COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT

Accompanying the document

Proposal for a Directive of the European Parliament and of the Council amending Council Directive 96/53/EC laying down for certain road vehicles circulating within the Community the maximum authorized dimensions in national and international traffic and the maximum authorized weights in international traffic

Table of contents

1........... Procedural issues and consultation of interested parties. 1

Identification. 1

1.1........ Organisation and timing. 1

1.2........ Consultation and expertise. 1

1.2.1..... Main results of the public stakeholder consultation. 2

1.2.2..... Main result of the targeted stakeholder meetings. 2

1.3........ Consultation of the Impact Assessment Board. 3

2........... Problem definition. 4

2.1........ Political context 4

2.2........ What is the issue or problem that may require action?. 6

2.2.1..... Part 1: Certain limits on weights and dimension set by the Directive constitute obstacles to energy efficiency gains of road vehicles and to intermodal transport operations. 6

2.2.2..... Part 2: Ineffective application of the Directive. 14

2.3........ Who is affected, in what ways, and to what extent?. 16

2.4........ How would the problem evolve, all other things being equal?. 17

2.5........ Does the EU have the right to act – Treaty base, ‘necessity test’ (subsidiarity) and fundamental rights limits? 19

2.5.1..... Link to the corresponding article of the Treaty. 19

2.5.2..... Subsidiarity test 20

2.5.3..... Test of added value. 20

3........... Objectives. 21

3.1........ Policy objectives. 21

3.2........ Possible trade-offs between the objectives of this initiative and the horizontal objectives of the EU 22

4........... Policy options. 23

4.1........ Discarded policy measures. 23

4.1.1..... List of considered policy measures in relation with energy efficiency. 24

4.1.2..... List of considered policy measures in relation with improving the functioning of the internal market for road transport 25

4.2........ Identification of the policy packages (in addition to the business-as-usual scenario) 26

4.2.1..... Policy Package 1: Limited revision. 27

4.2.2..... Policy Package 2: A more extensive revision. 28

4.2.3..... Policy Package 3: More binding regulatory approach. 29

4.2.4..... Overview of measures proposed in Policy Packages. 30

5........... Analysis of impacts. 31

5.1........ Environmental impacts. 31

5.1.1..... Climate change. 31

5.1.2..... Air pollution (NOx, PM, SOx, HCs, CO) 35

5.1.3..... Noise. 35

5.2........ Economic impacts. 36

5.2.1..... Impact on the functioning of the internal market and competition. 36

5.2.2..... Impact on competitiveness. 38

5.2.3..... Impact on transport sector 39

5.2.4..... Impact on the administrative burden, public administrations and onSMEs. 39

5.3........ Social impacts. 41

5.3.1..... Impact on working conditions, health and lifestyle of drivers. 41

5.3.2..... Impact on road safety. 41

5.4........ Summary of impacts. 43

6........... Comparing the options. 45

6.1........ Effectiveness. 45

6.2........ Efficiency. 46

6.3........ Coherence. 48

6.4........ Sensitivity analysis. 49

6.5........ Conclusion - ranking of the options. 49

7........... Monitoring and evaluation. 50

Annex 1... 51

Annex 2... 58

Annex 3. .................................................................................................................................... 61

Annex 4. .................................................................................................................................... 63

Glossary

Directive 96/53/EC[1] (hereafter referred to as such or as the ‘Directive’) concerns vehicles of categories M2, M3, N2 and N3 and their trailers of categories O3 and O4 as defined by Annex II to Directive 2007/46/EC[2]. These categories include the following vehicles:

- M2 and M3: Vehicles for the carriage of passengers, comprising more than eight seats in addition to the driver's seat, referred to from here on as 'buses' (for urban and for inter-urban transport). Buses and coaches are not differentiated for the purpose of this document;

- N2 and N3: Vehicles for the carriage of goods and having a maximum mass exceeding 3.5 tonnes, referred to from here on as 'heavy-goods vehicles' (HGV), 'trucks' or 'lorries';

- O3 and O4: Trailers with a maximum mass exceeding 3.5 tonnes.

In this document, the terms 'heavy goods vehicles', 'trucks' and 'lorries' all refer to vehicles of categories N2 and N3 with or without combinations of trailers O3 and O4. Heavy duty vehicles (HDV) refer to all HGVs and buses.

Combined transport is defined in accordance with Directive 92/106/EEC[3] as

"the transport of goods between Member States where the lorry, trailer, semi-trailer, with or without tractor unit, swap body or container of 20 feet or more, uses the road on the initial or final leg of the journey and, on the other leg, rail or inland waterway or maritime services where this section exceeds 100 km as the crow flies and make the initial or final road transport leg of the journey;

- between the point where the goods are loaded and the nearest suitable rail loading station for the initial leg, and between the nearest suitable rail unloading station and the point where the goods are unloaded for the final leg, or;

- within a radius not exceeding 150 km as the crow flies from the inland waterway port or seaport of loading or unloading."

Intermodal transport refers to transport of intermodal loading units (containers or swap bodies) using at least two different modes of transport as part of a transport chain with no limitation on the length of the road transport leg, nor of the other legs.

· Procedural issues and consultation of interested parties

Identification

Lead DG: MOVE

Agenda planning: 2012/MOVE/013

This impact assessment (IA) is the basis for a proposal to be submitted to the European Parliament and the Council with the aim of modifying Directive 96/53/EC on the maximum dimensions of certain road vehicles autorized for national and international traffic and the maximum weight authorized in international traffic (hereinafter 'the Directive').[4]

The reason for the revision is founded on multiple requests coming from professional stakeholders, demonstrating a growing gap between the directive and the market. Following the 2011 White Paper on Transport[5], it was decided to launch a public consultation to assess the opinions on the status of the implementation of the Directive 96/53/EC and propose for a revision the issues already highlighted by the stakeholders.

o Organisation and timing

For the preparation of this initiative, DG MOVE set up an Impact Assessment Steering Group in which the following DGs took part: SG, ENTR, JRC, ENV, CLIMA, LS.[6] The Steering Group held five meetings between September 2011 and September 2012.[7] The Steering Group’s comments were taken into account in the impact assessment.

o Consultation and expertise

External assistance has been used through a contract on specific technical issues with the French IFSTTAR laboratory and the Belgian Institute BRRC from November 2011 to April 2012. The consultants' role was to answer specific technical questions of DG MOVE on an ad-hoc basis. A stakeholder consultation was organised in two parts: 1) a public consultation via the Internet, which was open from 22 December 2011 to 27 February 2012[8], and 2) a targeted stakeholder consultation[9], consisting of four workshops organised by DG MOVE, with enforcement organisations (16 February 2012), vehicle manufacturers (6 March 2012), intermodal transport operators (2 April 2012) and road safety experts (26 June 2012). The Commission’s standards in terms of stakeholder consultation[10] have been met.

§ Main results of the public stakeholder consultation

Before launching the consultation, DG MOVE organised a meeting with representatives of the Member States on 26 October 2011 to discuss areas of possible scrutiny. Following this meeting the consultation was organised around the four following themes:

· Theme 1: energy efficiency and CO2 emissions, aerodynamics of the vehicles;

· Theme 2: intermodal transport of goods;

· Theme 3: controls, checks and enforcement of the Directive by the Member States.

· Theme 4: need for legal clarifications of derogations from the Directive for heavier and longer trucks;

300 replies from professional stakeholders were registered, as well as 700 responses from private citizens. The latter were largely identical, suggesting that members of some associations sent predefined answers. While the relevance of the proposed themes were confirmed by stakeholders, no other important topic was suggested during the consultation.

The key findings of the consultation can be summed up as follows:

· Theme 1: there is broad consensus on the objective to improve energy efficiency and fuel consumption by improved aerodynamics of heavy goods vehicles, especially by allowing rear flaps and new designs of the cabin. The same consensus applies with regard to a support to hybridization and to electric vehicles. For that purpose, stakeholders requested that some of the constraints set by the current Directive are released to accommodate these technological improvements (e.g. the weight of batteries).

· Theme 2: there is a general consensus on the necessity to accommodate containers of 45 feet length through an increase in length of the vehicle by 12 or 15 cm.

· Theme 3: most stakeholders of all kinds agreed that controls are not efficient and are insufficient in number. All means to improve the situation, including automatic systems would be useful. Professional stakeholders also highlight the necessity for harmonizing control procedures and sanctions at European level.

· Theme 4: the majority of stakeholders consider existing derogations as not sufficiently clear. Positions diverge on possible changes needed: Environmental NGOs, rail and combined transport associations as well as road safety associations advocate a restricted use of longer vehicles while manufacturers, the haulage industry and shippers highlight the energy efficiency of longer vehicles (two longer ones would be needed where currently three vehicles are required) and ask for a generalised authorisation of their cross-border use.

§ Main result of the targeted stakeholder meetings

The targeted hearings of associations of enforcement inspectors, vehicle manufacturers and hauliers associations, intermodal transport stakeholders and experts in road safety yielded the following results:

· Enforcement associations underlined the benefits to be achieved through automatic enforcement methods such as weigh-in-motion systems (WIM), which allow enforcers to filter traffic and more efficiently target vehicles for manual checks.

· Vehicle and trailer manufacturers confirmed the potential for aerodynamic improvement as well as the market interest for such solutions. They underlined the different product development lifecycles (10 years for tractors and <2 years for trailers), and promoted the idea of performance-based standards instead of fixed limits for the new designs of both rear flaps and the front of new cabins.

· The intermodal stakeholders confirmed that properly designed aerodynamic devices would not be a problem for trailers on most rail wagons. They requested the current administrative burden related to 45’ containers to be reduced by a release of the need for special permits.

· Road safety experts highlighted the relation between braking distance and the weight of vehicles, the benefits of widening the driver's field of visions through an improved design of cabins and the need for signalisation of any additional element at the rear of a vehicle.

