Autotuojat ja -teollisuus ry
AT
Autotuojat ja -teollisuus ry (AT) on autojen maahantuontiyritysten ja autoteollisuuden yhdistys.
ID: 348813031337-36
Lobbying Activity
Response to Review of the CO2 emission standards for heavy-duty vehicles
19 May 2023
The objectives of the limit value proposal are very important, as reducing emissions from trucks and buses requires accelerating a controlled shift to carbon neutral fuels. Limit value regulation is one of the most effective ways to influence emissions from the truck and bus fleet. The proposed regulation would undermine manufacturers' ability to place on the market vehicles suitable for the heaviest vehicle-trailer combinations. In Finland, four-axle trucks are commonly used as traction vehicles for truck trailer combinations, as the energy efficiency of a truck trailer combination is better than that of a semi-trailer combination. In Finland, the transport tasks of four-axle lorries are very different from those of similar vehicle groups in Central Europe. For example, in the rest of Europe, 8x4 trucks are mainly used as earthmovers, whereas in Finland they are mainly used as tractors for heavy vehicle combinations. The vehicle group specific emission simulations reflect the use of trucks in Central European conditions, as the simulations underlying the EU regulation have not been able to take into account the larger dimensions and masses that apply nationally. Therefore, the emission reduction per tonne-kilometre for the heaviest vehicle combinations cannot be identified with the current measurement methodology. The current simulation system does not detect the energy efficiency improvements that larger dimensions and masses allow, where the same number of vehicle-kilometres can transport a significantly higher number of tonne-kilometres. Indeed, energy efficiency improvements have been a key driver behind the reform of weights and measures, and the energy efficiency benefits have been demonstrated in a number of studies. In Finland, the road transport logistics system relies on heavier than average vehicle combinations. In 2021, around 70 percent of road tonne-kilometres were generated by combinations of vehicles of 60 tonnes or more, although they accounted for around 40 percent of vehicle-kilometres. As the 2030 technology path to carbon neutral fuels is still open, it would be important to introduce a carbon correction factor in the legislation. In the first phase, biomethane and synthetic methane in particular, and in the future also synthetic liquid fuels, should be included in the legislation to ensure that the emission reduction effects of fuel technology can also be fully exploited in the reduction of emissions. In order to solve the problem of regulating lorries pulling important combinations of vehicles in Finland, we propose - to exclude from vehicle groups 11, 12 and 16 vehicles with a total mass or combination mass above a certain limit, for example a lorry with a total mass of 32 tonnes or a combination of vehicles with a total mass of 60 tonnes - new vehicle groups 11, 12 and 16 to be regulated would be subject to lower emission reduction targets for 2030 and 2035 - for example, a 30% reduction target for 2030 under current legislation Vehicle groups 11, 12 and 16 account for around 5% of heavy-duty vehicle emissions in the EU. Even if trucks used to tow the heaviest combinations in these categories were excluded from the limit value regulation, the impact on overall emissions from truck transport would be small. The Commission proposes to abolish the so-called ZLEV mechanism for zero and low emission vehicles in 2029. We propose to extend the ZLEV mechanism for vehicles with a gross laden mass of 32 tonnes/60 tonnes or more until 2035, allowing manufacturers to receive credits for placing heavier-than-average zero-emission trucks on the market. An efficient way to mitigate the challenge of the ambitious -100% emission reduction target for city buses through delegated legislation or national derogations would be to set the 2030 limit at -90%. This would simplify fleet procurement in small towns awithout undermining the emission reduction targets.
Read full responseMeeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and Blic Oy
21 Jun 2018 · finnish initiative of small passenger cars w speed limitors for young drivers
Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen) and Blic Oy
3 May 2018 · Transport policy