emissions of pollutants in use as well as minimal CO2 emissions in its production and use: this is exactly why ASEVs could make a significant contribution to solving local mobility problems.

In 2013, the European Commission introduced the concept of Sustainable Urban Mobility Planning (SUMP), which was well received by cities and municipalities across Europe. This provided the basis for sharing experiences and learning from best practices, by supporting the creation and updating of hundreds of urban mobility plans.

The original concept was updated in 2023, taking into account new EU strategies and policy priorities, while maintaining the original philosophy. In March 2023, the Commission adopted a Recommendation calling on each Member State to establish a national program with a dedicated office to support cities in sustainable urban mobility planning. National SUMP support programs should include guidance material, training programs and capacity building, and provide technical expertise and financial support to cities.

The proposal also includes the introduction of performance indicators for these SUMPs. They are called UMI for Urban Mobility Indicators and relate to the 7 main categories of final objectives of SUMPs, namely (i) reduction of injuries and fatalities; (ii) modal split; (iii) noise; (iv) air pollution; (v) congestion; (vi) greenhouse gas emissions; and (vii) access to mobility services.

While the objectives and areas covered by SUMPs are those of large cities, the Commission is careful to specify that "a SUMP should cover the entire functional urban area (a city and its commuting zone), taking into account real traffic flows". A SUMP should foresee cooperation and synergies between all levels of government, local, regional, national and across different policy areas. It should be prepared in partnership with local residents and stakeholders. It ensures a variety of sustainable transport options for the safe, healthy and fluid passage of people and goods, with all due consideration for fellow residents and the urban environment.

Due to their characteristics, namely lower mass and dimensions compared to other vehicles as well as the electric traction system, the use of ASEVs in urban, peri-urban and semi-rural areas contributes directly to the reduction of injuries and fatalities, noise, air pollution and greenhouse gas emissions during operation. In combination with other approaches that go beyond their specific contribution, ASEVs can efficiently contribute to the implementation of modal split, congestion reduction and access to mobility services, which are probably the points where the mobility system in general is stuck in contradictions due to the lack of affordable and sustainable vehicles.

Before making some proposals to support the use of ASEVs, we point out that incentives for EVs need to be carefully balanced to ensure an optimum use of all vehicles (including remaining non-ZEVs) and to ensure the efficiency of public transport. The example of the policies applied in Oslo at the beginning of the 2010s have favored an amazing increase in sales of BEVs but have also produced many severe adverse effects (Aasness and Odeck 2015) as summarized below:

1. The exemption from tolls has reduced the capacity of creating / maintaining road infrastructure;
2. The exemption of parking fees has led to economic losses and made society lose sight of the fact that a parking lot is a public space with costs that must be regulated according to its use, regardless of the type of vehicle occupying it;

3. The free use of transit lanes has reduced the efficiency of public transport, leading to increased congestion during peak hours and additional travel costs for public transport users.

In light of this warning about BEV incentive policies that may not be beneficial to the overall mobility system, we recommend a more systemic and holistic approach to promoting the use of ASEVs, such as the following examples (which are not exhaustive of all possibilities):

1. In urban areas, free parking is only available in spaces reserved for charging stations. More broadly, modulate parking fees according to usage needs, not just the fuel of the vehicle: have high fees (reduced for ASEVS versus non-ASEVS) when the need for space turnover is high, and lower or even zero fees when the need for turnover is low;

2. In peri-urban or semi-rural areas, free parking fees for all vehicles in carpooling areas and low parking fees for ASEVs in parking lots near transport hubs;

3. Access to fast transit lane freely opened to ASEVs and non-ASEVs vehicles in (effective) situation of carpooling and to public transport vehicles;

4. For rural or peri-urban areas where car use remains the best solution, ASEVs could quickly replace the use of old cars for low-income households if their purchase (and that of the charging station) is supported by public funds, following the example of Japanese rural provinces that subsidize Kei cars;

5. Combine these policies with intelligent energy policies that facilitate, for example, controlled recharging, which is the most compatible with the production of decarbonized electricity and the problems of intermittency that it can pose;

6. Promote the use of ASEVs as the sole or main household vehicle by working with public transport providers or ASEV rental companies to develop practical intermodal solutions for families;

7. ...

