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International Council on Clean Transportation

ICCT

The International Council on Clean Transportation works to improve environmental performance of vehicles and transport systems to protect public health and quality of life.

Lobbying Activity

ICCT Urges Tougher Efficiency Rules for EU Aviation Taxonomy

5 Dec 2025
Topic — The EU is reviewing its taxonomy rules for sustainable aviation activities.
Message — The organization recommends stricter fuel efficiency margins for large aircraft. They also suggest excluding short-haul flights with quick rail alternatives. They propose mandatory targets for synthetic fuels to accelerate transition to e-kerosene.123
Why — This would allow the organization to see its technical standards adopted into law.4
Impact — Airlines lose green investment eligibility for short routes having fast rail alternatives.5
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ICCT urges mandatory quality standards for steel and battery recycling

6 Nov 2025
Topic — The European Commission is seeking input on proposed legislation to enhance circular production.
Message — The organization proposes harmonized quality standards for recycled steel and batteries to ensure high-grade material recovery. They also advocate for streamlined waste shipment rules and mandatory battery repairability to extend vehicle lifespans.123
Why — Stricter recycling and repairability rules would help the organization achieve its mission of cleaner transportation.4
Impact — Primary raw material producers would see decreased demand for iron ore and coal exports.5
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ICCT backs 2035 car targets and proposes credit banking

10 Oct 2025
Topic — This consultation revises the CO2 emission performance standards for cars and vans.
Message — The ICCT recommends maintaining the 2035 zero-emission targets to ensure long-term planning security. They suggest a banking and borrowing mechanism to reward manufacturers that exceed CO2 standards. They also argue that vehicle tailpipe and fuel life-cycle regulations should remain separate.123
Why — This would reward front-runners while providing manufacturers with flexibility for vehicle introduction.4
Impact — The climate suffers if the underestimated real-world emissions of hybrids are not corrected.5
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Response to Revision of the EU rules on car labelling

10 Oct 2025

We welcome the European Commission's initiative to revise the EU rules on car labelling. In a project jointly carried out with Öko-Institut e.V. and commissioned by the German Federal Environment Agency (UBA) and the German Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety (BMUKN), we developed a proposal for a revised car label. The analysis supporting our proposal and the developed label design can be found in the attached working paper.
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ICCT Urges Tax Reform to Speed Up Road Electrification

9 Oct 2025
Topic — A policy initiative to shift energy demand from fossil fuels to electricity.
Message — The organization suggests rethinking high electricity taxes and surcharges to lower operating costs. They propose smart charging solutions and pricing that reflects real electricity costs to manage grid capacity.12
Why — Lowering energy taxes would make the clean transport technologies they advocate for more competitive.3
Impact — Fossil fuel suppliers would lose market share as electric vehicles become more affordable.4
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Transport and Environment (European Federation for Transport and Environment) and Institut Mobilités en Transition

9 Oct 2025 · Automotive

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and Transport and Environment (European Federation for Transport and Environment) and Institut du Développement Durable et des Relations Internationales

9 Oct 2025 · CO2 standards for cars and vans

Meeting with Pascal Canfin (Member of the European Parliament)

26 Sept 2025 · Transport decarbonisation

ICCT urges revenue certainty for advanced aviation fuel producers

4 Sept 2025
Topic — This consultation establishes a framework to boost investment in renewable and low-carbon transport fuels.
Message — The ICCT recommends a system to provide revenue certainty directly to advanced fuel producers. They also suggest limiting or excluding mature biofuels from the current emissions trading subsidy scheme.12
Why — Shifting subsidies would accelerate the commercialization of technologies that meet the organization's environmental criteria.3
Impact — Producers of mature biofuels face losing financial support if they are excluded from subsidies.4
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Response to Clean corporate vehicles

4 Sept 2025

The International Council on Clean Transportation (ICCT) (EU Transparency # 06250094777-73) is replying to the call for evidence for the Clean Corporate Vehicles initiative. In the attached document we provide selected research and findings from recent ICCT publications relevant to decarbonizing corporate fleets. The findings are intended to support informed consultation. The ICCT is an independent nonprofit organization founded to provide unbiased research and technical analysis to environmental policymakers. Our mission is to improve the environmental performance and energy efficiency of road, marine, and air transportation, in order to benefit public health and mitigate climate change. We promote best practices and comprehensive solutions to increase vehicle efficiency, increase the sustainability of alternative fuels, reduce pollution from the in-use fleet, and curtail emissions of local air pollutants and greenhouse gases (GHG) from international goods movement.
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

3 Sept 2025 · Clean mobility

Meeting with Pascal Canfin (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment)

26 Aug 2025 · Automotive Package

Meeting with Edoardo Turano (Head of Unit Climate Action)

28 Jul 2025 · Discussion on CO2 standards for cars and vans

Response to Revision of the Roadworthiness Package

18 Jul 2025

The International Council on Clean Transportation (ICCT) supports the proposed enhancements to the EUs roadworthiness package, particularly the strengthened emission screening and inspection program. Excess pollutant and noise emissions from on-road vehicles present a serious public health and economic burden across the EU. The current roadworthiness framework, last updated in 2014, has significant shortcomings in identifying individual gross emittersvehicles responsible for disproportionately high emissions. Furthermore, current minimum EU standards for Periodic Technical Inspections (PTI) do not reflect available technological advancements that allow the detection of excessive particulate number (PN), nitrogen oxides (NOx), and noise emissions. We welcome the explicit inclusion of Remote Emission Sensing (RES) techniques and noise radars, which will significantly improve the efficiency and scope of in-use pollutant and noise emission monitoring, market surveillance and enforcement. Making RES and noise radar mandatory in all Member States would deliver substantial societal benefits aligned with the European Commissions assessment. Evidence from ICCT, The Real Urban Emission (TRUE) initiative, EU-funded projects such as CARES and NEMO, as well as established regulatory frameworks in the USA, South Korea, and Hong Kong, demonstrates that these technologies can efficiently screen both fleets and individual high-emitting vehicles. Integrating RES and noise radar into Periodic Technical Inspections and roadside checks, through effective pre-selection, would significantly enhance enforcement efficiency. We also endorse the establishment of a centralized data-sharing platform between Member States. This is essential to ensure transparency and to maximize the effectiveness of enforcement measures across the EU.
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ICCT urges EU to include batteries in decarbonization act

8 Jul 2025
Topic — The consultation addresses a new legislative framework to accelerate industrial decarbonization and competitiveness.
Message — The ICCT recommends including battery production and recycling projects within the scope of the new industrial support framework. They advocate for comprehensive product labels that account for all direct and indirect climate impacts. The organization also suggests using the automotive sector to scale up fossil fuel-free steel production.123
Why — Stricter environmental standards would give European manufacturers a competitive advantage over higher-polluting global rivals.45
Impact — High-emission international producers would lose their competitive edge against cleaner European industrial products.6
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ICCT urges EU to end private jet carbon exemptions

