CITTADINI PER L'ARIA
Our NGO aims at creating a network in support of Clean Air policies in Italy, joining in various citizens groups spread around Italy to jointly advocate and achieve swift improvement of air quality policies in Italy.
ID: 372227817849-54
Lobbying Activity
Response to Clean corporate vehicles
26 Aug 2025
Cittadini per laria considers that it is crucial for the improvement of air quality in Europe, especially in the most critical areas like the Po valley, and to achieve a relevant decrease of CO2 emissions, to make sure that new policies on companies mobility and acquisition of new fleets are drastically modified. It should in this respect considered that in Italy, for example, the largest quota of emissions from vehicles overall originates from corporate vehicles, as shown by the below chart developed by T&E based on 2025 data. Namely, in Italy, about half i.e. 48% - of new registrations come from corporate entities and, and the great majority of the emissions from vehicles namely 64% - originate from corporate fleets. This is because corporate fleets /vehicles are often more intensely used and utilized than private vehicles as they are used not only to reach workplaces, but also to meet clients and carry out the ordinary work activity that requires moving from one place to another and away from the corporate offices. This is the reason why corporate fleets vehicles must soon be changed to EV vehicles to ensure that the pace of emission reduction from transport is as fast as possible to reduce the deadly health impact of air pollution in Europe, in the EU cities and in the most polluted areas like the Po valley. To achieve that we ask the Commission to adopt a holistic approach that takes into consideration not only a technical change in mobility but also a mode switch is considered as a priority. I.E in this vision: 1) companies are incentivized to review their corporate fleets policies defining public transport or active travel as their main corporate way of transport, and substituting the offering of car as corporate incentive to employees and managers with more proactive support to sustainable mobility (public transportation subscription for the employees families, yearly train credit/bonus for leisure etc. etc). In this light a fiscal policy linked to standards of promotion of active mobility as corporate incentive, instead of vehicles, should be adopted and practiced at EU level. 2) corporate fleets are aimed at those activities that have reasonably no alternative way of transport. Corporate fleets should be defined to also include those vehicles that, despite not being owned by a corporation, are a critical means of deployment of the companys activity and instrumental thereto. This applies specifically to the logistics sector which is highly contributing to the bad air quality in our cities being that their vans drive hundreds of km daily and could, in theory, maybe apply to other sectors (cruise companies using private service providers for tourists transport from ports to cities, taxi cooperative companies and of course rent a car, car-hire and leasing companies). 3) In this respect, a criteria could be added to include a mechanism ensuring that large companies /shippers support and have a target also for the small logistic owners they use for their business in a way that they can go ZEV, both via using cargo bikes in the cities and ensuring ZEV in cities for their deliveries even if not owned by the company. Otherwise, the targets for most polluting activity carried out by large companies can be rather ignored. 4) An ambitious proposal for a Regulation advancing the uptake of criteria to reduce the overall car use within large and medium companies and as corporate bonuses and setting ambitious targets for new corporate fleets can drastically reduce the emissions output from transport in Europe which is, unfortunately, still growing. In this view, a target of 100% electrified new cars, vans, bus, trucks and vehicles for companies is a relevant and crucial objective, which should particularly be aimed at taxi companies, delivery companies, rent a car companies, logistic companies fleets and all other companies that use vehicles as a tool of their activity. The feedback continues in the attachment
Read full responseMeeting with Brando Benifei (Member of the European Parliament)
11 Sept 2023 · Discussion on Air quality directive
Meeting with Virginijus Sinkevičius (Commissioner) and
18 Nov 2022 · To discuss the recently adopted Commission proposal for the revision of the Ambient Air Quality Directives
Response to Revision of EU Ambient Air Quality legislation
14 Jan 2021
Citizens for Air welcomes the opportunity to provide a feed back on the AAQDs.
Please find attached the feed back.