The policy options analysed in this IA reflect suggestions collected during the consutlation process. A great deal of the technical information contained in this IA has also been gathered during the consultation process.

o Consultation of the Impact Assessment Board

The draft report for this IA was submitted to the Impact Assessment Board

(IAB) on 21 September 2012. In its opinion of 19 October 2012, the IAB made a number of recommendations which were taken into account in the final draft. The most important amendments in comparison to the version submitted on 21 September are the following:

· The baseline has been strengthened by introducing data on key variables (fuel and carbon prices, number of km driven and fuel consumption) from the PRIMES-TREMOVE baseline. Data on other variables, such as on forecasted movements of 45' containers, is not available in the PRIMES-TREMOVE baseline or other sources that we have investigated, which is why only qualitative information could be provided. Moreover, expected developments of weights of vehicles, containerisation, transport routes and enforcement have been indicated.

· The qualitative and quantitative analysis of the IA have been better integrated, assumptions and calculations have been clarified, and it has been explained which Member States are likely to be most affected.

· While keeping the incremental approach of assessing Policy Packages, the comparison of Policy Packages with the baseline has been clarified. Moreover, the effectiveness as well as the efficiency of the Policy Packages in terms of total costs and benefits have been outlined.

· Views of stakeholders have been presented more thoroughly in the main text and in Annex 1 with regard to the main elements of the report.

· Problem definition

Heavy duty vehicles transporting goods and passengers in Europe must comply with certain rules on maximum weights and dimensions. For each vehicle type, Directive 96/53/EC sets the respective maximum authorised length, width, height and weight (total weight and weight per axle). Vehicles which comply with these limits can perform international[11] transport operations within all EU Member States (Art. 3). To avoid that national operators benefit from undue advantages over their competitors from other Member States, they are bound, as a general rule, to comply with the limits set for international transport (Art. 4(1)). In line with the principle of subsidiarity, a number of derogations allow Member States to apply higher limits for transport within their own borders. The derogations concern the maximum height, the maximum weight (Art. 4(2)) and the possibility to employ longer vehicles in special transport, trials or with modular combinations of vehicles (Art. 4(3), 4(4) and 4(5)).

As explained further in section 2.2.1, these rules have been defined to strike a balance between requirements in terms of protecting the infrastructure as well as the environment, ensuring safety, energy efficiency and economic profitability. The infrastructure and the safety rules are important constraints on the possible evolutions of the vehicles. Concerning the infrastructures, three major issues are at stake :

- the weight per axle of the vehicle, which has the most important impact for road wear and tear,

- the total weight of the vehicle (relevant in particular for bridges),

- the capability of the vehicles to manoeuver, for instance in roundabouts and in urban areas.

These constraints will not be challenged by a revision of Directive 96/53/EC.

By avoiding technical hindrances at borders and ensuring fair technical conditions of competition to hauliers, the Directive aims at facilitating the internal market and ensuring the free movement of goods and persons in Europe.

o Political context

One of the key objectives of the Europe 2020 strategy[12] is sustainable growth aiming at building a more competitive low-carbon economy by notably increasing energy efficiency. In this context, the 2011 White Paper on transport[13] has put a clear emphasis on the need to reduce the CO2 emissions from the transport sector with a reduction target of 60% by 2050 compared to 1990 levels. In the area of road transport, the White Paper has stressed that Directive 96/53/EC on the maximum weights and dimensions should be adapted to technological developments and new circumstances, such as the evolution of containerisation and new vehicle technologies improving aerodynamics.

Insofar as the review of the Directive could contribute to more harmonised framework conditions for freight transport, it is linked to the review of the road freight market announced in the White Paper and in the Commission's 2013 work programme. This review includes other initiatives to further integrate the road transport market, such as a stepwise approach to further opening national transport markets (including through cabotage) and a review of existing road user charging rules, which will also contribute to increasing the energy efficiency of road transport.

The White Paper further aims at improving the resource-efficiency of the transport sector by making vehicles cleaner and more fuel-efficient, and by optimising the performance of multimodal logistic chains. This includes improving connections between modes and using each mode where it is the most efficient. Significantly increasing the loading capacity of road vehicles may result in adverse effects on infrastructure, road safety and other modes, thus undermining the aim of creating an efficient multimodal transport system. This option is therefore not evaluated in this impact assessment.

This initiative also builds on the draft Commission Regulation on type approval of heavy duty vehicles (HDVs) as regards masses and dimensions (currently under scrutiny by the European Parliament and due to be adopted by the end of 2012). This upcoming Commission Regulation (DG ENTR) will govern the conditions for manufacturing and distribution of heavy duty vehicles in the EU. It is developed in the context of the implementation of the type-approval Framework Directive 2007/46/EC[14] and of Regulation (EC) No 661/2009 ("General Safety Regulation")[15] in order to replace the current Directive 97/27/EC[16] with effect of 1 November 2014. It will introduce possibilities for new vehicles to deviate from maximum dimensions for small series by creating allowances for foldable aerodynamic devices at the side and back of vehicles within the limit of 500 mm at the back (when unfolded).

International standards would create no obstacles to such changes. The 1958 UNECE agreement on the adoption of uniform technical prescriptions for wheeled vehicles, equipment and parts[17] does not cover masses and dimensions of road vehicles nor does it include aerodynamic devices. On the one hand, no changes to international agreements will be required to amend Directive 96/53. On the other hand, failing the existence of international standards, there is a case to facilitate the roll-out of aerodynamic devices in this Directive.

Furthermore, the Commission is currently preparing a strategy to reduce the CO2 emissions of HDV. In the preparatory work to establish this strategy (carried out by DG CLIMA), a number of actions have been identified to reduce HDV CO2 emissions. One of them is the review of Directive 96/53/EC in order to facilitate the introduction of more energy-efficient road vehicles, including more aerodynamic vehicles. The review of Directive 96/53/EC may therefore contribute to the climate strategy.

Finally, legal uncertainties have long existed with regard to the derogations for longer vehicles in Art. 4 of the Directive. The wording of the Directive was considered to be insufficiently clear regarding the rules relating to the cross-border use of longer modular trucks. In light of these uncertainties and following requests from stakeholders, Vice-President Siim Kallas sent a letter on 13 June 2012 to the Chairman of the Transport Committee of the European Parliament (see annex 3). This letter provides guidance and considers the cross-border use of longer vehicles lawful if two Member States already allow this and if the conditions for derogations under Art. 4(3), 4(4) or 4(5) of the Directive are met. In particular, there should be no significant impact on international competition.

In a response to President Schulz of the European Parliament, President Barroso indicated in a letter of 26 July 2012 that the Commission would make a legislative proposal which would give an opportunity for the European Parliament to legislate on this issue if it wishes to do so and that until any revision of the Directive is fully implemented, the current Directive remains in force along the guidance provided.[18] Hence, given that existing uncertainties regarding Art. 4 of the Directive have been addressed and given that the legislator will have the opportunity to address the issue, as appropriate, in connection with the present revision of the Directive, this Impact Assessment will not address the issue of Art. 4.

o What is the issue or problem that may require action?

Against this background, new circumstances, technologies and user needs call for a revision of the Directive. More exactly, the main problem identified following the stakeholder consultation is that the limits set in the Directive are one of the obstacles to energy efficiency[19] in road transport and to intermodal transport. Moreover, the effectiveness of the Directive is hampered due to a lack of compliance by transport operators. Hence, the main problem consists of two parts described in more detail below.

§ Part 1: Certain limits on weights and dimension set by the Directive constitute obstacles to energy efficiency gains of road vehicles and to intermodal transport operations

As mentioned above, rules on weights and dimensions of commercial vehicles are meant to strike a balance among several, and in part competing requirements, namely: i) energy efficiency and environment; ii) economic efficiency; iii) safety; and iv) infrastructure needs. This balance has to be valid EU-wide to ensure a level playing field.

The current legislation, conceived in the 1990s to accompany legislation regarding the opening of the international road transport market, reflects the conditions present at the time. Several elements have changed in the meantime, implying that current rules no longer correctly balance the various elements and needs.

In particular, energy dependency and climate change considerations require that greater emphasis is now given to the energy efficiency of vehicles. Developments in maritime transport and containerisation have an impact on the logistics and the economy of road operations. Vehicle and infrastructure technology has advanced. Safety concerns have become more prominent.

Furthermore, the way manufacturers adapt their vehicle design to demand – within the regulatory limits – is likely to produce suboptimal results. This is because vehicle operators do not pay the full price of negative externalities such as climate change, energy dependency and the social cost of accidents, and are therefore attributing lower value to these features than it would be desirable.

Some of these problems have already been recognised by the policy maker and tackled with regulation imposing, for example, minimum safety and environmental standards, but as a result, the regulations adopted over the last two decades and the evolving importance given to respective policy goals has also altered the balance between the various elements of the problem. It can be said today that:

• Infrastructure and safety still represent a constraint to weights and dimensions and do not allow sizeable increases of vehicles. On the other hand, reducing the loading capacity would imply lower economic and environmental efficiency, since more kilometres would have to be driven to transport the same quantity of goods;

• The total weight limits have been set in a precautionary manner in the Directive. A limited increase in the maximum authorised weight would still be possible for most categories of heavy duty vehicles without being harmful to main roads, which are built to resist an axle weight of 11.5 tonnes. This safety margin would leave space for a slight increase of the maximum permissible weight of electric vehicles to compensate for the additional weight of their batteries;

• Since larger containers are becoming ever more common and have environmental advantages, the trade-off between a little additional length and safety/infrastructure problems is favourable to the former;

• The same consideration can be applied to aerodynamic appendices, in view of the greater social cost of energy these days.

