Ex-post evaluation of Directive 2009/33/EC on the promotion of clean and energy efficient road transport vehicles : final report.
Date: 2015-10-15
Institutions: Directorate-General for Mobility and Transport
Subjects: air quality, clean technology, directive (EU), motor vehicle, motor vehicle pollution, non-polluting vehicle, reduction of gas emissions, road transport

Ex-post Evaluation of Directive 
2009/33/EC on the promotion 
of clean and energy efficient 
road transport vehicles 
Final Report 
Study contract no. MOVE/A3/119-2013 Lot No 5 

21 September 2015 

By Charlotte Brannigan, Stephen Luckhurst, Felix Kirsch, Edina Lohr (Ricardo Energy & 
Environment) and Ian Skinner (TEPR)  
September 2015 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Directorate-General for Mobility and Transport  
Ex-post Evaluation of Directive 2009/33/EC on promotion of clean and energy-efficient road 
transport vehicles 

2015 

EUR 2015.5309 EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Mobility and Transport  
Directorate C – Innovative & Sustainable Mobility 
Unit C.1 – Clean Transport & Sustainable Urban Mobility 

Contact: José Fernandez Garcia 

E-mail:  move-c1-actions@ec.europa.eu 

Jose.Fernandez-Garcia@ec.europa.eu 

European Commission 
B-1049 Brussels 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ex-post Evaluation of Directive 
2009/33/EC on the promotion 
of clean and energy-efficient 
road transport vehicles 
Final Report 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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ISBN 978-92-79-51686-3 
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Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33/EC on the promotion of clean and energy-efficient road 
transport vehicles 

Final Report 

Table of Contents 

EXECUTIVE SUMMARY ..................................................................................................... I 

Objectives .............................................................................................................. i 
Methodology .......................................................................................................... i 
Main findings/conclusions........................................................................................ ii 
Recommendations................................................................................................. iv 

RÉSUMÉ ANALYTIQUE ................................................................................................ VIII 

Objectifs ............................................................................................................. viii 
Méthodologie ....................................................................................................... viii 
Principaux résultats et conclusions .......................................................................... ix 
Recommandations ................................................................................................ xii 

1. 

INTRODUCTION ..................................................................................................... 1 

1.1.  Purpose of the evaluation .............................................................................. 1 
1.2.  Scope of the evaluation ................................................................................. 1 
1.3.  Structure of this report .................................................................................. 1 

2. 

BACKGROUND TO THE INITIATIVE ........................................................................... 2 

2.1.  Description of the initiative ............................................................................ 2 
2.2.  Baseline ...................................................................................................... 4 
Intervention logic ......................................................................................... 8 
2.3. 

3. 

EVALUATION QUESTIONS ..................................................................................... 12 

4.  METHOD/PROCESS FOLLOWED .............................................................................. 13 

4.1.  Method/Process .......................................................................................... 13 
4.2.  Limitations – robustness of findings .............................................................. 17 

5. 

IMPLEMENTATION STATE OF PLAY (RESULTS) ......................................................... 20 

Implementation of Directive 2009/33 ............................................................ 20 
5.1. 
5.2.  Current situation ........................................................................................ 24 
5.3.  Unexpected results ..................................................................................... 25 
Issues ....................................................................................................... 26 
5.4. 

6. 

ANSWERS TO THE EVALUATION QUESTIONS........................................................... 28 

Introduction ............................................................................................... 28 

6.1. 
6.2.  Relevance: To what extent is increasing the market share of clean vehicles an 
adequate means to contribute to the overall objectives of increasing the energy 
efficiency  and  competitiveness  and  decreasing  CO2  and  pollutant  emissions  of 
transport? (Q1) .......................................................................................... 28 

6.4.  Effectiveness: To what extent has the mandatory inclusion of operational lifetime 
environmental  and  energy  impacts  in  the  procurement  decision  led  to  an 
increased market  share  of clean  vehicles and  contributed to reducing CO2  and 
pollutant  emissions  (NOX,  NMHC  and  particulate  matter)  from  the  transport 
sector? (Q3)............................................................................................... 36 

6.5.  Effectiveness:  To  what  extent  has  the  provision  of  different  options  to  include 
impacts  stimulated  the 
operational 
internalisation of operational costs in procurement decisions, and contributed to 
the harmonisation in determining these costs? (Q4) ........................................ 49 

lifetime  environmental  and  energy 

6.6.  Effectiveness:  To  what  extent  has  the  Directive  promoted  an  increased 
awareness  among  the  different  stakeholders  of  the  operational  lifetime 
environmental and energy impacts of vehicles? (Q5) ....................................... 52 

 
 
 
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

6.7.  Efficiency:  To  what  extent  has  the  Directive  generated  benefits  and  costs  for 
different  stakeholders  (e.g.  national  administrations,  contracting  authorities, 
transport operators, manufacturers)?  (Q6) ................................................... 54 

6.8.  Efficiency:  Could  the  effects  have  been  achieved  in  a  more  efficient  way  (e.g. 

through other or additional (legislative) measures)? (Q7) ................................ 64 

6.9.  European Added Value: Would it have been possible to obtain similar or better 
results in terms of the market share of clean vehicles without EU intervention, 
i.e. the Clean Vehicles Directive? (Q8) ........................................................... 69 

6.10.  European  Added  Value:  To  what  extent  have  the  Directive  and  the  associated 
Commission initiatives initiated and/or supported a recognised exchange of good 
practices between contracting authorities in different Member States? (Q9) ....... 70 

6.11.  Coherence:  How  well  does  this  legislation  interact  with  other  EU  policies  with 
similar  objectives,  in  particular  the  general  transport  policy  framework  as  laid 
down in the 2030 framework for climate and energy policies, the 2011 Transport 
White Paper, the conclusions from CARS2020, pollutant emissions limits (EURO 
standards  for  light  and  heavy  duty  vehicles)  and  CO2  limits  for  cars,  and  the 
deployment of alternative fuel infrastructure? (Q10) ....................................... 72 

6.12.  Coherence:  To  what  extent  is  the  provision  of  multiple  options  to  include 
operational  lifetime  environmental  and  energy  impacts  coherent  with  the 
objective of harmonising the determination of these impacts? (Q11) ................. 75 

6.13.  Coherence:  To  what  extent  are  the  provisions  of  the  CVD  coherent, 
complementary and/or redundant with the horizontal EU procurement legislation 
(in particular 2014/24/EU and 2014/25/EU)? (Q12) ........................................ 77 

6.14.  Sustainability: To what extent would the market develop differently should the 

intervention be ceased partially or completely at European level? (Q13) ............ 80 

7. 

CONCLUSIONS .................................................................................................... 84 

7.1.  Relevance .................................................................................................. 84 
7.2.  Effectiveness .............................................................................................. 84 
7.3.  Efficiency ................................................................................................... 85 
7.4.  EU Added Value .......................................................................................... 85 
7.5.  Coherence ................................................................................................. 86 
7.6.  Sustainability ............................................................................................. 86 

8. 

RECOMMENDATIONS ............................................................................................ 87 

8.1.  General recommendations ........................................................................... 87 
8.2.  Specific recommendations ........................................................................... 87 

9. 

ANNEX  1:  DETAILS  OF  BASELINE  SCENARIO  AND  APPROACH  TO  QUANTIFYING 
IMPACTS ............................................................................................................. 91 

9.1.  Estimation of volumes of publicly procured vehicles ........................................ 91 
9.2.  Estimation of volumes of publically procured vehicles procured via TED ............. 94 
9.3.  Summary of public procurement volume analysis ........................................... 95 
9.4.  Other key parameters considered in the analysis ............................................ 96 
9.5.  Estimation of passenger car and vans CO2 effects ........................................... 97 
9.6.  Estimation of air pollutant benefits effects ................................................... 100 

10.  ANNEX 2: EU LEVEL STAKEHOLDER INTERVIEWS .................................................. 103 

11.  ANNEX  3  -  WIDER  EU  STAKEHOLDER  WORKSHOP  –  AGENDA,  ATTENDEES  AND 

SUMMARY ......................................................................................................... 114 

12.  ANNEX 4 – ONLINE PROCURER SURVEY ................................................................ 127 

13.  ANNEX 5 – PROCURER INTERVIEWS ..................................................................... 142 

14.  ANNEX 6 – MANUFACTURER INTERVIEWS AND QUESTIONNAIRES ........................... 153 

15.  ANNEX 7 – CONTRACTOR ONLINE SURVEY ........................................................... 157 

16.  ANNEX 8 - MEMBER STATE REPRESENTATIVE’S WORKSHOP – AGENDA .................... 173 

17.  ANNEX 9: ASSESSMENT OF THE METHODOLOGY FOR MONETISATION OF COSTS ...... 174 

 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

17.1.  Introduction ............................................................................................. 174 
17.2.  Assessment – overview of effects and issues ................................................ 175 
17.3.  Assessment – case studies ......................................................................... 178 
17.4.  Assessment – conclusions on relevance and effectiveness .............................. 188 
17.5.  Possible solutions/improvements ................................................................ 189 

18.  ANNEX  10  –  ASSESSMENT  OF  THE  COMMISSION  INITIATIVES  AIMED  AT  THE 

PROMOTION OF THE DIRECTIVE .......................................................................... 192 

19.  ANNEX 11: EVALUATION OF THE EXTENT TO WHICH IT IS, AND WILL CONTINUE TO 
BE, IMPORTANT TO INCREASE THE ENERGY EFFICIENCY AND  COMPETITIVENESS OF 
TRANSPORT AND TO REDUCE ITS CO2 AND POLLUTANT EMISSIONS ........................ 201 

20.  ANNEX 12: GRAPHS FOR RELEVANCE ................................................................... 203 

21.  ANNEX  13  –  ASSESSMENT  OF  WHETHER  REPORTING  REQUIREMENTS  ON  MEMBER 

STATES WOULD BE EFFECTIVE AND PROPORTIONATE ............................................ 206 

ANNEX  14:  OVERVIEW  OF  RELEVANT  POLICIES  AND  INSTRUMENTS  (SUPPORTING 

COHERENCE Q10) .............................................................................................. 217 

REFERENCES ............................................................................................................ 223 

ABBREVIATIONS ....................................................................................................... 227 

 
 
 
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33/EC on the promotion of clean and energy-efficient road 
transport vehicles 

EXECUTIVE SUMMARY 

Objectives 

This ex-post evaluation covers Directive 2009/33/EC on the promotion of clean and energy 
efficient road transport vehicles (the “Clean Vehicles Directive”).  

