COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EC) No 715/2007 and (EC) No 595/2009 as regards the reduction of pollutant emissions from road vehicles
Date: 2014-01-31
Institutions: European Commission
Subjects: atmospheric pollutant, environmental standard, marketing standard, motor vehicle, reduction of gas emissions, road transport, technical standard













EUR-Lex - 52014SC0033 - EN











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52014SC0033

COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EC) No 715/2007 and (EC) No 595/2009 as regards the reduction of pollutant emissions from road vehicles /* SWD/2014/033 final */









COMMISSION STAFF WORKING PAPER
IMPACT ASSESSMENT 
Accompanying the document
Proposal for a REGULATION OF THE
EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EC) No 715/2007
and (EC) No 595/2009 as regards  the reduction of pollutant emissions from road
vehicles

Disclaimer: This report commits only the Commission's
services involved in its
preparation and does not prejudge the final form of any decision to be taken by
the Commission.
TABLE
OF CONTENTS
Contents
1............ Procedural
issues and consultation of interested parties. 5
1.1......... Identification. 5
1.2......... Organisation
and timing.. 5
1.3......... Consultation
and expertise. 5
1.4......... Scrutiny
by the Commission Impact Assessment Board. 6
2............ Context. 7
3............ Problem
definition. 7
3.1......... The
problem that requires action. 7
3.2......... Underlying
drivers of the problem.. 12
3.3......... Who
is affected, in what ways and to what extent?. 12
3.4......... Foreseen
evolution of the problem.. 13
3.5......... EU
right to act. 14
4............ Objectives. 15
4.1......... General
policy objectives. 15
4.2......... Specific
policy objectives. 15
4.3......... Operational
policy objectives. 15
4.4......... Consistency
with other policies and objectives. 16
5............ Policy
options. 17
5.1......... Potential
to reduce fuel consumption through efficient driving behaviour insufficiently
exploited. 17
5.2......... Scope
of ammonia (NH3) emission limits threaten to drive HD natural gas
vehicles out of the market. 18
5.3......... Upper
mass limit of LD Euro 6 regulation necessitates two type approvals for some
vehicle platforms. 19
5.4......... Euro
6 LD Low temperature emission limits not adjusted to technical progress  19
5.5......... Euro
6 LD emission regulation specifies a limit value for total emissions of
nitrogen oxides (NOx), but no separate limit value for nitrogen dioxide (NO2) 19
5.6......... Euro
6 LD THC emission limits cause problems for CNG vehicle manufacturers  20
6............ Analysis
of impacts. 20
6.1......... Potential
to reduce fuel consumption through efficient driving behaviour insufficiently
exploited. 21
6.2......... Scope
of ammonia (NH3) emission limits threaten to drive HD natural gas
vehicles out of the market. 26
6.3......... Upper
mass limit of LD Euro 5/6 regulation necessitates two type approvals for some
vehicle platforms. 29
7............ Comparing
the options. 31
8............ Monitoring
and evaluation. 33

Introduction
This impact assessment accompanies a
legislative proposal that would, if adopted by the Council and European
Parliament, introduce a number of complementary provisions to the Euro 5/6 and
Euro VI emission standards[1].
The focus of the initiative under consideration is on six specific areas where
market and regulatory failures hinder addressing the overarching challenges
situated within the context of the EU's air quality and climate change policy
and the Better Regulation Agenda.
It is considered that this impact assessment
concerns a ‘narrow’ legislative action. 
1.           Procedural issues and consultation of interested
parties 
1.1.        Identification 
Lead DG: Enterprise and Industry
Other involved DGs: ENV, ENER, CLIMA, MOVE, JRC,
SG
Agenda Planning/WP Reference: 2012/ENTR/019
1.2.        Organisation and timing
Preparatory work started with the commissioning
of an external study on the "Effects of a gear-shift indicator and a fuel
economy meter on fuel consumption" which was completed in December 2010. 
The impact assessment steering group was
composed of representatives of DG ENV, ENER, CLIMA, MOVE, SG and the JRC and
met three times. Meetings took place on 19 July 2011, 6 January 2012 and 13
January 2012. 
1.3.        Consultation and expertise
In developing the proposal the Commission
services have both drawn on external expertise and consulted stakeholders in a
number of ways:
The present report builds inter alia on the
findings of an external study by the Dutch research organisation TNO that
assessed the effects of a gear-shift indicator and a fuel economy meter on fuel
consumption that was carried out during 2010. The study can be found in Annex 4.
Vehicle manufacturers have been contacted for
some further data on financial costs and benefits as well as the environmental
impact.
The most relevant stakeholders (contracting
parties to the UN/ECE Agreement, relevant ministries and authorities from
Member States, suppliers of vehicles, suppliers of parts, consumers, type
approval authorities, NGOs, etc) participate in the meetings of the UN/ECE and
the Commission's Motor Vehicle Working Group. Individual components of the
initiative have been discussed in these fora and stakeholders provided
expertise and inputs on various topics related to the current initiative. 
Building on this work, a public consultation
was carried out:
–              
The consultation period started on 1 September
2011 and ended on 28 October 2011 (8 weeks);
–              
To ensure transparency, a consultation paper was
published in the automotive industries section of the DG ENTR website[2] and a consultation
notice was sent to a broad list of stakeholders by email. The mailing list used
for this purpose was the one for the MVEG (motor vehicle emissions group) which
brings together a broad range of automotive stakeholders, including environmental
NGOs and associations of suppliers which represent SMEs.
–              
The entire consultation process was carried out
in accordance with the Commission's minimum standards as outlined in COM(2002)704.
At the end of the consultation period 15
contributions were received. Despite the limited number of responses, the
consultation reached a broad range of stakeholders (6 public authorities, 6
industry stakeholders, 2 environmental NGOs, 1 private citizen) and diverse
views were expressed. As consultations on highly technical issues, such as
emission standards, tend to yield a much lower number of contributions than broader
and more accessible policy issues, the result of the consultation is considered
as sufficiently representative for the potentially affected stakeholders. A
short consultation summary is in Annex 2 to this report.
1.4.        Scrutiny
by the Commission Impact Assessment Board
The Impact Assessment Board of the European
Commission assessed a draft version of the present impact assessment and issued
its opinion on 17/02/2012. The Impact Assessment Board made several
recommendations and, in the light of the latter, the final impact assessment
report:
–              
Provides a strengthened evidence base of the
problem definition and a more detailed baseline scenario;
–              
Presents a more detailed analysis of the various
options, with particular focus on the assessment of SME and competitiveness
issues;
–              
Clarifies the future monitoring and evaluation
arrangements.
2.           Context
Common European emission standards define
acceptable limits for toxic exhaust emissions of all new motor vehicles sold in
the EU. At present, they cover nitrogen oxides (NOx), hydrocarbons (HC), carbon
monoxide (CO) and particulate matter (PM) emissions. These standards have been
defined in a series of European Union Directives, setting specific limits at
different levels for different motor vehicle types. Successive "Euro"
emission standards for light duty vehicles were initiated in the EU starting in
1993, the most recent ones being Euro 5 and Euro 6. Light duty vehicles are
defined as having a reference mass below 2,610 kg (2,840kg in some special
cases) regardless of the purpose of the vehicle. These are typically passenger
cars and light commercial vehicles, such as delivery vans. The work on reducing
emissions is also in progress for heavy duty vehicles with the Euro VI
standard. Heavy duty vehicles are defined as having a reference mass above 2,610
kg (2840 kg in some cases) and typically include larger vans, trucks and buses.
The Euro standards are formulated according to a split-level approach, which
means that essential aspects are contained in a main instrument that is agreed
via the ordinary legislative procedure by Council and European Parliament,
while non-essential technical aspects are regulated by means of delegated or implementing
legislation prepared by the Commission. The corresponding two main instruments
are:
–              
Regulation (EC) 715/2007 on type approval of
motor vehicles with respect to emissions from light passenger and commercial
vehicles (Euro 5 and Euro 6).
–              
Regulation (EC) 595/2009 of 18 June 2009 on
type-approval of motor vehicles and engines with respect to emissions from
heavy duty vehicles (Euro VI).
3.           Problem definition 
3.1.        The problem that requires
action
Air pollution
Air pollution, both indoors and outdoors, is a
major environmental risk to human health. Numerous studies have highlighted the
negative impact of atmospheric pollutants on human health and the environment.