Read full response25 Nov 2020
The missing “Option zero”, maintaining the existing climate architecture, strengthening the ESR
Cittadini per l'aria regrets that the Commission did not include the option of maintaining the current architecture by raising both the ambition of the ETS and the ESR.
The ESR is efficient incentivizing climate action:
● At domestic level, targets have been - and will continue to be - an important driver for domestic investment in infrastructures such as charging, LEZ and building renovation. They have led to ambitious taxation reform in some countries.
● At EU level, member states have supported ambitious EU regulatory measures (e.g. CO2 standards) to more easily achieve their national objective.
The ESR faces challenges like weak governance and inefficient flexibilities as main issues to address in this review:
● Improved governanceincludes more transparent annual carbon budgets, and a strengthened compliance framework, including fines and annual checks.
● Although cross-country exchanges are allowed, the mechanism is rarely used. A joint projects platform for cost-effective projects EU-wide should be created, with the help of e.g. the EIB. Wealthy countries with highest targets may be able to support investments in countries with low abatement costs and benefit from the reductions.
The EC should consider ways to strengthen the regulation, not scrapping it. Below we briefly analyse the three incomplete options included:
Options 1 and 3: why carbon pricing is not the holy grail
Repealing the ESR
● National targets at risk. The ESR contributed to the adoption of national policies, and more will be needed this decade. The EC must factor the risk of domestic policies to slow down in the case where national targets would be repealed.
● EU policies in danger. The repealing of the ESR will also alter the motivation of the Council to adopt ambitious EU sectoral measures. The Commission should factor the potential for an extended ETS to jeopardize increased ambition in many other climate regulations.
Extended ETS
● Inefficient measure for the climate. Analysis shows that under an extended ETS, additional emissions reduction in road transport will be about zero in 2030 and less than 10% in 2050 (see attachment) due to its inelastic demand. Additionally, within an extended ETS, a carbon price significant enough for road transport would be exorbitant for energy intensive industries.
● The fuel price increase resulting from the inclusion of road transport into the ETS will hit the low-income population the most, without addressing existing market barriers. The EC should really consider if it wants to link the Green Deal with impacts on the most vulnerable.
● Carbon pricing in road transport does not lead to fuel switching or timely investments into zero emission technology. To achieve 2050 targets, the last ICE car should be sold in 2035 at the latest. The Impact Assessment of the Climate Target Plan shows that ambitious CO2 standards compete politically with the road ETS. Standards have been the only tool that brought the transition from combustion to electric cars.
Option 2: Limited damage under conditions
A carefully-crafted and fair carbon pricing could be explored for road transport if some conditions are met:
● If national targets remain in place and are strengthened.
● If car CO2 standards become annual and reach 65% in 2030. Other measures must be taken to accelerate road transport CO2 cuts. If not, the carbon price will spiral out of control.
● If it is a system exclusively for road transport, with clear considerations on how the revenues could be used to contribute to the transition in the sector, particularly the most vulnerable.
● If no flexibility exists between this system and LULUCF and the EU ETS.
Administratively, it is possible to maintain road transport in the ESR and create a separate carbon pricing mechanism. Article 2 should be modified to integrate the list of sectors covered in the ESR,using UNFCCC categories
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
24 Nov 2020
Cittadini per l'aria shares T&E's view EU car CO2 standards are a climate and industrial policy, to achieve automotive transformation and securing supply of affordable electric cars to achieve zero carbon transport in Europe. T&E’s analysis shows that the 2020/21 standard of 95g/km will result in plug-in sales of 10% this year and 15% in 2021, making Europe a leading electric car market.
But such unprecedented growth means the 2025-2030 targets are inadequate. The momentum will slow as soon as 2022 - just as EVs reach price parity - if the regulation is not amended. The 2021 review is very timely, and the upcoming impact assessment (IA) should:
- Analyse the optimal CO2 reduction trajectory to ensure continuous market growth comparable with that seen in 2019-2021, and set higher 2025-2030 targets accordingly.