The  Directive  aims  to  stimulate  the  market  for  clean  and  energy-efficient  vehicles  by 
requiring various procurers to take account of lifetime environmental and energy impacts 
when purchasing road transport vehicles.   

Clean  Vehicles  Directive.  The  Clean  Vehicles  Directive  is  included  in  the  European 
Commission's Regulatory Fitness and Performance programme1 (REFIT) in order to assess 
if it has delivered against its objectives and is still fit for purpose. 

Methodology 

The  methodology  followed  the  standard  evaluation  framework  for  an  assessment  of 
legislation and the key evaluation questions related to relevance, effectiveness, efficiency, 
EU added-value, coherence and sustainability.  

The main research tools used included: 

  Desk  research  and  literature  review.  Reports  and  studies  directly  related  to 
Directive 2009/33/EC, Directives and their assessment in the wider policy context, 
European strategy documents and work previously performed by the study team - 
all  of  the  literature  is  referenced  throughout  the  report,  as  well  as  following  the 
Annexes.    

  Extensive stakeholder engagement. Including EU-level stakeholders (11 interviews 
and a workshop), Procurers (13 interviews, additional written responses, and 547 
online  survey  responses),  manufacturers  (3  interviews  and  additional  written 
responses), contractors (65 online survey responses), Member States (completed 
MS fiches and a workshop).  

  Case  studies.  Illustrative  examples  for  the  assessment  of  the  methodology  of  the 
monetisation of costs in Article 6, and qualitative case studies drawing upon existing 
case studies, e.g. Clean Fleets, Clean vehicle Portal, GPP 2020 etc. – contributing 
to the quantification of the impacts of CVD.  

The main quantitative analytical tools were: 

  Comparative analysis with a baseline/counterfactual scenario. The baseline 
was  used  for  quantifying  the  effects  of  the  intervention  on  costs  and  other  key 
outcome  indicators  including  CO2  emissions,  air  pollutant  emissions,  and  cost-
effectiveness.   

The  quantitative  techniques  described  above  were  supplemented  by  qualitative  analysis 
conducted on the basis of the literature review, stakeholder engagement and collation of 
data.   

The main limitations of the research were due to a lack of data availability and the limited 
time that the Directive has been in force and therefore its ability to deliver impacts. 

The  lack  of  existing  evidence  in  relation  to  the  implementation  of  the  Directive  and  its 
associated impacts is due to:   

1   EC’s REFIT  –  action  taken  to make  EU  law simpler  and  to reduce regulatory  costs,  thus  contributing  to  a 
clear,  stable  and  predictable  regulatory  framework  supporting  growth  and  jobs  European  Commission. 
from  http://ec.europa.eu/smart-
(2013).  "EU  Regulatory  Fitness  (REFIT)  --  Key  Documents." 
regulation/better_regulation/key_docs_en.htm. 

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

  There is no EU level monitoring mechanism in place other than the production of 

consultancy reports; 

  There are no reporting requirements in place for Member States;  

  Few  Member  States  have  undertaken  any  monitoring  or  evaluation  of  effects  on 
their  own  in  this  respect,  and  so  there  is  a  lack  of  information  on  MS 
implementation; and 

  There  is  little  in  the  way  of  published  views/position  papers  from  stakeholders 

currently available.  

The issues that are likely to limit the extent to which impacts will have been realised by 
the  Directive  include  the  limited  number  of  vehicles  procured  publicly  (compared  to  the 
rest of the vehicle fleet); the lifetime of  road transport vehicles (typically 10-15 years); 
and proportion of road transport vehicles procured falling below the CVD threshold value 
(i.e. out of scope of the  Directive, therefore reducing the number of potentially affected 
vehicles further).  

Main findings/conclusions 

Relevance 

  The needs at which the Directive is targeted, i.e. the need to decrease transport’s 
CO2  and  pollutant  emissions  and  to  increase  its  energy  efficiency  and 
competitiveness, are pertinent, and are likely to remain pertinent in the future.  

  Overall, targeting publicly procured vehicles is considered to be a relevant tool to 
increase the energy efficiency and to reduce the CO2 and pollutant emissions from 
road transport. Even though stimulating the public procurement of clean vehicles is 
not by itself sufficient to achieve these objectives, it is still beneficial. While publicly 
procured vehicles represent a small share of the overall vehicle market, there is still 
a case for using public procurement to stimulate the market for clean vehicles, as 
part of a more comprehensive approach to delivering the stated objectives.  

  Furthermore,  in  the  case  of  specific  categories  of  vehicles  (such  as  buses)  the 
potential for stimulating the market for clean vehicles is significantly greater.  

 

It  is  argued  that  (and  there  is  theoretical justification  for)  ‘stimulating  the  public 
procurement  of  clean  vehicles’  has  the  potential  to  contribute  to  increasing  the 
competitiveness of the wider EU economy and of cities, although difficult to prove 
in practice.    

  However, in addition to the small market share of publicly procured vehicles, the 
extent of the contribution of the Directive to increasing the energy efficiency of and 
reducing the CO2 and pollutant emissions from transport also depends on whether 
the focus is on the ‘right type’ of clean vehicle. This is an aspect that is currently 
not  clearly  defined  by  the  Directive  and  for  which  there  are  very  different 
approaches followed by contracting authorities.  

Effectiveness 

  Our estimates of the impacts of the CVD – on the basis of available evidence and a 
set  of  important  assumptions  –  suggests  that  these  are  much  more  limited  than 
was  initially  expected.  Furthermore,  the  estimated  impacts  of  up  to  5.5%  CO2 
emissions  reduction  for  passenger  cars  and  2.3%  for  vans  in  comparison  to  the 
baseline represent a best-case scenario, which, most probably, does not take full 
account of the impact of other relevant policies in place (such as the passenger car 
CO2  Regulation).  Our  analysis  suggests  that  the  impacts  directly  associated  with 
the Directive are more limited, although it has not been possible to get more precise 
estimates. 

 

In  addition,  the  analysis  suggests  that,  in  terms  of  air  pollutant  emissions,  the 
contribution  may  even  be  negative,  as  a  result  of  the  tendency  of  some  of  the 
options (see below) being biased towards diesel vehicles.   

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

  A key underlying reason for limited effectiveness of the Directive is the absence of 
a  definition  of  what  a  “clean  vehicle”  is  and  of  relevant  provisions  for  minimum 
requirements (e.g. limit values in terms of fuel/energy consumption, CO2 and air 
pollutant  emissions)  that  contracting  authorities  should  meet  when  setting  their 
requirements. In their absence, it is very often the case that contracting authorities 
set requirements that can be met by the majority, if not all, vehicles on the market.      

  Another  key  issue  related  to  the  implementation  and  the  effectiveness  of  the 
Directive  is  the  perceived  complexity  of  the  monetisation  methodology  and  the 
much greater preference by public authorities for the use of the other options given 
in  the  Directive.  On  the  one  hand,  the  monetisation  methodology  is  the  most 
effective approach in terms of ensuring the internalisation of the operational costs 
and its more widespread use could ensure a greater level of harmonisation in the 
approach  followed  by  authorities.  On  the  other  hand,  in  its  current  form,  the 
monetisation option is perceived to be complicated and demanding by a large share 
of  authorities.  In  addition,  our  analysis  suggests  that,  in  its  current  form,  it  has 
certain limitations and weaknesses.  

  The  absence  of  any  harmonised  community  standard  for  measuring  fuel 
consumption or CO2 emissions in the case of heavy duty vehicles, the category of 
vehicles where public procurement has the greatest potential, means that is difficult 
for  most  contracting  authorities  to  obtain  objective,  comparable  data  on  these 
vehicles.  As  a  result,  there  are  possible  missed  opportunities  for  contracting 
authorities to select the most appropriate vehicles.  

Efficiency 

  The estimated overall  benefit to cost ratio of the Directive is relatively low. Total 
expected benefits of the policy – reflecting CO2 and pollutant emissions reduction 
and fuel efficiency savings - are estimated to be in the range of €42.6 to €521.1 
million, against total costs of around €34.6 to €431.0 million. The low cost benefit 
ratio is expected as the direct impacts associated with public procurement are very 
limited. In most respects the Directive acts in a complementary way to other policy 
tools  (e.g.  CO2  and  emissions  requirements,  car-labelling  etc.)  and  any  wider 
benefits cannot be quantified.  

  At  the  same  time,  the  administrative  costs  associated  with  the  Directive  are 
relatively limited (less than €2.3 million on an annual basis). Our analysis suggests 
that this is primarily a reflection of the limited use of the monetisation methodology 
and the fact that in most cases the information/data required is readily available.  

