The strategy set the ambition for the transport
sector to reduce greenhouse gas emissions at least by 60% compared to 1990 by mid-century and be
firmly on the path towards zero. Action on vehicles' fuel/CO
2
emission performance is one of the key
levers to tilt the transport sector in the right direction.
The 2030 climate and energy framework agreed by EU Heads of State and Government in October 2014
requires a 30% reduction in non-ETS sector GHG emissions by 2030 compared to 2005. Road transport
represents 1/3 of the non-ETS GHG emissions and heavy-duty vehicles contribute to about 1/4 of road
transport emissions and some 5% of total EU GHG emissions.
The May 2014 Strategy Communication on reducing HDV fuel consumption and CO
2
emissions (
COM
/2014/0285
) emphasises the importance of closing the knowledge gap regarding the CO
2
emissions of
lories and buses with a view to improving market transparency.
The July 2016 Strategy for low-emission mobility furthermore announced that there is a need to curb CO
2
emissions from HDVs.
On 11 May 2017 the Technical Committee for Motor Vehicles has approved under type approval legislation
a certification procedure for the determination of the CO
2
emissions and fuel consumption of new HDVs,
using the results from
VECTO simulations
, which has been developed by the European Commission
since 2010. HDV manufacturers will have to run VECTO at the end of the production line and declare
such information at the time of registration as of 2019.
On 31 May 2017, as part of the Europe on the Move set of initiatives, the Commission adopted a proposal
for the monitoring and reporting of such HDV CO
2
emissions and fuel consumption. The data collected
will be made publicly available by the European Environment Agency, starting in 2020 to cover data
monitored in 2019.
This
inception impact assessment
will look into different options for setting the first EU measures to
actively curb CO
2
emissions from HDVs, including CO
2
emission standards.
It should be noted that EU manufacturers account for some 40% of global production. Furthermore, other
parts of the world, such as the United States, China, Japan and Canada, have already introduced HDV
fuel economy standards, and some European manufacturers participate in these schemes.
For the purposes of the present consultation the term HDV should be understood as including (For the
definition of vehicle categories see
Directive (EC) 2007/46
, Annex II, part A):
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goods vehicles of categories N2 and N3 and
passenger vehicles of categories M2 and M3 and
all trailers of categories O3 and O4.
The Commission is carrying out this consultation in order to be properly informed by public opinion in
preparation for possible future legislative action in the area of CO
2
emissions from HDVs, the results of
which will be published in consolidated form.
Parts 1 to 5 of this consultation are intended to be completed by every respondent to the extent possible.
Part 6 is mainly intended for experts in the field but of course every respondent may complete it as he
wishes.
If data, other information or studies are available which are relevant to the assessment, these can be
submitted as part of a stakeholder's general comments or directly to the mail box.
1. General information about respondent
*
1.1. In what capacity are you completing this questionnaire?
As an individual / private person
X
Public authority
Academic/research institution
International organisation
Civil society organisation
Professional organisation
Private enterprise
Other
*
If other, please specify:
Text of 3 to 200 characters will be accepted
1.2. If private enterprise
*
1.2.1. Business sector
Individual vehicle manufacturer
Automotive component supplier
Vehicle fleet operator
Logistics operator
Customer/user of transport services
Consultancy
Research
Other industry
*
If other, please specify:
Text of 3 to 200 characters will be accepted
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1.2.2. Is your company an SME? (
What is an SME?