- The CO2 reduction required in 2025 should be at least -25% from the 2021 baseline; anything less will delay investments and result in an inadequate European supply of EVs for the fast growing market.
- Analyse an EU-wide phase-out date for the sale of new combustion engine vehicles. Taking into account the average age when the large majority of petrol and diesel cars retire from the EU fleet, such a date should be set no later than 2035. Type approval provisions must be adjusted to allow individual member states to go for earlier phase-outs in line with their climate ambition and faster progress on e-mobility.
The progress seen in 2020 masks numerous failures of the current regulatory design to effectively cut emissions and bring timely supply of zero emission vehicles. The 2021 review should address the biggest problems, notably:
- The current 5-year target design allows CO2 emissions from new cars to grow in between the targets, creating much uncertainty for carmaker compliance. The IA should evaluate how the 5-year targets should be replaced by annual ones and propose what flexibility is needed (e.g. banking and borrowing or 2-3 years averaging of performance).
- Half of current EV sales are plug-in hybrids that - even on a charged battery - emit much higher CO2 on the road than lab tests claim. The IA must evaluate the negative impact of the current 0.7 multiplier on driving the market towards suboptimal PHEVs. The future regulation should - as a priority - remove this multiplier from 2025 onwards and all credits for low emission cars stopped by 2030.
- The design of the zero and low emission vehicle benchmark is sub-optimal and risks increasing CO2 emissions of new conventional cars in the 2020s (via generous CO2 bonuses). With EVs reaching price parity around 2025 and their sales higher than expected, the IA should consider whether there remains any need for the benchmark. The benchmark should be removed once EU-wide plug-in sales reach 25% and no later than 2030.
Additional recommendations:
- Decarbonisation of fuels should continue to be governed by separate legislation such as RED and FQD. The IA should assess the risks of mixing the roles and responsibilities of different actors, supply chains and industries into one regulation that only applies to carmakers. In particular, the IA should consider: the risk of double-counting, whether a vehicle manufacturer has any control over where a vehicle is fueled once placed on the market and whether there are any additional climate benefits of introducing a fuel mechanism into the vehicle regulation.
- Current mass adjustment provisions are no longer justifiable. The IA should analyse how the increasing share of heavier zero and low emission vehicles impacts the EU and OEM-specific average mass and propose ways in which the weight adjustment should be phased-out from the regulation.
To contribute to the -55% 2030 target, the car CO2 targets must be increased in the 2020s, not only 2030. This regulation is the single most important tool driving the transformation of Europe’s automotive sector - its design will determine whether Europe will lead the global
Read full responseResponse to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters
4 Jun 2018
Rather than being “already complete” as stated in the Roadmap, the EU system of remedies suffers from considerable shortcomings. As recognized already in the first ACCC’s findings in 2011, the preliminary reference system under Article 267 TFEU does not meet the requirements of Article 9(3) of the Convention. Over the last years, the CJEU has further consolidated its case law in claims brought by NGOs, thereby clarifying that members of the public have no standing under Article 263 TFEU to challenge acts and omissions of EU institutions that are not addressed directly to them. The Aarhus Regulation is the only remaining avenue for the public but it remains unduly restrictive in its current form.
The situation is therefore clear: (1) The EU is a party to the Aarhus Convention in its own right; it therefore constitutes an integral part of the EU legal order. (2) The EU is in non-compliance with the Convention and therefore violates international law and primary EU law. (3) Based on one of the fundamental principles of the international legal order (article 27 of the Vienna Convention of the Law of Treaties), the EU cannot avoid performing its obligations by invoking its internal law. (4) The only option open to the Commission to remedy this violation of international law is to propose an amendment of the Aarhus Regulation.
There is no need to conduct a further assessment of “how access to justice works”. For over 10 years, the Commission has been presented with legal analyses, an abundance of specific case examples and statistics on access to justice. Nonetheless, the Commission has delayed remedying this issue, even contrary to calls by international bodies and its fellow institutions. The time for studies is over – it is time to amend the Regulation.