To be complete, we mention that in France, a law adopted in 2019 (known as 'Loi d'Orientation des Mobilités') considered that mobility policy concerned all territories, regardless of their density, while centralized mobility governance (known as 'Autorités Organisatrices des Transports' or AOTs) existed only for large cities. Today, all territories are covered by such an authority (known as 'Autorité Organisatrice des Mobilités' or AOMs), which plays the role of SUMP manager.

The existence of AOMs makes it possible to better identify local mobility needs at the private, public and business levels and to fine-tune ad hoc solutions adapted to the topographical, social and economic characteristics of each territory.
Conclusion

At the heart of our proposals, ASEV must convince users to buy it, automakers to produce it profitably, and policymakers that it solves much more than emissions problems, which is expressed in 5 main features summarized below:

1. An accessible vehicle that offers impeccable performance for use in urban, peri-urban and semi-rural conditions;

2. A vehicle defined by supranational regulations that provide a common framework binding on all member states;

3. A vehicle that creates a competitive and sustainable space where there can be a volume effect, one of the key conditions for affordability;

4. A vehicle that contributes to CAFE and helps manufacturers meet their targets in the next decade;

5. A vehicle promoted by local authorities because it contributes to the improvement of their mobility system.

Our proposal of ASEV is carried out by two emblematic types of vehicles:

1. An ASEV M0, limited in mass, dimensions and peak power of the electric motor and in use (speed limited to 110 km/h), which offers impeccable safety conditions, but whose limited use and the complexity and duration of the regulatory framework required for its adoption may hinder both its implementation and widespread use;

2. An ASEV M1, limited in mass, dimensions and peak power of the electric motor, not limited in use, requiring rather limited modifications of the existing regulatory framework but whose (almost) full compliance with the M1 requirements may not bring as many cost and affordability breakthroughs as M0 ASEV.

In addition, both offer an excellent opportunity for all automakers to reduce the mass of their vehicles from 2025, and both could be jeopardized by insufficient financial/non-financial incentives at the national and local levels to ensure the segment's success.

We propose to link the ASEV concept with CAFE bonus, a dedicated financial framework for production take-off, Eco-score bonus at European level and financial/non-financial incentives at national/local level to give more traction to the proposal.

The basic proposal for CAFE bonus is inspired to what has already done previously for EVs, i.e., a multiplier for ASEVs. The rationale behind a temporary multiplier is to encourage automakers to produce and sell ASEVs in large quantities to achieve the economies of scale of a mass market. We recommend a degressive multiplier from 2x in the first year of implementation of ASEVs to 1.5x 4 years later and then to 1 starting 5 years later. We strongly suggest that the first year of implementation is 2026 to secure both 2030 and 2035 targets.

Although not central to this report, we believe that affordability and sustainability need to be improved for all BEVs. Therefore, we have proposed some additional measures to be implemented in the medium term to extend the concepts of ASEVs to other vehicle segments.
At present, there are no European regulations that directly address the definition and
application of an eco-score. While the existing proposals and the only regulation in force (in
France) may bring some interesting contributions to the definition of its content, we have
built an original proposal to be applied in successive steps. For step1, we propose the
following framework:

1. The eco-score must combine an indicator related to the total CO2 footprint of the battery<fnref n="40" /> and an indicator related to the total CO2 footprint of the vehicle calculated according to the EU regulations under construction;

2. One unique regulation to be modified to define the content of the eco-score and communicate to customers in an appropriate manner, namely the Car Labelling - Directive 1999/94/EC (DG CLIMA);

3. Based on this definition, Member States can already apply a set of financial/non-financial incentives, mainly based on ASEV ownership taxes in a first approach, while local authorities can also apply their set of incentives, fine-tuned to local characteristics, to favour the uptake of ASEVs.

