Agora Verkehrswende, Agora Transport Transformation gGmbH
Agora Verkehrswende is a Berlin-based think tank that seeks to promote climate-friendly mobility.
ID: 447579528197-45
Lobbying Activity
Response to Revision of the CO2 emission standards for cars and vans
26 Nov 2020
Agora Verkehrswende appreciates the opportunity to provide feedback at the beginning of this process.
Generally, as electrification progresses, it would be more suitable to base the standards on energy efficiency rather than CO2 emissions in order to address the imbalance between electric and combustion cars, to ensure that all vehicle types improve over time, and also because a shrinking share of new vehicles will actually emit CO2. Given the limited timeframe for the review, however, we make a number of targeted suggestions within the existing regulatory framework.
1. Level of stringency
For climate neutrality in 2050, a 50% reduction target for cars in 2030 as indicated in the Climate Target Plan is likely to be insufficient. We recommend exploring higher levels of reduction up to 70%.
2. Supplementary standards for combustion cars
Rising shares of zero and low-emission vehicles (ZLEV) in manufacturers’ fleets lead to rising allowable CO2 emission levels for the remaining internal combustion vehicles (ICEV), until their emission levels are no longer constrained. This effect can be countered with supplementary limit values (LV) for ICEV.
Thus, we suggest implementing a backstop LV curve related to the existing one but applied to ICEV only. The advantage of this approach is its continuation of the established format of a LV curve. Based on the observed emissions of ICEV in 2021, the curve could be determined in different ways whose distributional impacts need investigation. E.g.:
- A multiplier applied to the existing 2021 LV curve
- A parallel shift of the existing LV curve
- A regression line based on ICEV registered in 2021
An alternative approach would be manufacturer-specific backstop LV, also based on the observed 2021 values for ICEV.
As there are remaining low-cost options to improve ICEV even as manufacturers concentrate on introducing ZLEVs, the backstop LV could be tightened by a moderate improvement factor, such as 1% per year from 2021.
3. Mechanism to incentivise ZLEV
Observation suggests that the stringency of the overall limit value is itself the most effective mechanism to incentivise zero and low-emitting vehicles, as described above.
The influence of the existing ZLEV factor as an incentive mechanism is far weaker. Also, PHEV have been found to often have much higher real emissions than their test results. Therefore, we suggest to abandon this factor. With EV becoming competitive on their own, such mechanisms may eventually slow down rather than accelerate EV market uptake.
4. Potential contribution of renewable and low-carbon fuels
The legislation requires investigating the potential contribution of the use of synthetic and advanced alternative fuels to emissions reductions. Some understand this to mean fuel credits in emissions standards for vehicles. We strongly advise against this approach, for the following reasons:
- Loss of effectiveness as a result of commingling regulatory spheres: fleet standards have had great success improving vehicle technology, while fuels are subject to energy legislation. Mixing regulation in both of these areas creates the risk of confining future improvements to just one of the two sectors.
- Potential adverse impacts on fuel policy, such as incentivising conventional biofuels, and on the achievement by Member States of their ESR targets.
- Higher costs: where fleet standards on the whole reduce the overall costs through lower fuel consumption over the lifetime of a vehicle, synthetic fuels would increase the cost from a societal and consumer perspective.
- Loss of transparency and credibility: the actual improvement achieved by this instrument would be difficult to track. It could also undermine public trust if ICEV were thereby declared as ZLEV, especially if these receive related fiscal benefits.
We look forward to supplying more detailed input as the impact assessment proceeds.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
4 May 2020
We agree with the choice of the four problems identified in the inception Impact Assessment and the way they are to be tackled.
We would however point out a fifth line of enquiry which concerns the range of fuels covered by the Directive. With the advent of Euro VI standards the air quality advantage of natural gas vehicles has been diminished to the point where it is questionable whether an entire parallel fuelling infrastructure is warranted. Meanwhile the climate impacts of transport have risen in importance, as noted in the inception Impact Assessment. The ambition to achieve greenhouse gas neutrality by mid-century, as proposed by the Commission (COM(2020)80), is incompatible with the build-up of a fuelling infrastructure that relies on a fossil fuel such as natural gas. Regarding the climate-related impact of natural gas, its benefits compared to conventional diesel are limited at best [1], [2]. Even the most optimistic quoted value of up to 22% is far from bringing emissions down to zero, and less than the 30% required for all trucks on average by 2030 in accordance with Regulation (EU) 2019/1242. In addition, leakage in the upstream production is a major issue [3]. Finally, building up a natural gas infrastructure now would create a lock-in effect due to the long lifetime of the required technical installations, which would endanger the goal of climate neutrality in 2050.
The Directive also aims to minimise the dependence on oil. It is difficult to see how an increasing reliance on increasingly imported natural gas can support the objective of reducing the dependence on imported energy carriers.
This issue could be addressed in the following way:
1. Add a new Problem 5: “The current scope of the Directive in terms of alternative fuels as defined in Article 2(1) includes fossil fuels, notably natural gas and liquid petroleum gas (LPG). This is incompatible with the objective of climate neutrality as required in view of the Paris agreement.”
2. Add a new objective in section B: “(5) Concerning Problem no 5: to ensure the climate neutrality of the entire transport fuelling infrastructure in the EU in a manner consistent with the objectives of the European Green Deal.”
3. Include in the Impact Assessment the option of removing fossil fuels from the scope of the Directive (definition of alternative fuels in Article 2(1) and Article 6 on natural gas).
Regarding Problem No.4, a recent study by Agora Verkehrswende and the Regulatory Assistance Project (RAP) [4] found that “smart charging” of electric vehicles can help to reduce peak loads on the networks and, in turn, delay or obviate the need for network expansion.
Notes
[1] Transport & Environment: “Do gas trucks reduce emissions?”, September 2018. https://www.transportenvironment.org/publications/do-gas-trucks-reduce-emissions; NGVA: https://www.ngva.eu/medias/comments-on-the-te-report-do-gas-trucks-reduce-emissions/; T&E: https://www.transportenvironment.org/publications/do-gas-trucks-reduce-emissions-your-questions-answered.
[2] A recent investigation found that current LNG HGVs have 7% higher WTW GHG emissions than diesel, and that improving LNG vehicle efficiency could achieve 13% lower WTW GHG emissions. See Langshaw et al.: Environmental and economic analysis of liquefied natural gas (LNG) for heavy goods vehicles in the UK: A Well-to-Wheel and total cost of ownership evaluation. Energy Policy Volume 137, February 2020. https://doi.org/10.1016/j.enpol.2019.111161
[3] See e.g. https://www.iea.org/reports/methane-tracker-2020/interactive-country-and-regional-estimates#abatement. An overview of recent sources is given in https://www.nationalgeographic.com/science/2020/02/super-potent-methane-in-atmosphere-oil-gas-drilling-in-atmosphere-oil-gas-drilling-ice-cores/
[4] https://www.agora-verkehrswende.de/en/publications/distribution-grid-planning-for-a-successful-energy-transition-focus-on-electromobility/
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