Read full response27 Nov 2016
Risposta alla Commissione Europea circa la consultazione sul cd. Pacchetto RDE3
Cittadini per l’aria considera positiva la proposta contenuta nel cosiddetto pacchetto RDE3 e questa consultazione del pubblico allo scopo di affrontare il problema delle emission di particolato in particolare provenienti dalle auto a benzina ad iniezione diretta ed al fine di rafforzare il Sistema di test RDE.
Cittadini per l’aria segnala che – come evidenziato dal rapporto 2016 sulla qualità dell’aria in Europa dell’Agenzia Europea per l’Ambiente - l’Italia ha il maggior numero di morti premature in Europa da inquinamento atmosferico: Ogni eventuale tentativo da parte del rappresentante del Governo italiano nell’ambito del TCMV di indebolire l’attuale proposta RDE3 deve considerarsi in aperta violazione delle norme Europee sulla qualità dell’aria Direttiva 2008/50/CE ed una aperta violazione del diritto alla salute dei cittadini che dovrebbe al contrario tutelare.
Siamo tuttavia estremamente preoccupati per le seguenti ragioni:
- Innanzitutto l’estensione dei test RDE alla misura del numero delle particelle deve essere implementata senza alcun ritardo rispetto alle scadenze previste ovvero 2017 per i nuovi tipi e dal 2018 per tutte le auto nuove. Ogni slittamento di queste scadenze rappresenterebbe un inaccettabile danno per la salute umana e comporterebbe il ritardo degli investimenti urgenti e necessari al fine di assicurare che la flotta di veicoli a benzina a iniezione diretta sia rispondente ai limiti Euro 6 su strada.
- Inoltre, sia i risultati dei test RDE che i valori massimi dichiarati per le case automobilistiche devono essere resi accessibili in un database pubblico come previsto dalla proposta della Commissione. Qualunque indebolimento di queste previsioni di trasparenza dei dati comporterebbero l’inefficacia del RDE3 e il livello di informazione del pubblico. Vi sono enormi differenze nella quantità delle emissioni dei veicoli dotati di filtri antiparticolato e gli automobilisti devono essere messi al corrente di questa informazione.
La nostra associazione considera che l’attuale bozza di proposta legislative sia la minima per essere accettabile. Ulteriori indebolimenti della proposta nell’ambito della riunione del TCMV che si terrà il 20 dicembre comporterebbero una richiesta di rigetto della stessa da parte possibilmente del Parlamento Europeo e degli altri stakeholders quali per esempio T&E, EEB.
Le aree in cui la norma può essere migliorata ora o almeno entro l’entrata in vigore del pacchetto RDE” nel 2020. In particolare:
- E’ necessario che la proposta riguardi anche il particolato ultra fine (sub-23-nm) come riconosciuto dalla Commissione nel recital 14. Queste particelle sono le più pericolose per la salute umana e occorre includere la loro misurazione nel testo entro il 2020 al massimo.
- L’attuale approccio utilizzato per dare conto delle emissioni cold-start più (punto 27 allegato 2) dovrebbe essre sostituito con un più accurato processo di verifica del loro impatto pro quota in un tragitto medio urbano. Inoltre la possibilità di utilizzare un periodo fino a 30 secondi in sosta fra l’accensione del motore e il primo movimento (punto 25 allegato 2) rappresenta un sistema per sottostimare pesantemente le emission a freddo dei motori a benzina e deve essere eliminato.
- Per quanto riguarda gli eventi di rigenerazione, Cittadini per l’aria chiede che il TCMV rimuova la possibilita di usare I dati del Engine Control Unit (ECU) per identificare tali eventi in modo da evitare che i test RDE possano essere manipolati dalle case automobilistiche (punto 19 all. 2). Occorre invece utilizzare la temperature dei fumi di scarico.
- I fattori di conformità devono essere rivalutati annualmente.
Read full response