 

It is not clear that the impacts of the Directive could have been achieved in a more 
efficient way through additional measures or initiatives, as there was – and indeed 
still is – a rationale for using public procurement to stimulate the market for cleaner 
vehicles.  The  analysis  suggests  that  there  are  certain  aspects  that  need  to  be 
addressed  in  that  respect,  including  the  need  to  simplify  those  aspects  of  the 
Directive  that  are  currently  considered  to  be  complex  and  demanding  by  public 
authorities as mentioned above. 

EU added value 

  Based on the assessment of effectiveness and feedback from various stakeholders, 
it is  likely  that  the  limited  impacts  estimated  to  have  been  achieved  by  the  CVD 
could have been achieved without EU intervention, i.e. the Directive.  

  However, despite the lack of clear benefits, stakeholders have stated a preference 
for  retaining  the  Directive,  although  with  improvements  focussing  on  making  it 
more effective and delivering better results. Stakeholders believed that a repeal of 
the Directive would give out the wrong political message. Secondly they generally 
felt that a mechanism to stimulate the purchase of clean vehicles was still required 
(as barriers to their uptake still exist) and that public procurement is still potentially 

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

useful in this respect. Finally, stakeholders thought that the Directive may become 
more useful and relevant over time as more clean vehicles come onto the market.  

  There  is  some  evidence  to  suggest  that  the  Directive  and  the  accompanying 

initiatives have supported best practice exchange.    

Coherence 

  The Clean Vehicles Directive largely complements other EU policies and legislation 
with similar objectives. The overarching objectives of EU policy and legislation strive 
to increase environmental protection, reduce GHG and air pollutant emissions and 
attain  energy  security.  The  CVD  complements  a  range  of  other  policies  and 
legislation that work together to achieve these objectives, including both supply and 
demand-side measures in the transport sector. 

  The  Directive is broadly coherent  with most  other relevant policies, including the 
Public  Procurement  Directives,  although  there  are  challenges  with  respect  to  air 
quality, and a lack of coherence with the 2011 Transport White Paper’s objective of 
phasing out conventionally-fuelled cars. Contracting authorities face problems when 
they apply the CVD’s monetisation methodology in publicly procuring road transport 
vehicles,  which  results  in  the  selection  of  diesel  vehicles,  whose  use  can  be 
detrimental in achieving local air quality objectives, particularly in relation to NO2.  
Therefore,  provisions  such  as  the  monetisation  methodology,  may  on  certain 
occasions contradict with EU air quality targets, as it does not lead to the purchase 
of the types of vehicles that are most advantageous to reducing pollutant emissions 
in urban areas.  

  The  fact  that  the  Directive  allows  for  multiple  alternative  options  is  not  coherent 

with the objective of harmonising the determination of these impacts. 

Sustainability 

  A full repeal of the Directive would be unlikely to have significant practical impacts 
on  the  market  and  the  current  level  of  demand  for  clean  vehicles.  However,  the 
wider benefits – and the broader message – provided by public procurement would 
be lost.  

  Furthermore, in the case of the heavy duty vehicle (HDV) sector, particularly buses, 
waste collection vehicles and other HDVs primarily used by/in the service of public 
authorities, the potential impact would probably be greater as there is a lack of a 
wider policy framework to reduce the CO2 emissions of these vehicles.  

  A  partial  repeal  –  i.e.  retaining  only  the  monetisation  methodology  in  its  current 
format  –  would  bias  towards  diesel  vehicles,  which  tend  to  be  the  dominant 
technology in the HDV market anyway, and those technologies that (inaccurately) 
have zero emissions, as these are measured on the test cycle.      

Recommendations 

General recommendations 

  The  Directive  should  be  retained:  Despite  the  limited  benefits  of  the  CVD  to 
date,  there  is  supporting  evidence  identified  throughout  this  evaluation  that 
suggests that the Directive should be retained rather than repealed. Firstly, there 
continues  to  be  a  need  to  address  the  stated  objectives  of  the  CVD,  including 
reducing CO2 and air pollutant emissions, and increasing energy  efficiency of the 
transport sector and competitiveness (see Section 6.2.2). It is agreed that public 
procurement is a tool that can be beneficial in helping to achieve these objectives 
(as discussed in Section 6.3.3) - encouraging investment in clean vehicles by public 
authorities should help to increase the market  for  such vehicles and thus help to 
deliver  the  economies  of  scale  that  will lead  to  lower  production  costs  and  lower 
prices. In turn, this should help to stimulate demand more generally. Additionally, 
it was identified that there are currently no alternative (more efficient) measures 

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

that are able to stimulate the market for clean vehicles (see Section 6.8.2), which 
would  further  support  retaining  the  Directive.  Stakeholders  consulted  for  this 
evaluation also stated their preference and reasons for retaining the Directive taking 
action at the EU level, as outlined in the conclusions above. While the repeal of the 
CVD would not prevent environmental considerations being taken into account in 
the course of the public procurement of vehicles, this would no longer be required. 
It is likely that contracting authorities would find it more difficult to set qualitative 
and  environmental  award  criteria  since,  as  due  to  the  broad  nature  of  Directive 
2014/24/EU,  there  will  be  less  guidance  and  reference  to  suitable  values  to  use 
when  performing  calculations.  In  the  absence  of  mandatory  requirements  to 
consider  the  environment,  such  considerations  risk  being  ignored  as  a  result  of 
economic  pressures.  Hence,  there  is  still  a  rationale  for  requiring  the  public 
procurement of vehicles to take account of environmental considerations in order 
to stimulate the market for clean vehicles, as the Directive aims to do. It is therefore 
our assessment that a repeal of the Directive would not be the best action to take, 
but that it should be retained.  

  The Directive needs to be amended: The analysis conducted for this evaluation 
suggests that in its current form the CVD is not particularly cost-effective. However, 
as discussed in the point above, it is still a useful tool for stimulating the market for 
vehicles using cleaner technologies forming part of a broader package of  supply-
side and demand-side policy tools. It is evident that there is scope for improvements 
to be made to the Directive that would increase its effectiveness and efficiency. This 
could  include  changes  to  the  scope  of  the  Directive  but  also  changes  to  its 
mechanisms, including the monetisation options. There is also an evident need to 
improve  the  level  and  quality  of  information  and  data  available  that  will  support 
future monitoring of its effectiveness and efficiency (see Specific Recommendations 
below for further information).   

Specific recommendations 

  There needs to be more clarity as to what can be considered to be a clean 
vehicle: Clarification is required on which types of vehicles might be considered to 
be ‘clean’ and what should be the aims of the Directive in this respect. This could 
require  the  introduction  of  specific  provisions  setting  minimum  requirements  for 
contracting authorities (see also next point).  

  Encourage  higher  levels  of  ambition  with  regards  to  clean  vehicles 
purchased  required  by  the  Directive:  In  order  to  encourage  higher  levels  of 
ambition, the Directive could set higher standards that more ambitious contracting 
authorities  might  meet.  More  specifically,  if  all  of  the  alternative  options  for 
including  energy  and  environmental  considerations  are  retained,  the  following 
elements might be considered to ensure that the Directive delivers environmental 
improvements (also helping to define ‘clean’ vehicles): 

o  Option 1: Explicitly set out the minimum technical specifications to be used, 

e.g.: 

  For pollutant emissions: any future Euro 7/VII standard, if these are 
eventually  introduced,  or  any  relevant  standards  arising  from  the 
light duty real driving emissions (RDE) test that is to be implemented. 
Voluntary emission schemes and standards should also be included 
as  soon  as  they  are  introduced  (with  a  clear  distinction  towards 
existing Euro 6 vehicles). 

  For  CO2  emissions:  For  LDVs,  these  could  be  the  next  target  as 
agreed in the respective Regulations, e.g. 95 gCO2/km for cars and 
147 gCO2/km for LCVs (to be amended as new targets are introduced 
in  the  respective  Regulations);  for  HDVs,  minimum  technical 
specifications could be developed once the EU monitoring mechanism 
for HDV CO2 emissions has been put in place.  

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o  Option 2a: Explicitly state the minimum weighting that has to be applied to 
energy and environmental considerations if these are used as award criteria.  

o  Option 2b: Revise the monetisation methodology to address issues such as 
fuel  prices,  emissions  cost  factors  and  real  world  emissions  and  the  other 
ambiguous elements and better align the emphasis of the methodology with 
the three environmental objectives of the Directive.  

Clearly, the feasibility of any such approach will need to be analysed in more detail, 
and  any  changes  made  would  need  to  ensure  that  they  adequately  promote  the 
procurement of what has been more clearly defined as ‘clean vehicles’.   

