Transport for London
TfL
Transport for London (TfL) is the integrated transport authority responsible for delivering the Mayor of London’s Transport Strategy and, especially as a result of the COVID-19 pandemic, for continuing to keep London moving safely and sustainably.
ID: 955065910148-41
Lobbying Activity
Response to Sustainable and Smart Mobility Strategy
6 Aug 2020
On behalf of Transport for London, we welcome the opportunity to comment on the Road Map for a Sustainable and Smart Mobility Strategy. Thank you for the opportunity. Please see our comments in the attached two page document. We will be responding more fully to the main consultation.
Read full responseResponse to Evaluation of the Alternative Fuels Infrastructure Directive
20 Mar 2019
Our high level comments are as follows:
Data availability
Data, both public and private, on charging point location and utilisation is crucial for planning a network of alternative fuel infrastructure. Member states should maintain accurate and up to date national charging point registries of public and private alternative fuel infrastructure and make this data freely available in accessible formats.
Central coordination bodies
Given the highest density of alternative fuelled vehicles will be in cities, Member States should require cities to establish central coordination bodies for their geographic areas to facilitate charge and refuelling point installation. These coordination bodies should provide advice, guidance and manage data on charge and refuelling point availability.
Cleaner vehicles placed on the EU market
Measures such as mandatory targets or quotas at an EU level should be introduced to ensure OEMs place more alternative fuelled vehicles on the European market. Current wait times for these vehicles are long, partly because OEMs sometimes prioritise markets outside Europe.
Sharing best practice
The European Commission should bring together stakeholders in an EU-level Platform to share best practice, business case models and deployment strategies.
Read full responseResponse to Economic Equilibrium Test for national rail regulatory bodies
18 May 2018
We (TfL) consider that the criteria proposed for the economic equilibrium test are appropriate, with the exception of the evaluation of the impacts on performance and timetable planning. These are already considered as part of the access planning process so there is no need to consider them again as part of any economic equilibrium test.
It is important that the regulatory bodies have the ability to interpret the various criteria listed in a flexible manner, weighting them according to their own domestic priorities which may vary across member states depending on the degree of concern attached to financial (as opposed to economic) concerns. Some of the criteria listed such as competitive responses may be difficult to define and analyse so the framework for the test needs to recognise this.
Read full responseResponse to Improving the emissions legislation for Light Duty Vehicles
5 Apr 2018
The Mayor of London, through the Greater London Authority, is responsible for transport and environment in Greater London. Below is the GLA feedback on the amendments to improve light vehicle tests and procedures.
WLTP testing.
The introduction of the WLTP is very welcome as it better represents real driving conditions. Furthermore the updates to CO2 and fuel consumption monitoring are welcome providing far more meaningful data for vehicle buyers and for authorities.
RDE testing.
It is encouraging that the RDE legislation has been finalised, in particular, that the methodology for calculation of final results has been defined. The reduction in conformity factor from 0.5 to 0.43 is welcomed, but this figure must be kept under review and further reduced as soon as technology permits. It is imperative for city authorities, especially in Northern Europe, that after-treatment systems remain functional at realistic operating temperatures to ensure the control of NOx and PM. For this reason the GLA has previously expressed a view on Transfer Functions, which are unhelpful to the control of emissions under all operating conditions.
In-service conformity testing
The GLA believes that in-service conformity testing is vital to ensure that type approval utilising RDE is a robust and credible regime to ensure that new vehicles comply with legislation and that the confidence of the public and authorities is restored in the type approval mechanism. The success of euro VI for heavy duty engines should be repeated for light duty vehicles as soon as possible. In this regard it is reassuring that the type 1 tests have been updated and will be augmented with evaporative emissions testing.
Hybrid light duty vehicles.
The GLA would reiterate that a satisfactory methodology to perform RDE testing of hybrid and alternative fuel vehicles is urgently needed. Account should be taken of the specific performance features of these vehicles (eg EV range) so as not to disadvantage this technology type. Whilst a technology neutral approach is important, maintaining neutrality requires that the test methodology is suitable for the technology type. This is vital to encourage uptake of hybrid and plug-in light duty vehicles. At the earliest opportunity, a City Environment Zero-Emission Range duty cycle should be established for this purpose.
Multistage vehicles.
The GLA would advocate that multistage vehicles should be exempt from the RDE requirements, which are too onerous upon SME bodybuilders. The results from an OEM tested and approved sister vehicle should be allowed to stand for multistage vehicle approvals, unless the work of the body builder interferes with previously approved engines and emissions control systems on the vehicle in a way likely to affect their performance.
Transparency.
It is vital to ensure that good transparency exists in the type approval process to restore government and public confidence in the industry. Measures to improve test laboratory accreditation are therefore welcome. Furthermore, the requirement for type approval authorities to publish annual reports on the approval and test activity will be useful for
authorities needing to act on air pollution. To this end, it is important that ensure that OBD information is available to type approval authorities and also, at an appropriate level, to city authorities to assist in the design of pollution control schemes.