The World Health Organisation (WHO)[3]
estimates that urban outdoor air pollution alone causes 1.3 million deaths
worldwide per year. Although air quality in the European Union has improved
over the past decade, there are still significant air quality problems,
especially in urban areas and in densely populated regions. Two pollutants, ground-level
ozone (O3) and fine particulate matter (PM2.5), are now generally recognised as
the most problematic ones in Europe. Long-term and peak exposure can lead to a
variety of health effects, ranging from minor effects on the respiratory system
to premature mortality. Elevated ozone concentrations alone are associated with
21 000 premature deaths per year in the European Union[4]. According to the WHO,
exposure to particulate matter decreases the life expectancy of every person in
Europe by an average of almost 1 year[5].
High particulate matter and ozone concentrations are also among the most
persistent air quality problems in urban areas across the EU and have proven
very difficult to reduce.
Exhaust emissions from light duty (LD) and heavy
duty (HD) vehicles contribute to air pollution. This is particularly
problematic in urban areas where the motor vehicle and population density is the
highest. The European Environment Agency (EEA) states that road transport was
accountable for 42% of NOx[6]
emissions in the EU27 in 2009 and overall NOx emissions were still above the
emissions ceiling to be reached in 2010[7].
Alongside its direct health effects, NO2, a component of NOx, is also
the main source of nitrate aerosols, which form an important fraction of
particulate matter and, in the presence of ultraviolet light, of ozone[8]. Through this mechanism,
NO2 emissions aggravate O3 and PM2.5 pollution
problems.
Global warming
Increased greenhouse gas (GHG) emissions are
contributing to climate change and accelerate this process. Transport accounts
for roughly 24% of the European Union's GHG emissions with carbon dioxide (CO2)
being the main component of transport emissions (99%). Road transport is, in
turn, the largest contributor to CO2 emissions from the transport
sector (around 71% in 2008), thus accounting for more than 17% of the EU-27's
total GHG emissions[9].
As such, Europe must tackle transport emissions if it is to achieve significant
reductions in its overall GHG emissions.
Specific problem areas
Within the overall context of air pollution,
global warming and regulatory simplification, six specific problem areas have
been identified where market and regulatory failures hinder addressing the
overarching challenges described in the above paragraphs:
(1)         
Potential to reduce fuel consumption through
efficient driving behaviour insufficiently exploited
The potential to reduce fuel consumption, and
therefore pollutant and greenhouse gas emissions, through efficient driving
behaviour, so-called "eco-driving", is insufficiently exploited. This
is mainly due to a lack of information/awareness of drivers about how to drive
efficiently. The technical support for eco-driving is focused on two types of
in-vehicle systems: fuel consumption meters (FCM) and gear shift indicators
(GSI). A FCM is a display presenting instantaneous fuel consumption, average
fuel consumption, fuel consumption when idling or total fuel consumed. A GSI
indicates the optimal gear in case this is different to the selected gear, and
what the driver should do (shift up or down) to minimise fuel consumption. Its purpose
is to give the driver of a vehicle with a manual gearbox a visual warning when
a gear change is necessary. GSI have already been made mandatory in new
passenger cars of category M1 which are fitted with a manual gearbox[10], but not in any other
type of motor vehicle such as light commercial vehicles, trucks or buses. In
contrast to that, no legal requirement exists to fit FCM in any category of
motor vehicle at present. However, due to the high prevalence of automatic
gearboxes and typically higher engine operating loads in heavy duty vehicles,
the actual savings potential of FCM and GSI is expected to be considerably lower
than in the light duty segment. Studies[11]
into the effects of FCM and GSI in light duty vehicles show that the potential
of eco-driving can be better exploited when using both systems at the same
time. FCM and GSIcan be installed at relatively small costs for the vehicle
manufacturer but are currently often unavailable or sold as part of options
packages, which impedes their widespread use. Furthermore, where available,
these devices are often implemented in ways that are not well suited to support
eco-driving (e.g. no permanent visibility, no instantaneous information on fuel
consumption). The reasons for this include a lack of consumer awareness of the
benefits in terms of potential fuel savings. Another reason lies in the fact
that consumers have the tendency to not fully take into account future benefits
in their purchasing decision, a concept known as consumer myopia
(‘nearsightedness’). 
(2)         
Scope of ammonia (NH3) emission limits threaten
to drive HD natural gas vehicles out of the market
In modern heavy duty vehicles a chemical
reagent is used for NOx abatement from compression ignition engines (i.e.
diesel engines). This process, called selective catalytic reduction (SCR),
relies on the injection of a certain amount of the reagent into the catalyst,
which is then converted into ammonia (NH3), the compound which removes nitrogen oxides from the exhaust gas.
The amount of reagent injected must be proportional to the amount of pollutants
to be removed. Too little reagent will result in insufficient NOx abatement and
too much reagent leads to ammonia emissions (so called ammonia slip). To avoid
this risk of ammonia slip from diesel fuelled vehicles, which goes along with
the use of SCR, an ammonia limit value has been introduced in Euro VI emissions
legislation[12].
However, this ammonia limit value has been introduced for all heavy duty
vehicles, regardless of the engine type and will become binding as of
31/12/2012. As the formation of a small amount of ammonia[13] can also occur in the
engine combustion process of positive ignition engines (i.e. petrol of natural
gas engines) which do not require SCR technology to comply with NOx limits, the
entry into force of a NH3 limit would put vehicles in this very
small segment of the heavy duty market at a severe disadvantage. In particular,
this would require positive ignition vehicles to be fitted with a technically
complex NH3 clean-up system that would still have to be developed. This
would likely drive up the cost of vehicles such as compressed natural gas (CNG)
fuelled transit buses considerably, which would encourage their replacement
with otherwise more polluting diesel vehicles which is undesirable from an
environmental perspective. 
(3)         
Upper mass limit of LD Euro 6 regulation
necessitates two type approvals for some vehicle platforms
Currently there is a strict reference mass
limit defining whether vehicles have to be approved for their emissions
according to light or heavy duty legislation (currently Euro 5 or Euro V). Euro
5 applies to "light duty" vehicles of category M1, M2, N1 and N2 with
a reference mass not exceeding 2610 kg (under certain conditions this limit can
be extended to 2840 kg). Vehicles above this borderline have to be approved
according to heavy duty emissions legislation (Euro V). Depending on the type
of bodywork fitted on the vehicle, different variants of the same vehicle type
can therefore be located on different sides of the borderline, as one variant
may be below the mass limit and another one above. It needs to be stressed that
the current possibility to extend the limit to 2840 kg under certain conditions
does not solve this situation, as some variants can go considerably above this
limit. The consequence is that the same vehicle type will need a double
emissions certification which forces double testing. This means, for example,
that two different engine versions would need to be developed and tuned to
comply with different requirements. This creates considerable costs for the
manufacturer, without delivering any obvious environmental benefits. The issue
has been repeatedly raised by industry stakeholders who highlighted the
associated compliance costs and has also been discussed in the framework of the
Technical Committee – Motor Vehicles (TCMV).
(4)         
Euro 6 LD Low temperature emission limits not adjusted
to technical progress
The emissions of modern passenger cars (and
light commercial vehicles) are reduced by after-treatment (e.g. catalysts or
selective catalytic reduction (SCR) systems for NOx control of diesel vehicles)
or internal engine measures (e.g. exhaust gas recovery, so-called EGR). Since
aftertreatment systems require a certain temperature (typically above 250o
C) to work at full efficiency and the application of internal engine measures
is challenging at cold conditions, emissions are significantly higher at low
temperatures. Therefore, separate low temperature emission limits have been
introduced in European emission legislation. However, the current Euro 5 limits
for hydrocarbon (HC) and carbon monoxide (CO) are carried over from Euro 3 and
no longer reflect the technical progress made in engine- and emission control
technology. In addition, no Euro 6 NOx emission limits at low temperatures are
defined yet. HC are known to have a significantly detrimental impact on health
and Member States encounter air quality problems related to NOx.
(5)         
Euro 6 LD emission regulation specifies a limit
value for total emissions of nitrogen oxides (NOx), but no separate limit value
for nitrogen dioxide (NO2)
Nitrogen oxides (NOx) emitted by motor vehicles
are a by-product of the combustion process in an engine, consisting of nitrogen
oxide (NO) and nitrogen dioxide (NO2). Both components are toxic
gases that have important negative impacts on human health and the environment.
However, direct NO2 emissions are considered particularly
problematic as it is a highly reactive oxidant. Direct NO2 emissions
mostly affect air quality in areas in the vicinity of busy roads and therefore
have the most significant health impacts in inner-city areas, the so-called
urban hotspots. The percentage of each varies, but typically NO2
might make up 5-10% of the total NOx exhaust emissions of a motor vehicle.