  Facilitate  the  use  of  the  monetisation  option  (if  this  is  retained):  While  it 
can/could be considered appropriate to maintain the alternative options, it is also 
important to promote the use of the monetisation option as this is the only option 
that  explicitly  internalises  operational  costs.  This  requires  actions  to  address  the 
(perceived)  complexity  of  the  approach.  Potential  supporting  actions  to  consider 
include:  

o  Ensure that contracting authorities are equipped with a user-friendly tool for 
performing the calculations. The Clean Fleets Lifecycle Costing Tool  (Clean 
Fleets  2014)  is  an  existing  spreadsheet  tool  capable  of  performing  the 
monetisation  calculations,  but  its  effectiveness  might  be  substantially 
increased if it were converted into a web-based tool and then more widely 
publicised (potentially even referenced in the legislation itself).  

o  Use the information that is to be reported under the forthcoming monitoring 
mechanism  for  the  CO2  emissions  of  heavy  duty  vehicles  to  guide  the 
procurement of more fuel efficient heavy duty vehicles.  It is essential that 
objective,  comparable  information  is  available  on  the  CO2  impacts  and 
energy efficiency of these vehicles. 

o  Ensure  that  the  information  on  the  Clean  Vehicle  Portal  fulfils  its  aim  of 
providing comprehensive data on vehicle emissions as a one-stop-shop. As 
the  Portal  is  being  amended  at  the  time  of  writing,  it  is  not  possible  to 
comment on the extent to which this new version meets the needs. However, 
contracting  authorities  should  be  able  to  find  emissions  data  for  different 
vehicles in a comprehensive and accessible way. Maintaining information in 
such  a  centralised  manner  may  not  be  an  easy  or  cheap  task,  but  if  the 
monetisation methodology is to be retained, its effectiveness will be linked 
to  the  ease  with  which  contracting  authorities  can  find  the  appropriate 
information to input into it. 

o  Further  build  on  the  Commission  initiatives  that  have  been  undertaken  to 
date,  particularly  the  Clean  Vehicle  Portal  and the  Clean  Fleets  project,  in 
order  to  facilitate  the  exchange  of  practices  and  experience,  to  promote 
greater understanding of any revised requirements of the Directive, and to 
facilitate cross-border joint procurement.   

  Future  consideration  of  Well-To-Wheels  (WTW)  emissions:  In  order  to  be 
able to compare the full environmental impacts of vehicles, there is a need to take 
account of WTW emissions. This issue is also relevant for other EU legislation, such 
as  the  passenger  car  CO2  Regulation,  the  fuel  efficiency  label  etc.  It  should  be 
considered whether it is possible to introduce an approach, e.g. a WTW factor that 
could  be  applied  in  a  common  way  in  complementary  EU  legislation,  where  it  is 
appropriate.   

  Extend the scope of the Directive: The scope of the Directive could be extended 
by lowering the threshold values. However, the benefit to cost ratio of such a change 
will  need  to  be  examined  in  greater  detail.  The  expansion  of  the  scope  of  the 
Directive to all contracts procured by public authorities that have a major transport 
element,  and  possibly  to  private  fleets,  might  be  considered.  Both  of  these 
approaches have the potential to increase the impacts by increasing the numbers 

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of  vehicles  covered  by  the  Directive,  but  it  would  need  to  be  ensured  that  the 
approach was efficient once the scale of the potential impacts and costs have been 
considered. 

  Resolve the challenges posed by the lack of, or inaccurate data: A lack of 
information  or  a  means  of  discriminating  between  vehicles  on  the  basis  of  their 
energy consumption and emissions is a challenge. All new cars and LCVs, and all 
engines used in HDVs, have to meet the latest Euro emission standards (i.e. 6 and 
VI, respectively), and so unless a city has the resources and technical capacity to 
undertake  its  own  dedicated  tests,  there  is  no  room  for  a  city  to  differentiate 
between vehicles on the basis of their pollutant emissions. For cars and LCVs, test 
cycle  information  on  fuel  consumption  and  CO2  emissions  is  available  for 
conventionally-fuelled  vehicles,  but  this  information  for  alternatively-fuelled 
vehicles is less accurate as there is a greater need to take account of lifecycle and 
embedded emissions in order to accurately determine which type of technology is 
better  in  this  respect.  Also,  for  those  cars  and  LCVs  for  which  CO2  and  fuel 
consumption  data  is  available,  there  is  the  additional  issue  of  the  discrepancy 
between  real  world  and  test  cycle  emissions.  For  HDVs,  information  on  CO2 
emissions and fuel use is often not available in a consistent manner for most cities 
(again, other than those that have the resources and capacity to do their own tests). 
Our understanding is that many of these are issues have already been identified as 
important by the Commission and relevant action is being taken to address them. 
If this proves not to be the case, or is considered to not eventually be possible, it 
will  be  important  to  provide  at  least  more  guidance  to  contracting  authorities  in 
order to ensure that they are aware of how to apply the CVD in such cases.     

  Introduce a voluntary framework to facilitate Member State reporting: One 
of the challenges with understanding the effectiveness – and therefore efficiency – 
of  the  Directive  is  the  lack  of  knowledge  on  its  impacts,  and  indeed  costs.  It  is 
important not to introduce requirements that would incur excessive administrative 
costs  on  Member  States,  hence,  it  would  be  useful  to  introduce  a  framework  for 
Member State reporting in which Member States would be encouraged to report on 
the  impacts  of  the  Directive  in  a  consistent  and  comparable  manner.  This  would 
facilitate future evaluations and inform future amendments to the Directive. 

  Explore  whether  there  is  the  potential  for  a  Commission  initiative  to 
facilitate  cross-border,  joint  procurement:  As  barriers  to  cross-border  joint 
procurement remain, and the costs of vehicles with some clean technologies remain 
high, it would be useful to explore whether there is the potential to use financial 
instruments (i.e. not grants) to help overcome the high initial administrative and 
capital costs associated with the cross-border, joint procurement of clean vehicles. 
In  this  respect,  the  potential  use  of  instruments  developed  by  the  EIB  might  be 
explored. 

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transport vehicles 

RÉSUMÉ ANALYTIQUE 

Objectifs 

Cette  évaluation  a  posteriori  couvre  la  Directive  2009/33/CE  relative  à  la  promotion  de 
véhicules  de  transport  routier  propres  et  économes  en  énergie  (la  «Directive  sur  les 
Véhicules Propres»).  

La Directive a pour objet de dynamiser le marché des véhicules propres et économes en 
énergie en exigeant des divers acheteurs qu’ils tiennent compte des impacts énergétiques 
et environnementaux pendant toute la durée de vie des véhicules lorsqu’ils achètent des 
véhicules de transport routier.   

Directive sur les Véhicules Propres. La Directive sur les Véhicules Propres est incluse dans 
l’Initiative  REFIT  (Programme  pour  une  Réglementation  Affûtée  et  Performante2)  de  la 
Commission Européenne de manière à déterminer si celle-ci a atteint ses objectifs et si elle 
toujours adaptée aux besoins. 

Méthodologie 

La méthodologie a suivi les prescriptions du cadre d’évaluation standard destiné à évaluer 
les lois et les principales questions d’évaluation en matière de pertinence, d’efficacité, de 
valeur ajoutée au niveau de l’UE, de cohérence et de soutenabilité.  

Parmi les principaux outils de recherche employés, on peut citer : 

  La recherche documentaire et l’analyse bibliographique. Les rapports et les études 
se  rapportant  directement  à  la  Directive  2009/33/CE,  les  Directives  et  leur 
évaluation  dans  un  contexte  politique  plus  large,  les  documents  stratégiques 
européens  et  les  travaux  précédemment  effectués  par  l’équipe  de  recherche. 
L’intégralité  des  ouvrages  documentaires  et  bibliographiques  font  l’objet  de 
références tout au long du rapport, ainsi qu’après les Annexes.    

  Un vaste engagement des parties prenantes. Ceci inclut des parties prenantes au 
niveau  de  l’UE  (11  entrevues  et  un  atelier),  des  acheteurs  (13  entrevues,  des 
réponses  écrites  supplémentaires  et  547  réponses  à  une  étude  en  ligne),  des 
fabricants (3 entrevues et des réponses écrites supplémentaires), des prestataires 
(65 réponses à une  étude en ligne), des  états-membres (fiches d’états-membres 
remplies et un atelier).  

  Les  études  de  cas.  Des  exemples  illustrant  l’évaluation  de  la  méthodologie  de  la 
monétisation  des  coûts  à  l’Article  6,  et  des  études  de  cas  qualitatives  s’inspirant 
d’études  de  cas  existantes,  par  exemple  Clean  Fleets,  Clean  Vehicle  Portal,  GPP 
2020,  etc.,  contribuant  à  la  quantification  des  impacts  de  la  Directive  sur  les 
Véhicules Propres.  

Parmi les principaux outils analytiques quantitatifs employés, on peut citer : 

  Une  analyse  comparative  mettant  en  œuvre  un  cadre  de  référence  et  un 
scénario  hypothétique.  Le  cadre  de  référence  a  été  utilisé  pour  quantifier  les 
impacts de l’intervention sur les coûts et d’autres indicateurs-clés générés, parmi 
lesquels les émissions de CO2, les émissions de polluants aériens et la rentabilité.   

Les  études  quantitatives  décrites  ci-dessus  ont  été  complétées  par  des  analyses 
qualitatives  réalisées  sur  la  base  de  la  recherche  documentaire,  de  la  participation  des 
parties prenantes et de la collecte de données.   

2   Initiative REFIT de la CE – Il s’agit d’une action entreprise pour simplifier les lois de l’UE et pour réduire les 
coûts associés à la réglementation, contribuant ainsi à la création d’un cadre réglementaire clair, stable et 
prévisible  soutenant  la  croissance  et  l’emploi  (Commission  Européenne  -  2013).  “Cadre  Réglementaire 
l'adresse  : 
(Regulatory  Fitness  :  REFIT)  de 
http://ec.europa.eu/smart-regulation/better_regulation/key_docs_en.htm. 

l'UE  --  Documents  directeurs”  accessibles  à 

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Les principales limites de la recherche résultaient d’un manque de disponibilité des données 
et du peu de temps écoulé depuis l’entrée en vigueur de la Directive, ce qui a donc affecté 
sa capacité à avoir un impact. 