8 Jul 2025
Topic — The EU is reviewing its emissions trading system for aviation, maritime, and industry.
Message — ICCT recommends expanding the carbon market to include all departing flights and smaller ships. They propose removing private jet exemptions and focusing fuel subsidies on advanced technologies.123
Why — Stricter rules would help the organization achieve its primary goal of rapid transport decarbonization.4
Impact — Private aviation operators would lose their current tax-free status, significantly increasing their operational expenses.5
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

1 Jul 2025 · Studies on batteries, CO2 standards for cars and vans and life-cycle emissions

ICCT Urges Mandatory Energy Monitoring For All Electric Vehicles

13 May 2025
Topic — This consultation defines emission testing and energy monitoring requirements for light-duty motor vehicles.
Message — The ICCT requests that the Commission include electric vehicles in energy monitoring requirements. They advocate for alignment with Euro 7 standards across all powertrain types.12
Why — Acquiring standardized energy data across all powertrains supports their mission to improve transportation efficiency.3
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

21 Mar 2025 · Shipping and aviation decarbonisation

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

12 Mar 2025 · Future of the automotive sector

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

12 Mar 2025 · ICCT publications

Response to Rules for the FuelEU database under Article 19(3) of the FuelEU Maritime Regulation

7 Mar 2025

The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the draft implementing regulation Ares(2025)966724, which lays down the rules for access rights and the functional and technical specifications of the FuelEU database. To summarize our comments, we suggest the following points be considered by the Commission: (1) publish FuelEU database information in MRV Annual Reports; (2) provide more information on RFNBOs; (3) describe the use of banking, borrowing, and pooling for FuelEU compliance; (4) provide information related to onshore power supply (OPS) use and exemptions; and (5) provide annual interim reports to the public. Please find our full comments in the attached file.
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Meeting with Wopke Hoekstra (Commissioner) and

12 Feb 2025 · Dialogue on the future of the automotive sector - Thematic Working Group on 'Clean Transition and Decarbonisation'

Meeting with Sara Matthieu (Member of the European Parliament, Shadow rapporteur)

16 Dec 2024 · Discussion on Regulation on Vehicle Design and EoL Management

ICCT Urges Stricter GHG Rules for Low-Carbon Fuel Certification

24 Oct 2024
Topic — This consultation establishes a methodology for assessing greenhouse gas emissions from low-carbon fuel life cycles.
Message — The organization recommends requiring measurement of CO2 venting and fugitive emissions during production. They argue for realistic default values for methane leakage to prevent underestimating pollution. They also request complete life-cycle accounting for emissions associated with imported fuel processing.123
Why — Improved methodology prevents high-polluting fuels from receiving undeserved low-carbon certification status.4
Impact — Fuel exporters would face higher barriers if their leakage rates fail stricter assessments.5
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

10 Sept 2024 · climate & transport area

Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55 (Batch 2)

26 Jul 2024

The International Council on Clean Transportation (ICCT) appreciates the opportunity to provide feedback on this implementing act. Please find our feedback attached as a PDF file.
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ICCT urges realistic mileage and PPA inclusion for batteries

28 May 2024
Topic — This consultation establishes the methodology for calculating electric vehicle battery life-cycle carbon footprints.
Message — ICCT urges lowering assumed battery charge cycles and allowing Power Purchase Agreements for renewable energy. This ensures footprints aren't underestimated and encourages wider decarbonization.12
Why — This ensures international producers are not unfairly penalized by high-emission national electricity grids.3
Impact — Manufacturers using unrealistic mileage data lose the ability to report artificially low carbon footprints.4
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ICCT urges mandatory recycled steel targets for all vehicles

4 Dec 2023
Topic — Revision of EU rules to improve vehicle recycling and circular design.
Message — The group recommends setting a minimum recycled content for steel in production. This minimum share should be based on postconsumption scrap rather than fabrication scrap. They encourage to include all types of road vehicles in all provisions.123
Why — This would achieve their goal of significantly abating emissions from vehicle manufacturing.4
Impact — Primary steel producers will lose demand as industry shifts away from virgin materials.5
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Response to Review of the CO2 emission standards for heavy-duty vehicles

19 May 2023

The proposed revision to the CO2 standards for heavy-duty vehicles introduces one of the worlds most stringent CO2 standards for a major market. It would significantly accelerate the market for zero-emission technology vehicles, and provides a framework to increase the emissions reductions over those from the current standards. The ICCT's modelling projects that this proposal will enable a cumulative reduction in emissions of 1.8 billion tons of CO2 relative to the current proposal, roughly equivalent to 8 years of today's annual emissions from the heavy-duty sector. Despite the emissions reduction over the current standards, the proposal falls short of complying with the European Climate Law. We estimate the proposal to reduce emissions by 64% by 2050 relative to 1990, whereas the European Commission set an emissions reduction target of 90% across all transport over the same period. Increasing the targets to align with the Impact Assessments high ambition scenario - i.e., a 50% target in 2030, 70% in 2035, and 100% in 2040 - would increase these annual emission reductions in 2050 to 79%, relative to 1990. In contrast, the latest projections from major heavy-duty manufacturers on the sales share of zero-emission vehicles will reach over 60% across Europe by 2030. There is also an opportunity to expand the coverage of the standards; the proposal increases the coverage from 69% of annual HDV emissions up to 91%. Vocational vehicles are excluded from the scope but can be easily integrated. Including vocational vehicles would increase the coverage of the standards from 91% to 95% of total heavy-duty emissions and would close a potential loophole whereby a vehicle is originally reported as vocational, but later modified and used as a delivery vehicle. The change in the definition of a zero-emission vehicle allows for a truck to emit up to 9% of the emissions of a standard conventional tractor trailer while being certified as zero-emission, or 25% in the case of buses. This change in definition allows for dual-fuel hydrogen combustion engines using diesel as a pilot fuel to be certified as zero-emissions and may diminish the standards CO2 benefit, risking an increase in the cumulative emissions reduction by 130 million tons of CO2 relative to if only true zero-emission technologies were counted. Revising the allowance from 5gCO2/tkm to 1gCO2/tkm is the simplest regulatory approach, allowing for both mono-fuel and highly efficient dual-fuel hydrogen combustion engines to be categorised as zero emissions. The credit and debt system grants ample flexibility by increasing the credit life from 5 years to a maximum of 15 years. Such a long credit life risks the integrity of the standards, particularly for city buses. City buses are rapidly electrifying (18% zero-emission sales share in 2022), and based on their current trajectory, manufacturers are on track to start earning a significant number of credits once they enter regulation in 2025. The resulting credits earned will allow them to avoid a 100% reduction in 2030 for several years. Finally, we welcome the exclusion of a carbon correction factor or a fuels crediting system from the standards. A carbon correction factor would dilute the standards without any additional effort required from either manufacturers or fuel suppliers due to pre-existing obligations under the Renewable Energy Directive (RED II). E-fuels are a much less efficient use of renewable electricity compared to direct electrification. The lowest cost biofuels are unsustainable because they are made from food or feed materials, or they are made from waste oils, which carry fraud risk. Further, fuels crediting would require a significant administrative burden and may risk the integrity of the standards due to the potential of double counting with the RED II and distract manufacturers from focusing their innovation efforts toward the deployment of technologies capable of reducing vehicle CO2 emissions.
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ICCT demands tougher Euro 7 standards for cars and vans