For the next steps, we mainly suggest to give the eco score a higher weight in the definition of carmakers' strategies by influencing their design choices through additional CAFE bonus or modulation of some fees, e.g., fees for extended producer responsibility.

Finally, we are convinced that ASEVs are a very good tool for local authorities to improve their mobility system, as they can efficiently contribute to achieving significant performance according to the Urban Mobility Indicators associated to SUMPs. Due to their characteristics, namely lower mass and dimensions compared to other vehicles, as well as the electric traction system, the use of ASEVs in urban, peri-urban and semi-rural areas contributes directly to the reduction of injuries and fatalities, noise, air pollution and greenhouse gas emissions during operation. In combination with other approaches that go beyond their specific contribution, ASEVs can efficiently contribute to the implementation of modal split, congestion reduction and access to mobility services, which are probably the points where the mobility system in general is stuck in contradictions and the lack of affordable and sustainable vehicles.

Taking into account the lessons learned from the deployment of EVs in Norway at the beginning of the last decade, we suggest that ASEVs incentives must be embodied in a holistic and systemic definition of a mobility system to ensure an excellent complementarity between all its components, be it ASEVs and non-ASEVs, public transport or scooters, bikes, etc.

ASEVs - like Kei Cars - do not need to be defined as urban vehicles: they are affordable small vehicles with very low environmental impact, small footprint and low electricity consumption. In themselves, they offer enough benefits to be bought (or leased) by customers, profitably produced at scale by automakers, and efficiently promoted by local authorities to significantly improve their mobility system.

<footnote n="40">⁴⁰ For the battery, we need the total carbon footprint calculated by multiplying the proposed indicator (Draft delegated act CFB methodology – Ares (2024)3131389) by the capacity of the battery in KWH.</footnote>
production. The Eco-Score will also become available as a tool for fiscal policies supporting the diffusion of ASEVs at national level.

The publication of the M1 ASEV policy toolkit in 2026 will detail how the Eco-Score can/should be used by EU governments to promote the diffusion of ASEVs. The creation of a dedicated label "Cities and/or Territories for ASEV" will further contribute to the diffusion of ASEVs via their integration in the EU Sustainable Urban Mobility Planning at each area level.

To maximise the decarbonisation impact of ASEVs we expect a reconfiguration of fiscal policies promoting BEVs from 2026/2027 onward with a strong focus on conversion bonuses and social leasing to incite the owners of the most aged and polluting part of the European car fleet to scrap their old ICE and acquire/lease an ASEV.

By this time ASEVs will be supported by fiscal and non-fiscal measures to reduce their acquisition and use costs relative to other vehicles, to promote their use in cities (free parking, preferential lanes, etc.), to integrate their acquisition/leasing in simplified multimodal mobility services for city access and long-distance travel. These policies would be therefore designed with the aim of both developing electromobility and limiting cars number and use.

We also expect that the creation of the ASEV category as well as the introduction of the European Eco-Score will modify the general European regulatory framework for new cars, and for ASEVs in particular, from the current siloed maximalist and techno-solutionist approach to a more holistic one where environmental sustainability and social affordability will work as transversal criteria adopted by all the DGs involved to manage trade-offs between its different dimensions.

The implementation of all these measures will rely on a strong European political compromise over the ASEV proposal, as well as different but complementary national compromises adapting the ASEV proposal to different national, regional and city/area context. These compromises will be based:

- on a clear determination to limit the reduction in production and headcount associated with electrification, by linking the electrification objective with a target for volumes and/or the rate of fleet renewal; the maintain of a rate of fleet renewal above 5% could become a target for the EU, which could then be broken down into 27 national targets depending on current car fleet renewal rates;

- on the strong contribution of ASEVs to the achievement of the "fit for 55" CO2 targets for new car sales of 2030 and 2035 (for OEMs and automotive suppliers);