Le manque d’évidence actuelle concernant l’implémentation de la Directive et les impacts 
qu’on peut en attendre est due aux raisons suivantes :   

 

Il n’y a aucun mécanisme de contrôle en place au niveau de l’UE autre que via la 
production de rapports de consultants 

 

Il n’existe aucune obligation de rapport mise en place au niveau des états-membres 

  Très peu d’états-membres ont entrepris de contrôler ou d’évaluer les impacts par 
eux-mêmes  dans  ce  domaine,  de  sorte  qu’il  y  a  un  manque  d’informations 
concernant l’implémentation dans les états-membres  

 

Il y a actuellement peu d’opinions publiées ou d’exposés de principe rendus publics 
par les parties prenantes.  

Parmi les obstacles limitant la portée des effets obtenus par la Directive, on peut citer le 
nombre restreint des véhicules achetés par les organismes publics (par rapport au reste 
du parc automobile), la durée de vie des véhicules de transport routier (habituellement de 
10  à  15  ans)  et  la  proportion  de  véhicules  de  transport  routier  achetés  se  situant  en-
dessous  de  la  valeur-seuil  de  la  Directive  sur  les  Véhicules  Propres  (autrement  dit,  en-
dehors du périmètre d’application de cette Directive, ce qui réduit d’autant le nombre de 
véhicules potentiellement affectés).  

Principaux résultats et conclusions 

Pertinence 

  Les besoins que la Directive cible, à savoir la nécessité de réduire les émissions de 
CO2 et de polluants des transports et d’augmenter leur rendement énergétique et 
leur  compétitivité,  sont  pertinents  et  ils  resteront  probablement  pertinents  à 
l’avenir.  

  Dans l’ensemble, le fait de cibler les véhicules achetés par les organismes publics 
est considéré comme un outil adapté pour augmenter le rendement énergétique et 
réduire les émissions de CO2 et de polluants des transports routiers. Bien que le fait 
d’encourager les organismes publics à acheter des véhicules propres ne suffira pas 
à lui seul à atteindre ces objectifs, cette initiative est toutefois bénéfique. Et bien 
que les véhicules achetés par les organismes publics ne représentent qu’une petite 
part du marché des véhicules dans son ensemble, il est justifié d’utiliser la passation 
de marchés publics pour dynamiser le marché des véhicules propres dans le cadre 
d’une approche plus vaste pour atteindre les objectifs déclarés.  

  En outre, dans le cas de certaines catégories spécifiques de véhicules (comme les 
autobus), le potentiel de dynamisation du marché des véhicules propres est encore 
plus grand.  

  On peut soutenir (et il existe des éléments théoriques probants dans ce sens) que 
«l’encouragement des achats de véhicules propres par les organismes publics» a le 
potentiel de contribuer à augmenter la compétitivité de l’économie de l’UE dans son 
ensemble  et  plus  particulièrement  celle  des  villes,  bien  que  cela  soit  difficile  à 
prouver en pratique.    

  Toutefois, outre la petite part de marché des véhicules achetés par les organismes 
publics, l’importance de la contribution de la Directive à augmenter le rendement 
énergétique  et  à  réduire  les  émissions  de  CO2  et  de  polluants  provenant  des 
transports routiers dépend par ailleurs de la justesse du ciblage, qui doit viser le 
«bon  type»  de  véhicule  propre.  C’est  là  un  aspect  qui  n’est  actuellement  pas 
clairement  défini  par  la  Directive  et  au  sujet  duquel  les  divers  pouvoirs 
adjudicateurs suivent des approches très différentes.  

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Efficacité 

  Notre estimation des impacts de la Directive sur les Véhicules Propres, sur la base 
de l’évidence disponible et d’un ensemble d’hypothèses importantes, suggère que 
ceux-ci sont plus limités qu’initialement prévu. En outre, les impacts estimés d’une 
réduction allant jusqu’à 5,5% des émissions de CO2 pour les voitures particulières 
et  jusqu’à  2,3%  pour  les  véhicules  utilitaires  légers  en  comparaison  du  cadre  de 
référence,  représentent  le  meilleur  des  cas;  lequel  ne  tient  probablement  pas 
complètement  compte  des  impacts  des  autres  politiques  pertinentes  mises  en 
œuvre (comme la Réglementation sur le CO2 pour les voitures particulières). Notre 
analyse conduit à penser que les impacts directement associés à la Directive sont 
plutôt  limités,  bien  qu’il  n’ait  pas  été  possible  d’obtenir  des  estimations  plus 
précises. 

  De  plus,  l’analyse  suggère  qu’en  termes  d’émissions  de  polluants  aériens,  la 
contribution pourrait même s’avérer négative en raison de la tendance de certaines 
des options (voir ci-dessous) à privilégier les véhicules à moteur diesel.   

  L’une des principales raisons sous-jacentes de l’efficacité limitée de la Directive tient 
à l’absence de définition de ce qui constitue un «véhicule propre», et de dispositions 
appropriées  concernant  les  exigences  minimales  (ex.  valeurs-limites  en  ce  qui 
concerne la consommation de carburant ou d’énergie et les émissions de CO2 et de 
polluants  aériens)  que  les  pouvoirs  adjudicateurs  doivent  respecter  lorsqu’ils 
définissent  leurs  critères.  En  l’absence  de  telles  exigences,  il  est  courant  que  les 
pouvoirs  adjudicateurs  définissent  des  critères  qui  peuvent  être  remplis  par  la 
majorité, si ce n’est l’intégralité des véhicules disponibles sur le marché.      

  Un  autre  problème  important  concernant  l’implémentation  et  l’efficacité  de  la 
Directive résulte de l’apparente complexité de la méthodologie de monétisation, et 
de la plus grande préférence manifestée par les organismes publics pour l’utilisation 
des  autres  options  exprimées  dans  la  Directive.  D’une  part,  la  méthodologie  de 
monétisation constitue l’approche la plus efficace en ce qui concerne l’internalisation 
des  coûts  opérationnels  et  son  utilisation  plus  répandue  pourrait  entraîner  une 
meilleure harmonisation des approches mises en œuvre par les divers organismes 
concernés ; d’autre part, sous sa forme actuelle, l’option de monétisation semble 
être perçue comme étant trop compliquée et trop exigeante par une grande partie 
desdits  organismes.  En  outre,  notre  analyse  semble  indiquer  que,  sous  sa  forme 
actuelle, elle comporte certaines limitations et certaines faiblesses.  

  L’absence d’une norme communautaire harmonisée pour mesurer la consommation 
de carburant ou les émissions de CO2 dans le cas des véhicules utilitaires lourds, 
qui est la catégorie de véhicules dans laquelle les achats par les organismes publics 
présentent le plus grand potentiel, fait qu’il est difficile pour la plupart des pouvoirs 
adjudicateurs d’obtenir des données objectives et comparables sur ces véhicules. 
En  conséquence,  il  est  possible  que  les  pouvoirs  adjudicateurs  parfois  manquent 
une occasion de sélectionner les véhicules les plus appropriés.  

Rendement 

  Le rapport bénéfice-coût général estimé de la Directive est relativement faible. Le 
bénéfice total prévu de la politique, reflétant la réduction des émissions de CO2 et 
les économies obtenues grâce à un meilleur rendement énergétique, est estimé se 
situer dans la plage de 42,6 à 521,1 millions d’euros, pour un coût total d’environ 
34,6 à 431,0 millions d’euros. Ce faible rapport bénéfice-coût était attendu, car les 
impacts directs associés aux achats par des organismes publics sont très limités. À 
maints égards, la Directive agit en complément d’autres instruments politiques (ex. 
exigences  d’émissions  de  CO2,  étiquetage  des  voitures,  etc.)  et  les  bénéfices 
d’ensemble sont difficiles à quantifier.  

  Dans  le  même  temps,  les  coûts  administratifs  associés  à  la  Directive  sont 
relativement limités (moins de 2,3 millions d’euros sur une base annuelle). Notre 
analyse suggère que ceci est principalement dû à l’usage limité de la méthodologie 

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de  monétisation  et  au  fait  que,  dans  la  plupart  des  cas,  les  informations  et  les 
données nécessaires sont facilement accessibles.  

 

Il est difficile de dire si les impacts de la Directive auraient pu être obtenus d’une 
manière plus efficace par le biais d’autres mesures ou initiatives, car il y avait, et il 
y  a  toujours,  un  argument  en  faveur  de  l’usage  des  règles  d’achat  par  les 
organismes  publics  pour  stimuler  le  marché  des  véhicules  propres.  L’analyse 
suggère  qu’il  y  a  certains  aspects  qui  doivent  être  adressés  à  cet  égard,  parmi 
lesquels la nécessité de simplifier les aspects de la Directive qui sont actuellement 
considérés comme étant trop complexes et trop exigeants par les pouvoirs publics, 
comme cela est mentionné plus haut. 

Valeur ajoutée au niveau de l’UE 

  En se basant sur l’évaluation de l’efficacité et sur les réactions des diverses parties 
prenantes, on peut estimer probable que les impacts limités que l’on estime avoir 
été obtenus par la Directive sur les Véhicules Propres auraient tout aussi bien pu 
avoir été obtenus sans intervention de l’UE, c’est-à-dire sans la Directive.  