Modern diesel engines may, however, bring this share up substantially, strongly
depending on the particulate reduction systems used. Continuously regenerating
filter systems in particular can tilt the balance towards NO2 as
they rely on NO2 to burn off the soot filtered from the exhaust
stream. However, the relatively low concentration of NO2 in diesel
exhaust gas is normally insufficient to support this process of filter
regeneration. For this reason, an oxidation catalyst is commonly applied ahead
of the particulate filter, which provides additional NO2 formed from
NO and excess oxygen. Balancing NO2 production with NO2
consumption by the particulate filter therefore plays a critical role for preventing
a potential increase in NO2 emissions. To ensure that the use of
this technology does not result in an increase in direct NO2
emissions, specific NO2 emission limits are already foreseen for
heavy duty vehicles in the Euro VI legislation. However, the current Euro 6
light duty vehicle emissions regulation only specifies a limit value for total
emissions of nitrogen oxides NOx, but no separate limit value for NO2.
(6)         
Euro 6 LD THC emission limits cause problems for
CNG vehicle manufacturers
The current Euro 6 light duty emission limits
for total hydrocarbons (THC) include the methane and non-methane hydrocarbon
(NMHC) emissions. In general, the direct effect of methane emissions is not
considered dangerous for health or the environment and they have only been
regulated since 2005/6, when the Euro 5/6 co-decision proposal was negotiated.
The main reason for the inclusion of methane is the fact that it is a strong
greenhouse gas. However, in the light of automotive CO2 Regulation
443/2009/EC, (defining fleet targets rather than regulating the greenhouse gas
emissions of individual vehicles) such an approach seems to be too restrictive.
It would be more appropriate to add methane to the CO2 equivalent
emissions of a vehicle for the purposes of the automotive CO2
Regulation and to "deregulate" methane emissions at type approval (i.e.
increase or abolish the THC emission limit). This would also help the entry
into the market of natural gas vehicles (NGV), which naturally have relatively
high methane but low CO2 emissions. As natural gas consists
primarily of methane, the exhaust emissions of NGVs contain some uncombusted
methane. The inclusion of methane therefore makes it difficult for NGVs to meet
THC limit values. However, per unit of energy, natural gas contains less carbon
than other fossil fuels, and thus produces lower GHG emissions per distance
travelled. Industry stakeholders have raised this issue as a matter of major
concern for CNG vehicles.
3.2.        Underlying drivers of the
problem
Increasing demand for transport                 
New motor vehicles are, on average, more
energy-efficient and emit fewer pollutants than older ones. However, due to the
persistent growth of road transport volume, this is not translating into an
equivalent decrease of atmospheric pollutant and GHG emissions from road
transport. The distance travelled in passenger cars, expressed in terms of
passenger kilometres, has been growing continuously between 1995 and 2009 by an
average of 1.5% year on year in the EU[14].
The picture is similar for road freight transport in the EU with an average
year on year increase of 2% between 1995 and 2009 in terms of tonne-kilometres.
The only difference between passenger and freight transport being that, while
passenger transport stayed relatively stable, the effects of the economic
crisis resulted in a marked reduction in road freight transport in the years
following 2007. 
In line with this overall trend of steadily
growing transport demand, GHG emissions from road transport have continued to
increase since 1990, while those from other sectors are generally falling[15]. 
Market and
regulatory failures aggravating the problems
In order to help reduce GHG emissions and fuel
consumption, tools exist that allow more fuel efficient driving (problem 1). However,
their mandatory introduction has only started for passenger cars, and no
requirements exist for other categories of motor vehicles. No stimulus to
better exploit fuel reduction potential is currently provided for these
vehicles.
As explained above, some regulatory failures
(problems 2 and 6) hinder the uptake of more environmentally friendly vehicles
(e.g. gas powered ones) and are thus problem drivers that can and should be
addressed.
Similarly, current emission limits do not fully
reflect technical progress (problem 4) or do not fully address environmental
concerns in sufficient detail (problem 5). These regulatory failures can and
should equally be addressed.
Finally, current type approval requirements are
rather burdensome for certain vehicle types (problem 3) and could possibly be
simplified (regulatory failure).
3.3.        Who is affected, in what ways and to what extent?
A range of different groups are affected by the
problems discussed above:
–              
The population of the European Union is affected
by poor air quality through the acute (i.e. short-term) and chronic (i.e.
long-term) effects on health[16].
Effects can range from minor respiratory irritation to cardiovascular diseases
and premature death. A number of groups within the population are particularly
vulnerable, including children, elderly people and those with an existing
cardio-respiratory disease;
–              
Consumers of motor vehicles are affected by
changes in the price of new vehicles, which may alter as a result of stricter
or more lenient vehicle emission limits. However, they may also profit from
increased fuel economy;
–              
Manufacturers of motor vehicles are affected as
stricter emission limits necessitate improvements to new vehicle types through
the development and introduction of better technologies. However, manufacturers
could benefit from simplification and a possible revision of NH3 and
THC emission limits. The impact on third-country manufacturers is not expected
to differ from the impact on domestic ones;
–              
Manufacturers rely on a complex, tiered network of
suppliers. Some component
suppliers may be affected by increasing demand for certain parts, such as
catalytic converters and piezoelectric fuel injectors.
SMEs are almost exclusively located at the beginning of the automotive supply
chain and in the traditional manufacturing sectors e.g. cast or pressed metal
parts, plastic mouldings etc. The effect on SMEs is therefore expected to be
minimal.
3.4.        Foreseen evolution of the
problem
As this assessment is focused on six specific
problem areas that all relate to the emission of air pollutants and greenhouse
gases by motor vehicles, the baseline scenario is centred on this issue. Without
additional public intervention, the evolution of the problem would be mainly
determined by the regulation already in force or already adopted by Member
States and at European level, transport volume and the rate of fleet renewal. 
A recent assessment by the European Environment
Agency[17]
finds that despite a 26 % increase in transport fuel use over the period
1990–2005, the introduction of the Euro vehicle standards has reduced road
transport emissions significantly. However, in contrast to other pollutants,
road transport remains the dominant source of NOx emissions (42% of total NOx
in 2009). 
Overall, road transport emission reduction
measures have proven to be effective in reducing NOx, CO and NMVOC emissions
from gasoline‑fuelled vehicles and PM2.5 emissions from diesel‑fuelled
vehicles. CO and (exhaust) NMVOC cannot be reduced much further. NOx emissions
from diesel-fuelled vehicles have so far not been considerably reduced. 
By problem area, the situation is expected to evolve
as follows, if EU policy is left unchanged:
–              
The continued absence of technical systems
assisting the driver in adopting an eco-efficient driving style from parts of
the vehicle fleet would result in a foregone reduction of pollutant and GHG
emissions;
–              
The share of natural gas HD vehicles (mostly
urban transit buses) would most likely decline, as older diesel fuelled
vehicles would be either replaced by LPG or new diesel vehicles instead of
natural gas ones. This, in turn, would result in higher NOx and GHG emissions;
–              
Variants of motor vehicles spanning across the
heavy duty / light duty borderline would require double emissions certification.
Unnecessary compliance costs would continue to be imposed on the manufacturers
of these vehicles;
–              
The emissions of NOx, CO and HC from modern
light duty vehicles would continue to be strongly elevated during a cold start;
–              
The amount of NO2 emitted by Euro 6
diesel vehicles is expected to increase further above today's already very high
level (potentially giving rise to significant air quality problems) as the
share of NO2 within their overall NOx emissions is expected to
increase further due to new technologies;
–              
Relatively clean natural gas vehicles would be
put at a disadvantage in comparison to more polluting diesel and petrol
vehicles, and as a consequence of CNG vehicles losing market share, the PM and
NOx and GHG emissions would increase.
3.5.        EU right to act
In line with other legislation concerning the
type-approval of motor vehicles, the action under consideration is based on
Article 114 of the TFEU ensuring the functioning of the internal market. As
this concerns amendments to existing EU legislation, only the EU can
effectively address the issues. The subsidiarity principle is respected, since
the policy objectives cannot be sufficiently achieved by actions of the Member
States, and can be better achieved at Community level. European Union action is
necessary because of the need to avoid the emergence of barriers to the single
market notably in the field of the automotive industry, and because of the
transnational nature of air pollution and climate change. Even though the
effects of the main toxic air pollutants are most severe close to the source,
the effects on air quality are not limited to the local level and cross-border
pollution is a serious environmental problem that often frustrates national
solutions. Atmospheric modelling shows that the pollution emitted in one Member
State contributes to pollution in other Member States[18]. In order to solve the
problem of air pollution, concerted action at the EU scale is required.
4.           Objectives 
4.1.        General policy objectives
The proposal pursues the following general
policy objectives:
–              
Ensuring the proper functioning of the internal
market; and
–              
Providing for a high level of environmental and
health protection in the European Union.