9 Feb 2023
Topic — This initiative develops stricter pollutant emission standards for all combustion-engine road vehicles.
Message — ICCT requests significantly stricter emission limits for cars and vans to match more ambitious policy options. They advocate for extending vehicle durability requirements and expanding the conditions for real-world driving tests. They also suggest introducing new limits for harmful substances like formaldehyde and greenhouse gases.12
Why — These changes would ensure EU transport policy reflects the organization's scientific research and mission.34
Impact — Urban residents face continued health risks from air pollution exceeding global safety limits.567
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ICCT supports strict verification for co-processed renewable fuels

19 Jul 2022
Topic — Methodology for measuring biogenic content when biomass is processed with fossil fuels.
Message — The ICCT recommends that GHG calculations include natural gas inputs used to replace exported bio-propane. They also suggest explicitly listing radiocarbon testing as a primary method for determining bio-content in fuels.12
Why — These rules would protect the integrity of climate targets by ensuring bio-content claims are technically accurate.3
Impact — Economic operators may see reduced carbon benefits if they must account for fossil fuels used to replace diverted biogas.4
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ICCT supports rigorous GHG accounting for alternative transport fuels

17 Jun 2022
Topic — Establishing a methodology for greenhouse gas savings from renewable and recycled fuels.
Message — ICCT supports the methodology but requests strict accounting for electricity greenhouse gas intensity. They recommend defining recycled carbon fuels specifically as non-renewable waste streams.12
Why — Rigorous standards ensure that policy support targets fuels with significant climate mitigation benefits.3
Impact — Fuel producers with modest climate benefits lose the opportunity to receive regulatory investment.4
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ICCT Urges Stricter Real-World Emission Testing for Hybrid Vehicles

17 Jun 2022
Topic — Consultation on amending type-approval procedures for light-duty vehicle emissions and fuel consumption monitoring.
Message — The ICCT recommends adjusting the utility factor for plug-in hybrids by 2023 to reflect real-world usage accurately. They also advocate for extending on-board energy monitoring to battery electric vehicles and making transparency databases public.123
Why — Enhanced data transparency allows independent researchers to accurately verify manufacturers' emission and energy efficiency claims.4
Impact — Automobile manufacturers lose the ability to exploit regulatory loopholes and must meet more stringent reporting deadlines.5
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Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur)

9 Jun 2022 · Sustainable aviation fuels (ReFuelEU Aviation Initiative) 2021/020(COD) (Staff Level)

ICCT demands stricter methane rules for imports and renewable gases

18 Apr 2022
Topic — The EU is proposing legislation to monitor and reduce methane emissions in the energy sector.
Message — The ICCT suggests expanding the regulation to include leakage from biomethane and bio-hydrogen production. They call for importers to follow the same measurement and verification standards as domestic producers. Additionally, the Commission should set clear venting prohibition dates and volumetric emission limits.123
Why — Stricter rules would ensure that renewable fuels actually deliver the greenhouse gas savings they promise.4
Impact — Foreign energy exporters and renewable gas producers would face more expensive and complex compliance requirements.5
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Response to Revision of EU rules on Gas

12 Apr 2022

Please see the attachment for comments from the International Council on Clean Transportation.
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Response to Revision of EU rules on Gas

12 Apr 2022

Please see the attachment for comments from the International Council on Clean Transportation.
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Response to Review of the CO2 emission standards for heavy-duty vehicles

14 Mar 2022

ICCT’s general position: Heavy-duty vehicles (HDVs) play a crucial role in Europe’s efforts to move towards climate neutrality by 2050. The sector is responsible for 2.5% of total road vehicles yet contributes to 27% of the EU27’s annual road CO2 emissions, and 6% of annual total net greenhouse gas emission. Regulating the emissions of HDVs through the introduction of the CO2 standard (EU) 2019/1242 has been an important first step in the move towards targeting a decarbonization from the sector. However, the impact of the standard in its current form is limited, with ICCT analysis projecting an overall increase in HDV emissions by 2050 relative to 2019 of 8% based on the adopted policies, driven predominantly by increasing levels of activity in the coming decades. As such, The ICCT is fully supportive of amending regulation 2019/1242 to mandate an equitable contribution from HDVs in achieving climate neutrality by 2050. The HDV market has changed considerably since the genesis of the standard. All major HDV manufacturers have committed toward a considerable deployment of zero-emission HDVs over the coming two decades, with a joint pledge towards a phase out of fossil-fueled vehicles by 2040 and a sales-weighted interim target of 38% by 2030. At a minimum, the CO2 standard should be updated to reflect these commitments. ICCT analysis finds that increasing the 2030 target from 30% to at least 60%, and introducing targets for 2035 and 2040 of 90% and 100% respectively aligns with manufacturer commitments toward zero-emission HDV deployment, while still ensuring a consistent improvement in the efficiency of conventionally fueled vehicles. ICCT finds that introducing targets in line with this will achieve a 96% reduction in annual HDV emissions by 2050 relative to 2019. Extending the scope: To realize a decarbonization level in line with what is required for HDVs to comply with the EU Climate Law, it is also critical that certain modalities of the standard be amended. In particular, the ICCT recommends for the inclusion of CO2 reduction targets for vehicle groups which are already, or will soon be covered by the CO2 certification regulation. Segments already covered by the certification regulation represent 76% of annual HDV sales in the EU27, and the inclusion of buses and light- and medium-trucks will increase this value to 94%. In particular, the deployment of zero-emission buses, and light- and medium-trucks have been increasing faster than other HDVs. ICCT considers a phase-out of the conventional forms of these vehicles by 2035 to be feasible and necessary to align with the EU Climate Law. Extending the standard to trailers can save an additional 24% cumulative CO2 emission in the period 2020-2035. Incentive mechanism for zero- and low-emission vehicles: All major HDV manufacturers have already committed to deploying a zero-emission vehicle fleet far in excess of the 5% cap under the benchmark phase of the HDV CO2 Standard; to date, Renault Trucks have committed to a 35% ZEV share by 2030, Scania and Volvo Trucks have committed to a 50% share, MAN have committed to 40-60%, and Daimler up to a 60% share. These manufacturers represent 75% of all major HDV OEMs in the EU. The ZLEV factor is thus not necessary to incentivise manufacturers in its current form, and should be phased out post-2030. However, a ZEV sales requirement may be suitable for the HDVs not currently covered under the Certification Regulation (EU) 2017/2400 or its planned extension to other HDVs later in 2022, i.e., VECTO groups 0, 6, 7, 8, 13, 14, 15, and 17 as well as buses. Banking and borrowing scheme: The banking and borrowing system acts as an effective tool in incentivising manufacturers to accrue CO2 credits beyond the targets set by the regulation and trade with underperforming manufacturers. As such, we propose that it should be extended in its current form beyond 2030.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the Commission’s proposed ReFuel EU Aviation regulation. We commend the Commission for its continuing efforts to promote a cleaner, lower-carbon transportation sector that uses less petroleum-based fuels. This proposal builds upon the impressive steps the Commission has undertaken to promote low-carbon biofuels. We have attached a PDF of our comments which contain a number of technical observations and recommendations for the Commission to consider in its continued efforts to strengthen the regulation and maximize its benefits in mitigating the risks of climate change and reducing petroleum use.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Nov 2021

