Opinion of the Economic and Social Committee on the "Proposal for a Directive of the European Parliament and of the Council amending Council Directive 70/220/EEC concerning measures taken against air pollution by emissions from motor vehicles"
Date: 2001-02-28
Institutions: European Economic and Social Committee
Subjects: air quality, combustion gases, environmental protection, motor vehicle, technical standard, vehicle parts

11.5.2001

EN

Official Journal of the European Communities

C 139/1

II

(Preparatory Acts)

ECONOMIC AND SOCIAL COMMITTEE

Opinion of the Economic and Social Committee on the ‘Proposal for a Directive of the European
Parliament and of the Council amending Council Directive 70/220/EEC concerning measures
taken against air pollution by emissions from motor vehicles’

(2001/C 139/01)

On 26 September 2000, the Council decided to consult the Economic and Social Committee, under
Article 262 of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for the Single Market, Production and Consumption, which was responsible for preparing
the Committee’s work on the subject, adopted its opinion on 7 February 2001. The rapporteur was
Mr Bagliano.

At its 379th plenary session (meeting of 28 February 2001) the Economic and Social Committee adopted
the following opinion by 105 votes to one, with two abstentions.

1.

Introduction

This draft directive ties in with the framework directive
1.1.
on the comprehensive type-approval of vehicles (Directive
70/156/EEC (1)), which defines the various vehicle categories
that are then addressed in individual directives. This proposal
refers to the following categories:

— ‘N1’ vehicles — with a maximum mass (weight when
empty + maximum technically admissible load) of under
3 500 kg, designed exclusively for the transport of goods
(vans and small lorries).

N1 category vehicles are divided into three classes,
depending on their weight when empty:

— class I for vehicles with a weight when empty of

under 1 205 kg,

— class II for vehicles with a weight when empty of

between 1 205 kg and 1 660 kg,

— class III for vehicles with a weight when empty of

over 1 660 kg.

— M1 vehicles — designed to carry under nine occupants,
including the driver. In practice, a distinction is made
between genuine passenger vehicles with a maximum of
six seats, and vehicles, such as minibuses, that can carry
up to nine occupants or weigh over 2 500 kg.

Lorries and buses meanwhile fall within the N2 and N3, and M2
and M3 categories respectively.

Directive 70/220/EEC (2), as amended by Directive
1.2.
98/69/EC (adopted by the Council on 13 October 1998),
introduced emissions tests conducted at an ambient tempera-
ture of – 7°C but applied only to passenger vehicles and N1,
class 1 vehicles with positive-ignition engines (i.e. excluding
vehicles equipped with diesel engines).
It also gave the
Commission a mandate to draft a new proposal to extend
these tests to all M1 and N1 vehicle types, though still only
those with positive-ignition engines, by 31 December 1999.

(1) OJ L 42, 23.2.1970, pp. 1-5.

(2) OJ L 350, 28.12.1998, p. 1.

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1.3.
This extension was found to be necessary following
the results of the Auto Oil programme, although updated Auto
Oil figures estimate that in 2000 the vehicles concerned by
this proposal were responsible for no more than 2,5 % of
road transport-generated emissions of polluting substances.
European sales volumes for these categories are very small as
market preference is for their diesel-engine equivalents.

2.4.
In keeping with the commitment and care it has always
shown with regard to the environment, the Committee warmly
welcomed the decision (Directive 98/69/EC) to introduce low
ambient temperature emission tests, using a driving cycle
equivalent to a short urban journey, and the corresponding
limit values, as a measure to complement the controls carried
out at the conventional temperature of 20 to 30°C.

1.4.
The Commission’s current proposal extends the scope
of the emissions tests conducted at an ambient temperature of
– 7°C to other vehicles, specifically:

this type of

initiative to N1 and M1
The extension of
vehicles in the higher weight classes, was therefore logical and
necessary, with a view to moving closer to environmental
targets, especially in urban areas.

— N1 class II and III vehicles, with positive-ignition engines;

— M1 vehicles, with positive-ignition engines, with a mass
greater than 2 500 kg or over six but under nine seats;

and sets limit values for CO and HC emissions, to be enforced
from 1 January 2003.