)
Yes - medium-sized enterprise (i.e. having less than 250 staff and/or turnover below €50m and/or
a balance sheet below €43m)
Yes - small enterprise (i.e. having less than 50 staff and/or turnover below €10m and/or a balance
sheet below €10m)
Yes - micro enterprise (i.e. having less than 10 staff and/or turnover below €2m and/or a balance
sheet below €2m)
No
I don’t know
1.3. If professional organisation
*
1.3.1. Please indicate the sectors your organisation represents
Vehicle manufacturers association
Automotive component suppliers association
Vehicle fleet operators association
Logistics operators association
Customers and users organisation
Labour rights organisation
Other organisation
*
If other, please specify:
Text of 3 to 200 characters will be accepted
*
1.3.2. Where are your member companies located?
Whole EU
Afghanistan
Åland Islands
Albania
Algeria
American Samoa
Andorra
Angola
Anguilla
Antarctica
Antigua and Barbuda
Argentina
Armenia
Aruba
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Australia
Austria
Azerbaijan
Bahamas
Bahrain
Bangladesh
Barbados
Belarus
Belgium
Belize
Benin
Bermuda
Bhutan
Bolivia
Bosnia and Herzegovina
Botswana
Bouvet Island
Brazil
British Indian Ocean Territory
British Virgin Islands
Brunei
Bulgaria
Burkina Faso
Burundi
Cambodia
Cameroon
Canada
Cape Verde
Cayman Islands
Central African Republic
Chad
Chile
China
Christmas Island
Clipperton
Cocos (Keeling) Islands
Colombia
Comoros
Congo
Cook Islands
Costa Rica
Côte d’Ivoire
Croatia
Cuba
Curaçao
Cyprus
4
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Czech Republic
Democratic Republic of the Congo
Denmark
Djibouti
Dominica
Dominican Republic
Ecuador
Egypt
El Salvador
Equatorial Guinea
Eritrea
Estonia
Ethiopia
Faeroe Islands
Falkland Islands
Fiji
Finland
France
French Guiana
French Polynesia
French Southern and Antarctic Lands
Gabon
Gambia
Georgia
Germany
Ghana
Gibraltar
Greece
Greenland
Grenada
Guadeloupe
Guam
Guatemala
Guernsey
Guinea
Guinea-Bissau
Guyana
Haiti
Heard Island and McDonald Islands
Honduras
Hong Kong
Hungary
Iceland
India
Indonesia
Iran
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Iraq
Ireland
Isle of Man
Israel
Italy
Jamaica
Japan
Jersey
Jordan
Kazakhstan
Kenya
Kiribati
Kuwait
Kyrgyzstan
Laos
Latvia
Lebanon
Lesotho
Liberia
Libya
Liechtenstein
Lithuania
Luxembourg
Macao
Macedonia
Madagascar
Malawi
Malaysia
Maldives
Mali
Malta
Marshall Islands
Martinique
Mauritania
Mauritius
Mayotte
Mexico
Micronesia
Moldova
Monaco
Mongolia
Montenegro
Montserrat
Morocco
Mozambique
Myanmar/Burma
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Namibia
Nauru
Nepal
Netherlands
New Caledonia
New Zealand
Nicaragua
Niger
Nigeria
Niue
Norfolk Island
North Korea
Northern Mariana Islands
Norway
Oman
Pakistan
Palau
Panama
Papua New Guinea
Paraguay
Peru
Philippines
Pitcairn Islands
Poland
Portugal
Puerto Rico
Qatar
Réunion
Romania
Russia
Rwanda
Saint Barthélemy
Saint Helena, Ascension and Tristan da Cunha
Saint Kitts and Nevis
Saint Lucia
Saint Martin
Saint Pierre and Miquelon
Saint Vincent and the Grenadines
Samoa
San Marino
São Tomé and Príncipe
Saudi Arabia
Senegal
Serbia
Seychelles
Sierra Leone
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Singapore
Sint Maarten
Slovakia
Slovenia
Solomon Islands
Somalia
South Africa
South Georgia and the South Sandwich Islands
South Korea
South Sudan
Spain
Sri Lanka
Sudan
Suriname
Svalbard and Jan Mayen
Swaziland
Sweden
Switzerland
Syria
Taiwan
Tajikistan
Tanzania
Thailand
the Holy See/Vatican City State
Timor-Leste
Togo
Tokelau
Tonga
Trinidad and Tobago
Tunisia
Turkey
Turkmenistan
Turks and Caicos Islands
Tuvalu
Uganda
Ukraine
United Arab Emirates
United Kingdom
United States
United States Minor Outlying Islands
Uruguay
US Virgin Islands
Uzbekistan
Vanuatu
Venezuela
Vietnam
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Wallis and Futuna
Western Sahara
Yemen
Zambia
Zimbabwe
1.4. If civil society organisation
*
If civil society organisation, please indicate your main area of focus:
200 character(s) maximum
*
1.5. Please give your name if replying as an individual/private person, otherwise give the name of your
organisation:
Text of 3 to 200 characters will be accepted
Danish Ministry of Energy, Utilities and Climate
1.6. If your organisation is registered in the
Transparency Register
, please give your Register ID number:
20 character(s) maximum
If your organisation is not registered, you can
register now
. Please note that contributions from
respondents who choose not to register will be processed as a separate category 'non-registered
organisations/business'.