Please see the attachment for comments from the International Council on Clean Transportation (ICCT)
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Response to Revision of the EU Emission Trading System Directive concerning aviation

8 Nov 2021

The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the Proposal to revise the EU Emissions Trading Scheme (ETS) treatment of aviation emissions. The ICCT is an independent non-profit organization founded to provide first-rate, unbiased technical and scientific analysis to environmental regulators. The ICCT’s Aviation Team works to improve policies to reduce air pollution and greenhouse gases from aviation. ICCT’s research focuses on the potential technological and policy routes to aviation decarbonization, including efficiency standards, non-CO2 emissions, and sustainable aviation fuels (SAFs). ICCT participates in the environmental committee of the International Civil Aviation Organization (ICAO) as a technical observer for the International Coalition for Sustainable Aviation (ICSA). We thank the Commission for the opportunity to comment on this important Proposal. We suggest that the Commission consider the technical analysis and recommendations that we have attached as a PDF to this submission.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

Please find attached our evaluation, including a set of recommendations.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

28 May 2021 · Zero emission transport in the Fit for 2030 package

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

17 May 2021 · Euro 7

Response to Monitoring and reporting of Light Duty Vehicles (LDVs)

3 Dec 2020

Dear Sir or Madam, The analysis of real-world fuel and energy consumption of passenger cars and light duty commercial vehicles and comparing it to the type-approval values is a key element to ensure that real-world CO2 emission reduction follows the targets defined in regulation (EU) 2019/631. The data, if published with a sufficient level of detail, can also contribute to raise the awareness of consumers and allows to make informed purchase decisions for vehicles with a lower negative climate impact. Furthermore, the data can be used to gain a better understanding of the usage and real-world fuel and energy consumption of plug-in hybrid electric vehicles and on this basis, to improve the type approval procedure in order to determine type-approval values more representative for real-world operation. We welcome the European Commission’s initiative to define a procedure to collect type approval data and real-world fuel and energy consumption data, recorded by on-board monitoring devices (OBFCM). Collecting the data through manufacturers and during periodical technical inspection is a good bridging solution until an automated, direct transfer from the vehicle to the Commission is available. To get most value out this data, both for the environment and the society, we would however recommend to be more ambitious and transparent when it comes to publishing the data. We have performed a detailed review of the draft text and annex and provide our feedback and recommendations in the attached file. Kind regards, Jan Dornoff Senior Researcher
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

Our own analysis confirms the Commission's finding that, without further policy intervention, emissions from road transport are not on a trajectory for achieving the 2030 target and climate neutrality by 2050. We find that with the policies currently adopted, CO2 emissions from cars and vans will only decrease by about 70% in 2050 relative to 2020. Strengthening the current 2030 fleet targets, -37.5% for cars and -31% for vans, to a level of about -70% by 2030 and about 100% by 2035 would help to secure a decrease of CO2 emissions by approximately 95% by 2050, thereby much more in line with the EU's climate neutrality target. For achieving a notable reduction of CO2 emissions from cars and vans by 2030, in comparison to the adopted policies scenario, it is not sufficient to only revise the 2030 and to define post-2030 fleet targets. Instead, it is indispensable to also strengthen the current 2025 fleet target of -15%. From our detailed technology cost assessments, we conclude that the technologies necessary to achieve strengthened CO2 targets are available and are cost-efficient both, from a consumer as well as a societal standpoint. We find that electric vehicles provide the most cost-efficient pathway towards decarbonization of the cars and vans market and, in light of strengthened fleet target requirements, expect a market uptake well above 50% by 2030. As summarized in recent ICCT papers, a number of large vehicle manufacturers have already publicly announced to sell 50% or more of their new vehicles by 2030 as electric – that is under the currently adopted policies. A growing group of national governments are anticipating much higher market shares and are implementing their own requirements for the electrification of the new vehicle fleet, most recently the UK requiring 100% of new vehicles to be electric by 2030. How effective the EU CO2 targets for cars and vans are, and how quickly vehicle manufacturers can adapt their product portfolio, could be witnessed in the past months. In 2019, at a time when the 2015 CO2 target of 130 g/km (for cars) was still in place, the share of electric vehicles in Europe stayed low at 3% and the fleet CO2 level even increased to 122 g/km. With a new CO2 target of 95 g/km coming into place in 2020, from January onwards, the market share of electric vehicles began to quickly increase and the fleet CO2 level to decrease. In October 2020, the share of electric vehicles reached a level of 13%. Year-to-date, electric vehicles accounted for 9% and the average CO2 emission level had decreased to a level of 110 g/km (or 100 g/km if taking into account credits provided as part of the regulation). This corresponds to more than 1% of CO2 reduction per month, while the rate of reduction was below 1% per year in the 2015-2019 time period. It highlights the importance of annual interim targets to avoid sudden disruptions in the market and a delay of the deployment of technologies that are readily available. A recent analysis for more than 100,000 plug-in hybrid vehicles, carried out by Fraunhofer ISI and ICCT, concluded that those vehicles – on average in real-world driving – emitted two to four times more CO2 emission than according to type approval. In light of these findings, the testing procedures for plug-in hybrid vehicles, in particular the utility factor assumptions, as well as any credits for Zero- and Low Emission Vehicles should be re-considered. More generally, it is imperative to ensure a continued decline in emission levels under real-world driving conditions and not only under type approval testing conditions, for all vehicle types. With implementation of mandatory Fuel Consumption Meters for new vehicles, the necessary data for monitoring and enforcing real-world performance of manufacturers is now available to the European Commission to rapidly being made use of.
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Response to Light Duty Vehicles (LDV) monitoring - amendment of Annexes I, II and III

31 Aug 2020

We welcome the European Commission’s initiative to extend the list of CO2-relevant parameters to be annually reported by the member states to the Commission by amending Regulation (EU) 2019/631. When combined with real-world fuel consumption data, recorded by the recently introduced on-board fuel consumption meters, the additional parameters proposed for the amendment will allow a detailed analysis of the discrepancy between real-world and type-approval fuel consumption values. We have performed a review of the draft text and provide our feedback and recommendations in the attached file.
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Response to Revision of the EU Emission Trading System Directive concerning aviation