Under the Commission proposal, vehicles that are
1.5.
equipped with positive-ignition engines but that are designed
to run exclusively on gaseous fuels, such as LPG or natural gas,
are exempt from these tests.

2.5.
The Committee believes that the technological sol-
utions developed by the industry, to ensure passenger vehicles
conform to the new rules on emissions at an ambient
temperature of – 7°C, are transferable to N1 vehicles of
classes II and III and the heaviest M1 vehicles. As these
categories of N1 vehicles usually have the same engine systems,
it should be possible to implement the Commission proposal
at sustainable costs, within the set deadlines.

The Committee, being aware of

2.6.
the problems of
pollution in general and atmospheric pollution in particular
and the consequent urgency of the situation, feels obliged to
draw attention to the Commission’s slowness in carrying out
the mandate given by the European Parliament and the
Council.

2. General comments

3.

Specific comments

2.1.
In the past, exhaust emission limit values only had to
be met in laboratory tests after vehicles had been stationary
for a minimum period of eight hours in a constant ambient
temperature of between 20 and 30°C. The laboratory also had
to be kept between those two temperatures.

2.2.
Exhaust catalysts, which were introduced for all
vehicles with positive-ignition engines from 1992/93 onwards,
significantly reduce the quantity of pollutants emitted. How-
ever, their efficiency level is practically zero when the vehicle
is started and increases only slowly as the catalyst warms up
to its optimum temperature, i.e. after travelling about 1 km.
Moreover, when the ambient temperature is low, carburation
needs to be concentrated to start the engine more easily and
to ensure it is running properly when the vehicle begins to
move.

3.1.
The Committee accepts that the limits proposed by the
Commission for low ambient temperature tests stem from
MVEG (Motor Vehicle Emission Group) expert recommen-
dations and are based on data produced both by the industry
and by independent laboratories. Furthermore, the limited
contribution of these categories of vehicle to total pollutant
emissions does not justify tougher limit values (see point 1.3).

3.2.
The Committee also notes that the implementation
date for these limits has been set at two years after the entry
into force of the tougher limits on emissions at an ambient
temperature of between 20 and 30°C set by Directive
98/69/EC. The present Commission proposal is therefore in
line with what has already been approved by the European
Parliament and the Council for passenger vehicles and N1,
class I vehicles under the above-mentioned directive.

2.3.
In towns, passenger vehicles are usually used for
short journeys. During cold seasons, therefore, the levels of
pollutants released can be significantly higher than those
indicated by exhaust emission data recorded using traditional
testing procedures. The measures proposed by the Commission
are therefore justified, in order to keep these increases within
acceptable limits from both an environmental and a techno-
logical viewpoint.

3.3.
The Committee agrees with the Commission that
vehicles with positive-ignition engines but that are designed to
run exclusively on gaseous fuels should be exempt from this
type of test. Engines of this type do not require the concen-
trated carburation necessary for starting up traditional engines
and running them until they warm up. The Committee also
agrees with the definition of vehicles designed to run only on
gaseous fuels. The distribution network for this type of fuel is
as yet limited, however, making it advisable for these vehicles

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to carry a small petrol tank as well, for emergency use. Lastly,
the Committee agrees with the Commission that where
vehicles designed to run on either petrol or gaseous fuel are
concerned, the low temperature tests should be conducted on
the petrol-using engine only.

4.2.
Furthermore, it recommends that the Commission pay
close attention to new technology (1) developed to minimise
the impact of transport on the environment, and promote
research in the industry and in specialist institutes, while not
forgetting alternative options, certain of which are already at
an advanced stage of testing.

4. Conclusions

4.1.
The Committee agrees on the need to extend this type
of low ambient temperature test to vehicles that were initially
excluded from Directive 98/69/EC (see point 1.4).

(1) For instance, fuel cells that run on liquid fuel and/or hydrogen, and
propulsion systems that combine electric and internal combustion
engines.

Brussels, 28 February 2001.

The President

of the Economic and Social Committee

Göke FRERICHS