Read full responseResponse to Recast of Regulation (EC) 1371/2007 on rail passengers' rights and obligations
14 Nov 2017
Dear Sir/Madam,
I have the following points to raise in relation to the Commission's proposed revisions to Regulation (EC) 1371/2007 on rail passengers' rights and obligations:
• The exemption for urban, suburban and regional services should be retained, as otherwise there is the potential that metro networks could be drawn into various commitments that could prove onerous, particularly in the area of ticketing. It is important that the current exemptions available for these services are not eroded by the revised Regulation;
• The requirement to give passengers basic information on their rights at the time they book their ticket is potentially costly in the context of transactions at stations involving staffed ticket offices and ticket machines. A practical solution is needed here such as the printing of a web address on all tickets that provides further information on passenger rights. The integration of this requirement with electronic ticketing media including smartcards and contactless also requires careful consideration as there is no practical way of providing this information when customers touch in or out using such media. Alternatives such as posters at stations and internet based information should therefore be considered. The latest generation of ticket machines that are now being installed by TfL display a short message at the point of sale which provides a link to the terms and conditions pertaining to the ticket sold on the National Rail website; information on the rights and obligations contained within the Regulation could potentially be provided using this approach;
• The requirement to avoid discrimination in terms of currency of payment is problematic in the context of cash transactions at ticket offices or ticket machines. It is unreasonable to expect these facilities to accept all EU currencies so a more practical proposition I needed here e.g. limiting this requirement to credit/debit card payments where exchange rates can automatically be applied. Even this approach can lead to additional costs so it is important that these are considered as part of the deliberations over the Regulation;
• The requirement for Infrastructure Managers to publicize their contingency plans to protect and assist passengers in the event of major transport disruptions is also potentially problematic as it could raise security concerns if it indicated to terrorist groups how such disruption is managed. Such plans should exist and staff should be well briefed on them however there should be no requirement for these to be made public;
• Requirements for the supply of information in accessible and other formats should permit the usage of electronic formats rather than requiring the use of paper formats to minimize the costs incurred for the provision of this type of information;
• Requirements to sell through tickets should be expressed carefully to avoid the need to sell tickets valid for international travel from small, local stations as this would be disproportionate and cause significant additional costs to be incurred.
Regards,
Alan Smart,
Transport for London.
Read full response7 Dec 2016
The Mayor of London, through the Greater London Authority, is responsible for transport and environment in Greater London. Below is the GLA feedback on the RDE3 package.
We ask that the European Commission (EC) reconsider the 5 min calculation and ensure that cold start emissions accurately represent urban driving conditions. Given the pressure upon cities to ensure compliance with air quality regulations, it is vitally important that the RDE test is optimised to help control emissions in these sensitive areas, where human exposure is highest. The EC has established that more than 30 percent of car trips in Europe are of less than three km in length, so cold start emissions are a significant proportion of these journeys. It is therefore important that the RDE test cycle is considered in two parts, such that the 5 minute cold start section is counted as part of the urban section as well as being counted as part of the overall driving cycle. This will ensure that sufficient weight is assigned to the urban section. This straightforward approach is preferable to a protracted debate about weighting factors.
We support the proposal to introduce Particulate Number testing in 2017 for new types and 2018 for all new vehicles. Whilst there have been proposals to delay the introduction of particle number testing to align it with the NOx testing implementation dates, the requirement for PN testing was set out in regulation 715/2007 when Euro 5 was defined. As such, the GLA group see no reason for further delay and would encourage the EC to keep to the current timetable of 2017 for new types and 2018 for all new vehicles. The control of fine particles is particularly important in urban areas to protect human health, given the rapidly increasing number of gasoline direct-injection vehicles.
In the interests of transparency, the results of RDE should be published, and recorded on the certificate of conformity, making it visible to vehicle owners and to inform buyer decisions. The information should include the test result and the level of conformity factor that this result represents. OEMs could use this information in their marketing so that the cleanest vehicles can be identified and understood by vehicle buyers. This would be a departure from the arrangements put in place by ACEA which require the vehicle identification number (VIN) in order to access the test results. The RDE results could be published by type approval authorities. This would improve market transparency by supporting new car labelling schemes and marketing tools.
It is vital to resolve the issue of how to represent the zero emissions mode for plug-in hybrids on the RDE test. The current measure using raw emissions data does not fairly represent the performance of hybrids and will communicate the wrong message to vehicle buyers. The Mayor of London has a vision for urban road vehicles to be zero-emission as soon as possible. It is important that hybrids are correctly represented in RDE to support this objective.
Careful consideration should be given to the way that regeneration events for after treatment systems are monitored to avoid opportunities for data manipulation. One potential solution is to monitor exhaust temperature, rather than by any electronic means, to detect regeneration events.
Conformity factors for NOx testing in RDE (set at 2.1 moving to 1.5) should be reviewed annually. PEMS equipment is relatively new and the manufacturers may improve correlation between these systems and laboratory analysers, allowing the conformity factor to be reduced towards one, at an early date.
It is of vital importance that the 3rd package of RDE measures is ratified by the European Parliament and implemented as soon as possible. Above all, it is important to avoid protracted or nuanced debate that would delay the establishment of RDE within the type-approval procedure. Any delay will set back the dates by which urban air quality targets can be met.
Read full response