27 Aug 2020

The ICCT applauds the European Commission’s intention to secure the aviation sector’s contribution to EU climate goals. While other sectors have made significant progress in deploying renewable energy and improved efficiency to curb or even reduce their emissions, emissions from international flights in Europe have increased by 141% since 1990. If aviation emissions continue to increase unabated, the sector’s impact could pull the EU further away from its long-term climate targets. Through 2019, global airline traffic grew almost four times faster than fuel efficiency improved, and sustainable alternative fuel (SAF) penetration has remained minimal. The need for stronger regional policies to address aviation emissions is clear. 2028 efficiency standards for new aircraft recommended by International Civil Aviation Organization (ICAO) and adopted by the European Aviation Safety Agency are technology-following and were met on average back in 2016. The International Air Transport Association (IATA) notes that ICAO’s CORSIA policy is an offsetting scheme that does not promote SAFs. CORSIA has been weakened further by the large pool of eligible offsets under CORSIA’s pilot phase and the recent revision to raise the pilot phase baseline in response to the COVID-19 traffic downturn. Low and zero carbon technologies for aviation remain underdeveloped and in need of policy support. Turboelectric, battery electric, and hydrogen fueled aircraft are just starting to be developed and face technical and cost hurdles. Moreover, the levelized cost of producing the best-performing sustainable aviation fuels (SAFs) ranges from approximately two to five times the wholesale price of aviation kerosene; furthermore, aviation fuels are not obligated under the RED II. Finally, preferential tax exemption for aviation kerosene reduces the effective cost of continued fossil fuel use for commercial aviation. This background highlights the need to strengthen regional regulation of aviation emissions, including the EU ETS. The ICCT supports an immediate or swift phase-out of free allowances granted to aviation to better ensure that aviation contributes its fair share towards broader climate goals. Transitioning aviation away from free allowances would make advanced aircraft and fuels more cost competitive, while redirecting auction revenue through a mechanism such as the Innovation Fund to support the research and development of new technologies could support the long-term decarbonization of the sector. On the relative roles of EU ETS vs. CORSIA, the ICCT believes that all aviation emissions should be allocated and regulated according by the State of the airport of departure rather than by where an airline is registered. This avoids market distortions across carriers and aligns most closely with fuel sales. Furthermore, we believe that the EU ETS is in principle a much stronger and robust tool for reducing aviation emissions than CORSIA. While CORSIA is intended to stabilize emissions at close to 2020 levels using internationally sourced offsets, the EU ETS has an ambitious, economy-wide binding 2030 target. The ICCT recommends applying the EU ETS on all flights departing EU/EFTA airports, including air travel between intra-EU/EFTA aerodromes. Incoming flights could be subject to CORSIA requirements based upon the decision of the state from which those flights depart. We note that this approach raises the possibility that some international and intra-EU flights could be subject to both EU ETS and CORSIA obligations. Those requirements could be justified given that the non-CO2 climate impacts of aircraft, which are believed to be of the same order of magnitude as CO2 and are not covered under either system. Alternatively, we expect that double obligations for carriers could be avoided via negotiations under bilateral service agreements, and that CORSIA could be modified as needed at ICAO’s 41st Assembly in 2022 to avoid overlapping obligations.
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Response to FuelEU Maritime

24 Apr 2020

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the FuelEU Maritime inception impact assessment roadmap. We approve of the Commission’s intention to support the decarbonization of the marine sector. The comments below offer a number of technical observations and recommendations for the Commission to consider in its development of a work programme under the initiative. The Commission has correctly identified some of the primary barriers to the uptake of sustainable alternative fuels in the marine sector, particularly the high cost of alternative fuels relative to conventional marine fuels. Furthermore, in the absence of carbon pricing through either the International Maritime Organization (IMO) or under the European Emissions Trading Scheme (ETS), there is little incentive to transition to more expensive, lower-carbon fuels. The ICCT has identified the high cost of alternative fuels to be a much larger barrier to decarbonization of the maritime sector than fuel compatibility; there are already several existing or near-term alternative fuels that would be usable in marine engines. It is critical that any proposed alternative fuel policy for the maritime sector incorporates rigorous life-cycle accounting that takes into account the full, well-to-wake greenhouse gas (GHG) emissions attributable to alternative fuels. In the absence of life-cycle accounting, there would be a large risk of carbon leakage upstream due to fuel production and during use. ICCT’s analysis has also demonstrated that in many cases LNG fails to provide any carbon savings relative to conventional marine fuels when evaluated on a life-cycle basis, when upstream leakage and methane slip are included. Similarly, food-based biofuels could even increase emissions relative to heavy fuel oil; several rounds of indirect land-use change modeling by experts have indicated that additional demand for food-based biofuels—particularly oilseeds such as rapeseed and palm oil—is linked to deforestation and high indirect emissions. In order to ensure that a fuels policy for the maritime sector has long-term policy certainty and would generate genuine GHG reductions, we recommend that the Commission prioritizes innovative fuel pathways that offer the greatest carbon reductions, rather than LNG or first-generation biofuels produced from food crops. Suitable pathways include fuels produced from wastes and residues using novel conversion technologies as well as electrofuels produced using additional, renewable electricity. The quantity of wastes and residues is likely to be constrained, and care should be taken that policies promote feedstocks that are currently under-utilized, rather than the diversion of these materials from existing uses. Ensuring long-term success for advanced alternative fuels will necessitate direct policy support over the next decade to foster the development of pilot projects, allowing for technology learning and scaling up to lower costs over the long-term. Of the policy options discussed in the inception impact assessment roadmap, the ICCT recommends measures to boost the uptake of marine fuels through facilitating access to funding for emerging technologies, rather than any prescriptive blending requirements for sustainable alternative fuels; blending mandates present a high risk of technology lock-in to unsustainable biofuels. Funding will be needed for fuel production, bunkering infrastructure, plus shipside demonstration. Despite its low energy density, an ICCT scoping study on hydrogen use in transoceanic container shipping suggests that bunkering challenges may be manageable even on deep sea routes. Prioritization of maritime alternative fuel use over other transport sectors, such as with revisions to the multiplier for fuels within the RED II could prove counter-productive, diverting existing production from uses in the road sector without a net climate benefit.
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