  Toutefois, en dépit du manque de bénéfices clairement établis, les parties prenantes 
ont manifesté une préférence pour la conservation de la Directive, à condition que 
des améliorations lui soient apportées pour la rendre plus efficace et pour qu’elle 
apporte  de  meilleurs  résultats.  Les  parties  prenantes  estiment  qu’une  abrogation 
de  la  Directive  enverrait  un  mauvais  message  politique.  De  plus,  elles  sont 
généralement  d’avis  qu’un  mécanisme  permettant  de  stimuler  les  achats  de 
véhicules  propres  est  toujours  nécessaire  (car  des  obstacles  à  leur  adoption 
subsistent  toujours)  et  que  les  achats  par  les  organismes  publics  sont 
potentiellement  un  bon  moyen  à  cet  égard.  Finalement,  les  parties  prenantes 
pensent  que  la  Directive  peut  se  révéler  plus  utile  et  plus  pertinente  sur  le  long 
terme, alors qu’un plus grand nombre de véhicules propres arrivent sur le marché.  

  Certaines  évidences  semblent  suggérer  que  la  Directive  et  les  initiatives  qui 

l’accompagnent ont permis l’échange de bonnes pratiques.    

Cohérence 

  La Directive sur les Véhicules Propres complète dans une grande mesure les autres 
politiques et législations de l’UE ayant des objectifs similaires. Les objectifs ultimes 
des  politiques  et  des  législations  de  l’UE  sont  d’accroître  la  protection  de 
l’environnement, de  réduire les émissions de gaz à effet de serre  et de polluants 
aériens, ainsi que d’atteindre une bonne sécurité énergétique. La Directive sur les 
Véhicules Propres s’inscrit en complément de toute une série d’autres politiques et 
législations qui se combinent pour atteindre ces objectifs, en incluant des mesures 
favorisant tant l’offre que la demande dans le secteur des transports. 

  Dans son ensemble, la Directive est largement cohérente avec la plupart des autres 
politiques  apparentées,  y  compris  les  Directives  concernant  la  Passation  des 
Marchés  Publics,  bien  que  certaines  difficultés  subsistent  en  ce  qui  concerne  la 
qualité de l’air et le manque de cohérence dans les objectifs déclarés du Livre Blanc 
sur  les  Transports  de  2011  qui  vise  à  éliminer  progressivement  les  véhicules 
utilisant des carburants conventionnels. Les pouvoirs adjudicateurs sont confrontés 
à  des  problèmes  lorsqu’ils  appliquent  la  méthodologie  de  monétisation  de  la 
Directive  sur  les  Véhicules  Propres  aux  achats  de  véhicules  de  transport  routier 
effectués  par  les  organismes  publics,  car  cela  peut  entraîner  la  sélection  de 
véhicules à moteur diesel dont l’utilisation peut être préjudiciable à la poursuite des 
objectifs  de  qualité  de  l’air,  en  particulier  en  ce  qui  concerne  le  NO2.  En 
conséquence,  les  dispositions  comme  la  méthodologie  de  monétisation  peuvent, 
dans  certains  cas,  contrevenir  aux  objectifs  de  qualité  de  l’air,  car  elles  ne 
conduisent  pas  à  l’achat  des  types  de  véhicules  qui  sont  les  plus  efficaces  pour 
réduire les émissions de polluants dans les zones urbaines.  

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  Le fait que la Directive permette le choix de nombreuses autres options n’est pas 

conforme à l’objectif d’harmonisation de la détermination de ces impacts. 

Soutenabilité 

  Une abrogation totale de la Directive n’aurait probablement aucun impact significatif 
sur  le  marché  et  sur  la  demande  actuelle  en  véhicules  propres.  Toutefois,  les 
avantages plus généraux et le message à l’échelle de la société que représente la 
passation des marchés publics seraient perdus.  

  En outre, dans le cas du secteur des véhicules utilitaires lourds, en particulier les 
autobus,  les  véhicules  de  ramassage  des  ordures  et  les  autres  véhicules  lourds 
principalement utilisés par ou dans le cadre des services assurés par les pouvoirs 
publics, l’impact potentiel serait probablement plus important en raison du manque 
d’un cadre  réglementaire plus large visant à réduire les émissions de  CO2 de ces 
véhicules.  

  Une abrogation partielle, c’est-à-dire la seule conservation de la méthodologie de 
monétisation sous sa forme actuelle, privilégierait les véhicules à moteur diesel qui 
de  toute  façon  représentent  déjà  la  technologie  dominante  sur  le  marché  des 
véhicules  utilitaires  lourds,  ou  les  technologies  qui  indiquent  (faussement)  des 
émissions nulles lorsqu’elles sont mesurées au cours des cycles de tests.      

Recommandations 

Recommandations Générales 

  La Directive doit être conservée : En dépit des bénéfices limités apportés à ce 
jour par la Directive sur les Véhicules Propres, certains éléments probants ont pu 
être  identifiés  au  cours  de  cette  évaluation  qui  conduisent  à  penser  que  cette 
Directive doit être conservée au lieu d’être abrogée. D’abord, il est nécessaire de 
continuer  à  s’efforcer  d’atteindre  les  objectifs  déclarés  de  la  Directive  sur  les 
Véhicules  Propres,  à  savoir  la  réduction  des  émissions  de  CO2  et  de  polluants 
aériens, ainsi que l’augmentation du rendement énergétique et de la compétitivité 
dans le secteur des transports (voir la Section 6.2.2). Il est évident que la passation 
des marchés publics constitue un instrument qui peut s’avérer bénéfique dans la 
poursuite  de  ces  objectifs  (comme  cela  a  été  établi  à  la  Section  6.3.3); 
l’encouragement des investissements dans les  véhicules propres par les pouvoirs 
publics devraient contribuer à élargir le marché de ces véhicules et ainsi créer des 
économies d’échelle qui conduiront à des coûts de production et des prix moindres. 
Ceci devrait, à son tour, stimuler la demande de manière plus générale. En outre, 
il a été établi qu’il n’existe actuellement pas d’autres mesures (plus efficaces) pour 
stimuler  le  marché  des  véhicules  propres  (voir  la  Section  6.8.2),  ce  qui  incite 
d’autant plus à conserver la Directive. Les parties prenantes consultées lors de la 
présente  évaluation  ont  également  déclaré  leur  préférence  et  leurs  raisons  pour 
conserver cette Directive, qui les ont conduit à agir en ce sens au niveau de l’UE, 
comme  cela  a  été  décrit  dans  les  conclusions  présentées  ci-dessus.  Bien  que 
l’abrogation de la Directive sur les Véhicules Propres n’empêcherait en aucun cas 
la prise en compte des considérations environnementales lors de la passation des 
marchés  publics  pour  l’achat  de  véhicules,  celle-ci  ne  serait  plus  obligatoire.  Il 
est probable que les pouvoirs adjudicateurs éprouveraient alors plus de difficultés 
à établir des critères qualitatifs et environnementaux pour l’attribution des marchés, 
car, la Directive 2014/24/UE étant par nature trop générale, cela réduirait le niveau 
de  conseils  et  valeurs  de  référence  disponibles  pour  les  calculs.  En  l’absence  de 
toute obligation impérative de tenir compte de l’environnement, il existe un risque 
que  ces  considérations  soient  ignorées  en  raison  des  pressions  économiques.  Il 
subsiste donc un argument justifiant que la passation des marchés publics tienne 
obligatoirement  compte  des  critères  environnementaux  de  manière  à  stimuler  le 
marché  des  véhicules  propres,  ce  qui  est  l’objectif  déclaré  de  la  Directive.  Notre 
conclusion est donc que l’abrogation de la Directive ne serait pas la meilleure action 
à entreprendre, mais qu’au contraire, celle-ci doit être conservée.  

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  La Directive doit être modifiée: L’analyse réalisée dans le cadre de l’évaluation 
conduit à penser que la Directive sur les Véhicules Propres sous sa forme actuelle 
n’est  pas  particulièrement  rentable.  Toutefois,  comme  cela  a  été  dit  dans  le 
paragraphe ci-dessus, elle constitue quand même un instrument utile pour stimuler 
le marché des véhicules utilisant des technologies plus propres dans le cadre d’un 
ensemble  plus  vaste  d’instruments  politiques  s’adressant  tant  à  l’offre  qu’à  la 
demande.  Il  est  évident  qu’il  y  a  encore  de  gros  progrès  à  faire  pour  augmenter 
l’efficacité  et  le  rendement  de  cette  Directive.  Pour  cela,  il  faudrait  apporter  des 
changements  non  seulement  à  son  périmètre  d’application  mais  aussi  à  ses 
mécanismes, parmi lesquels les options de monétisation. On peut également noter 
un besoin évident d’améliorer le niveau et la qualité des informations et des données 
disponibles qui permettront à l’avenir de contrôler son efficacité et son rendement 
(voir  ci-dessous  les  Recommandations  Spécifiques  pour  des  informations  plus 
détaillées).   

Recommandations Spécifiques 

  Il est nécessaire de définir plus clairement ce que l’on appelle un «véhicule 
propre»  :  Les  types  de  véhicules  considérés  comme  étant  «propres»,  et  les 
objectifs  de  la  Directive  à  cet  égard,  doivent  être  clarifiés.  Il  pourrait  s’avérer 
nécessaire  d’introduire  des  dispositions  spécifiques  imposant  des  exigences 
minimales aux pouvoirs adjudicateurs (voir également le paragraphe suivant).  

