Opinion of the Economic and Social Committee on the "Proposal for a Directive of the European Parliament and of the Council amending Council Directives 70/156/EEC and 80/1268/EEC as regards the measurement of carbon dioxide emissions and fuel consumption of N1 vehicles" (COM(2001) 543 final — 2001/0255 (COD))
Date: 2002-03-20
Institutions: European Economic and Social Committee
Subjects: air quality, commercial vehicle, energy consumption, greenhouse gas, motor fuel, motor vehicle

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Official Journal of the European Communities

27.5.2002

Opinion of the Economic and Social Committee on the ‘Proposal for a Directive of the European
Parliament and of the Council amending Council Directives 70/156/EEC and 80/1268/EEC as
regards the measurement of carbon dioxide emissions and fuel consumption of N1 vehicles’

(COM(2001) 543 final — 2001/0255 (COD))

(2002/C 125/02)

On 27 November 2001 the Council decided, under Article 95 of the Treaty establishing the European
Community, to consult the European Economic and Social Committee on the above-mentioned proposal.

The Section for the Internal Market, Production and Consumption, which was responsible for drawing
up the Committee’s opinion on the subject, adopted its opinion on 1 March 2002. The rapporteur was
Mr Colombo.

At its 389th Plenary Session (meeting of 20 March 2002) the European Economic and Social Committee
adopted the following opinion by 55 votes to 0, with 5 abstentions.

1. Aim of the proposal

— total EU CO2 emissions road transport sector (1995):
655,7 Mton CO2 eq (= 20 % of total CO2 emissions);

1.1.
The aim of the proposal in question is to extend the
harmonised standards on CO2 emissions and fuel consumption
already laid down for M1 class vehicles (cars) by Directive
1999/100/EEC amending the original Directives 70/156/EEC
and 80/1268/EEC to cover also N1 vehicles (light commercial
vehicles).

1.2.
It is clear that the main objective of the proposal is
that of preparing specific measures designed to reduce CO2
emissions and fuel consumption to protect the environment
where transport is concerned.

— EU CO2 emissions other sectors (1995)

other transport sources: 195,7 Mton CO2 eq

combustion (energy sector): 1 041 Mton CO2 eq

combustion (non industrial): 654,9 Mton CO2 eq;

2. Scope of the proposal

2.1.
The present proposal covers light commercial vehicles
(N1 vehicles) having a maximum mass not exceeding
3,5 tonnes: this definition includes a wide range of vehicles
(e.g. smaller car-derived transport vehicles, sport utility vehicles
and multi-purpose vehicles, pick-ups and larger vans). Each
base model usually has a relatively large number of different
versions.

2.2.
The size of this market segment is considerable: in the
year 2000, about 1,8 million of such vehicles were sold in the
EU, as compared with about 14 million passenger cars. Light
commercial vehicles account for about 10 % of total road
transport CO2 emissions. The synoptic table below, drawn up
by the Commission, gives a clear picture of the situation.

— CO2 emissions of N1 vehicles are estimated at approxi-
mately 10 % of total road transport CO2 emissions
(± 65 Mton CO2 eq);

— the division of the fleet between class 1, 2, and 3 is

estimated at approximately:

— class 1: 25 %

— class 2: 50 %

— class 3: 25 %;

— total EU CO2 emissions (1995): 3 227 Mton CO2 eq;

— CO2 emissions for the different classes are probably in
the same order of magnitude with somewhat higher value
for class 3 (higher fuel consumption, higher mileage);

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— the total number of different versions for class 2 and 3 is
estimated at 3 000 different versions. However, this does
not mean 3 000 type approvals would be required,
as there is a significant degree of
flexibility to the
manufacturers to group different versions into one type
approval;

3.4.
There is in fact a lack of differentiation as to the
composition of the N1 category which Directive 98/69/EEC
divides into three sub-categories on the basis of the reference
mass (tare): the first sub-category up to 1 305 kg, the second
from 1 305 kg to 1 760 kg and the third above 1 760 kg.

— the exemption for small volume manufacturers is really
to ensure that type approval cost would not be excessive
with respect to the number of vehicles to which the
approval applies. The CO2 contribution of these vehicles
is negligible.

3.5.
As regards the criterion for measuring the vehicles,
which is done solely unloaded, the Committee takes note of
the Commission’s comments on the difficulties involved in
increasing the tests and therefore the costs. However, it stresses
the fact — and calls upon the Commission to take account of
it — that consumption clearly varies with the rated load and
type of fittings of the vehicle.

2.3.
This figure is likely to rise since a gradual increase has
been noted in this market share. No Community initiative has
been taken on this so far in order to monitor and then improve
fuel economy and CO2 emissions for this category of vehicles.