In short, as reported by stakeholders, especially hauliers and manufacturers, the Directive imposes limits which, although pertinent in the 1990s, do no longer strike for some of them the right balance between the four above-mentioned requirements and today create undue obstacles to energy efficiency gains and to intermodal transport. In this respect, the limits acting as obstacles can be regrouped under two main groups:

Root cause 1) Certain maximum weights and dimensions prevent the market uptake of more aerodynamic, electric and hybrid trucks and reduce the attractiveness of certain coach services

A. Certain dimensions prevent the deployment of aerodynamic solutions for trucks

Aerodynamics is a major factor influencing the energy efficiency of HGVs.[20]

When driving a truck at constant speed on a flat level road, about 40% of the fuel consumed is used to overpower the air resistance (drag)[21]. The drag, which slows the truck down, is caused by high or low pressure at certain points in relation to the ambient atmospheric pressure. The oncoming airflow pushes against (1) the tractor front, creating a high-pressure region, just as it does on (2) the wheels and the front of (3) the semi-trailer. The heavy duty vehicle moving forward in the airflow creates a low-pressure region (4) behind the tractor and (5) the semi-trailer, which ’pulls’ the vehicle backwards. Interestingly, the high-pressure region at the front contributes just as much to drag as the low-pressure region at the rear.

The sources of drag numbered (2), (3) and (4), representing one third of the total drag, are currently addressed by respectively side skirts, roof-top spoilers and reflectors between cabins and trailers, which can be installed on trucks as these devices do not extent weights or dimensions of vehicles beyond the maximum limitations of the Directive. Notably roof-top spoilers and reflectors are widely used on approximately 90% of all long-distance trucks[22]. Side skirts, on the other hand, are only used to a very limited degree, according to stakeholders, due to their exposure to damage when loading HGVs from the side.

Figure 1: Different aerodynamic devices which allow overcoming the aerodynamic drag for a heavy goods vehicle.

(5) An aerodynamic rear device would exceed current maximum limitations on length of HGVs

(4) Reflector – currently in use

(1) An aerodynamic cabin being rounded and longer would exceed current maximum limitations on length of HGVs

(2) Side skirt – currently in use

The main sources of drag numbered (1) and (5) above, representing each one third of the total drag, can only be addressed within the current limitations of dimensions of HGVs stipulated by Directive 96/53/EC by decreasing the length of loading units, which consequently would reduce loading capacity. Stakeholders argued during the public consultation that reducing loading capacities of HGVs[23] would compromise the commercial viability of such vehicles, and that the Directive currently hampers innovations of HGVs that could contribute to improving their energy efficiency and reducing their CO2 emissions. As an illustration, accomodating aerodynamic devices at the front and at the back of HGVs (of for instance 2 metres) within current maximum dimensions of 18.75 m, would require a correponding decrase of loading capacity, and thus of revenues, by 18%[24]. Although aerodynamic devices at the front and at the back of HGVs would generate substantial fuel savings, as explained below, reducing overall costs by more than 18% by means of fuel savings alone – to compensate for the loss of revenues alone – would require a more than 60% improvement in fuel efficiency of HGVs[25], which could not be achieved by means of aerodynamic devices. On the other hand, allowing additional length of HGVs beyond current maximum dimensions would enable hauliers to maintain existing loading capacities and to benefit from fuel savings (see also cost-benefit analysis carried out in chapter 6.2).

As regards the drag source numbered (5), the frame table here below gives an idea of possible solutions to improve the energy efficiency of trucks by additional equipment on the trailer. Adding this equipment would exceed the maximum length allowed by the Directive. The potential CO2 emissions reduction provided in the table have been confirmed by numerous studies and trials[26] carried out by the industry.

Table 1: Devices to Reduce Aerodynamic Drag at the Rear of Trucks

Source: Towards a lower fuel consumption and CO2 emissions by means of aerodynamic add-ons for trailer rear-end, PART Consortium[27]

As to the drag source numbered (1), studies have been performed on the front of the trucks, suggesting that much improved performances could also be achieved by a more aerodynamic shape of the vehicle, as for instance the one presented here below in Figure 2. The expected reduction of fuel consumption is 3-5 % (FKA report 104190 Aachen 2011). Figures must however be taken with care as they result from theoretical studies, and laboratory tests, not from real-life tests of trucks in operational conditions.

Figure 2: Current design and example of 'Design of a Tractor for Optimised Safety and Fuel Consumption'

Source: FKA Report 104190, Aachen 2011.

Combining the devices presented in Table 1 and the change to the cabin presented in Figure 2, it would be possible to reduce the drag coefficient (cw) of today’s trucks and tractor-semitrailer combinations, ranging from 0.5 up to 0.9, to at least 0.3. In real numbers, today's technology allows reducing the aerodynamic drag by 20 to 25%, resulting (according to scientific studies) in fuel savings of 7 to 15%[28]. However, such changes would necessitate a modification of the maximum dimensions specified in the Directive, or alternatively a reduction of the loading capacity by reducing the length of the trailers, a solution which, as earlier mentioned, would be economically unsustainable.

Additionally, the redesign of the cabin allows taking other problems mentioned by stakeholders into consideration, including an improvement of driver comfort and the safety of vulnerable road users. Currently, truck drivers are seated on top of the engine, which poses serious challenges in terms of cooling of the cabin and access to the engine. The size of the couchette is small, and the cabin is occupied by several mandatory devices. Changes to the cabin would moreover benefit citizens in terms of safety, as cabins with a more rounded front would reduce the impact and the number of victims in case of accidents. While fatalities involving HGVs in absolute numbers have halved over the last 10 years, the number of fatalities in accidents with HGVs is still around 4,000 per year or 11.4% of total road fatalities in the EU in 2009. As highlighted by several stakeholders, changes to the cabin design for a longer and more rounded front would allow reducing the number of fatalities in accidents with HGVs. Simulations have shown that rounded fronts would prevent overruns of persons hit by HGVs[29] and therefore reduce the number of fatalities. See section 5.3.2 of this document.

The implementation of new aerodynamic devices or designs must also take into account issues like signalisation, the lighting of vehicles at night and room for manoeuvre of the vehicles.

B. Certain maximum weight limitations prevent the market uptake of electric/hybrid vehicles

The introduction of hybrid or electric powertrains, mainly in urban or small-size trucks and buses (typically with a maximum total weight of 18 tonnes [30]) could additionally contribute to improving energy efficiency. However, batteries used in these propulsion systems continue to be very heavy, weighing around one tonne according to figures provided during the stakeholder consultation. One tonne less in terms of the payload would undermine the economic sustainability of many transport operations. As an illustration, reducing the payload by 1 tonne for buses with a capacity of 30 passengers, weighing on average 75 kg (excluding luggage – see chapter 4.1.1), would reduce the capacity of buses by approximately 13 passengers, or some 40%. Consequently, the current weight limits of the Directive may hinder the market uptake of such vehicles and act as an obstacle to reap their environmental benefits in terms of energy efficiency.

C. Certain maximum weight limitations have not evolved to keep pace with the growing weight of vehicle safety and comfort equipment and of passengers

The total weight of vehicles, which is limited by Directive 96/53/EC, is determined by the weight of the vehicle as well as its payload. Technical developments of vehicles in relation to on-board safety equipment and cleaner powertrains have made vehicles heavier. It has been particularly striking in coaches where safety and comfort requirements are relatively higher. This has resulted in a decreasing capacity to load goods (lorries) or passengers (buses) (and hence the need for more HGVs / more buses to transport the same amount of goods and passengers respectively). The table below provides a non-exhaustive list of examples of items, which have made vehicles heavier:

Table 2: Examples of items which make vehicles heavier

Items || Situation - mid-1990s (in kg) || Current situation (in kg) || Additional weight (in kg)

Euro IV/V Engines || 260 || 450 || 190

Noise reduction || 15 || 100 || 85

Retarder and brake systems: ABS, ESP, ACC, AEBS, LDWS || 70 || 220 || 150

Strength of the body (UN R 66) || 110 || 200 || 90

Underrun protection (UN R 58) || 0 || 60 || 60

Safety belts and anchorages || 80 || 200 || 120

Air-conditionning system + Toilets + Water tank + Kitchen || 315 || 480 || 165

Onboard equipment: Camera & Mirrors + Multimedia + ITS systems || 30 || 70 || 40

At the same time, the standard weight of a European passenger has increased by 7 kg[31], and the weight and size of personal luggage has also gone up. Therefore, the number of passengers that a coach can carry has decreased, at constant size and weight, contributing to an increased price per passenger (the total cost of the trip has to be divided by fewer passengers), making transport by bus and coach less attractive, and thus contributing to a potential reverse shift from collective transport to personal vehicles. It could be necessary to accommodate these developments to make collective transport of passengers more efficient, in terms of energy, demand management and economic profitability for the operators.

The 2011 White Paper on transport similarly stressed the need for transporting ‘greater numbers of travellers jointly to their destination by the most efficient (combination of) modes.҆҆

Root cause 2) Certain maximum weights and dimensions have not kept pace with the technical developments of intermodal transport and containerisation

The development of trade has gone hand in hand over the two last decades with the growing containerisation of global logistic chains. Containerisation presents a further opportunity for the development of intra-EU intermodal/combined transport as an alternative to door-to-door road transport solutions. However, the incomplete standardisation of the transport units hampers this development. As a result certain large containers used in maritime transport can hardly be accommodated in the land transport legs of the chain, because of the maximum dimensions imposed by the Directive.

This is the case of the 45' containers which are increasingly used as they carry more payload, and for example 2 pallets more (on the floor and more when stacked) than in traditional 40’ containers.