24 Apr 2020

ICCT welcomes the development of Euro 7/VII standards. Of the preliminary set of policy options put forward by the Commission, ICCT favors Option 3. Below ICCT’s recommendations. Further details can be found in the file attached. RECOMMENDATIONS FOR EURO 7 (LDV) Emission limits should be fuel-, technology- and application-neutral. The limits should be tightened to reflect the technical feasibility and to harmonize with other markets. To limit CO emissions, fuel enrichment as an auxiliary emissions strategy should be out ruled and CO should be added to RDE. PN emissions should receive renewed attention, lowering the cutoff size from 23 nm to at least 10 nm, developing a methodology to measure (semi-) volatile particles, and setting limits for brake wear particles. Low temperature limits should be tightened, and limits should be set for a wider set of pollutants. Unregulated pollutants should now be tackled. Limits should be placed for ammonia, aldehydes, and VOCs. Furthermore, non-CO2 GHG emissions, most notably N2O, should be regulated. For petrol vehicles, the evaporative emission provisions should be revised. The EVAP limit should be tightened and an on-board refueling emissions standard introduced to drive the adoption of ORVR systems. Furthermore, the EVAP test procedure should be improved by, at least, increasing the temperature during hot-soak, and introducing requirements for leak monitoring. The RDE provisions should be revised. The boundary conditions for RDE tests should be extended, such as the driving dynamicity limitats, vehicle speed requirements, cumulative elevation gain, and amb. temperature range. Furthermore, the trip requirements should allow shorter urban sections and cold-start driving. The RDE evaluation factor for adjusting emissions downwards should be eliminated. RECOMMENDATIONS FOR EURO VII (HDV) NOx limits should be tightened. Commercially available emission controls allow setting lower NOx limits than those in place today. Focus should be placed on cold-start emissions and low-load operation. Emission limits should drive the adoption of technologies that simultaneously reduce NOx and CO2. Tighter NOx limits do not necessarily make it more difficult to comply with CO2 standards. The PN size cutoff should be lowered from 23 nm to at least 10 nm and include (semi-) volatile particles. Emissions that occur during the regeneration of the aftertreatment in on-road ISC tests should be considered. Stringent certification limits for N2O should be introduced, including on-road in-service conformity provisions. Regarding the evaluation methodology for in-service conformity PEMS tests, all valid windows in the evaluation methodology should be used for compliance. Furthermore, the minimum power requirements for window validity should be eliminated. Urban driving should be prescribed, with cold-start being better captured in on-road tests. To ensure adequate performance in challenging urban conditions, a low-load cycle for engine certification, in addition to the WHTC/WHSC, should be added. The limit should be stringent enough to drive the adoption of technologies targeting low-load and low-speed operation. Furthermore, strict idling standards should be introduced to drive the adoption of aftertreatment active thermal management and for reducing idling. COMMON RECOMMENDATIONS FOR EURO 7/VII The durability provisions should be significantly revised. The useful life for durability demonstration should be extended. The age/mileage requirements for in-service conformity should be extended to the full useful life. A new minimum emission warranty program should be introduced, together with a complementary defect tracking and reporting program. On-board monitoring (OBM) of pollutant emissions should be introduced, and the OBD requirements should be aligned with best international practices, enabling strong anti-tampering provisions. OBD/OBM systems should be compatible with PTI programs.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the inception impact assessment for the ReFuelEU Aviation Initiative. The Commission’s suggestion in the roadmap that food and feed-based fuels have limited potential for decarbonization is sound and evidence-based. Future SAF policy must leapfrog the road sector’s reliance on food-based biofuels and instead set a clear policy signal that prioritizes advanced alternative fuels. Therefore, we recommend that any future SAF policy prioritizes those fuels produced from wastes & residues or additional, renewable electricity with over 70% carbon reduction relative to conventional, petroleum jet fuel on a life-cycle basis. Europe’s experience with the RED implementation illustrates that the quantity of alternative fuels supplied to the market is not necessarily an indicator of GHG reductions. The use of food-based fuels not only created political uncertainty due to the controversy over competition with food, but also undermined the climate benefits of the policy due to indirect land-use change (ILUC) emissions. Multiple rounds of indirect land-use change modeling by the European Commission and by the International Civil Aviation Organization (ICAO) suggest that ILUC emissions for food-based biofuels are high enough such that these fuels’ emissions would either approach or exceed those from conventional petroleum fuels on a life-cycle basis. Policy targets for SAF deployment will be most effective if they are both sufficiently ambitious to contribute towards the eventual decarbonization of the sector and work within the constraints of availability of SAF feedstocks. ICCT recommends that as part of its forthcoming impact assessment, the Commission considers EU feedstock availability for feedstocks suitable for the expected SAF conversion pathways during the policy timeframe. HEFA fuels comprise the vast majority of existing and near-term SAF production; these fuels are primarily manufactured from waste oils. The bulk of EU waste fats and oils are already utilized to produce biodiesel and renewable diesel for the road sector; further incentives would likely just shift this resource from its existing uses towards the aviation sector without a net climate benefit. There is low potential to increase production of these feedstocks through increased collection. Domestic lignocellulosic feedstocks that qualify under Annex IX List A of the RED II are available in much larger quantities than waste oils. These feedstocks are largely unutilized by the road sector and can therefore be used in aviation without impacting the road sector’s climate ambitions. Our research suggests the most effective policy support to support SAFs would be an auctioning mechanism in conjunction with facilitation of purchase agreements between SAF producers and airlines. The central auctioning authority could invite bids from advanced fuel projects meeting feedstock and sustainability criteria, de-risking the transition to advanced fuels pathways. Long-term policy uncertainty, in conjunction with crowding out by first-generation biofuels, has historically been a barrier to the deployment of advanced biofuels. An SAF blending mandate may not be the most effective policy, particularly for the 2030 timeframe. We note that a high target in excess of advanced fuel feedstock availability may either simply divert waste oils already used in the road sector or incent the use of cheaper, food-based fuels to meet the target in the near-term, thereby undermining policy certainty and the climate benefits of the policy. Similarly, revising the multiplier for aviation fuels within the RED II would not likely be effective. This change would do little to drive overall transport sector decarbonization; increasing the multiplier would shift more fuel to the aviation sector from the road sector, and at a higher policy cost, without a net climate benefit.
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

13 Feb 2020 · Review of EU light-duty CO2 standards

Response to Amendment to Implementing Regulations (EU) 2017/1153 – clarification of WLTP measured values

3 Sept 2019

Dear Sir or Madam, we welcome the European Commission’s initiative to improve the Regulation (EU) 2017/1153, which sets a methodology to determine the WLTP to NEDC CO2 correlation parameters for M1 passenger vehicles that emit CO2 emissions. The changes proposed in the draft document significantly improve clarity of how to apply the regulation and correct some errors. We have performed a review of the draft text and provide our feedback and recommendations in the file attached. Best regards, Peter Mock
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Response to Amendment to the emissions type approval testing for heavy-duty vehicles with portable emissions measurement systems