–              
Contribute to the European Union's ambitious
Greenhouse Gas reduction targets.
4.2.        Specific policy objectives
The specific objectives are:
–              
to have emissions legislation and type approval
requirements that reflect technical progress and that address regulatory
failures that have been identified; and
–              
to make use of simplification potential in the
legal framework for the type approval of motor vehicles; and
–              
to improve the efficiency of driving patterns in
order to reduce air pollutant and GHG emissions.
4.3.        Operational policy objectives
The operational objectives are:
–              
to ensure that new motor vehicles are equipped
with the essential technical systems assisting the driver in adopting an
eco-efficient driving style where potential fuel savings are not fully
exploited;
–              
to avoid that the agreed NH3 limits
for all heavy duty vehicles obstruct the  further development and market-uptake
of certain positive ignition vehicles;
–              
to resolve the need for costly double emissions certification
for variants of vehicles spanning across the heavy duty / light duty borderline
and thereby eliminate unnecessary compliance cost;
–              
to enable the Commission to propose updated low
temperature emission limits in a timely manner by way of delegated act if this
is deemed necessary and justified by the evidence base;
–              
to enable the Commission to propose a separate NO2
limit for light duty vehicles by way of delegated act if this is deemed
necessary and justified by the evidence base;
–              
to enable the Commission to propose the
deregulation of methane emissions in the context of motor vehicle type approval
by way of delegated act if this is deemed necessary and justified by the
evidence base, and provided that methane emissions are included as CO2
equivalent emissions under the automotive CO2 Regulation;
4.4.        Consistency with other
policies and objectives
The initiative under consideration is aimed at correcting
market and regulatory failures and by doing so improving environment and health
protection. At the same time, it is aimed at ensuring the functioning of the single
market for motor vehicles, while removing unnecessary burden on the companies
operating in it. It is therefore entirely consistent with the Europe 2020 strategy
and fully aligned with the EU's Sustainable Development Strategy. 
Additionally, the European Union has committed
itself to providing for a high level of environmental and public health
protection and has taken on ambitious objectives as part of the EU air quality
policy and the integrated climate and energy policy framework.
In this context, the objectives of the
initiative under consideration tie in with the following policy communications
and legislation:
Air quality
–              
The EU’s 6th Environmental Action Programme
which proposed to attain “levels of air quality that do not give rise to
significant negative impacts on, and risks to human health and the
environment”;
–              
The Thematic Strategy on Air Pollution published
in September 2005; 
Furthermore, the initiative under consideration
is aligned with all other relevant policies in the areas of transport, energy,
environment and health.
Integrated climate and energy policy
–              
The European Council in March 2007 set three
objectives to be reached by 2020 as part of the EU integrated climate and
energy policy framework, namely to save 20% of the EU’s total primary energy consumption,
and binding objectives to increase the share of renewable energy (RES) of the
EU final energy consumption by 20% and to reduce the EU greenhouse gas
emissions (GHG) by 20% compared to 1990 levels. Particularly the first and the
last target are of relevance for this initiative.
–              
The "Effort Sharing Decision"
specifies that the transport sector will have to make an important contribution
to reaching these commitments. In this context, the European Commission has
devised the "integrated approach", i.e. a comprehensive strategy to
reduce CO2 emissions from new motor vehicles sold in the European
Union (COM(2007)19), to ensure that the EU meets its greenhouse gas emission
targets. Regulation 443/2009/EC on the reduction of CO2 emissions
from passenger cars and Regulation 510/2011/EC addressing light duty commercial
vehicles are the main legislative instruments underpinning this strategy. In
this context, Regulation 661/2009/EC of 13 July 2009 concerning type-approval
requirements for the general safety of motor vehicles plays an important role
by defining the complementary technical requirements of in-vehicle systems
designed to support this goal, in line with the objectives of the integrated
approach.
Regulatory simplification
–              
The Commission Communication of October 2010 on
“Smart Regulation in the European Union” (COM(2010)543) calls for a
continuation and merging of simplification and administrative burden reduction
efforts. This is to ensure that businesses feel the benefits of the smart
regulation agenda. In particular, regarding double certification (see specific
problem 3 above), an elimination of this burden would be in line with
simplification and administrative burden reduction objectives. 
5.           Policy options 
In line with the description of six specific
problem areas in section 4.1, policy options are presented under six headings
that correspond to these areas. 
5.1.        Potential to reduce fuel consumption through efficient
driving behaviour insufficiently exploited
Option 1: No changes to the existing
situation
–              
This option would imply that no measures are put
in place to improve fuel efficient driving behaviour, apart from the
requirement to install GSI in new passenger cars. 
Option 2: Introduce mandatory fuel
consumption meters (FCM) for light duty (LD) vehicles and extend the mandatory
installation of gear shift indicators (GSI) from only passenger cars to all
LD vehicles
–              
This option would consist of introducing the
obligation to install FCM and GSI to all LD vehicles by adding the respective
requirements to Article 11 of Regulation 661/2009/EC[19]. It should be noted
that the vast majority (approximately 90%) of LD vehicles fall under the type
approval rules for passenger cars (M1) and therefore already need to have a
gear shift indicator as of 2012 (all new car models) or as of 2014 (all new
cars). This option would extend that requirement to those 10% (mostly light
commercial vehicles) that don't fall under M1. For fuel consumption meters, no
obligation exists today for passenger cars and light commercial vehicles.
Option 3: Introduce mandatory FCM for LD and
HD vehicles and extend the mandatory installation of GSI from only passenger
cars to all LD and HD vehicles
–              
This option would consist of introducing the
obligation to install FCM and GSI to all LD and HD vehicles by adding the
respective requirements to Article 11 of Regulation 661/2009/EC. A number of
stakeholders, including an environmental NGO and a public authority, spoke out
in favour of this option during the stakeholder consultation.
Option 4: A "soft law" approach
focused on driver information and education
This option would have the following
implications:
–              
As driving behaviour is a key factor in determining
the fuel consumption, and therefore also the pollutant and GHG emissions of a
motor vehicle, any measure aimed at encouraging fuel-efficient driving is a potentially
effective way to address the problem;
–              
However, the regulatory options identified above
are considered to be complementary to such a component. There would be
synergies between technical and awareness raising measures, since GSI and FCM
would provide the necessary information to drivers open-minded for
fuel-efficient driving. Educational measures to encourage fuel-efficient
driving already form part of compulsory driver training in some Member States
and could potentially be implemented on a broader scale alongside the mandatory
introduction of GSI and FCM. For professional drivers, EU Directive 2003/59/EC
already stipulates that their training needs to cover principles of eco-driving.
As such, it appears necessary to first introduce the technical preconditions
for assisted eco-driving in the most relevant categories of motor vehicles, and
then to consider whether EU action or coordination concerning the training of
non-professional drivers may potentially be needed.
Therefore this option is discarded from
further analysis in the given context.
5.2.        Scope of ammonia (NH3) emission limits threaten to drive HD natural gas vehicles out of
the market
Option 1: No changes to the existing
situation
–              
This option would leave the situation unchanged
and the Euro VI NH3 emission limits would apply to all heavy duty
vehicles. 
Option 2: Change the scope of the Euro VI NH3 limits so that they only apply to heavy duty vehicles with compression
ignition (diesel) engines
–              
This option would limit the scope of Euro VI NH3
limits so that they only apply to heavy duty vehicles with compression ignition
engines. 
5.3.        Upper mass limit of LD Euro 6 regulation necessitates
two type approvals for some vehicle platforms
Option 1: No changes to the existing
situation
–              
This option would leave the current situation
unchanged. Where different vehicles share a common platform but some vehicles
have a reference mass of more than 2610 kg while some are below, this means
type approval needs to be done according to two different sets of rules.
Option 2: remove the upper mass limit of the
LD Euro 6 regulation for emission purposes
–              
This option would give manufacturers a choice to
type approve vehicles with a reference mass of more than 2610 kg according to
the LD or HD emission requirements. In particular, in case of vehicle platforms
cross cutting the current LD-HD borderline, the manufacturer could simply type
approve all vehicles according to LD rules. As will be examined in the impacts
section, LD requirements are at least equivalent or even more stringent than HD
requirements in terms of environmental standards.
5.4.        Euro 6 LD Low temperature emission limits not adjusted
to technical progress
Option 1: No changes to the existing
situation
–              
As outlined in the problem definition, this
option would mean that the current low temperature emission limits would remain
unchanged. 
Option 2: introduce a mandate for the
Commission to set low temperature emission limits for carbon oxide (CO) and
hydrocarbons (HC) of positive ignition (petrol and gas) vehicles and NOx for positive
ignition and compression ignition (diesel) vehicles by way of a delegated act
–              
This option would consist of giving a mandate to
the Commission for a delegated act by amending Euro 5/6 Regulation 715/2007/EC.