45’ containers represent 20 % of the global stock of containers[32], the number of which increased by 86% between 2000 and 2010 to 14.875 million TEU (Twenty Foot Equivalent Units)[33]. Today, some 20 % of these containers reach Europe. 45’ containers thereby represent 2-3% of the total container market in Europe and this share is reportedly rapidly increasing. When arriving in EU ports, such containers are often transported by rail, in short sea shipping or on inland waterways towards the final destination, but the transport from the port to the connecting transport mode as well as the final part of the trip are usually performed by road.

45’ containers have the potential of decreasing energy consumption and consequently to promote the efficiency and attractiveness of intermodal transport chains on routes which combine short sea shipping or rail transport with road transport. But 45’ containers may currently only be transported by road under certain conditions[34], with a special permit or by way of derogation from Directive 96/53/EC, which needs to be notified to the Commission. Such permits and derogations entail administrative burdens which are costly for operators and which may hinder and slow down the development of intermodal transport. As an example, obtaining a special permit for transporting a 45’ container from Hamburg (DE) to Aarhus (DK) by road costs € 90. As the application for the permit is complex, lengthy (at least 14 days) and has to be submitted in the language of the country in which the permit is requested, hauliers usually apply via specialised organisations charging a fee, which reportedly can amount to approximately € 70 (in DK), i.e. a total cost of € 160.

Moreover, the maximum weight of vehicles carrying 45' containers remains limited to 40 tonnes, unlike vehicles transporting 40' containers for which a maximum weight of 44 tonnes is allowed as part of a combined transport operation[35] to factor in the dead weight of the container. This discrepancy between 40’ and 45’ containers is due to the fact that Directive 96/53/EC was drafted at a time when 45' containers were only rarely used.

Other types of containers are arriving from overseas; 45' pallet wide (containers with a length of 45 feet but which are more than 5 cm wider than a standard 45' container. Thanks to this extra width these containers can carry two pallets side by side instead of one, i.e. 33 pallets in total instead of 27), 48' and 53'. Whereas these containers allow operators to carry more pallets, they would require more significant extensions of trailers in both width and length to be carried over road (as part of a standard operation).

§ Part 2: Ineffective application of the Directive

An important problem highlighted by a group of stakeholders during the public consultation is the relatively large number of infringements related to weights of HGVs. The association Euro Control Route, which, out of 28,639 HGVs controlled in week 21 of 2012, found 6,800 HGVs with offences, of which 1,446 (21%) were overloaded. Other evidence has shown that during a roadside check on motorway A11 in France (March 2010), 1/3 of vehicles were overloaded, several vans by 1 tonne, a truck by 80 %, and a coach by 7 tonnes. This is consistent with reports from enforcers from other Member States, according to which 35% of the vehicles checked were non-compliant.

In cooperation with DG MOVE, Euro Control Route sent a separate questionnaire to its members asking about the most frequent infringements related to Directive 96/53/EC. The majority of the members pointed to an overweight of the driving axle. The poor compliance with, and hence the lack of effectiveness of Directive 96/53/EC, leads to damages to the infrastructure (especially road pavement and bridges) made by overloaded HGVs. ISWIM, the International Society on Weigh-In-Motion, estimates an additional average share of 3.8 %[36] of total maintenance costs (€ 25 billion – see chapter 5.2.1) caused by overloaded HGVs. In addition, road safety could be undermined by HGVs that do not respect authorised weights, since stopping a heavier vehicle requires a longer distance and collisions involving a heavier vehicle lead to more damage.

This poor compliance leads to distortion of competition between hauliers and negatively affects the internal market for road transport. In a context of fierce competition, operators operating at the edge of the rules by maximising their load can gain a substantial competitive advantage to the detriment of the others.

Levels of enforcement are very different between Member States. First of all, the limits authorized for national transport operations are quite different: from 40 to 48 tonnes in most countries, 50 tonnes in the Netherlands, 60 tonnes in some Nordic countries. In some countries, there is little enforcement in place. In many of the others, enforcement is done with portable static equipment, mainly during the day, not at night. There are only a few countries where checks are performed by well-trained staff in well-equipped sites along main roads or motorways. Weigh-in-motion stations (WIM) are essentially used in the following countries: NL – FR – DE – UK – CZ. CZ is the sole country where a law authorizes the use of WIM stations for direct enforcement, whereas in others WIM stations are only allowed for filtering, due to their level of inaccuracy.

Furthermore, levels of penalties vary between Member States, as well as thresholds above which these penalties are applied.For example, the threshold of overweight for immobilization of the vehicle varies from 6 % to 15 % between Member States.

Root cause 3) Lack of common and dissuasive enforcement methods

One of the main reasons for the poor compliance with the Directive is that controls are too infrequent, leaving an impression of impunity for potential offenders. According to estimates in France, trucks are weighed on roadside stations on average every 2 million kilometres. Moreover, in the case of container transport, the wrong actors are fined: while drivers have no means to control the weight of the containers they transport, they are the ones responsible according to the law. On the contrary, legislation does not foresee the possibility of fining the shippers/forwarders, who have the possibility to estimate or measure the weight of the cargo and therefore to prevent overloading.

Furthermore, the enforcement policies and control practices in Member States using simple risk profiling are lacking effectiveness, considering that 1 out of 2 controls affect vehicles which comply with the rules, and is thus unnecessary,[37] and consuming scarce resources of public authorities, which could be employed more efficiently to obtain a higher dissuasive effect. Without considering the level of sanctions, which is another crucial element, current checks, when done, are often not cost-efficient and lack effectiveness.

It has to be noted that Directive 96/53/EC does not contain any provisions on the enforcement of the rules it has put in place. This has led the Member States to develop their own practices resulting in widely differing methods of checks and different categorisation and tolerances of offences.

As regards methods, checks performed by Member States vary from a purely manual selection of vehicles to be checked to the pre-selection using technical methods to filter vehicles to be checked manually. Modern and efficient methods, allowing targeted checks, are not widespread: for instance, Weigh in Motion (WIM) systems, which allow pre-checks to be carried out without physically stopping all HGVs and thus stopping only those with a very high likelihood of committing an infringement, are used by enforcement officers in a limited number of Member States only.[38]

On-board weighing devices are another option offered by technology to make drivers aware of the weight of their vehicles. These alert hauliers immediately when an overweight load is being loaded onto the truck. These equipment are currently not standardized, costly (around 3,000 €) and consequently not well deployed. In certain cases, without such devices and when an overweight container[39] is loaded onto a truck, hauliers have no way of checking whether they comply with maximum weight limits. However, there is no common legal framework requiring the use of these devices, and the lack of effective control policy by the Member States has not incentivized hauliers to equip their vehicle fleets.

As regards categorisation and tolerances of infringements, Member States deviate with respect to levels applied when checking HGVs. The result of the questionnaire prepared by Euro Control Route and DG MOVE showed that some Member States allow a tolerance of up to 5% whereas other Member States only allow a tolerance of 2%.

Those differing national enforcement practices is a source of confusion and contradictory signals to hauliers who are subject to different checks and sanctions throughout the EU. Furthermore, drivers have to face the risks of situations coming from the divergence in procedures, documents of proofs required, causing them delays, loss of time, and extra costs.

As a conclusion, current enforcement by Member States is insufficient, not cost effective and lacks harmonisation. As a consequence, hauliers frequently infringe the Directive, which leads to a distortion of competition between transport undertakings, to damage of infrastructure and to safety hasards.

Other problems, which could have been addressed by the revision process, have not been covered, either because these problems are not of a legislative nature but a technical one (for instance the fragility of the side skirts), or because they reflected positions expressed by some stakeholders which were not supported by a majority of them.

o Who is affected, in what ways, and to what extent?

On average, fuel consumption amounts to 1/3 of the costs of road haulage. The provisions of the current Directive, which effectively prevent a more aerodynamic design of the vehicles under the commercial constraints of maximising load capacity, therefore negatively affect commercial road operators. It is obvious that they equally strongly reduce the market opportunities of the manufacturers of such innovative aerodynamic devices and aerodynamic trucks.

Road operators and combined/intermodal transport operators are currently restricted in their capacity to transport larger containers. They would benefit – in terms of new commercial opportunities – from a change in the legislation which would allow them to fit maritime containers on semi-trailers and optimising the use of their transport means with smarter combinations of containers and swap bodies. All intermodal transport operators, including road, rail, sea and inland waterway operators, would benefit from the greater choice and flexibility introduced by these changes.

Truck drivers would be positively affected by changes to the cabin, which would allow for more comfort compared to the current cabins, which are designed to take up as little space as possible to allow for maximum loading space. Other road users would be positively affected by the reduction of the dead vision angles reducing the number of wounded vulnerable users during manoeuvers. Citizens will be positively affected by lower emissions of CO2, NOx, fine particulates and other pollutants, although a possible rebound effect (more road transport resulting from lower costs) will need to be assessed.

Public authorities will be affected as they are in charge of the enforcement of the Directive. They will benefit from reduced damages to road infrastructure and consequently reduced maintenance costs. Infrastructure adaptions will not be required beyond adaptions already introduced in Member States where longer vehicles are already allowed to circulate. Similarly, aerodynamic devices, which could also increase the total length of vehicles, would only be fully effective at speeds above 50 km/h and they would be intended to be folded when entering urban areas, when loading or when the vehicle is involved in an intermodal operation (loading the semi-trailer on to a rail wagon or the whole vehicle on to a boat).

Fuel savings may mean reduced fuel tax revenues but also a positive impact on fuel security and the EU's external trade balance.

FunFinally, all economic actors (companies and consumers) will benefit from lower transport costs and more efficient combined and intermodal transport.

The issue of control of the weights and dimensions of the vehicle will impact the police officers in charge, providing them assistance on procedures and technical means. It would affect the haulage industry by securing a level playing field and all citizens as overloaded vehicles induce higher risks during collisions and have a negative impact on the wear and tear of roads.

o How would the problem evolve, all other things being equal?