  Il serait utile d’encourager l’inclusion dans la Directive de niveaux d’intérêt 
plus ambitieux pour l’achat de véhicules propres : De manière à encourager 
des niveaux d’intérêt plus ambitieux, la Directive pourrait définir des normes plus 
exigeantes que les pouvoirs adjudicateurs les plus ambitieux pourraient appliquer. 
Plus  spécifiquement,  si  toutes  les  autres  options  incluant  des  considérations 
énergétiques  et  environnementales  sont  conservées,  les  éléments  suivants 
pourraient  être  considéré  pour  garantir  que  la  Directive  apporte  réellement  des 
améliorations  environnementales  (cela  contribuerait  également  à  définir  ce  que 
sont les véhicules «propres») : 

o  Option  1  :  Définir  explicitement  les  spécifications  techniques  minimales  à 

utiliser, par exemple : 

  Dans  le  cas  des  émissions  de  polluants  :  Toute  future  norme 
Euro7/VII, si celle-ci est finalement introduite, ou toute autre norme 
pertinente  découlant  des  tests  RDE  (émissions  dans  des  conditions 
de  circulation  réelle)  pour  véhicules  légers  qui  doivent  être 
implémentés. Des programmes et des normes volontaires concernant 
les émissions devraient également être inclus au fur et à mesure de 
leur  introduction  (en  effectuant  une  distinction  claire  avec  les 
véhicules Euro 6 existants). 

  Dans  le  cas  des  émissions  de  CO2  :  Les  véhicules  légers  devraient 
constituer  la  prochaine  cible,  comme  cela  a  été  convenu  dans  les 
Réglementations  respectives,  ex.  95  gCO2/km  pour  les  voitures  et 
147  gCO2/km  pour  les  véhicules  utilitaires  légers  (ces  valeurs 
devraient  être  modifiées  lorsque  de  nouveaux  objectifs  seront 
introduits dans les Réglementations respectives) ; pour les véhicules 
utilitaires lourds, des  spécifications techniques minimales devraient 
être développées après que le mécanisme de contrôle des émissions 
de CO2 des véhicules utilitaires lourds de l’UE a été mis en place.  

o  Option  2a  :  Définir  explicitement  la  pondération  minimale  qui  doit  être 
appliquée  aux  facteurs  environnementaux  et  énergétiques  si  ceux-ci  sont 
utilisés comme critères d’attribution.  

o  Option  2b  :  Réviser  la  méthodologie  de  monétisation  pour  traiter  les 
problèmes comme le prix des carburants, les facteurs de coût des émissions 
et les émissions dans des conditions de circulation réelle, ainsi que tous les 

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autres éléments ambigus, et mieux aligner l’accent de la méthodologie sur 
les trois objectifs environnementaux de la Directive.  

À l’évidence, la faisabilité d’une telle approche devra être analysée plus en détail, 
et tout  changement introduit devra prouver qu’il promeut de manière appropriée 
l’achat  de  ce  qui  aura  été  plus  clairement  défini  comme  étant  des  «véhicules 
propres».   

  Il  faut  faciliter  l’usage  de  l’option  de  monétisation  (si  celle-ci  est 
conservée) : Bien qu’il soit possible d’envisager le maintien des autres options, il 
est  également  important  de  promouvoir  l’usage  de  l’option  de  monétisation,  car 
c’est la seule option qui internalise explicitement les coûts opérationnels. Pour cela, 
il faudra que des actions soient entreprises pour simplifier la complexité (perçue) 
de cette approche. Parmi les actions potentielles en ce sens, on peut citer ce qui 
suit :  

o  Veiller à ce que les pouvoirs adjudicateurs  soient équipés d’un instrument 
convivial pour effectuer les calculs. L’instrument de calcul des coûts du cycle 
de vie d’un parc automobile propre (Clean Fleets Lifecycle Costing Tool ou 
«Clean Fleets 2014») existe déjà et est capable d’effectuer les calculs de la 
monétisation, mais son efficacité pourrait être fortement améliorée si il était 
disponible  sur  le  web  afin  que  sa  divulgation  se  fasse  à  une  plus  grande 
échelle (idéalement, il serai même mentionné dans la législation proprement 
dite).  

o  Utiliser  les  informations  sur  les  émissions  de  CO2  des  véhicules  utilitaires 
lourds  qui  seront  rapportées  par  le  biais  du  mécanisme  de  contrôle 
prochainement  disponible  afin  de  recommander  l’achat  de  véhicules 
utilitaires  lourds  dont  la  consommation  en  carburant  offre  un  meilleur 
rendement. Il est essentiel que des informations objectives et comparables 
concernant  les  émissions  de  CO2  et  le  rendement  énergétique  de  ces 
véhicules soient disponibles. 

o  Veiller à ce que les informations du Portail sur les Véhicules Propres soient 
utilisées pour satisfaire l’intégralité des besoins de données sur les émissions 
des véhicules en offrant un «guichet unique» à cette fin. Étant donné que le 
Portail est en cours de modification au moment même de la rédaction de la 
présente  évaluation, 
il  ne  nous  est  pas  possible  d’effectuer  des 
commentaires  sur  la  mesure  par  laquelle  cette  nouvelle  version  répondra 
aux  besoins.  Toutefois,  les  pouvoirs  adjudicateurs  ont  besoin  d’accéder 
facilement à des données exhaustives sur les émissions des divers véhicules. 
La gestion des informations d’une manière aussi centralisée ne sera pas une 
tâche facile ni bon marché, mais si la méthodologie de monétisation doit être 
conservée, son  efficacité dépendra de la facilité avec laquelle les pouvoirs 
adjudicateurs  pourront  accéder  aux  informations  appropriées  pour  les  y 
intégrer. 

o  Une  meilleure  coordination  avec  les  autres  initiatives  de  la  Commission 
entreprises à ce jour, en particulier le Portail sur les Véhicules Propres et le 
Projet «Clean Fleets», pour faciliter l’échange de pratiques et d’expériences,  
promouvoir une meilleure compréhension des modifications de la Directive 
et faciliter la passation commune de marchés publics transfrontaliers.   

  Une future prise en compte des émissions WTW (Well-To-Wheel: « Du puits 
à  la  roue»)  :  De  manière  à  pouvoir  comparer  l’ensemble  des  impacts 
environnementaux  des  véhicules,  il  est  nécessaire  de  prendre  en  compte  les 
émissions WTW. Ce problème est également pertinent pour les autres législations 
de  l’UE,  comme  la  Réglementation  applicable  aux  émissions  de  CO2  des  voitures 
particulières,  l’étiquetage  du  rendement  énergétique,  etc.  Il  est  nécessaire 
d’envisager la possibilité d’introduire une approche, comme par exemple le facteur 
WTW, qui pourrait être appliquée communément dans la législation complémentaire 
de l’UE, lorsque cela est approprié.   

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  Élargir le périmètre d’application de la Directive : Le périmètre d’application 
de  la  Directive  pourrait  être  élargi  en  abaissant  les  valeurs-seuils.  Toutefois,  le 
rapport  bénéfice-coût  d’un  tel  changement  devra  être  examiné  plus  en  détail. 
L’élargissement du périmètre d’application de la Directive à toutes les passations 
de  marchés  publics  ayant  une  composante  importante  dans  le  secteur  des 
transports et, si possible, aux parcs automobiles privés, pourrait être envisagé. Ces 
deux  approches  présentent  le  potentiel  d’augmenter  le  nombre  des  véhicules 
couverts  par  la  Directive,  mais  il  faudra  s’assurer  que  l’approche  choisie  offre  le 
niveau d’efficience requis après que l’échelle des impacts potentiels et des coûts a 
été étudiée. 

  Surmonter  les  problèmes  posés  par  le  manque  ou  l’inexactitude  des 
données : Un manque d’informations ou l’impossibilité de différencier les véhicules 
sur la base de leur consommation énergétique et de leurs émissions constitue un 
vrai défi. Toutes les voitures et tous les véhicules utilitaires légers, ainsi que tous 
les  moteurs  utilisés  dans  les  véhicules  utilitaires  lourds,  doivent  respecter  les 
normes d’émissions Euro les plus récentes (à savoir, 6 et VI, respectivement) et, à 
moins  que  les  villes  ne  disposent  des  ressources  et  des  moyens  techniques  pour 
entreprendre leurs propres tests dédiés, il ne leur est pas possible de différencier 
entre  les  véhicules  sur  la  base  de  leurs  émissions  de  polluants.  Dans  le  cas  des 
voitures et des véhicules utilitaires légers, des informations sur les cycles de tests 
portant  sur  la  consommation  en  carburant  et  sur  les  émissions  en  CO2  sont 
disponibles  pour  les  véhicules  motorisés  de  manière  conventionnelle,  mais  ces 
informations pour les véhicules motorisés d’une autre manière sont moins précises, 
car il est nécessaire de prendre mieux en compte les émissions intégrées et celles 
du  cycle  de  vie  pour  déterminer  avec  précision  quel  type  de  technologie  est  le 
meilleur à cet égard. Par ailleurs, dans le cas des voitures et des véhicules utilitaires 
légers pour lesquels les données de consommation en carburant et d’émissions de 
CO2 sont disponibles, il y a le problème supplémentaire de la divergence entre les 
émissions mesurées dans des conditions de circulation réelle et celles mesurées lors 
des  cycles  de  tests.  Dans  le  cas  des  véhicules  utilitaires  lourds,  les  données  de 
consommation en carburant et d’émissions de CO2 ne sont souvent disponibles que 
de manière hétérogène pour la plupart des villes (là encore, les villes autres que 
celles  ayant  les  ressources  et  les  moyens  techniques  d’effectuer  leurs  propres 
tests).  Nous  pensons  savoir  qu’un  grand  nombre  de  ces  problèmes  ont  déjà  été 
identifiés comme importants par la Commission et que des actions appropriées sont 
actuellement entreprises pour les résoudre. S’il s’avérait que ce n’est pas le cas, ou 
s’il est finalement déterminé que ces actions ne sont pas possibles, il sera important 
d’émettre  des  recommandations  plus  détaillées  à  l’intention  des  pouvoirs 
adjudicateurs afin qu’ils sachent comment appliquer la Directive sur les Véhicules 
Propres dans de tels cas.     