*
1.7. Please give your country of residence/establishment:
Austria
Belgium
Bulgaria
Croatia
Cyprus
Czech Republic
Finland
France
Germany
Greece
Hungary
Ireland
Italy
Latvia
Lithuania
Luxembourg
Malta
Netherlands
Poland
Portugal
Romania
Slovakia
Slovenia
Spain
Sweden
United Kingdom
Iceland
Norway
Other
X
Denmark
Estonia
*
If other, please specify:
Text of 3 to 200 characters will be accepted
1.8. If your organisation is involved in the implementation of the HDV legislation, please indicate its role (e.
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1.8. If your organisation is involved in the implementation of the HDV legislation, please indicate its role (e.
g. manufacturer, system supplier, technical service,…):
200 character(s) maximum
*
1.9. Please indicate your preference for the publication of your response on the Commission’s website:
(Please note that regardless of the option chosen, your contribution may be subject to a request for access
to documents under
Regulation 1049/2001
on public access to European Parliament, Council and
Commission documents. In this case the request will be assessed against the conditions set out in the
Regulation and in accordance with applicable
data protection rules
.)
X
Under the name given:
I consent to publication of all information in my contribution and I declare that none of it is subject
to copyright restrictions that prevent publication
Anonymously:
I consent to publication of all information in my contribution and I declare that none of it is subject
to copyright restrictions that prevent publication
Questions
The questions below are based on the initial analysis carried out by the Commission and presented in its
Inception Impact Assessment to which you may refer for further background on each specific question.
Fuel consumption and CO
2
emissions of Heavy-Duty Vehicles' (HDVs) are treated together as they are
strongly correlated and proportional: both would be certified and monitored together.
2. Main problem to address
The following 3 key problems have been identified in the context of the Inception Impact Assessment
where more detailed information can be found. In your view, how important are the problems to be
addressed?
I
Very
important
Important
Somewhat
important
Not
important
don't
know/
no
views
Growing GHG emissions from the
heavy-duty vehicle sector
Increasing competitiveness
challenges for vehicle manufacturers
Transport operators and their
clients miss out on possible fuel
savings and reduced fuel bills
x
x
x
Are there other key problems to be addressed?
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Are there other key problems to be addressed?
200 character(s) maximum
3. The need for EU action
There is a single market for HDVs across the EU. If no EU action was taken to address the problem,
Member States might adopt individual approaches to reduce HDV CO
2
emissions, in order to achieve the
needed reductions for the non-ETS sector. In your view, what would be likely to happen without EU action?
Likely
Member States would individually implement legislation to reduce
HDV CO
2
emissions
Legislation introduced by individual Member States would lead to
market fragmentation and higher costs
Member States would have difficulty to achieve the necessary
reductions to meet EU climate goals
Neutral
Unlikely
x
x
x
Are there other potential effects?
200 character(s) maximum
4. Main policy objectives
The following 3 key policy objectives have been identified in the context of the Inception Impact
Assessment where more detailed information can be found.