The economic crisis will, together with rising costs of fuel and increasingly stringent measures to reduce CO2 emissions from transport, intensify the already fierce competition between hauliers in the road transport sector. This expected development is likely to increase the demand for fuel efficient vehicles by users and consequently to intensify R&D efforts by manufacturers to supply such vehicles. According to the PRIMES-TREMOVE baseline, the total average energy efficiency of HDVs is expected to improve from 309 to 271 tonnes of fuel (all types included) per mio vehicle-kilometres (vkm).

CO2 emissions from HGVs represented approximately a third of total CO2 emissions from transport in 2010 in the EU. This share is likely to increase as measures to reduce the emissions from other transport means have recently been introduced (e.g. emissions from new cars, ETS in aviation). In absolute terms, CO2 emissions from trucks amount to 270 million tonnes per year. Despite the current economic crisis, the amount of vkm of HGV in Europe is rising and expected to increase from 314 mio vkm in 2010 to 390 mio vkm on 2030. If nothing is done, total fuel consumption of HGVs will increase, despite expected energy efficiency improvements, by 9% between 2010 and 2030 according to the PRIMES-TREMOVE baseline, resulting in increased air pollution and CO2 emissions.

Truck manufacturers and equipment suppliers are working on several fronts to improve the energy efficiency of HGVs, for instance through more efficient engines. However, as mentioned by the manufacturers in the targeted stakeholder meeting organised by DG MOVE in the context of this IA, the current limits of Directive 96/53/EC prevent manufacturers from improving the aerodynamic performance of HGVs.

The upcoming Commission Regulation on the type approval of heavy duty vehicles will allow rear devices of a maximum length of 50 cm which could help saving 2 % of the fuel consumption (see Figure 3). This limited extension, would not require a revision of Directive 96/53/EC. Indeed the measurements in Directive 96/53/EC refer to Directive 97/27/EC (and as a result to the Commission Regulation which will repeal Directive 97/27/EC). Since rear deflectors are accepted in addition to the maximum measurements in the Regulation, they will not be considered as exceeding the maximum dimensions in Directive 96/53/EC either. However, the fuel savings would remain limited in light of the potential offered by longer extensions (see table 1 above).

Figure 3: 500 mm deflector under test

The small scale of the changes brought by this future Commission Regulation can result in a loss of competitiveness of the EU HDV manufacturing sector on markets in other world regions where developments are on-going to reduce the aerodynamic drag of HDVs[40].

The use of intermodal transport, which is generally acknowledged having the potential to increase energy efficiency and CO2 performance of transport, is hampered by the Directive in terms of the use of 45’ containers requiring special permits for transport by road. Due to the remaining additional administrative burden for 45' containers, as described earlier the EU risks staying behind the worldwide evolution of containerisation, and the additional costs of special permits and derogations will hinder the economic sustainability of an economic sector under considerable stress.

The use of 45’ containers in land-only movements is unattractive for hauliers as – compared to conventional trailers – such containers are very heavy and thus reduce the permissible payload while allowing loading the same number of pallets as in conventional trailers and while requiring costly permits for such movements. Hence, the use of 45’ containers in land-only movements is not expected to increase in the future.

The use of hybrid or electric vehicles in freight transport is currently hampered – in addition to their price – by the additional dead weight of these vehicles and thus the need to reduce the payload of the vehicles, either passengers or goods, in order not to exceed the maximum allowed weight. This situation, unless unchanged, contributes to a slower uptake of hybrid and electric vehicles for freight transport, which will prevent the sector from becoming more energy efficient. The dead weight of HGVs seen in isolation is expected to increase in the future due to more stringent requirements related to safety and other equipment. Whereas this will reduce the permissible payload, the fierce competition between hauliers will require a greater consolidation with the risk of infringing weight limitations.

Moreover, both increasing mandatory safety requirements in HDVs and the general increase in the weight of human beings negatively impact the permissible payload and hence freight rates/ticket prices of the road freight and passenger transport sector respectively. Assuming that this situation would not impact traffic volumes, or only to a minor degree, passengers may increasingly choose to disfavour buses and coaches and use private cars, and more trucks will be needed to meet the transport demand for goods leading to higher CO2 and pollutant emissions.

Leaving cabin designs of HGVs unchanged would also result in a missed opportunity to simultaneously reduce aerodynamic drag and to further reduce numbers of fatalities with HGVs.

In terms of compliance with current legislation on weights and dimensions, it is expected that the fierce competition in the EU road haulage market will intensify with the crisis and with increasing fuel costs. Hauliers are likely to operate more and more on the margins of the existing legislation, hence committing more infringements than currently reported. Current controls and methods applied by enforcement bodies are obviously not able to effectively ensure full compliance with the Directive. This situation is expected to increasingly result in distortion of competition between hauliers, and non-respect of maximum weight limits will result in damages of the infrastructure and reduced road safety.

o Does the EU have the right to act – Treaty base, ‘necessity test’ (subsidiarity) and fundamental rights limits?

§ Link to the corresponding article of the Treaty

This impact assessment explores and analyses options for revising Directive 96/53/EC, which is based on Article 91 TFEU (ex-Art 71). The EU added value was recognized when this Directive was adopted and the arguments, which substantiate this added value, still hold.

These arguments are predicated upon the ever-increasing reality that road transport within the EU is transnational in nature. Cross-border road freight transport accounts for approximately one third of total road freight transport[41] and passenger road transport also has an important international dimension. Data compiled by the European Commission shows that cross-border road freight is an increasing proportion of this total. This is due to increasing cross-border trade and economic growth, which have in part been facilitated by the EU Internal Market and by the liberalisation of the road freight market in Europe.

§ Subsidiarity test

The objective of Directive 96/53/EC is to set limits to the size of the vehicles allowed on public roads in the EU, safeguarding the right for each Member State to accommodate bigger or heavier vehicles on its own territory if its infrastructure allows it. The objective of the current revision does not question the possibility for Member States to develop solutions according to local circumstances. It also aims to adapt the terms of the Directive to technical progress, within the existing constraints of infrastructure, road safety and market conditions. Indeed it appears that some limits in the Directive could be relaxed to harness the benefits from new technologies. An adaptable approach to the definition of new standards is suggested so as to reflect techincal evolutions and changing market standards.

As at the time when Directive 96/53/EC was adopted, an action by Member States alone would not be sufficient to ensure an EU-wide harmonisation of maximum lengths and dimensions. A patchwork of differing national rules would hinder the creation of a truly integrated EU road haulage market.

In a context of increasing cross-border road freight transport, the preceding chapters have highlighted the fact that common rules and levels of enforcement are increasingly required to ensure a level playing field between hauliers. Different levels of enforcement between EU Member States favour certain hauliers and may create incentives for hauliers to plan routes via countries or itineraries where enforcement levels are the lowest. These different levels are also causes for discrimination between hauliers and additional burdens in international traffic. Action at EU level is therefore required to harmonise effectively the implementation of the limits set in the Directive.

However, given that enforcement is subject to important subsidiarity considerations, as measures in this area may be costly and as they are under the competence of Member States, any measure proposed in this area will be studied carefully in the section on assessment of impacts. Similarly, categories and levels of sanctions, which are outside the scope of the existing Directive and which are under the competence of Member States, will be scrutinised and will be assessed in terms of added value before any proposal is recommended in this area.

§ Test of added value

Considering the nature of the problems addressed in this IA having a clear EU dimension – both in terms of harmonisation and in terms of controls – the EU is in a better position to address the problems than Member States. Lastly, EU Directives may only be revised at EU level.

· Objectives

This section defines the general, specific and operational policy objectives of the proposed initiative, discusses possible trade-offs between them and verifies their consistency with other EU horizontal objectives.

o Policy objectives

General objectives

In line with the problems described in section 2 above, the general objective of this initiative, taking account of the general economic context and the headline goal of the White Paper, is twofold:

· To improve the energy efficiency of road transport and to facilitate intermodal transport while respecting the requirements of infrastructure maintenance, road safety and the protection of the environment. [42]

· To improve the internal market for road transport by ensuring a level playing field for hauliers and by increasing the effectiveness of Directive 96/53/EC.

Specific objectives

In light of the above and in order to address the problem and its root causes identified earlier, the general objective of this initiative can be translated into three specific objectives (SO). These objectives must be achieved without upsetting the balance between the requirements of infrastructure maintenance, road safety and the protection of the environment, as explained under the first general objective and in section 2.2.1 above.

SO1: To enable the market uptake of more aerodynamic, electric and hybrid trucks and to increase the attractiveness of certain coach services.

SO2: To enhance the development of intermodal/combined transport via a support to new possibilities of containerisation.

SO3: To ensure better enforcement of the maximum weights and dimensions across the EU.

Table 3: Mapping problem and objectives

Problem – Part 1 Certain limits on weights and dimensions set by the Directive constitute obstacles to energy efficiency gains of road vehicles and to intermodal transport operations. || General objective – Part 1 To facilitate energy efficiency of road transport and intermodal transport by revising certain limits on weights and dimensions of vehicles while maintaining the balance with the requirements of infrastructure maintenance, road safety and the protection of the environment.

Root cause 1: Certain maximum weights and dimensions prevent the market uptake of more aerodynamic, electric and hybrid trucks and reduce the attractiveness of certain coach services. || Specific Objective 1: To enable the market uptake of more aerodynamic, electric, hybrid trucks and to increase the attractiveness of certain coach services.

Root cause 2: Certain maximum weights and dimensions have not kept pace with the technical developments of intermodal transport and containerisation. || Specific Objective 2: To enhance the development of intermodal/combined transport

Problem – Part 2 The Directive is not applied in an effective manner || General objective - Part 2 To improve the internal market for road transport by providing for a fairer playing field for hauliers.