- on the appeal of ASEVs as an affordable, sustainable, safe, new and innovative mobility solution in particular for those populations that own and drive the oldest and most polluting cars in Europe and are currently excluded from the access to BEVs;

- on the appeal of ASEVs for the EU, EU member states, regions and cities, but also for environmental NGOs, as a strategic technology to decarbonise road transport faster and more efficiently and to rethink urban/peri-urban/rural mobility in a way that is both more ecologically and politically sustainable (greener and more affordable).
## 5.2. A desirable future with ASEV

Based on these assumptions, we expect that at least 3 million ASEVs will be sold in 2028. We expect that at least half of these sales will be supported by scrapping schemes promoting a faster renewal of the car fleet that will grow from the current 5% to 6-6,5%. ASEVs will represent from 2028 onward 18% of the total sales of new cars, whose total volume will grow from the current 13 (2023) to 16 million cars, restoring the total European automobile production to pre-Covid levels, preventing the loss of thousands of jobs in the automotive production.

We believe that such a volume of production will provide a welcome stimulus to the currently difficult structuring of a complete European battery value chain, but also to the reactivation of core competences of automotive suppliers in lightening and optimise parts/components for small vehicles, that will be both key in driving down the cost of manufacturing ASEVs. This would enrich the European automotive innovation system by diversifying it. This broadening of its range of skills would maximise its capacity to adapt and its ability to remain a key player in the global automotive game.

More specifically, ASEVs will also reactivate and further develop the existing capabilities of the European automotive eco-system in making affordable small cars, contributing to preserve and develop its overall competitiveness, not only in the premium segment, but also in the volume segment where otherwise Chinese imports and Chinese European based production could capture significant market share. While the compensation currently proposed by the EU to offset the various types of aids received by Chinese vehicle importers could be a satisfactory temporary solution, it does not resolve the entire competition problem. The assembly plants set up by Chinese manufacturers in Europe as a result of this policy will concentrate on accessible vehicles, and it is therefore the development of such products designed and manufactured in Europe by European manufacturers that is urgently needed. By creating such a vehicle category to stimulate and securitise car manufacturers product policies considering this segment as a crucial one, EU would give to its pro-EVs orientations a real chance to survive these attacks.

We estimate that under such conditions, our proposal could contribute to reduce CO2 emissions from the car fleet of 24% (71 million tons CO2) in 2035 and of 38% (40 million tons CO2) in 2050 by comparison with a scenario without ASEVs that is currently incompatible with the achievement of carbon neutrality in 2050 (see box below for the methodology). We think in particular that ASEV will represent the main technological solution to decarbonise faster the most aged car fleets in Southern and Central and Eastern Europe.

## 5.3. A new European coalition for ASEVs

While we are fully aware of the challenges that our proposal raises in terms of policy-making, we believe that it could gather a wide support from all the main stakeholders in the automotive sector and in all EU member states.

First, starting from 2025 onward all European OEMs will have to move towards lighter cars in order to comply with the CO2 regulation given the shift from a positive to a negative slope for weight-based standards. ASEVs should therefore appeal to all OEMs and ACEA as their representative body. Furthermore, ASEVs will not compete directly with the current supply of BEVs, precisely because the current supply does not cater for the demand for such
vehicles. ASEVs are meant to compete against aged second-hand cars which is why they will
contribute to boost sales and production.

We therefore expect that also European automotive suppliers will benefit from ASEVs and should support our proposal via their representative European body, the CLEPA. European and national automotive trade unions should also support the proposal, all the more as it is already coherent with several of their own proposals for smaller and more affordable electric cars (Fondation Nicolas Hulot and CFDT 2021; CGT Renault 2023). In the same manner, we expect the European Committee of Regions and in particular the CoR's Automotive Regions Alliance to see the benefits of producing ASEVs, in particular in regions where volume of production is now particularly threatened.

Because our proposal is meant to reduce significantly acquisition and use cost of cars for millions of European consumers while helping them to board the train of electrification, we also expect the BEUC to see how proposal in favorable terms.