14 Jun 2019

ICCT welcomes the Euro VI, Step E proposal as it brings two crucial elements to the Euro VI PEMS framework: Cold-start emissions and PN requirements. Still, the proposal does not guarantee the Commission’s intent in addressing cold start emissions. As proposed, the data evaluation only starts once the coolant has reached 30C. The rationale being to align with the cold-start definition on the engine dynamometer, as per UN R49. While ICCT recognizes that alignment with existing definitions of cold-start is an important aspect, we argue that the current Euro VI-E proposal does not achieve that. UN R49 establishes heat to be naturally or forcibly removed from the engine and aftertreatment; that is, the engine is allowed to go from a warm state to a colder one. Furthermore, UN R49 establishes a 20-30C range for not just the coolant, but also for the aftertreatment. The Euro VI-E proposal is not in-line with UN R49 as it does not set requirements for the aftertreatment temperature, thereby allowing heat to unevenly build-up in the aftertreatment instead of requiring its removal. The LDV RDE regulation defines a vehicle conditioning before cold-start. The vehicle must be driven for at least 30 min, and then cold soaked between 6 and 56 hours at ambient conditions. The cold-start data evaluation begins at ’test start’, defined as the first ignition of the engine or movement of the vehicle. The Euro VI-E proposal is not in-line with the LDV Regulation, as the data evaluation does not begin at ’test start’ and does not require a preconditioning or a cold soak. Although artificial warming up of the emission control systems is prohibited by the proposal, this is not unambiguously defined. By the time the coolant temperature reaches 30C in a test at -7C ambient temperature, the aftertreatment warms up close to the activation temperature of 200C. This is no longer a cold-start and it is not clear if this would constitute an “artificial warming up.” To align the cold-start definition with existing regulations, ICCT suggests extending the cold-start temperature requirements to also include the emission control system; and to start the data evaluation at test start. Amendment suggestion: "2.5.5 Vehicle conditioning Before testing, the vehicle shall be driven for at least 30 min, and then soaked between 6 and 56 hours at ambient conditions. 2.6.1. Test start For the purposes of the test procedure, ’test start’ shall mean the first ignition of the internal combustion engine or the first movement of the vehicle with speed greater than 1 km/h. … The coolant, lubricant and emissions control system temperature shall not exceed the ambient temperature by more than 2C nor shall it exceed 30C at test start. The data evaluation shall start at test start." TIMELINE: In the proposal, the implementation of the regulation for gas engines is 24 months later than the implementation for diesel engines. ICCT is cognizant of the different nature of particulate emissions of gas engines compared to diesel, and of the challenges in piston and ring-pack design to minimize oil combustion and wear. Yet, we disagree about the technical barriers for the applicability of particle filters in gas engines. A 14-year-old field-trial in the US already found that adding an off-the-shelf filter to the aftertreatment of a CNG HD engine (transit bus) reduced the PN emissions without adverse effects. ICCT acknowledges that the soot and ash cake formation will be different compared to diesel exhaust. Yet, there are lubricant and filter design parameters available to tailor the filtration characteristics. For example, low-ash oil formulations are already available for CNG engines and filter manufacturers have different materials, geometries, and pore characteristics, to satisfy OEMs’ requirements. ICCT recommends reducing the difference in implementation between gas and diesel from the currently proposed 24 months to the originally proposed 12 months.
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Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

19 Feb 2019

Please find attached research and technical analysis related to this draft delegated act from the International Council on Clean Transportation.
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Response to Improving the emissions legislation for Light Duty Vehicles

5 Apr 2018

The International Council on Clean Transportation (ICCT) welcomes the European Commission’s public consultation for this new draft regarding the RDE 4th package and WLTP 2nd act regulations. The ICCT believes in the necessity of its rapid implementation with the necessary revisions detailed in the attached document.
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Response to Post 2020 light vehicle CO2 Regulation(s)

8 Feb 2018

The annual CO2 reduction rates in the EC proposal are less ambitious in absolute and relative terms than the current 2020/21 regulations and fall short of the rate of reduction recommended by the European Parliament in 2013. According to the EC’s impact assessment, meeting its long-term climate goal would require that “by 2050, electrically chargeable vehicles [. . . ] represent about 68–72% of all light duty vehicles on the roads.” Yet EC modeling estimates electrically chargeable vehicles would account for less than 20% of new car sales by 2030 under the LDV proposal. The EC proposal, together with potential HDV standards with moderate ambition, would reduce CO2 emissions from road transport by approximately 1.4% per year from 2020 to 2035. To meet the 2050 climate goal, road transport CO2 emissions would then have to be reduced more than three times as quickly (5.5% per year) from 2035 to 2050. More ambitious LDV and HDV CO2 standards for 2021–2030 would reduce road transport CO2 emissions by 3.0% per year from 2020 to 2035 and substantially increase the likelihood of meeting the 2050 climate goal. The EC’s technology cost curves for passenger cars indicate a 30% CO2 reduction by 2030 would maximize consumer benefits (fuel savings minus technology costs), whereas up to a 40% reduction by 2030 is cost-effective (fuel savings exceed technology costs). Yet the EC’s final cost curves discount the benefit of mass reduction and do not consider the cost reductions achievable by eco-innovation technologies. ICCT’s cost curves indicate much higher CO2 reductions are achievable at reasonable additional manufacturing costs. With ICCT cost curves, both consumer benefits and net benefits for society (consumer benefits plus the value of avoided CO2) would be highest with a CO2 reduction of 70% for cars by 2030. For vans, all scenarios assessed by the EC result in a net benefit for society. The highest consumer benefits (from a societal perspective) are achieved, according to the EC figures, with a 40% reduction by 2030. Hence, the EC’s analysis justifies a more ambitious target for vans than is included in the EC proposal. The proposed sales targets for zero-emission and low-emission vehicles (ZLEVs) incentivize greater deployment of electric vehicles and also, importantly, push these future electric vehicles to achieve greater electric range over time. However, the ZLEV provisions do not take into account some recent announcements of higher future market share goals by major European manufacturer groups. Essentially the ZLEV credits are rewarding car manufacturers with less stringent CO2 reduction requirements for deploying electric vehicles in numbers consistent with what they have already announced they plan to do. To ensure a greater and more predictable market penetration of electric vehicles that is more in line with long-term climate stabilization, the regulations could set more stringent CO2 reduction targets, change the ZLEV targets to incorporate a two-way adjustment scenario, or change the ZLEV targets from rewards to enforceable requirements with a penalty mechanism. The transition to WLTP introduces an element of uncertainty regarding the absolute CO2 target levels for 2025/30. Depending on the development of the vehicle market between now and 2020, the proposed EC target values are likely to move further away from the CO2 reduction range originally envisioned by the European Parliament. Without regularly adjusting the slope for the vehicle mass vs. CO2 relationship or shifting away entirely from a mass-based CO2 target system, under the current EC proposal manufacturers would have an incentive to increase the mass of their vehicles to comply with the regulatory requirements. As an alternative approach, defining 2025 and 2030 CO2 targets in absolute (g/km) terms, applying a technically sound NEDC-WLTP conversion factor, would provide more planning security and would eliminate potential for gaming.
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Response to Heavy Duty Vehicles CO2 emission standards