Root cause 3: Lack of common and dissuasive enforcement methods || Specific Objective 3: To ensure better enforcement of the maximum weights and dimensions across the EU

Operational objectives

The above-mentioned specific objectives related to energy efficiency (SO1 and SO2) of road and of intermodal transport are complex and depend on factors which are independent from the scope of this initiative. Due to complications of dissociating these factors, it has been decided not to propose any quantified operational objectives with regard to energy efficiency. Alternatively, the following operational objectives are proposed, which will allow monitoring and evaluation (see Chapter 7) of the impacts, and their evolution, of the proposal of the Commission:

OO1: Achieve a significant share of long-distance trailers equipped with rear aerodynamic devices (75%) and aerodynamic cabins (50%) by 2030

OO2: Achieve a doubling of the use of 45’ containers transported as part of a combined/intermodal transport operation by 2030

SO3 logically should be associated with an operational objective measuring the evolution of the compliance with Directive 96/53/EC. The following operational objective is proposed:

OO3: Increase the effectiveness of manual checks (number of infringements / number of checks). Such an increase will improve the reliability of checks and at the same time avoid 100,000 unnecessary checks annually by 2020.

o Possible trade-offs between the objectives of this initiative and the horizontal objectives of the EU

Increasing the energy efficiency of road and of intermodal transport will increase economic efficiency of these modes of transport, which could potentially lead to a minor rebound effect resulting in freight and passenger transport shifting to road from other modes of transport and thereby contributing to increased CO2 emissions. However, as mentioned in Chapter 2, and also in the 2011 transport White Paper, this initiative would not stand alone. Other initiatives are planned, which increasingly will implement the ‘user-pays’ and the ‘polluter-pays’ principles, and which will complement this initiative with the goal of ensuring competitive transport services, while at the same time seeking to avoid rebound effects. For example, the 2011 White Paper on Transport announces the introduction of an infrastructure charging scheme for heavy duty vehicles, with a common tariff structure and cost components such as the recovery of wear and tear, noise and local pollution costs, which would replace the existing user charges.

· Policy options

The stakeholder consultation, the targeted stakeholder meetings and research allowed the Commission to identify a set of individual measures having the potential to address the root causes identified in the problem definition above. The following process was applied for establishing the policy packages that will be analysed in later parts of the present report:

Identify the policy measures which can be discarded on the basis of a first preliminary assessment;

Identify a list of retained policy measures addressing the problems and respective root causes in full;

Combine retained measures into policy packages constituting viable policy alternatives for achieving the objectives.

o Discarded policy measures

A few policy measures were proposed by some stakeholders, yet contested by other stakeholders and in some cases contradicted by scientific evidence. They are described in more detail below along with reasons for excluding them from further assessment in this IA.

Firstly, several proposals were made in the public consultation to increase the loading capacity of vehicles in cross-border traffic (for instance to liberalize the traffic of EMS vehicles at 60 tonnes and 25.25 m, or to raise the weight limit for five- or six-axle vehicles to 44 tonnes). Such proposals were based on studies having been carried out on the potential of vehicles to increase the efficiency of road transport by increasing the loading capacity. However, discussions and objections from several other stakeholders, and the fact that the underlying studies present conflicting results, do not allow establishing a mature and clear position on the long-term impact of an EU-wide use of such vehicles, notably as regards possible infrastructure damages or expansion/investment needs, road safety, rebound effects and modal shift. Moreover, maximum dimensions of vehicles and lengths of loading units – and thus the loading capacity of vehicles – are directly related. As standard loading units are essential to ensure interoperability in and between transport modes, any extension proposed by stakeholders to increase loading capacity would hinder interoperability and consequently not be considered as a valid policy measure. Therefore, and as it was initially announced in the introduction to the public consultation, all measures beyond what is currently authorised by Directive 96/53/EC[43] intending to significantly increase the total weight and the loading capacity of long-distance HGVs are out of the scope of this initiative and will not be considered in this impact assessment.

Secondly, some proposals were made by niche sectors to accommodate specific needs. For instance, transporters of completed vehicles and of refrigerated goods suggested that an increase in the maximum loading length and/or width may be beneficial to accommodate their specific loading conditions. Given the limited market share of these sectors and given potential needs of other niche markets, which were not expressed during the consultation and which would be overlooked, it was decided not to provide specific derogations for each of these as it would lead to a fragmentation of legislation on a sectorial basis. Moreover, some of the sectorial requests – if satisfied – would lead to a significant increase of the loading capacity, an option excluded from the scope of this revision of the Directive as explained in point 2.2.1 above.

List of considered policy measures

The tables below provides a mapping between the retained list of policy measures proposed by stakeholders, Member States and other interested parties, and the root causes identified ealier in this Impact Assessment.

§ List of considered policy measures in relation with energy efficiency

Table 4: Measures corresponding to root cause 1: Certain maximum weights and dimensions prevent the market uptake of more aerodynamic, electric and hybrid trucks and reduce the attractiveness of certain coach services.

Measures || Description

1. Rear flaps || The maximal allowed length is increased for vehicles equipped with special aerodynamic devices fitted at the rear of the trailer/semi-trailer. The devices must respect essential requirements on aerodynamics, road safety and suitability for the infrastructure. They must be foldable or retractable in order to allow urban traffic, loading onto rail wagons, and to accommodate the constraints of the infrastructure on and off motorways. These allowances shall be used for no other purpose than aerodynamics and cannot increase the loading capacity.

2. Aerodynamic cabins || The maximum allowed length of HGVs with more aerodynamic cabins is increased. The conditions, including the essential requirements for the devices on energy efficiency, CO2 emissions and road safety and suitability for the infrastructure are defined by the Commission with the help of a committee. The extended length will allow manufacturers to redesign the cabin to improve its aerodynamics, to improve the safety of other road users and the comfort of the driver. As above, these permissions are used for no other purpose than aerodynamics and cannot increase the loading capacity of HGVs.

3. Make rear flaps mandatory on all vehicles || This measure concerns all new vehicles as well as retrofitting of existing ones by 2025. This date is fixed to give sufficient time to hauliers to adapt or renew their fleets of trailers.[44]

4. Higher weight limits for electric/hybrid trucks || The maximum weight of vehicles using electric or hybrid propulsion is increased by 1 tonne for the sole purpose of accommodating the extra weight of the batteries for electric or dual propulsion (hybrid motorization), and with the condition that current maximum axle weight limits are respected[45].

5. Max. 19 t for two-axle coaches || The maximum weight of two-axle coaches is increased from 18 t to 19 t to accommodate the extra weight of the new mandatory on-board devices for safety and control, and to take into consideration the increase in weight of passengers and luggage[46]. The increase in the weight of vehicles due to legal obligations is detailed above (see chapter 2.2.1)..

Table 5: Measures corresponding to root cause 2: Certain maximum weights and dimensions have not kept pace with the technical developments of intermodal transport and containerisation

Measures || Description

6. Allow for 45' containers in combined transport || Extension in length of the trailers by 15 cm to accommodate 45' containers in combined transport, and only for that purpose. In addition, as the cross-border transport of 40' containers is already allowed with a weight of 44 tonnes to account for the dead weight of the container, transport of 45' containers is also permitted to reach 44 tonnes in combined transport. Furthermore, the transport of non-ISO 40' containers is also allowed in combined transport.

7. Allow for 45' containers in intermodal transport[47] || The transport of 45' containers is allowed in intermodal transport and by standard trailers only extended by 15 cm, with a weight of 44 tonnes. No more reference to combined transport is made.

8. Facilitations for larger containers || The future tendency seems to be going towards expanded sizes of containers in intercontinental shipping to 48 or even 53 feet. It is proposed that the Commission is empowered to update the limitations in dimensions and weight fixed in Annex I to the Directive in order to accommodate the evolution of intermodal transport of containers. This includes also pallet-wide 45 feet containers. Such an update would be based on a market study, expert consultation and an impact assessment.

§ List of considered policy measures in relation with improving the functioning of the internal market for road transport

Table 6: Measures corresponding to root cause 3: Lack of common and dissuasive enforcement methods

Measures || Description

9. Guidelines on enforcement || The Commission will define guidelines on good practices for controls and checks with the help of a committee and experts from stakeholder organisations. These guidelines will address methods and best practices to make checks more efficient (ways to target vehicles and to perform checks efficiently and safely), with a view of harmonization between all Member States. The work will be based on the results of European projects, the experience gained in different Member States and from the operation of weigh-in-motion stations and of other automatic systems.

10. Common categorisation of infringement || Binding categorisation of the levels of seriousness of infringements to the Directive, with a regular reporting obligation to the Commission for Member States on checks carried out and infringements. Reports will be used to monitor the effectiveness of the enforcement policy of the EU and the Member States. The synthesis of the reports will be published. The categorization of infringements will be defined according to different thresholds on excessive weight, length or width of the vehicle. Depending on the category, vehicles could/shall be stopped until obtention of a special permit or unloading, a financial penalty would be imposed or even – for the highest infringement class – the procedure for loss of good repute of the company would be launched.

11. Mandatory preselection of vehicles targeted for manual checks || In order to limit the number of vehicles stopped for manual control, and to increase the number of vehicles controlled by automatic means, all Member States should implement filtering methods for checks on weights and dimensions enabling a pre-selection. Preselection of vehicles could be carried out with weigh-in-motion stations or on-board weighing sensors linked to the digital tachograph, or with company profiling. The preselected vehicles would be stopped for manual check and only this manual check would possibly lead to an infringement and a prosecution. The obligation will be defined in terms of performance and not in terms of means.