Such a mandate would allow the Commission to propose rather technical and
narrow legislation in a lighter procedure. At this point in time, the available
information does not allow including the technical aspects in this initiative.
Before proposing any delegated act, the Commission would investigate the need
to do so and possible options in a follow-up impact assessment.  
5.5.        Euro 6 LD emission regulation specifies a limit value
for total emissions of nitrogen oxides (NOx), but no separate limit value for
nitrogen dioxide (NO2)
Option 1: No changes to the existing
situation
–              
As explained in the problem definition, this
option would imply that the NO2 emissions of light duty vehicles
limit would continue to be accounted for as part of the overall NOx limit. 
Option 2: Introduce a mandate for the
Commission to specify in addition to the limit value for total emissions of NOx
a limit value for emissions of NO2 by way of a delegated act
–              
This option would consist of giving a mandate for
a delegated act to the Commission by amending Euro 5/6 Regulation 715/2007/EC[20]. The same reasoning
applies as for the previous issue.
5.6.        Euro 6 LD THC emission limits cause problems for CNG
vehicle manufacturers
Option 1: No changes to the existing
situation
–              
This option would leave the current THC limits
unchanged.
Option 2: Introduce a mandate for the
Commission to account for the greenhouse gas effects of methane emissions as CO2 equivalents in vehicle type approval information and accordingly
increase or remove limit values of THC emissions of positive ignition vehicles
by way of a delegated act
–              
This option would consist of giving a mandate to
the Commission by amending Euro 5/6 Regulation 715/2007/EC to make the
necessary changes to Annex XII of the Euro 5/6 implementing Regulation
692/2008/EC by way of a delegated act. Again, the same reasoning as for the
previous two issues applies concerning the usefulness of having a mandate for a
delegated act.
Each of the regulatory options in the 6 issue
areas are considered to be in line with the proportionality principle as they
envisage that the EU would only act to the extent that is needed to achieve the
objectives. For any subsequent delegated acts (issues 6.4, 6.5, and 6.6), follow-up
impact assessments would be done that would also look at the proportionality
aspect.
6.           Analysis of impacts 
As
this impact assessment concerns a ‘narrow’ legislative action, it
will assess the options in a proportionate way with quantification of those
impacts for which sufficient data is available. The options will be analysed
with focus on the economic and environmental aspects, as these are the most
pertinent given the nature of the present initiative. The economic impacts
considered include the effects on industry and the indirect impact on
consumers. The environmental impacts considered include the emissions of
greenhouse gases and of the relevant air pollutants. If any, social impacts are
mainly expected in the area of employment. However, due to the low order of
magnitude of the possible employment effects, the scope for meaningful quantification
is very limited in this domain. 
Given
that the regulatory options identified in problem areas 4, 5 and 6 are aimed at
giving the Commission a mandate to amend or supplement emission legislation by delegated
act, no assessment of impacts can be provided for these options at this stage.
The decision to modify or introduce specific limit values for the pollutants in
question will be taken at a later stage and will be supported by a separate
impact assessment. Therefore, this report is focused on
providing a proportionate assessment of the impacts of the policy options devised
to address problem areas 1, 2 and 3. 
6.1.        Potential to reduce fuel consumption through efficient
driving behaviour insufficiently exploited
The impact of the possible introduction or
extension of the requirement to fit motor vehicles with GSI/FCM is to be
assessed here. The analysis is focused on CO2 and pollutant emission
reduction and additional costs imposed on vehicle manufacturers that can be
expected from the mandatory fitting of GSI and FCM to the most relevant motor
vehicle categories. This
assessment is mainly based on a TNO study on the effects of a gear-shift
indicator and a fuel economy meter on fuel consumption[21] which is in annex to
this report. It should be noted that this study is first of all applicable to
the LD sector.
Option 1: No changes to the existing
situation
The no policy change option coincides with the
baseline scenario. GSI would continue to be mandatory for vehicles of category
M1 (passenger cars) only and no legal requirement for FCM would be introduced. 
Option 2: Introduce mandatory fuel
consumption meters (FCM) for light duty (LD) vehicles and extend the mandatory
installation of gear shift indicators (GSI) from only passenger cars to all LD
vehicles
Economic impacts 
This option would require the fitting of FCM
and GSI to all light duty vehicles. Economic benefits would result from energy
savings through reduced fuel consumption (for quantitative figures see figure 5
below) and potentially an increase in consumable income resulting from reduced
spending on fuel. 
For the manufacturers of the vehicles
concerned, the extension of the requirement to fit FCM would mean moderate additional
costs, estimated to be in a 0-10 EUR bracket per vehicle[22]. Since in a modern
vehicle the information about the injected fuel is already available, the main
cost of implementing a FCM arise from the adaptation of the dashboard. Therefore
the low end of this bracket would be applicable to vehicle types that already
have the possibility to display fuel consumption information in the existing
dashboard. The higher end would apply to vehicle types for which a redesign of
the dashboard would become necessary. However, it can be expected that the
extra cost per unit produced would converge towards the low end of the cost
bracket quickly. An overview of the estimates for passenger cars from a short
and a long term perspective is presented below.
Figure 3 – Passenger car fleet penetration
and cost of Fuel Consumption Meter
   || FCM short term* || FCM long term 
 Small passenger car fleet penetration || currently <5% || mandatory 
 Costs/vehicle || Up to 20 Euro || 0-10 Euro 
 Medium passenger car fleet penetration || Unknown || mandatory 
 Costs/vehicle || 5-10 Euro || 0-10 Euro 
 Large passenger car fleet penetration || currently >95% || mandatory 
 Costs/vehicle || 0-10 Euro || 0-10 Euro 
* depending on dash board properties, redesign and
component costs
Source: TNO 2010
For light commercial vehicles no separate cost
estimates are available but costs are expected to be similar to costs of medium
or large passenger cars and thus be in the range of 0 to 10 EUR. 
For GSI, it needs to be recalled that these
will be mandatory for all passenger cars (M1) as of 2012 (all new car models)
2014 (all new cars) already under the baseline. M1 vehicles constitute the
large majority of light duty vehicles. Under this option, those light duty
vehicles that are not in category M1, such as light commercial vehicles, and
for which a GSI is not mandatory in the baseline would fall under the mandatory
fitting obligation. The extra cost per unit is estimated to be between 0 and 15
EUR for passenger cars in the short term. In principle, the motor management
system of modern motor vehicles supplies all information needed for the GSI. The
upper range of the cost bracket would be reached if the addition of a GSI would
necessitate a redesign of the dashboard to accommodate a suitable display. In
the long term the costs per vehicle would be in a 0-7 EUR range.
Figure 4 – Passenger car fleet penetration
and cost of Gear Shift Indicator
   || GSI short term* || GSI long term 
 Fleet penetration || currently <5% || mandatory 
 Costs/vehicle || 0-15 Euro || 0-7 Euro component costs 
*depending on dash board properties and existence of
fuel meter, redesign and component costs
Source: TNO 2010
Separate estimates for other LD vehicles are
not available. However, as their technical and design features relevant in this
context are very similar to those of passenger cars, the estimates are fully
transferable and also valid for these vehicles. 
However, next to the extra costs imposed on
manufacturers, the mandatory fitting of FCM and GSI in all light duty vehicles would
also create additional demand for sensors, suitable dash boards and related
components and could thereby open-up certain business opportunities for
suppliers. 
Social impacts 
Due to the low order of magnitude of the cost
increase per vehicle no effects on employment are expected. 
Environmental impacts
The main expected benefit would be CO2
emission savings, which are directly linked to reduced fuel consumption. When
analysing effects of systems supporting fuel efficient driving, it is important
to make a distinction between achievable effects and actual effects. Achievable
effects refer to the obtainable effects in fuel reduction in case the system’s
advice is optimally followed. The actual effect is determined as follows:
Actual effect (%) = achievable effect (%) x
effectiveness (%) x durability (%)
The actual effect equals the achievable effect
adjusted for effectiveness and durability. Effectiveness is the percentage of exposed
drivers really adapting their driving style and durability is the longevity of
the effect (i.e. how much of the effect is maintained in the longer term). 
Using the above formula, it is estimated that
the fitting of a GSI effectuates a net reduction in CO2 emission of
up to 1.5%. The corresponding figure for a FCM is in the order of magnitude of
0.3 to 1.1 %. These estimates are based on the findings of a number of earlier
studies[23]
on achievable effect, an effectiveness rate of 30% and a durability of 75%. The
below table summarises these findings.