13 Dec 2017

ICCT agrees with the European Commission (EC) in section A. In 2017, India finalized the 1st phase of their HDV efficiency stds., bringing the global total to 5 regions with finalized stds. ICCT studies show that there is significant near-term potential to cost effectively improve HDV efficiency with available tech. There are 4 key barriers preventing the uptake of these tech: Uncertain return on investment, Capital cost constraints, Split incentives, and Lack of tech. availability. To ensure the curbing of CO2 from HDVs, the competitiveness of the EU HDV industry in the international arena, and reducing the costs of transport operators, it is indispensable to introduce HDV CO2 stds. TTW CO2 stds. represent the single largest regulatory lever that policymakers have to improve HDV efficiency. Efficiency stds. are not the place to dwell into WTT considerations. These should be addressed in separate regulatory measures e.g., the Renewable Energy Directive. ICCT has the following comments regarding section B.: Non-binding targets and market forces alone are not sufficient. In 1998, LDV automakers signed a nonbinding agreement to reduce the CO2 to 140 g/km by 2008. By 2006 it was evident the target would not be met and the EC announced mandatory CO2 stds. The difference of the voluntary and mandatory approaches is evident; until 2007, the annual CO2 reduction averaged 1%, while since 2008 it has averaged 3.5%. A successful HDV CO2 std. must have the following components: (1) Whole vehicle stds. (2) Separate engine stds. (3) Separate trailer stds. Including separate engine and trailer stds. would have significant benefits in the EU and the work already done to support the US std. would be useful to simplify the EU’s efforts. The existence of special purpose vehicles (SPV) within the regulated vehicle groups (VG) should be addressed. However, these SPV should not be exempted from the std. but addressed with separate targets and mission profiles. SPV mainly belong to the non-regulated VG, 11-17. Their share in the regulated groups should be limited. A robust identification of the SP veh. is necessary. The stds. should set absolute CO2 targets for a fixed date of application. A first stage std. should be able to use the lessons learned for future stages. It is recommended to set targets for 2025 and commit for targets for 2030. Under a clear certification procedure, the metrics g/t-km and g/km are equivalent since they are tied to the fixed payloads in VECTO. The weighting between the 10% and reference payload levels should reflect the actual use of the VG. The upcoming CO2 stds. should also include provisions to incentivize the adoption of low and zero emission HDVs in the form of mandates or credits. The targets should be set over weighted mission profiles and payloads. The weighting should reflect the VKT distribution and reflect the share of empty trips of the VG. Rethinking the segmentation at this late stage, to account for utility, carries risks. The number of subgroups arising from the utility consideration should be kept to a minimum. For example, appropriate weighting of the Long Haul and Regional Delivery mission profiles is sufficient to address the usage of the veh., without resorting to cabin differentiation. Flexibilities should provide opportunities for OEMs to introduce tech. and reduce cost, without compromising overall environmental objective. However, these flexibilities require careful oversight and transparency. The negative impacts of the flexibilities should be carefully documented in the final IA. E.g., transferring between VG should not be permitted. It may be easier to comply in one VG and not advance technologies in the other, creating market distortions. E.g., credits should have a limited lifetime. Otherwise, today’s best in class OEM will accumulate credits at a rate that might make justifiable a delay in product deployment in the future. 5 supporting ICCT studies attached
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Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

22 May 2017 · Electric vehicles

Meeting with Jos Delbeke (Director-General Climate Action)

17 Mar 2017 · CO2 emissions from transport

Meeting with Jos Delbeke (Director-General Climate Action)

15 Dec 2016 · Low emission mobility

Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

8 Dec 2016

The International Council on Clean Transportation (ICCT) congratulates the European Commission for introducing this draft and we encourage a rapid implementation of the 3rd RDE package, which is a clear step forward toward lower real-world emissions. The introduction of a PN limit combined with a cold engine start test is welcomed and is likely to enhances the use of improved emissions control technology, especially for vehicles equipped with gasoline direct injection engines. Since the urban driving emissions limit has to be met separately and includes the cold start, these new provisions are expected to substantially reduce emissions in cities where public exposure is greatest. The ICCT requests that the comments below be considered for integration into this or future regulations: 1) PN Limits: The PMP sampling protocol contains a size cut-off of 23nm, excluding from measurement any particles of smaller size that may be harmful to public health. In the case of any future revision to the PMP sampling protocol, including changes to lower the size cut-off, revisions to the RDE regulation will be necessary. We recommend that RDE make direct reference to PMP and provide a mechanism to harmonize it with any future change. 2) Cold Start Test: The fact that the engine can be kept idling up to 30 seconds before moving the vehicle is non-representative of most normal driving behavior. Therefore, at least one cold start test should be performed with initial idling of less than 5 seconds to ensure that emissions control strategies are not optimized for 30 seconds of idling prior to driving. 3) DPF Regeneration: The expected reduction in real-world NOx emissions from RDE compliant cars may lead to an increase of DPF regeneration events in real-world conditions due to the likely increased use of EGR over a wider portion of the engine’s operating conditions. It is unclear if the current method for determination of Ki factors performed in type-approval conditions reflects the real-world occurrence, duration and emissions impact of regeneration events. It would be useful to conduct real world tracking of DPF regeneration events to ensure Ki factors are representative of real world DPF regeneration. 4) Data Transparency: It is currently impossible to access publicly available RDE data online without knowing the exact type, variant, and version of the vehicle. Therefore, we appreciate the addition of the text that allows for a wildcard search of the data. We believe that it is important to not only include the PEMS test results in the publicly available data, but to also include the RDE conditions, such as ambient temperature and pressure range, dynamic criteria, trip composition, distances and average speeds, cumulative altitude gain, payload and stop percentage. This data will be important to determine if the range of RDE testing conditions is in line with the range of driving conditions in the EU. 5) Small Volume Manufacturers: Independent small and ultra small volume manufacturers have specific exemptions. The term “independent” should be defined more precisely in order to avoid a case where manufacturers that belong to larger manufacturing groups are able to unfairly claim the exemption. 6) Extended documentation: We appreciate the new requirement to submit documentation that lists and justifies any use of an AES. That being said, it should be noted that documentation submissions alone are probably not enough. It will ultimately be up to the Type Approval authority to have both the expertise and the will to analyze the documentation and ask appropriate follow up questions to the manufacturer in order to ensure all AES requests are technically sound. It is still unclear whether European Type Approval authorities will be willing and able to take such steps to prevent the widespread use of illegal defeat devices. The ICCT is looking forward to the implementation of the proposed draft with any necessary revisions.
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Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

22 Nov 2016 · Biofrontiers report

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

24 Oct 2016 · Presentation of Biofrontiers report

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

21 Sept 2016 · Standards for LDV/HDV

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

1 Jun 2016 · Low-emission mobility

Meeting with Jos Delbeke (Director-General Climate Action)

31 May 2016 · Decarbonisation of transport

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

8 Mar 2016 · decarbonisation of transport – position of ICCT