12. Co-liability of the shipper / forwarder || Road transport operators transporting containers often have to rely on the weight stated on the freight documents to ensure compliance with the maximum permissible weight. In cases where HGVs are overweight due to inaccurate weight specifications on the documents, and in cases where the transport operators had no other means of verifying the total weight, shippers, freight forwarders or other parties having indicated the weight of the containers on the freight documents and having signed these shall be jointly liable in case of infringements.

13. Standards for on-board weighing devices || The Commission will define EU standards of on-board weighing devices in order to ensure pan-European interoperability so that the devices can communicate with roadside equipment. It will facilitate the deployment of on-board weighing devices, which would transmit in real time data from a vehicle to a police officer alongside the road through a DSRC interface and beacon. This would allow police forces to know the weight of the vehicle without stopping it. It would also allow hauliers to know the weight of their truck more precisely when loading.

14. Compulsory on-board weighing devices || On-board weighing devices will have to be installed by default for all new trucks and coaches as from 2025. Retrofitting of older vehicles will not be mandatory.

15. Minimum number of manual checks || All Member States shall mandatorily check a certain percentage, e.g. 10%, of the number of trucks and coaches on their road network for offenses to the rules on maximum weights and dimensions.

o Identification of the policy packages (in addition to the business-as-usual scenario)

To address the problem and all the problem root causes in full, and given the substantial list of measures, it is proposed to form policy packages (PP) of measures for further assessment. Each policy package will be composed of a series of policy measures addressing both the issue of energy efficiency and the issue of enhancing the rules governing the functioning of the internal market.

It is proposed to keep for in-depth assessment three PPs, which are cumulative, meaning that PP 2 would include the measures of PP 1, and PP 3 would include the measures of PP 1 and of PP 2. The policy packages are conceived to include measures with increasing intensity addressing respectively energy efficiency and compliance with the rules of the Directive. The amplitude of impacts, both negative and positive, is expected to be higher in PP 2 than in PP 1, and higher in PP 3 than in PP 2.

Other policy packages with measures of varying intensities were also provisionally envisaged combining measures with high intensity in the area of energy efficiency with measures of low intensity in the field of enforcement. Such policy packages were however discarded as measures to increase the maximum length and weight of vehicles would require proportionately reinforced control measures in order to avoid additional infringements, which may have adverse impacts on safety and on the infrastructure. On the other hand, policy packages envisaging measures of low intensity in the area of energy efficiency and measures of high intensity in the area of enforcement were discarded for reasons of political acceptability, acknowledging that higher levels of enforcement without preselection, in a situation where current limitations of weight and dimensions of HGVs would remain unchanged, may be considered as a significant burden to stakeholders and to Member States and such policy packages would have little chances of being adopted[48].

§ Policy Package 1: Limited revision

This package is based on limited revisions of the Directive as well as on soft measures aiming at an improved implementation of the Directive with minimal changes and costs. It therefore excludes measures which:

· require changes at the vehicle manufacturing phase (measure 2),

· lead to a serious re-organisation of the logistics structures and procedures (measures 8, 12 and 13),

· priviledge compulsory over optional changes (measures 3, 10, 11, 14 and 15),

· are general, rather than limited in application (measure 7).

In order to improve the energy efficiency of trailers and so as to reduce their CO2 emissions, the Directive needs to be amended to improve the aerodynamic performance of vehicles. Studies performed by different stakeholders and presented during the stakeholder meetings as references suggest that an extension of the length of the vehicle is necessary in order to accommodate foldable or retractable rear flaps. These flaps would primarily be used when the truck exceeds 50 km/h and should thus be retractable or foldable when entering urban areas, slow roads with roundabouts for instance, or for use on rail wagons or ships in combined transport. These flaps would be allowed if they comply with technical requirements on aerodynamic performance, on traffic safety and suitability for the geometry of the different types of road or streets. A committee will help the Commission to refine and to update these requirements on a regular basis. The measure would be immediately operational, given that manufacturers of trailers indicated that they would be in a position to react very rapidly.

A second way to improve the energy efficiency and environmental performance of trucks and coaches is to provide the possibility to better accommodate alternative propulsion systems in these vehicles. Therefore, derogations in weight are provided for alternative systems – electric or hybrid – for both trucks and buses. Studies on batteries and hybrid motorisation suggest that an increase of 1 tonne is needed to the weight limits for trucks and coaches.

Energy efficiency also entails a shift from personal transport to public transport. It is therefore important to take into account the current evolution of the weight of passengers and their luggage and to adapt the maximum weight of a coach for that purpose. A weight increase of 1 tonne will be proposed for two-axle coaches.[49] This extra weight will also accommodate the different types of equipment made mandatory for the purpose of, for instance, passengers' safety and comfort, as explained in chapter 2.2.1 above.

In order to accommodate the development of intermodal transport and of containerisation, and drawing on the stakeholder consultation and workshops, it is proposed to allow an additional 15 cm extension of the length of the trailer for the transport of 45' containers. This is a very limited modification and it would have virtually no impact on manoeuvrability or safety. Considering that vehicles carrying containers of 40' as part of a combined transport operation may currently be loaded up to 44 tonnes without a special permit so as to take into account the dead weight of the container and to give an advantage to intermodal transport, the same derogation should for reasons of consistency apply to vehicles carrying 45' containers. Measures 6, related to combined transport, and 7, related to intermodal transport, are both retained in PP1 as alternative solutions for facilitating the transport of 45' containers. They were both suggested during the stakeholder consultation and, given their similar nature, it seems appropriate to analyse these measures as variants of the same policy package rather than as parts of different policy packages. Policy Package 1 thus offers two variants regarding measures 6 and 7 on respectively combined and intermodal transport of 45’ containers:

• In variant "a", the facilitations for the transport of 45' containers at 44 tonnes would remain restricted to the area of combined transport, like in PP1 (measure 6)

• Variant "b", on the other hand, proposes to extend the possibility to transport 45' containers at 44 tonnes beyond the scope of combined transport (measure 7), and enable these to be part of intermodal transport chains as well, in order to further promote containerisation.

Moreover, under this package an improved enforcement of infringements against the Directive would be addressed through guidelines drawing the attention of all stakeholders including Member States' authorities to the requirements of the Directive, especially on the maximum weight, and providing some rules and procedures, as well as technical means on how to use them. These guidelines, strongly welcomed by the enforcement community, would harmonise the procedures across the EU, thereby avoiding that drivers face different situations from one country to another with the same truck or coach. Policy Package 1 thus addresses the issue of ineffective application and absence of control standards (specific objective 3).

§ Policy Package 2: A more extensive revision

This package would entail a more intensive (in terms of magnitude of impacts) revision of the Directive, with new measures in addition to the measures proposed in Policy Package 1 including the variants. The additional measures will require a certain adaptation effort from the automotive industry and from the administrations. Far-reaching measures or those requiring a very large adaptation effort from the industry and administrations would still be excluded (measures 3, 8, 14 and 15).

Concerning the aerodynamics of the trucks, in addition to rear flaps, a redesign of the cabin will be allowed, with an increase of the cabin length. This redesign will also be based on technical requirements on aerodynamic performance, road safety and suitability to infrastructure. The same committee proposed in measure 1 will be used for the purpose of measure 2. The reason for which measure 2 on the aerodynamics of the tractors has been proposed in PP 2 and not in PP 1 is a matter of time and amplitude of impacts. A redesign of the cabin is a substantial task for the automotive sector and can have wider implications than rear flaps (on infrastructure, road safety and driver comfort). It cannot be considered as a limited revision of the Directive. The time required for the design and development of new cabins is expected to last several years, in order to take into account other issues such as safety of vulnerable users in accidents, the comfort of the driver and the inclusion of mandatory equipment related to road safety. This is why this measure would be made operational only after a period of several years after the adoption of the Directive.

In terms of controls and enforcement of offences, new binding measures are proposed harmonising the categorisation of infringements throughout Europe, and the obligation for Member States to perform a pre-selection by filtering of vehicles possibly infringing the Directive and targeted for manual checks. Preselection could be determined by weigh-in-motion systems allowing enforcers not to slow down traffic for vehicles complying with the limits, or on-board weighing devices installed in trucks and coaches. The obligation is in terms of performance, not in terms of technical means. A reporting obligation to the Commission would allow measuring the evolution of the rates of infractions, and the effectiveness of the Directive. By developing common EU standards, the revision will encourage the deployment of on-board weighing devices which would transmit the weight of the vehicles and per axle in real time to police officers along the roadside through a DSRC interface (20 meters range). This type of equipment would be linked to the digital tachograph by some functionalities. With such a system, hauliers would also know precisely the weight of their vehicle when loading. Knowing the weight of the vehicle, the haulier will have the possibility to take the appropriate measures to respect the legislation in force.

Road transport operators transporting containers indicated that they often have to rely on the weight stated on the freight documents to ensure compliance with maximum permissible weight limitations. In cases where HGVs are overweight due to inaccurate weight specifications on the freight documents, and in cases where the transport operators had no other means of verifying the total weight, shippers, freight forwarders or other parties having indicated the weight of the containers on the freight documents and having signed these shall be jointly liable in case of infringements.

These measures address the problem of unsatisfactory enforcement (specific objective 3).

§ Policy Package 3: More binding regulatory approach

Beyond the measures presented in the PP 1 and 2, including the variants, other measures are envisioned, as follows, in order to push forward more actively the realisation of the objectives of the revision.

On the energy efficiency side, rear flaps are made mandatory for new trailers and trucks and by 2025 are made compulsory for older vehicles through retrofitting. This would ensure that the whole European fleet of trucks and trailers is equipped with these devices in a time frame also acceptable for SMEs to adapt their fleets. This measure contributes to meeting specific objective 1 and to address the problem of suboptimal energy efficiency and CO2 emissions.