1. Reduce the climate impact of HDVs in line with the requirements of EU climate policy and the 2030
climate and energy framework.
2. Contribute to the improvement of the competitiveness of HDV and component manufacturers
(suppliers to HDV manufacturers)
3. Facilitate a reduction in the total cost of ownership for transport operators, most of which are SMEs.
In your view, how important are the following policy objectives?
Very
important
Reduce the climate impact of HDVs
Somewhat
important
Not
important
I
don't
know
Important
x
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Contribute to the improvement of
the competitiveness of the European
HDV and component manufacturers
Facilitate a reduction in the total
cost of ownership for transport
operators
x
x
Are there other key objectives to be reached?
200 character(s) maximum
5. Form that action should take to reduce HDV CO
2
emissions
Please indicate, by order of importance, your preferred options to reduce new HDVs CO
2
emissions, and
contribute to the 2030 Energy and Climate Targets (with 1
st
being your most preferred option and 7
th
the
least preferred)?
1
st
2
nd
3
rd
4
th
5
th
6
th
7
th
8
th
Legislation setting HDV CO
2
emissions targets
at EU level
Legislation defining a CO
2
labelling scheme at
EU level
Use of vehicle or fuel taxes or other incentives
by Member States to affect vehicle choice and
use
A voluntary agreement with industry to reduce
new vehicle CO
2
emissions
Member State actions to influence vehicle
choice and use in other ways such as labelling
schemes based on VECTO, best practice
dissemination
Development of international standards for HDV
fuel economy
No action
Other option
x
x
x
x
x
x
x
x
If other, please specify:
200 character(s) maximum
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The reason why Member States' use of fuel taxes is marked with high priority is that
Denmark has already implemented such mechanism.
6. Options to consider for regulating CO
2
emissions of HDV
If CO
2
emissions of HDVs will be regulated by defining binding targets, the following options are
considered.
6.1. Options for the basic regulatory approach
Option A: CO
2
emission standards would be defined for the engines only.
Option B: CO
2
emission standards for the whole vehicles, to be based on VECTO simulations
Option C: Separate CO
2
emission standards for engines and complete vehicles
Please indicate the order of your preference (numbers 1, 2, 3) for the different options:
1
st
2
nd
3
rd
4
th
A
B
C
Other
option
x
x
x
x
If other, please specify:
200 character(s) maximum
Comments on your choices on options for the basic regulatory approach:
300 character(s) maximum
As a principle, targets should be set for the complete vehicle. Initially, targets for tractor-
trailers should include motor and tractor and aim at including targets for trailers as soon
as possible. Similarly, targets for rigid trucks and busses should be introduced as soon
as possible.
6.2. Options for the types of targets
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Option A: targets at the level of each individual vehicle; CO
2
emissions would be limited at the level
of individual vehicles/engines (i.e. specification of limit values)
Option B: average targets per vehicle group on the basis of the vehicles placed on the market by
each manufacturer (similar approach as for cars and light commercial vehicles)
Please indicate the order of your preference (numbers 1, 2, 3) for the different options:
1
st
2
nd
3
rd
A
B
Other
option
x
x
If other, please specify:
200 character(s) maximum
Comments on your choices on the options for the types of targets:
300 character(s) maximum
Average targets per vehicle group provide vehicle manufacturers with flexibility and
incentives to focus on the best efficiency potentials.
6.3. Options for the timing of the targets
Option A: fixed dates of application
Option B: annual reduction targets
1
st
2
nd
3
rd
A
B
Other
option
x
x
If other, please specify:
200 character(s) maximum
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Comments (please indicate also your suggestions for the first application date of targets as well as the
quantitative annual reductions (for option B)):
300 character(s) maximum
Targets should be set for 2025 and 2030. The level of ambition should be based on
latest research on cost-effective reduction potentials, experiences and efficiency
standards in third countries and should be in line with ambitions of the Paris Agreement
and the EU climate goals.