We also think that our proposal could speak to the EU governments that are currently concerned by the respective capacity of their own countries and automotive industries to board the train of electrification while preserving employment and ensuring good job quality.

Environmental NGOs, which have become key players in Europe, should also logically support such proposals. They have already spoken out in favor of smaller, lighter and more ecologically virtuous vehicles. They should be seduced by a "fleet policy" that would, for example, set renewal targets, possibly accompanied with targets for fleet growth (or stagnation or decline).

Finally, and more generally, the ASEV proposal will give a welcome stimulus and a clearer direction to different strands of the European Union Green Deal policies – such as the Net Zero Industrial Act, the Batteries Regulation, the CBAM, the Vehicle Type Approval Regulation, the CO2 regulation, the Just Transition framework and fund, the ETS 2 carbon market, etc. – making easier for the European Commission to articulate them as a coherent industrial policy.

Conclusion

What is at stake in our proposal is the idea that electrification should be an opportunity for a New Deal around the car and its place as an industry and as a mobility tool in European societies. In a way, Joe Biden's IRA dealt with electrification and the hostility it aroused in a very political way, by linking the return to the Paris Agreements to a policy of massive subsidies and very firm protection against Chinese imports and installations. As the year 2024 shows, the EU can no longer simply set very ambitious electrification targets and then leave the industry to deal with the consequences. If, as seems to be the case, there is no question of turning back the clock, then we need to get back on track and seek compromises that will make this transition ecologically, socially and industrially credible. In the same way that ASEVs would be a major component of local mobility policies, the policy and financial framework designed to create this category and give it the importance it deserves could in the coming months symbolise this reorientation.
<table><caption>Table 14. Timeline of ASEV proposal implementation</caption><thead><tr><th>Year</th><th>2024</th><th>2025</th><th>2026</th><th>2027</th><th>2028</th><th>2029</th><th>2030</th><th>2031</th><th>2032</th><th>2033</th><th>2034</th><th>2035</th></tr></thead><tbody><tr><td>Technical regulations</td><td>Regulation proposal: introduction of the ad-hoc category M1 ASEV</td><td>Regulation adoption</td><td>Entry in force of M1 ASEV</td><td>No new technical requirement for ASEV</td><td></td><td>Full adoption of pre-2030 technical regulations for ASEV</td><td>Adoption of ART package for M1 non-ASEV</td><td></td><td></td><td></td><td>Full adoption of pre-2035 technical regulations for ASEV</td><td>Adoption of ART package for M1 non-ASEV</td></tr><tr><td></td><td></td><td></td><td>First Automotive Round Table (ART)</td><td>Adoption of ART1 package</td><td></td><td></td><td></td><td>Second ART</td><td>Adoption of ART2 package</td><td></td><td></td><td></td></tr><tr><td>CAFE</td><td>Modification of CAFE regulation to introduce ASEV and multiplier for ASEV</td><td></td><td>Multiplier x2</td><td>. x1.75</td><td>. x1.5</td><td>x1.25</td><td>No multiplier</td><td></td><td></td><td></td><td>End of non-ZEV</td><td>Adoption of new metrics (LCA)</td></tr><tr><td>Eco-score</td><td>Debate on Eco-score</td><td>Draft proposal on Eco-Score</td><td>Adoption of Eco-Score</td><td>Entry in force of Eco-score</td><td></td><td></td><td></td><td></td><td></td><td></td><td>Progressive withdrawal of lowest eco-score vehicles + progressive tightening of eco-score regarding the climate damaging</td><td></td></tr><tr><td>National and local Policy package</td><td></td><td></td><td>Publication of the M1 ASEV policy Toolkit</td><td></td><td></td><td></td><td>Fiscal policies based on the Eco-score / Social leasing and conversion bonus tied to ASEV category</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td></td><td></td><td></td><td>Label "Cities for ASEV"</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr></tbody></table>
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