Further developments expected in intercontinental sea shipping and containers longer than 45 feet (48 or 53 feet for instance) might have to be accommodated in the future by road transport in a sufficient number to imagine legal instruments beyond special permits. Although data on such containers is scarce, it is known that they are increasingly used in countries such as the USA and China. The Commission might thus be given the mandate to accommodate the evolution of intermodal transport with further modifications of the size and weight limits in Annex I to Directive 96/53/EC, on the basis of studies performed by a committee of experts. The update of the Annex would be made through a Commission Decision. This measure will help to meet specific objective 2 by ensuring that standards on containerisation are constantly updated.

In case the measures described above are not considered as sufficient to cope with the excessive number of infringements against the Directive and in order to correctly implement possible changes in weight limits in the Directive due to the transport of larger containers, onboard weighing devices would be made mandatory to new vehicles produced after 2025 and a percentage of the traffic of heavy goods vehicles and coaches could be fixed that every Member State will have to check manually every year, with an obligation to report to the Commission. The mandatory onboard weighing devices would help in the preselection of vehicles to be inspected by manual checks. The addition of the two measures would ensure the most effective way of lowering the level of infringement currently recorded.

Finally, since the options are incremental, PP 3 contains the same variants "a"/"b"as PP 1 and PP 2 respectively.

§ Overview of measures proposed in Policy Packages

Table 7: Overview of measures proposed in Policy Packages

|| PP1 || PP2 || PP3

Specific Objective SO1: To enable the market uptake of more aerodynamic, electric and hybrid trucks and to increase the attractiveness of certain coach services.

1. Rear flaps || X || X || X

2. Longer cabins || || X || X

3. Mandatory rear flaps for all vehicles || || || X

4. Higher weight limits for electric/hybrid trucks || X || X || X

5. Max. 19 t for two-axle coaches || X || X || X

SO2: To enhance the development of intermodal/combined transport

6. Allow for 45' containers in combined transport || X/Ø || X/Ø || X/Ø

7. Allow for 45' containers in intermodal transport || X/Ø || X/Ø || X/Ø

8. Facilitations for larger containers || || || X

SO3: To ensure better enforcement of the maximum weights and dimensions across the EU

9. Guidelines on enforcement || X || X || X

10. Common categorisation of infringement || || X || X

11. Mandatory preselection of vehicles targeted for manual checks || || X || X

12. Co-liability of the shipper/forwarder || || X || X

13. Standards for on-board weighting devices || || X || X

14. Compulsory on-board weighing devices || || || X

15. Minimum level of manual checks || || || X

· Analysis of impacts

The present chapter will assess the impacts of the three proposed policy packages, compared to the baseline, with respect to relevant impacts identified in the Commission Impact Assessment Guidelines[50].

The analysis of the impacts will be partly of a qualitative nature and partly of a quantitative nature where quantitative evidence is available and can be usefully applied in the analysis of impacts.

Due to the policy packages being cumulative, the analysis of the impacts will focus on incremental changes between the policy packages. According to this approach, PP 1 will initially be compared to the baseline, PP 2 will be compared to the baseline and to PP 1 and PP 3 will be compared to the baseline and to PP 2.

o Environmental impacts

§ Climate change

Obstacles caused by Directive 96/53/EC to achieving efficiency gains from road and from intermodal transport were identified as one of the main problems of the present impact assessment. Addressing this problem by way of adapting maximum weights and dimensions of HDVs would allow increasing energy efficiency and consequently reducing GHG emissions, which would provide a positive contribution to the fight against climate change. The current initiative has, in line with the problem definition, identified measures related to aerodynamics of vehicles, which would require an extension or derogation from current maximum length limitations, and related to propulsion systems and to buses, which would require an increase in current maximum weight limitations.

Firstly, concerning aerodynamic devices, it is important to note that the front and the rear of HGVs contribute equally to aerodynamic drag. These two factors are the most influential ones, contributing each to approximately 1/3 of the overall aerodynamic drag of HGVs[51]. As 40% of the fuel consumption of HGVs is used to overpower aerodynamic drag[52], these two factors are significant, and lowering any of them could potentially lead to important reductions in fuel consumption. Such reductions would help prevent climate change.

The rear of HGVs creates a low-pressure zone ‘pulling’ vehicles backwards, which is responsible for approximately 35% of all drag affecting a tractor with a semi-trailer[53]. By installing aerodynamic devices at the rear of trailers it is possible to achieve gains of 5 to 8 % (or possibly even 15 % when combined with aerodynamic cabins) in fuel consumption[54], which would result in a similar reduction in GHG emissions. The performance of these devices increases with their length and would require an extra length ranging between 0.5 m and 2 m. It can be demonstrated that, in this range, there is a near-linear relationship between the length of aeodynamic rear devices and the resulting fuel saving. This relationship does not extend beyond 2 metres, after which any additional effect would diminish[55].

However, an assessment of the impacts of extra length due to the fitting of aerodynamic devices would have to be based on their actual effectiveness (and safety – see below), which is closely related to speed, and hence to use, as displayed in Figure 4 below.

Figure 4: Fuel consumption according to speed

Source: Trailer aerodynamics, PART - Platform for Aerodynamic Road Transport, 2012

As highlighted by the IRU during the public consultation, while studies convincingly demonstrate that rear flaps would allow recovering the investment costs by lowering fuel consumption in long-distance transport, no trials have been performed to demonstrate how much a standard truck performing short- or medium-distance trips would gain in fuel reduction during its lifetime. Should it turn out to be insufficient, it may limit the attractiveness of rear flaps for many hauliers. Hauliers also warn of possible problems linked to damage to flaps during loading or unloading.

Regarding the front of HGVs, one recent study[56] has shown that if the lower part of the front of the driving cabin was streamlined and extended by 0.8 m, the aerodynamic drag coefficient (CD) would drop by 6.4 % resulting in a reduction of fuel consumption by 3.2 to 5.3 %. Shorter extensions (0.4 m) of cabins would yield markedly poorer results (4.5% reduction in CD). With a longer extension (1.2 m) the gain would increase to 8.9 %. These results were also obtained on high-speed long-distance trips.

In Table 8 below, fuel savings for HGVs, and the corresponding climate change mitigation, are estimated at different market penetration rates of the various policy measures. It should be noted first of all that the data used in this table are based on modelling and projections (for instance of fuel prices) and may therefore only give an estimate of the foreseen effects. Furthermore market penetration rates are likely to differ for the policy measures due to differences in the product cycles and in investment requirements. Whereas rear devices could be deployed relatively quickly, including their installation on existing vehicles, and would require a minor investment, the deployment of cabin re-designs and hybridisation are expected to have longer lead times due to higher investment requirements and/or longer product development cycles. It is should however be highlighted that providing estimates on the uptake of such devices is challenging due to their innovative nature.

The vehicle stocks are determined according to the use made of the devices described above. Of the total estimated EU HGV fleet in 2030 (9.8 million vehicles), only those above 20 tonnes in maximum weight are expected to be equipped with rear devices and cabins (41.5% or slightly more than 4 million). Roughly 1 in 4 (around 25%) of these are thought to be used to travel long distances (about 1 million). Due to their safety benefits in urban contexts, the fleet of vehicles using new cabins is expected to be larger than the one equipped with rear flaps. However the fuel savings linked to their aerodynamic properties will only take place on long-distance high-speed trips. The fleet used to estimate the fuel savings from this measure is therefore the same as for vehicles using rear add-ons.

Moreover, in order to calculate the fuel savings (in million litres) for the potential stock of HGVs at different market pentration rates, it was assumed, using statictics from Eurostat and evidence from France, Germany and the UK, that average HGVs drive between 39,000 km/year (short distance) and 98,000 km/year (long distance), and that HGVs on average consume 30 litres fuel per 100 km.

The total fuel saving (in million Euro) was calculated multiplying the resulting fuel savings (in litres) by the forecasted price of fuel in 2030 of 2.10 €/litre from the the PRIMES-TREMOVE reference scenario.

The carbon reduction potential (in tonnes) was calculated multiplying the total fuel saving (in litres) by the carbon content of diesel (2.6 kg CO2 / litre, diesel) and the benefit in terms of the lower contribution to the climate change (in Euro) was calculated multiplying the total carbon reduction potential (in tonnes) by the estimated price of carbon in 2030 of €36/tonne from the DG Clima IA on a Roadmap for moving to a competitive low carbon economy in 2050.

Table 8: Estimated fuel saving and corresponding climate change mitigation (2030)

Source: Own calculations (main assumptions: 1. Forecasted EU27 HGV stock of 9.8 million by 2030 from PRIMES-TREMOVE reference scenario of which 25% drive mainly long distance, 2. Average HGVs drive between 39.000 km/year (short distance) and 98.000 km/year (long distance) and consume 30 liter diesel/100 km[57], 3. The forecasted price of fuel is 2.1 €/liter in 2030[58],, 3. Price of carbon in 2030 is €36/tonne[59]).

These results show distinct progress in comparison to the baseline scenario.

Hybridisation of lorries and of buses could potentially lead to a reduction in fuel consumption of 20-30%[60]. By allowing the extra weight to carry these propulsion systems, and in addition, extra weight to handle the increase in weight of passengers and their luggage, and the extra weight required for mandatory safety equipment, the payload could be maintained[61] resulting in an increased energy efficiency per tonne/passenger transported. If on the other hand such propulsion systems were introduced without an allowance to increase the total weight of vehicles, the payload would have to be reduced which would off-set potential gains in energy efficiency per tonne/passenger transported, and hence potentially hamper the market uptake of such propulsion systems. Concerning the weight of the passengers in buses, maintaining the current total weight of buses (and therefore limiting the passenger capacity) would restrict the shift from personal to public transport, which is being promoted by the EU among others to protect the environment.

Lastly, reducing the administrative burden on the use of 45’ containers is likely to increase their use in Europe, which is currently