ARRIVAL LTD
Arrival is a technology-first company that is disrupting the automotive industry with a radical new approach to the design and production of electric vehicles.
ID: 104315245793-44
Lobbying Activity
Response to Review of the CO2 emission standards for heavy-duty vehicles
14 Mar 2022
Arrival is a technology-first company that is disrupting the automotive industry with a radical new approach to the design and production of electric vehicles. Arrival’s mission is to improve air quality by replacing all vehicles with affordable electric solutions produced in local Microfactories. To have the greatest impact, Arrival is focused on commercial vehicles and has vehicle programmes across the Bus, Van and Car (commercial ride-hailing) segments.
Arrival welcomes the opportunity to respond to the consultation on the revision of CO2 standards for heavy duty vehicles (HDVs). The revision is an opportunity to reinforce the need to align CO2 targets with the EU’s ambition to reduce GHG emissions by 55% in 2030 as outlined in the Fit for 55 package and achieve climate neutrality by 2050. Arrival argues for all new HDVs to be zero emission by 2035 at the latest.
To accelerate the transition to zero emission in the next decade Arrival calls for a greater level of ambition in the revision of the CO2 regulation. Greater ambition in the regulation will support the scale up of ZEV production and investments in EV technology development in Europe.
Arrival calls on the EU Commission to enact the following:
1. Arrival advocates for stricter carbon reduction targets to ensure the EU is on the right trajectory to meet climate neutrality by 2050.
1a. Arrival proposes the following CO2 reduction targets for HDVs:
-- 2025 - 50%
-- 2030 - 75%
-- 2035 - 100%
1b. Arrival calls for a more ambitious near term target specifically for buses based on the amplified air quality benefits with inner-city vehicles. To spur action now Arrival also calls for a new vehicle target for all new buses to be zero emission by 2025.
1c. Progressive states for example, Israel have mandated an end to ICE buses for all new buses from 2026. A 2025 target for the EU would demonstrate the global leadership toward zero emission that the EU wishes to take while.
1d. This will send a clear signal to producers on the trajectory of demand and support to increase the supply of zero emission buses.
1e. Targets should take into account the views of transport operators and vehicle manufacturers to ensure alignment with natural fleet renewal cycles.
2. Extend the regulation to all vehicles in the HDVs segment including urban buses.
3. Strengthen the ambition of the incentive mechanism.
3a. Include buses in the scope of the incentive scheme.
3b. Introduce a bonus-malus system for zero emission HDVs.
3c. Revise the 2% benchmark to align with the greater level of ambition needed to achieve the EU’s overall aim of reducing by 55% GHG emissions by 2030 and climate neutrality by 2050.
4. Do not include credits for renewable and low carbon fuels as they do not help address the emissions problem of HDVs.
4a. Low-carbon fuels may be seen as a transition technology for existing fleets with long lifetimes, but do not represent a just transition, particularly for vehicles such as buses which operate in cities. Low carbon fuels can still produce significant air pollution, so new legislation should call for zero tailpipe emission vehicles.
4b. The focus of the regulation on OEMs should be reducing g/km emissions of vehicles sold in the EU.
5. Assigning revenues from fines to fund the just transition.
5a. Arrival supports the intention behind this as knowing how revenues from fines are used allows an educated choice to be made on whether to pool or not.
5b. Using revenues from fines in this way also supports more equitable transportation systems particularly if the revenue is funnelled into improved public transport.
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