Belgian & Luxembourg Federation of Automobile & Two-wheeler Industry
FEBIAC
Algemene focus op monitoring, analyse, positionering, belangenverdediging op subnationaal, nationaal, Europees en internationaal vlak.
ID: 641098515046-40
Lobbying Activity
Meeting with Frans Timmermans (Executive Vice-President) and Association des Constructeurs Européens d'Automobiles and
19 Jan 2023 · visit to see developments in electric mobility
Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders)
8 Jul 2021 · meeting with FEBIAC BMC - alternative fuels infrastructure and decarbonisation
Response to Revision of Alternative Fuels Infrastructure Directive
4 May 2020
Revision of the Alternative Fuels Infrastructure Directive (AFID)
Contribution by FEBIAC – the Belgian & Luxembourg Federation of Automobile & Two-wheeler Industry
www.febiac.be
1. Cornerstone of the European Green Deal
The European Union has set clear objectives to reduce emissions of greenhouse gases and pollutants from road transport. These ambitious goals require the development of a low and zero-emission ecosystem, attracting necessary investments in alternative fuels infrastructure.
The development of AFI is essential to realise the European Green Deal. It should be a priority in the economic and societal relaunch programme of the European Commission in the aftermath of the COVID-19 crisis.
2. Technology neutrality
Large-scale investments in research and development are on-going to develop cleaner and safer fuels for the future. Various technologies may be at different stages of development today and may be more suitable for some transport applications than for others.
European policy should encourage investments in order to reap the full potential of various fuels technologies, including electric, gas, hydrogen and liquid fuels, and not exclude any technologies at this stage.
3. Binding AFI targets
The quality and availability of alternative fuel infrastructure varies widely across Europe. The availability of the necessary infrastructure in member states is a key enabler for the uptake of low and zero-emission vehicles.
Future AFI legislation must include binding targets for member states for publicly accessible infrastructure, including details on the number of charging and fuel stations and type of electric charging station (slow / fast / ultra-fast).
4. Right-to-plug
Availability of charging points for electric vehicles is essential to ensure market uptake. Consumers and businesses should have a right to install and use a charging point on their premises and to charge their vehicle whenever they seem fit under acceptable market conditions.
5. European AFI roll-out plan for high-speed charging infrastructure
Charging of electric cars happens mostly at home or at work but travelling longer distances remains a challenge. A dense network of high-speed charging infrastructure along key road transport corridors, such as the TEN-T network, must be developed across Europe to provide peace of mind for leisure and professional drivers.
6. Smart electricity grids and markets
Physical electric grid development is costly and time consuming. Digital solutions should be promoted to address grid saturation and capacity constraints. Flexible price settings should incentivise optimal use of available electricity and grid capacity as well as off-peak charging. In any case and at any time, electric chargeable vehicles should be able to be charged at an acceptable charging speed and tariff.
7. Holistic approach for specific fleet requirements
Different vehicles serve different operational needs. Particular attention should be given to flanking measures in the use of alternative fuels in logistics and long-distance transport, including safe parking facilities and comfortable resting areas.
8. European standardisation and interoperability
Alternative fuels infrastructure in Europe should be standardised across European operators to ensure attractiveness and ease-of-use by consumers, including interoperable payment systems, labelling and sharing of data on the availability of charging and tank infrastructure.
9. Price transparency and display
To boost consumer confidence, information of prices and fees of EV-charging must be displayed clearly through various platforms. Essential information must be made available offline.
10. Monitoring
Technological developments need rapid policy adjustments. A comprehensive monitoring is required to map evolutions, shortcomings and support additional action.
30 April 2020
Laurent Willaert
Director Public Affairs
Laurent.willaert@febiac.be
www.febiac.be
Read full response8 Dec 2016
The members of FEBIAC recognize the importance of European RDE legislation and concur with the COM on the need for improving air quality in Europe and especially in a densely populated country like Belgium. On the other hand, economic strength, industrial rationale and automotive activities are important for our country as well. They have contributed to becoming a country with one the highest GDP per capita & per km². All these elements have to be taken on board of the RDE ship by COM when it comes to the wellbeing (air quality) and welfare (growth & jobs) of each of its member states.
More in concrete, that’s why industry and its BE representatives have reiterated on many occasions in the RDE legislative process that vehicles are designed and developed in a well-structured process requiring adequate lead-time. Along with the product development, a complex supply chain needs to be negotiated and put in place. All stakeholders in the process equally need proper and fair lead-time in order to answer their commitments as well as to fulfill legal requirements.
The RDE regulation 2 (adopted in October 2015) established a timeframe for introduction in two steps: step1 (2017/19) for tuning the engine and emission settings, step2 (2020/21) for thorough overhaul of relevant vehicle systems and components.
COM has chosen to introduce a highly complex regulation in multiple packages and a process of adoption spanning several months. It is regrettable that COM introduces requirements in pack 3 to be applied in 2017/18 which are well beyond the margins of improvement of mere engine parameter settings (RDE step 1). COM herewith significantly changes the targets for manufacturers and forces manufacturers into a near to impossible mission.
In specific, RDE3 introduces two significant new requirements to apply from 09/2017. COM aims to have this agreed by the regulatory committee on 20/12/2016. Assuming that EP scrutiny will not interfere, publication may be expected at best by April/May 2017. COM thus introduces major legislation for which industry only has 4 to 5 months lead-time to comply. COM proposal is not realistic in not providing realistic lead-time.
FEBIAC members see major issues deriving from the WLTP regulation that enters into force from 9/2017 & 9/2018. WLTP regulation interferes with the dates that were agreed for RDE (i.e. 9/2017 & 9/2019) thus disrupting the planning and manufacturing process for all manufacturers and their suppliers, also in a country like Belgium where nearly half a million vehicles are produced and assembled by nearly 100.000 workers.
In summary:
• RDE3 legislation should be complete, robust and accurate no later than end-December 2016.
• Missing RDE boundary conditions for LCV’s as well as other outstanding RDE issues should be resolved in RDE4 without delay.
• PN-PEMS instruments have yet to be improved and a suitable error margin (in line with the accuracy of PEMS) must apply for PN instruments. Vehicle manufacturers do not share COM position on PEMS accuracy figures, PEMS instruments should therefore be approved/certified through a PEMS approval process ready by end-2017.
• Also quality of market fuels should be considered when evaluating real driving emissions.
Read full response