Figure 5 – Summarised effects of a GSI and
FCM used to calculate an estimate of the combined effects
   || GSI || FCM 
 Achievable effect (lower estimate) [%] || 7 || 1.5 
 Achievable effect (higher estimate) [%] || N/A || 5 
 Effectiveness rate [%] || 30 || 30 
 Durability rate [%] || 75 || 75 
 Actual effect (lower estimate) [%] || 1.5 || 0.3 
 Actual effect higher estimate) [%] || N/A || 1.1 
Source: TNO 2010
When the actual effects of both measures are simply
added up, the combined effect would be between 1.8% (for the lower estimates)
and 2.6% (taking into account the higher estimate for the FCM). Since no
empirical studies are available on their combined effectiveness and durability an
expert estimate had to be made. Overall, there are compelling arguments for
synergies between GSI and FCM as their effects on driving behaviour are assumed
to be mutually reinforcing (e.g. the FCM immediately displays the consequences
of following or not following the advice of the GSI). The combined effect of higher
effectiveness and durability rates is estimated at 10-15%. This would result in
an actual combined effect between 2% (1.8 * 1.10 = 2%) and 3% (2.6 * 1.15 = 3%).
Fuel consumption could therefore be reduced by 2-3% for the average driver if
FCM and GSI are implemented together on a vehicle type. 
The above figures are best estimates for light
commercial vehicles. Taking into account that M1 vehicles (cars) will in future
need to be equipped with a GSI already under the baseline, the additional fuel
saving from requiring the installation of a fuel economy meter will be lower
than the 2-3% mentioned above. At that same time it is expected to be at least
as high as the 0.3 to 1.1 % savings that are expected from having only an FCM
(without GSI), given that synergies between the two are likely. A conservative
estimate would therefore be a 1% fuel saving on all M1 vehicles. It should be
noted that in light of the rather low cost of FCM and GSI, even a relatively
low fuel saving potential will make the investment pay off very quickly.
The effect that FCM and GSI would have on the noxious
emissions of vehicles fitted with them is less straight forward. While it can
be expected that the introduction of a FCM would lead to a decrease of noxious
emissions due to more fluent driving, better anticipation, more coasting and
possibly lower average speeds on motorways, there is some evidence that GSI in
vehicles with modern diesel engines or direct injection petrol engines could
lead to slightly elevated NOx emission. A study[24], which assessed a
range of measures to reduce fuel consumption, suggests that the implementation
of a GSI might increase NOx emissions from some modern diesel and direct
injection petrol engines as a result of shifting up at lower engine speed. The
magnitude of the total effect when both instruments are implemented is however unknown.
It should be noted that these studies were done on Euro 3 and Euro 4 vehicles,
where NOx emissions are controlled with internal engine measures and are
therefore sensitive to engine torque (which in turn is influenced by the gear
shift strategy). The proposed legislation is valid for Euro 6 (and possibly
future higher Euro classes) vehicles, which will be equipped with efficient NOx
aftertreatment systems that are not sensitive to these impacts. In addition,
NOx emissions of Euro 6 vehicles under real driving conditions, including the
use of GSI, will be assessed by more robust type approval procedures. Therefore,
NOx emissions of Euro 6 vehicles are not expected to increase when the GSI is
used.
Option 3: Introduce mandatory FCM for LD
and HD vehicles and extend the mandatory installation of GSI from only M1 to
all LD and HD vehicles
Economic impacts 
Albeit no precise cost estimates exist for FCM
and GSI to be installed in HD vehicles, the following qualitative statements
can be made:
–              
Costs for FCM are probably of the same order as
costs for LD vehicles, since the same technology (display of injected fuel
quantity normalised to distance driven) can be used.
–              
Costs for GSI are estimated to be significantly
higher than for LD vehicles since the variety of HD vehicles is much higher
than the one of LD vehicles (HD vehicle variants are typically only produced in
small series of a few hundred vehicles) and the GSI has to be adapted to each
vehicle type and variant. In addition, most modern HD vehicles have a highly
efficient automatic gear shift mode, which makes a GSI redundant. 
The economic impacts of option 3 therefore
appear to be less favourable than those of option 2. It should also be noted
that industry stakeholders oppose the mandatory installation of GSI in HD
vehicles.
Social impacts 
Due to the low order of magnitude of the cost
increase no effects on employment are expected. 
Environmental impacts
While, in principle, similar positive effects
on eco-driving and therefore reductions of CO2 emissions can be
expected when installing FCM and GSI in HD and LD vehicles, the following
elements need to be considered:
–              
HD vehicles are typically driven by professional
drivers, which is not the case for LD vehicles. For economic reasons operators
of HD vehicles are concerned about fuel costs and professional drivers are
advised to keep fuel consumption low, for which they also need to be trained,
as prescribed in the Professional Drivers Directive (2003/59/EC). Therefore,
the positive effect of tools supporting eco-driving, such as FCM and GSI, is
more limited than for LD vehicles.
–              
The vast majority of new HD vehicles are
equipped with automatic gearboxes, which render GSI obsolete.
–              
As compared to LD vehicles, HD vehicles are
typically operated at higher and more constant engine loads. This limits the
degree of freedom for operational parameters, such as acceleration and choice
of gear and speed. Boundary conditions such as vehicle load and traffic flow
largely determine the driving style, giving only limited scope for improved
eco-driving that could be assisted by FCM and GSI.
–              
As a consequence of the above, the additional
positive environmental impact of option 3 over option 2 is considered to be very
limited.
6.2.        Scope of ammonia (NH3) emission limits threaten to drive HD natural gas vehicles out of
the market
Option 1: No changes to the existing
situation
Economic impacts 
In Euro VI legislation, ammonia emission limits
have been introduced for all heavy duty vehicles regardless of engine or fuel
type. This limit value is set at the level of 10 parts per million (ppm) and
becomes binding at the end of 2012[25].
While the technology to bring the NH3 emissions from compression
ignition (diesel) engines under this limit is commercially available, no such
system exists for the small market segment of heavy duty vehicles with positive
ignition (natural gas and petrol) engines. For these vehicles to meet the
ammonia limit value, the development, testing and fitting of a number of
additional aftertreatment components would be required. Therefore, it is plausible
that the development and production costs of these vehicles would increase
disproportionately. This also corresponds to the feedback received from
industry stakeholders concerned by the issue.
The effect of the current limit value on natural
gas HD vehicles is further aggravated by the way emissions are measured in the
type approval process[26].

In 2010 roughly 473,000 new heavy duty vehicles
were registered in the EU27[27].
The vast majority was equipped with diesel engines (i.e. compression ignition)
which dominate the European market. In contrast, heavy duty vehicles equipped
with positive ignition engines registered annually in the EU are only a few
thousands. Most of these vehicles are urban transit buses running on natural
gas. The total number of positive ignition vehicles in the EU that would be
affected by the Euro VI NH3 limit is expected to be in the range of
2000 – 4000 units per year depending on future demand trends. 
The following material and development cost
estimate is based on the assumption that, in order to meet the NH3
limit, a clean-up catalyst would need to be installed in addition to the 3-way
catalyst that would otherwise suffice. The required additional material would
include the following main components:
·              
clean up catalyst;
·              
injection system to inject oxidant to convert NH3;
·              
NH3 concentration sensor;
·              
more complex wiring harness;
·              
various modifications due to the impact on
vehicle lay-out and packaging
As already stated, these components would still
need to be developed for the given purpose as they are not commercially
available at present. A reliable cost estimate is therefore very difficult to
produce, but due to the considerable increase in technical complexity, it can
be assumed that the material cost of the aftertreatment system would increase
by at least 50%. The only available estimate of the additional material costs
in absolute terms comes from an industry stakeholder, who stated that they
would amount to at least EUR 1600 per vehicle[28].

Alongside the material cost that would be
incurred for each produced unit, there are also additional project costs for
each engine/vehicle family that would need to comply with the limit. An
industry estimate of these additional costs is in the range of EUR 6-8 million
per engine/vehicle family[29].
This is particularly salient as the vehicles in question are normally produced
in relatively small series and often according to specific requirements of
individual public transport providers. 
Assuming a market of 3000 units/year composed
of 10 engine families, the total additional material costs would amount to EUR
48 million per year and the total additional project costs would be in the
range of EUR 60-80 million. This would lead to total additional costs under the
baseline of EUR 108-128 million. Moreover, the related activities would require
an estimated 2 years for completion, delaying as a consequence the start of
production of Euro VI compliant natural gas vehicles, assuming that producers
would continue offering them.
Social impacts 
The employment effects of the no policy change
option largely depend on how the entry into force of NH3 limit
values will affect the business case for natural gas transit buses. However,
the order of magnitude of the cost increase suggests that the market potential
of these vehicles would be seriously diminished. Next to the direct effect on
the producers, this would disproportionately affect specialised small and
medium sized component suppliers. If the potential loss in employment could be
offset by positive employment effects triggered by an increase in the demand
for conventional diesel buses is doubtful. 