3.6.
The Committee also wishes to point out the lack of a
reference to a cost-benefit analysis, which would seem to be
necessary for a more careful assessment of the results which
can be achieved under this proposal. For the two sub-categories
II and III in particular, the cost of funding the necessary
infrastructure and manpower does not seem to be commensur-
ate with the expected results.

3. General comments

4. Specific comments

3.1.
The Committee supports planned Commission initiat-
ives to introduce measures to reduce CO2 emissions and
optimise fuel consumption: these initiatives are important for
achieving the Community’s ambitious environmental protec-
tion plans in the transport sector.

Using the breakdown of category N1 given in detail in
4.1.
point 3.4 above, the Committee believes that for the first sub-
category there are no special problems, since such vehicles are
derived directly from cars, and it is well-known that they are
already subject to roller bench tests. This means in effect that
there are no problems of implementation.

Achieving the CO2 reduction objectives laid down at
3.2.
Kyoto must be regarded as a priority strategic aim with a view
to ‘lasting and sustainable development’. It seems fundamental
that the transport sector should play a part in achieving these
objectives, and the Committee has supported this argument in
earlier opinions.

3.3.
However, in the Committee’s view, while the Com-
mission proposal is a step in the right direction it does raise
some doubts: it may fail to achieve the desired results because
of the additional costs arising from either duplication of the
planned tests or the funds needed for the new tests. These
factors will inevitably have an impact on the product’s final
price. These costs double whenever production takes place in
different establishments and countries. An initial examination
of the costs confirms this assessment and has led the Com-
mission to provide for firms which produce fewer than
2 000 units per year to be exempted from this testing method.

4.2.
The situation is different with regard to the second
sub-category, and more particularly the third sub-category:
both involve considerable problems of implementation.

These vehicles are produced in factories which build
4.3.
heavy vehicles, the motors of which are subject to different
tests (Directive 88/77/EEC and subsequent amendments).
Extending the rules now covering cars, as envisaged in the
present proposal, would therefore lead to a system with two
types of test.

4.4.
The proposed directive provides for the exclusion
of the pay-load from the test methodology, although the
Explanatory Memorandum of the same proposal states in
point E.2 that ‘the pay-load has a significant impact on the
actual fuel consumption and CO2 emissions.’ This exclusion
seems to arise from the existence of a large number of different
versions, which would ‘result in a substantial amount of
additional testing and associated costs’ (see point 3.4 above).

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It

It also provides for exemption of small manufacturers
4.5.
(see point 3.3).
is understandable and proper for the
Commission to concern itself with the effects on SMEs.
However, it is necessary to avoid this exemption being used to
reduce the effectiveness of the standard laid down in the
proposed directive.

The ESC favours this solution, which forms part of the
4.6.
broader approach of support for small and medium European
enterprises, and suggests that for those who produce only
slightly more than 2 000 units per year the public bodies
responsible for type-approval checks could make available the
technical type-approval equipment (dynamometer bench) at a
reasonable cost.

Brussels, 20 March 2002.

5. Conclusions

5.1.
For the reasons set out above, the Committee, while
endorsing the application of this provision to the first sub-
category, would ask the Commission to provide further
justification for the application of the draft directive’s pro-
visions to vehicles in the second and third sub-categories; it
seems more realistic for such vehicles to be excluded from its
scope. It would also seem desirable to extend the deadlines for
new type-approvals as well from 1 July 2003 to 1 October
2005. That would enable the present draft directive to come
into force at the same time as the more restrictive emission
standards known as EURO 4.

The President

of the Economic and Social Committee

Göke FRERICHS

Opinion of the Economic and Social Committee on the ‘Proposal for a Regulation of the European
Parliament and of the Council amending Council Regulation (EEC) No 95/93 of 18 January 1993
on common rules for the allocation of slots at Community airports’

(COM(2001) 335 final — 2001/0140 (COD))

(2002/C 125/03)

On 12 July 2001 the Council decided to consult the Economic and Social Committee, under Article 80
(2) of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 26 February 2002. The rapporteur
was Mr Tosh.

At its 389th Plenary Session of 20 and 21 March 2002 (meeting of 20 March) the Committee adopted
the following opinion unanimously.

1.

Introduction

1.2.
It offers clarification to the definition of slot rights,
airports status, new entrant management, coordination, con-
ciliation and ultimately enforcement.

1.1.
This proposal attempts to re-focus upon the manage-
ment of slots and in conjunction with that to reflect ATC,
airports operation and capacity issues alongside current
fair and transparent
environmental objectives,
procedures to protect and encourage the industry and users
alike and arbitrate upon congestion.

to impart

1.3.
It sets out to enhance the prospects of finding and
maintaining the right balance between air carriers and the
development of a competitive network within the EU and with
third countries.