6.4. Options for the setting of the quantitative targets
Option A: Targets (initial values and annual reductions, if applicable) are defined ex-ante by the
legislation by relative technology improvements over some baseline (as for cars and vans)
 Option B: Targets for the year y + n (n ≥1) are defined by the performance of a certain percentile of
best performing vehicles in the year y ("top runner" approach) with a minimum yearly target
1
st
2
nd
3
rd
A
B
Other
option
x
x
If other, please specify:
200 character(s) maximum
Comments your choices on options for the setting of the quantitative targets:
300 character(s) maximum
6.5. Options for the scope of the legislation
VECTO and the underlying type approval legislation will provide certified CO
2
emission values for the
four main groups of HDVs (Vehicle groups 4, 5, 9 and 10 as defined in Table 1 of Annex I of the
draft
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Commission Regulation
implementing Regulation (EU) No 595/2009 as regards the determination of the
CO
2
emissions and fuel consumption of heavy-duty vehicles, which are responsible for about 65% of all
HDV CO
2
emissions), which would also be addressed by the first step of regulatory binding targets.
Currently VECTO provides the CO
2
emission values for these trucks only for the long haul and regional
delivery mission profiles.
However, there are also a limited (between 2 – 10% (indicative figures to be confirmed in the IA)) number
of vocational vehicles in these groups, which serve for special purposes, for instance construction sites or
waste collection.
Option A: the targets are applied to all vehicles within the 4 main vehicle groups, regardless of their
use and on the basis of the long haul and regional delivery mission profiles
Option B: Separate targets are applied to vocational vehicles within the 4 main vehicle groups, on
the basis of VECTO urban, municipal and construction mission profiles
Option C: certain vocational vehicles to be specified are excluded for this first regulatory step
Please indicate the order of your preference (numbers 1, 2, 3) for the different options:
1
st
2
nd
3
rd
4
th
A
B
C
Other
option
x
x
x
If other, please specify:
200 character(s) maximum
Comments on your choices on options for the scope of the legislation:
300 character(s) maximum
Separate targets could enhance administrative burdens if they result in different/
additional registration regimes than existing ones. On the other hand, exemptions from
targets could create unintended incentives. Therefore option A is preferred.
Can you suggest technical criteria for the definition of 'vocational' trucks?
200 character(s) maximum
6.6. Options for the metric for expressing the targets
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The CO
2
emission targets will have to be formulated in terms of a certain "metric", meaning that  the
regulatory target corresponds to CO
2
mass emissions divided by some "transport utility parameter", e.g.
mileage travelled (km), mileage travelled times weight (km x t)  or volume (km x m3) transported.
Option A: targets expressed in g CO
2
/km,
Option B: targets expressed in g CO
2
/(km x t)
Option C: targets expressed in g CO
2
/(km x m3)
Option D: targets expressed in a combination of several metrics listed in options A to C
1
st
2
nd
3
rd
4
th
5
th
A
B
C
D
Other
option
x
x
x
x
If other, please specify:
200 character(s) maximum
Comments on your choices on options for the metric for expressing the targets:
300 character(s) maximum
The regulation should target the point of obligation with measures that are possible to
influence. Consequently, option A is preferred for tractors, tractor-trailers, rigid trucks and
busses. Additionally, Option A is the most transparent way of regulating and is most
applicable to the test regime.
Would you suggest any other metric for expressing the targets?
200 character(s) maximum
6.7. Options regarding mission profiles
For mainstream HDVs used for the transport of goods, VECTO simulations provide four different CO
2
emission values: for a regional delivery and long haul driving pattern, each driven "empty" and a "typically
full" payload. Targets may apply to each of these four emission profiles separately or as a weighted
average.
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YES
Should all four mission profiles be applied to all HDVs?
Should the targets be defined for each mission profile separately?
Should the targets be compared with a weighted average of the mission
profiles?