Environmental impacts
The main reason why the segment of natural gas
fuelled transit buses has developed, in a market that is otherwise dominated by
diesel engines, is the overall emission performance of natural gas vehicles.
These vehicles are normally used in urban areas as they have low PM and NOx
emissions. Due to the low carbon content of natural gas in comparison to other
fossil fuels, the CO2 emissions are also lower. 
Assuming that producers decide to develop and
market natural gas buses that comply with Euro VI in its current form, the
associated cost increase and the likely effect on the price could inhibit the
production and diffusion of these comparatively clean vehicles. The gradual
replacement of natural gas buses, reaching the end of their service life, by
diesel buses would result in an increase of PM, NOx and CO2
emissions. 
The NH3 emission reduction linked to
maintaining the status quo would be largely insignificant, as the contribution
of the entire road transport sector to the total NH3 emissions in
the EU is very small. In 2009, agriculture was responsible for 93.3% of the
total EU27 ammonia emissions. In contrast to that, road transport only
accounted for 1.9%[30].
Based on the total EEA emission figure of 3,783,000 tonnes of NH3
for 2009, the 1.9% share of transport would amount to 71,877 tonnes in absolute
terms.
Option 2: Change the scope of the Euro VI
NH3 limits so that it only applies to diesel engines
Economic impacts
The proposed change would facilitate the
introduction of new natural gas HD vehicles to the market, taking into account
that in cost-sensitive cases the development of Euro VI compliant vehicles may
be critically affected. Therefore, there is a positive economic impact for
manufacturers and operators of natural gas HD vehicles, as additional material
and project costs estimated to be EUR 108-128 million per year would be
avoided. This option is also strongly favoured by a majority of the stakeholders
who replied to the public consultation.
Social impacts 
As the business case for HD natural gas
vehicles would stay unaffected by Euro VI, the effect on employment is expected
to be neutral or slightly positive compared to today, as there may be some
limited creation of jobs in manufacturing of natural gas HD vehicles. The
potential negative effects on employment under the baseline would be avoided in
this option.
Environmental impacts
The only available estimate of the additional
NH3 emitted following a removal of the limit value for positive
ignition engines was provided by an industry stakeholder[31] and is based on a
number of simple assumptions:
Registration
of diesel Euro VI vehicles                                            450.000
units/year
Registration of natural gas Euro VI vehicles                                    3.000
units/year
Standard annual mileage of a HD vehicle                                        50.000
km
Assumed energy efficiency                                                              1
kWh/km
NH3 emissions of typical diesel Euro VI SCR engine                     40
mg/kWh
NH3 emissions of typical gas Euro VI engine with NH3
limit         20 mg/kWh
The total NH3 emissions from such a
fleet of Euro VI vehicles would amount to 903 tons per year. Assuming that the
NH3 emissions of a typical Euro VI natural gas engine would go up to
36 mg/kWh if the NH3 limit were to be removed, the amount emitted
would increase to 905.4 tons per year. This corresponds to a 0.2-0.3% increase.
Even if the above calculation is very indicative, it makes clear that the
additional NH3 emissions from removing the limit value would be largely
insignificant.
In contrast to that, the wider replacement of
diesel by natural gas heavy duty vehicles, in particular in urban areas, would
have a significant positive environmental effect with respect to the emissions
of NOx and CO2. In principle, this positive environmental impact has
to be balanced with potentially slightly higher NH3 emissions. As it
has been explained above, the overall importance of these emissions is small.
Therefore, the global environmental impact of this option can be considered
positive.
6.3.        Upper mass limit of LD Euro 5/6 regulation necessitates
two type approvals for some vehicle platforms
Option 1: No changes to the existing
situation
Economic impacts 
Where different vehicles share a common
platform but some vehicles have a reference mass of more than 2610/2840 kg while
some are below, type approval needs to be done according to two different sets
of rules, which creates some burden for manufacturers. Here two different types
of costs have to be distinguished:
–              
Administrative costs for two type approval
procedures (these are relatively limited, i.e. are in the order of 100 000 Euro
per type approval)
–              
Additional design and development costs since
the same vehicle platform has to be calibrated for two different design
requirements. Such costs are difficult to estimate because they are considered
as commercially sensitive, it can however be estimated that they correspond to
several million Euros per calibration of a vehicle type (and depend of course
on the complexity of individual calibrations). 
Social impacts 
No impacts on employment are expected.
Environmental impacts
No environmental impacts are expected.
Option 2: remove the upper mass limit of
the LD Euro 5/6 regulation for emission purposes
Economic impacts 
Vehicle manufacturers would get an additional
choice for type approval, which would reduce the regulatory burden in
particular for vehicle platforms with some vehicles above and others below
today's LD-HD reference mass borderline. While LD requirements are at least
equivalent but possibly more stringent than HD requirements (see below under
environmental impacts), the freedom of choice for manufacturers allows them to
determine whether the benefits of simplification outweigh possible additional
costs of having to meet more stringent requirements. If those costs are higher
than savings from simplification, manufacturers can simply decide to type
approve a vehicle under HD standards and are thus at least not worse off than
under the baseline. Where the additional costs are lower than the cost savings
from single certification true cost savings this option will allow true cost
savings. However, no data is available for reasons explained above as to the
likely magnitude of the overall cost savings.
Social impacts 
No major employment impacts are expected. To
the extent that manufacturers make use of the simplification possibility, this
should lead to cost reductions that could potentially translate into lower
prices for buyers.
Environmental impacts
The central question in the assessment of
environmental impacts is whether the application of Euro 6 instead of Euro VI
emission legislation on a voluntary basis would result in negative
environmental consequences. A direct nominal comparison between the two is not
possible as they set pollutant limits in different ways (mass per distance
travelled in Euro 6 vs. mass per unit of power output in Euro VI) and define
different testing methods. While the qualitative requirements defining the
scope of emission relevant elements of a vehicle being tested can be considered
technically equivalent for Euro 6 and Euro VI, the effect of the quantitative
requirements (i.e. the actual limit values) is more difficult to establish. 
In this context, it is important to recall that
the reference quantity for emission limits is the distance driven (regardless
of the weight or size of the vehicle) in LD Euro 6 and the work generated by
the engine in HD Euro VI. Since heavier vehicles tend to emit more pollutants
per km driven, the application of LD Euro 6 becomes more demanding with
increasing mass. As a consequence there will be a "natural" limit for
the voluntary application of LD Euro 6 legislation to heavier vehicles. It is,
therefore, extremely unlikely that Euro 6 would be applied to vehicles with
reference masses above 5 tons.
Also for "borderline" HD vehicles
with reference masses just above the LD-HD borderline, which in the future
would typically be the subject to the voluntary application of Euro 6 (LD) instead
of Euro VI (HD) emission limits, the former would be more demanding than for typical
light duty vehicles falling in the mandatory scope of Euro 6, which have
smaller masses. In particular, if Euro 6 emission limits are applied to a
"borderline" HD vehicle, it would not be more polluting than any
light duty vehicle falling in the mandatory scope of Euro 6.
Unfortunately no data for Euro VI (HD) tested
against Euro 6 (LD) requirements are available at this stage, since Euro VI
"borderline HD" vehicles are not available on the market yet. The
European automobile manufacturers' association (ACEA) has however provided some
data on NOx emissions[32]
of a Euro V (HD) vehicle, which was tested against Euro 5 (LD) requirements.
These data suggest that the Euro V "borderline HD" vehicle in
question would exceed Euro 5 NOx emission limits by about 50%. Compliance with
Euro 5 instead of Euro V emission limits requirements would therefore result in
lower emissions. 
As a consequence the impact of this option can
be considered as environmentally neutral, if not slightly positive.
Given
the different nature of the issue areas covered by this impact assessment,
there are no synergies or trade-offs between the options assessed in different
areas. Their cumulative effect across options is therefore equal to the sum of
the parts. 
7.           Comparing the options 
When comparing the policy options in the three
problem areas that were subject to a detailed assessment of impacts, the
following picture emerges:
 COMPARISON OF THE OPTIONS FOR PROBLEM 1 Potential to reduce fuel consumption through efficient driving behaviour insufficiently exploited 
 OPTIONS || EFFECTIVENESS || EFFICIENCY || COHERENCE 
 Option 1: No changes to the existing situation || N.A || N.A || N.A. 
 Option 2: Introduce mandatory fuel consumption meters (FCM) for light duty (LD) vehicles and extend the mandatory installation of gear shift indicators (GSI) from only passenger cars to all LD vehicles || HIGH: Puts in place essential devices for more fuel efficient driving in the most important segment of the new vehicle fleet. || MEDIUM: Some limited  costs imposed on the producers of light duty vehicles (0-10 EUR per vehicle) || HIGH: Coherent with relevant EU strategies and objectives, in particular with the EU's energy and climate change policy. 
 Option 3: Introduce mandatory FCM for LD and HD vehicles and extend the mandatory installation of GSI from only passenger cars to all LD and HD vehicles || HIGH: Puts in place essential devices for more fuel efficient driving in the entire new vehicle fleet.   || LOW: Some limited costs (0-10 EUR per vehicle) c imposed on the producers of light duty vehicles. Slightly higher costs imposed on producers of heavy duty vehicles (per unit). || MEDIUM: Coherent with relevant EU strategies and objectives. 
Option 2 emerges as the preferred one from this
comparison, as it is the more efficient way to address the problem. The
positive environmental impacts of option 3 are unlikely to be significantly
higher than the ones for option 2. Although there would be some limited,
additional environmental benefits of option 3 over option 2, these are unlikely
to be proportionate to the associated costs. Therefore, at the current stage,
the mandatory installation of GSI or FCM in HD vehicles appears difficult to
justify. 
 COMPARISON OF THE OPTIONS FOR PROBLEM 2 Scope of ammonia (NH3) emission limits threaten to drive HD natural gas vehicles out of the market 
 OPTIONS || EFFECTIVENESS || EFFICIENCY || COHERENCE 
 Option 1: No changes to the existing situation || 0 || 0 || 0 
 Option 2: Change the scope of the Euro VI NH3 limits so that they only apply to heavy duty vehicles with compression ignition (diesel) engines || HIGH: Avoids that Euro VI NH3 limits for heavy duty vehicles obstruct the further development and market-uptake of natural gas vehicles. || HIGH: No associated costs (would avoid potential costs for industry in the area of EUR 108-128 million per year in comparison to the baseline) || HIGH: Fully coherent with all relevant EU strategies and objectives 
Option 2 is clearly preferable to the baseline,
as it solves the problem without creating any costs. The coherence with EU
policy objectives is high as the environmental and social impacts are expected
to be positive on balance
 COMPARISON OF THE OPTIONS FOR PROBLEM 3 Upper mass limit of LD Euro 6 regulation necessitates two type approvals for some vehicle platforms 
 OPTIONS || EFFECTIVENESS || EFFICIENCY || COHERENCE 
 Option 1: No changes to the existing situation || 0 || 0 || 0 
 Option 2: Remove the upper mass limit of the LD Euro 6 regulation for emission purposes || HIGH: Resolves the need for costly double emissions certification. || HIGH: No associated costs || HIGH: Coherent with the competitiveness and sustainability concept of Europe 2020, the objectives of industrial policy and the simplification agenda. 
Option 2 is clearly preferable to the baseline,
as it solves the problem without creating any costs. No negative environmental
or social impacts expected.
8.           Monitoring and evaluation 
A joint evaluation of the measures contained in
this impact assessment and the follow-up impact assessment could be usefully
carried out five years after entry into force of the act adopted through the
ordinary legislative procedure and any delegated acts that may be adopted. 
Extensive reporting mechanisms are already in
place to monitor ambient air quality and Member States' adherence to Community
air quality objectives. Non-compliance with legal air quality requirements is
enforced pursuant to existing Treaty provisions. These reporting mechanisms
also generate data that allow the monitoring of pollutant emissions, e.g. whether
urban NOx emissions increase or decrease. The compliance of motor vehicles sold
in the European market with EU requirements is checked by the national type
approval authorities during the approval process for new vehicle types. The
existing reporting mechanisms, therefore, would allow the Commission to monitor
the effects of the proposed legislation to a certain extent. However, due to
the relatively low order of magnitude of the initiative under consideration, it
may be difficult to link the data obtained from the existing reporting
mechanisms to the actual impact of the intervention. Therefore, it could be
considered to complement this data with additional evidence that could be
obtained through a background study.
Glossary
CNG                                             Compressed
natural gas
CO                                                            Carbon
monoxide
CO2                                                               Carbon
dioxide
Compression ignition                    Diesel engine
FCM                                              Fuel
consumption meter
Gg                                                 Gigagram
GHG                                             Greenhouse
gas
GSI                                               Gearshift
indicator
HC                                                            Hydrocarbon
HD                                                            Heavy
duty vehicle
kWh                                              Kilowatt
hour
LD                                                 Light
duty vehicle
LPG                                              Liquefied
petroleum gas
MVEG                                          Motor
vehicle emissions group
NGV                                             Natural
gas vehicle
NH3                                                              Ammonia
NMHC                                          Non-methane
hydrocarbons
NMVOC                                       Non-methane
volatile organic compounds
NO                                                            Nitrogen
oxide
NO2                                                              Nitrogen
dioxide
NOx                                              Generic
term for NO and NO2
O3                                                                  Ozone
PM                                                            Particulate
matter
ppm                                               Parts
per million
Positive ignition                            Petrol or
gas engine
SCR                                              Selective
catalytic reduction
THC                                              Total
hydrocarbons
UN/ECE                                       United
Nations Economic Commission for Europe
[1]               Arabic numerals designate light duty (LD) vehicle emission
standards and Roman numerals heavy duty (HD) vehicle emission standards.
[2]               http://ec.europa.eu/enterprise/sectors/automotive/documents/consultations/2011-emission-standards/index_en.htm 
[3]               WHO 2011, Air quality and health, Factsheet No 313,
updated September 2011
[4]               WHO 2008, Health risks of ozone from long-range
transboundary air pollution.
[5]               http://www.euro.who.int/en/what-we-do/health-topics/environment-and-health/air-quality/facts-and-figures
[6]               NOx is a generic term for nitric oxide (NO) and
nitrogen dioxide (NO2).
[7]               EEA 2011, EU27 air pollutant emissions – factsheet
[see Annex 3]
[8]               WHO 2011, Air quality and health, Factsheet No 313,
updated September 2011
[9]               DG MOVE 2011, EU transport in figures: Statistical
Pocketbook.
[10]             Article 11 of Regulation (EC) 661/2009 requires all
vehicles of category M1 to be equipped with gear shift indicators. This
requirement becomes effective for all new car models as of 2012 and for all new
cars as of 2014.
[11]          TNO 2010,
Effects of a gear-shift indicator and a fuel economy meter on fuel consumption.
[12]             Regulation (EC) 595/2009
[13]             As described in section 7.2, IVECO estimate that the
mass of ammonia typically emitted could reach 36mg/kWh.
[14]             European Commission 2011, EU transport in figures,
Statistical Pocketbook 2011.
[15]             DG CLIMA
[16]             WHO 2004, Health aspects of air pollution. 
[17]             EEA (2010) Impact of selected policy measures on
Europe's air quality.
[18]             WHO 2008, Health risks of ozone from long-range
transboundary air pollution.
[19]             Article 11 of the General Safety Regulation 661/2009/EC
already provides for the mandatory installation of GSI in passenger cars (M1
vehicles that are subject to LD vehicle legislation)
[20]             It should be noted that Article 12(1) of Euro VI
Regulation 595/2009/EC already provides for such a mandate with respect to Euro
VI heavy duty vehicles.
[21]             TNO 2010, Effects of a gear shift indicator and a fuel
economy meter on fuel consumption
[22]             TNO 2010, Effects of a gear shift indicator and a fuel
economy meter on fuel consumption
[23]             See for example Van der Voort (2001), Vermeulen (2006) and
Smokers et al. (2006). 
[24]             Vermeulen 2006
[25]             Regulation 595/2009 stipulates that all new type
approvals have to comply as of 31/12/2012 and all new vehicles as of
31/12/2013. 
[26]             This is caused by the fact that the NH3
limit has been expressed in concentration (ppm) instead of mass per power
output (mg/kWh). As diesel engines typically operate with a high quantity of
air in excess, the pollutants in the exhaust gas are subject to a relatively
high level of dilution. In contrast to that, natural gas engines typically work
with a quantity of air exactly proportionate to the amount of fuel to be burnt.
So the level of dilution is lower and the exhaust concentration is higher than
in case of diesel engines. This means that, under certain conditions, the NH3
emission measured as concentration (ppm) of natural gas engines could exceed
the Euro VI limit, even if the NH3 emissions expressed in mass
(mg/kWh) is lower than the one of a diesel engine with same power output and
displacement.
[27]             Source: ACEA
[28]             Source: IVECO
[29]             Source: IVECO
[30]             Source: EEA
[31]             Source: IVECO
[32]             Looking at air quality problems of Member States and
the real driving emissions, NOx is the most critical regulated pollutant.