NO
Neutral
x
x
x
If no, according to what criteria should certain mission profiles not be applied and to what sorts of HDVs?
200 character(s) maximum
If yes on the last question, how should the mission profiles be weighted?
200 character(s) maximum
If you think that the weighing of the mission profiles should depend on some technical characteristics of
the vehicles, please explain and suggest these characteristics:
200 character(s) maximum
Weighing should be based on the number of axels and total weight and should
accordingly differ between tractor-trailers and rigid trucks.
6.8. Options regarding utility parameters
Any future legislation defining targets aims at achieving a certain level of CO
2
savings for the least overall
costs while ensuring that the requested transport utility is still available. If the design of a vehicle (e.g.
stronger engine or higher transport volume) has an impact on CO
2
emissions and the vehicle's utility, it
may have to be factored into the applicable target (e.g. by choosing appropriate utility factors and formulas
setting the targets as a function of thereof). In the case of cars and vans, mass is used as an utility
parameter in the current legislation on CO
2
emission standards.
Should utility parameters be used for regulating CO
2
emissions from HDVs?
YES
x
NO
Neutral
If yes, what utility parameter should be used and factored in for setting the targets?
200 character(s) maximum
Utility parameters could undermine the reduction efforts and is therefore not supported.
6.9. Options for elements supporting cost-effective implementation of the targets
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Several options can be considered to support the cost-effective implementation of the targets, which may
however also create additional administrative burden:
Pooling: Several manufacturers may decide to combine their vehicle fleets for assessing the
compliance with the regulatory targets (as in the case in the cars and vans CO
2
legislation.)
Banking and borrowing: A manufacturer may compensate non-compliance with targets in a given
calendar year by over-achievements in previous ("banking") or future ("borrowing") years according
to well defined regulatory rules.
Trading: a manufacturer over-achieving its targets may sell corresponding credits in order to
facilitate compliance of other manufacturers.
Transfer of credits between vehicle groups of a manufacturer. In the case of targets set at the level
of each vehicle group, a manufacturer may transfer credits between the different groups of its
vehicles.
What are your views on these options?
YES
Pooling of manufacturers
Banking and borrowing
Trading between manufacturers
Transfer of credits between vehicle groups of a
manufacturer
NO
Neutral
x
x
x
x
Please provide your comments on these or possible other elements for supporting cost-effective
implementation:
500 character(s) maximum
Due to smaller number of vehicle manufacturers of HDVs, pooling is not relevant to the
same extent as for LDVs. Banking and borrowing could create unintended incentives.
Trading could be feasible, if transparent, but should be further analysed. Transfer is not
supported due to risk of vehicles manufacturers only prioritising special types of vehicles
with possible low usage/mileage.
7. Governance - HDV CO
2
certification and real driving emissions
Under the current process, CO
2
emissions of HDVs are certified on certain pre-defined mission profiles,
the design of which is inspired by real driving data.
What are your views:
YES
Will it be important to develop processes assessing the certified CO
2
emissions against real driving emissions of HDVs?
NO
Neutral
x
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EFK, Alm.del - 2017-18 - Bilag 137: Regeringens høringssvar vedr. kommende CO2-krav til nye tunge køretøjer (HDVs)
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If such processes are being developed, should there be some ex-post
feedback mechanism requiring compliance of the certified CO
2
emissions
with real driving emissions (within certain tolerances)?
x
Can you suggest such a process?
500 character(s) maximum
In-service checks should be mandatory to ensure a constant relation between type
approval test results and in-service test results. Otherwise the regulation could risk
missing out on its main purpose; to reduce greenhouse gas emissions. EC should
consider proposing mandatory measurement devices for fuel consumption in new
HDVs and relevant market surveillance mechanisms.
8. Additional comments and Upload of Documents
If you wish to add further information, comments or suggestions – within the scope of this questionnaire –
please feel free to do so here:
1000 character(s) maximum
In addition, you could also upload a document providing further information, comments or suggestions.
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