  Introduire un cadre de référence volontaire pour faciliter la production de 
rapports par les états-membres : L’un des défis associés à la compréhension de 
l’efficacité, et donc du rendement de la Directive, est le manque de connaissance 
de ses impacts et, surtout, de ses coûts. Il est important de ne pas introduire des 
exigences  qui  entraîneraient  des  coûts  administratifs  excessifs  pour  les  états-
membres; en conséquence, il pourrait être utile d’introduire un cadre de référence 
pour  la  production  de  rapports  par  les  états-membres  qui  les  encouragerait  à 
communiquer  les  impacts  de  la  Directive  d’une  manière  qui  soit  constante  et 
comparable.  Ceci  faciliterait  les  évaluations  futures  et  apporterait  les  arguments 
nécessaires pour justifier d’éventuels changements à la Directive. 

  Explorer  le  potentiel  d’une  initiative  de  la  Commission  pour  faciliter  la 
passation  commune  de  marchés  transfrontaliers  :  Alors  qu’il  subsiste  des 
obstacles à la passation commune de marchés transfrontaliers et que les coûts des 
véhicules intégrant certaines des technologies propres restent élevés, il serait utile 
d’explorer  la  possibilité  d’utiliser  des  instruments  financiers  (et  non  pas  des 
subventions)  pour  contribuer  à  surmonter  les  coûts  administratifs  et  en  capitaux 
initialement  élevés  dans  le  cas  de  la  passation  commune  de  marchés 

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transfrontaliers  portant  sur  les  véhicules  propres.  À  cet  égard,  l’utilisation 
potentielle d’instruments développés par la BEI pourrait être explorée. 

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transport vehicles 

1.  INTRODUCTION 

1.1.  Purpose of the evaluation 

This evaluation has been commissioned by DG MOVE and focusses on Directive 2009/33/EC 
on the promotion of clean and energy efficient road transport vehicles (the “Clean Vehicles 
Directive”) (European Commission 2009).  

Article  10  of  the  Clean  Vehicles  Directive  (CVD)  requires  that  the  Commission  prepares 
monitoring reports every two years. The reports are required to evaluate the effects of the 
Directive and the options provided for in the Directive3 (including methodology of option 
2b  as  set  out  in  Article  5(3)  –  see  Section  2.1).  The  first  (and  most  recent)  monitoring 
report  was  prepared  in  2012  (Ricardo-AEA  and  TEPR  2012).  The  future  handling  of  the 
Clean  Vehicles  Directive  has  been  considered  in  the  context  of  the  2013  REFIT  exercise 
(the  EC’s  Regulatory  Fitness  and  Performance  programme4),  so  it  has  therefore  been 
decided to evaluate the Directive as a whole.  

This  report  therefore  provides  the  Commission  with  an  ex-post  evaluation  of  the  Clean 
Vehicles Directive, building upon conclusions from previous assessments, including the first 
monitoring report of the Directive (Ricardo-AEA and TEPR 2012).  

1.2.  Scope of the evaluation 

The transposition deadline of the  Clean Vehicles Directive was 4th December 2010, from 
which  point  Member  States  were  required  to  bring  into  force  the  laws,  regulations  and 
administrative  provisions  necessary  for  compliance.  Hence  the  evaluation  will  cover  the 
period from 2010 to present (2015).  

Geographically the focus of the evaluation is on the implementation of the Directive in the 
EU28 Member States.  

1.3.  Structure of this report 

The report is structured as follows: 

  Background to the initiative (Section 2); 

  Evaluation questions (Section 3); 

  Method/process used (Section 4); 

 

Implementation/state of play (results) (Section 5); 

  Answers to the evaluation questions (Section 6); 

  Conclusions (Section 7); 

  Recommendations (Section 8); and  

  Annexes. 

3   Options  presented  in  Article  5(3)  include  Option  1:  Setting  technical  specifications  for  energy  and 
environmental  performance;  Option  2a:  Including  energy  and  environmental  impacts  in  the  purchasing 
decision using award criteria; and Option 2b: Including energy and environmental impacts in the purchasing 
decision by monetising the impacts.  

4   EC’s REFIT  –  action  taken  to make  EU  law simpler  and  to reduce regulatory  costs,  thus  contributing  to  a 
clear,  stable  and  predictable  regulatory  framework  supporting  growth  and  jobs  European  Commission. 
from  http://ec.europa.eu/smart-
(2013).  "EU  Regulatory  Fitness  (REFIT)  --  Key  Documents." 
regulation/better_regulation/key_docs_en.htm. 

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

2.  BACKGROUND TO THE INITIATIVE 

2.1.  Description of the initiative  

The Clean Vehicles Directive (European Union 2009) aims to stimulate the market for clean 
and energy-efficient vehicles by requiring various public bodies to take account of lifetime 
environmental and energy impacts when purchasing road transport vehicles.   

These  requirements  oblige  contracting  authorities,  contracting  entities  and  transport 
operators charged with public service obligations (Article 5(1)) to take into account at least 
energy consumption and lifetime emissions of carbon dioxide (CO2), nitrogen oxides (NOX), 
non-methane hydrocarbons (NMHCs), particulate matter (PM) and energy consumption in 
purchases  of  road  transport  vehicles  (Article  5(2)).    To  this  end,  the  focus  of  the  Clean 
Vehicles  Directive  was  to  internalise  the  operational  lifetime  environmental  and  energy 
costs in the purchase decision of procurers.   

Article 5(3) of the Directive sets out the means by which paragraphs 1 and 2 of Article 5 
can be fulfilled: 

“(a) by setting technical specifications for energy and environmental performance 
in  the  documentation  for  the  purchase  of  road  transport  vehicles  on  each  of  the 
impacts considered, as well as any additional environmental impacts; or 

(b)  by  including  energy  and  environmental  impacts  in  the  purchasing  decision, 
whereby:  

- In cases where a procurement procedure is applied, this shall be done by using 
these impacts as award criteria, and  

-  In  cases  where  these  impacts  are  monetised  for  inclusion  in  the  purchasing 
decision, the methodology set out in Article 6 shall be used. ” 

Related to the last point, Article 6 of the Directive sets out the methodology by which the 
operational lifetime costs can be calculated when monetising the impacts.  

Article 10 of the Directive requires that the Commission prepares a report every two years 
on the actions taken by individual Member States to promote the purchase of clean and 
energy-efficient road transport vehicles. The reports should also assess the effects of the 
Directive,  especially  of  the  options  referred  to  in  Article  5(3),  and  the  need  for  further 
action, and include proposals as appropriate.  

The Clean Vehicles Directive (CVD) is one of several pieces of EU legislation that contribute 
to achieving similar objectives.  In the field of road transport, it works in parallel with EU 
Regulations on CO2 emissions for cars5 (European Commission 2009) and vans6 (European 
Commission  2011),  standards  on  tailpipe  emissions  of  air  pollutants7  (European 
Commission 2007), fuel quality requirements8 (European Commission 2009), a target on 
the  share  of  renewable  energy  sources9  (European  Commission  2009),  infrastructure 
development  for  alternative  fuels  and  energy  sources10  (European  Commission  2014), 

5 Regulation (EC) No 443/2009 setting emission performance standards for new passenger cars as part of the 

Community’s integrated approach to reduce CO2 emissions from light-duty vehicles 

6 Regulation (EU) No 510/2011 setting emission performance standards for new light commercial vehicles as part 

of the Union’s integrated approach to reduce CO2 emissions from light duty vehicles.  

7 Regulation (EC) No 715/2007 of the European Parliament and of the Council  of 20 June 2007 on type approval 
of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and 6) and 
on access to vehicle repair and maintenance information 

8 Directive 2009/30/EC as regards the specification of petrol, diesel and gas-oil and introducing a mechanism to 

monitor and reduce greenhouse gas emissions (Fuel Quality Directive) 

9 Directive 2009/28/EC on the promotion of the use of energy from renewable sources 

10 Directive 2014/94 on the deployment of alternative fuels infrastructure 

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consumer information11 (European Commission 1999) and research support.  Legislation 
also  applies  with  respect  to  noise,  tyres,  mobile  air  conditioning,  lubricants  and  other 
aspects.  At Member State level, the EU legislation is complemented by national legislation 
and initiatives. 

In  a  broader  context,  the  European  Sustainable  Consumption  and  Production  and 
Sustainable Industrial Policy Action Plan (European Commission 2008) aims to change the 
way  we  consume,  produce  and  promote  environmental  and  energy  efficient  products, 
including through green public procurement (GPP).  The EU GPP criteria for transport were 
updated in 2012 to take into account the obligations set out in the CVD, which allow for 
setting maximum values in the technical specifications and/or awarding higher marks to 
vehicles  that  have  better  environmental  ratings/energy  consumption  (European 
Commission 2012). The criteria cover both “core” and “comprehensive” levels  - the core 
criteria are designed to be easy to implement with minimal verification effort and/or cost 
increases,  while  the  comprehensive  criteria  define  more  advanced  environmental 
performance and cover a wider  range  of issues that go beyond the  requirements of the 
Directive. In addition, the GPP criteria also reference the methods defined under the CVD 
(referring  to  the  guidance  provided  on  the  Clean  Vehicle  Portal)  for  calculating  the 
operational lifetime costs of a vehicle. 

While  the  CVD  introduced  for  the  first  time  sustainability  obligations  into  public 
procurement law for the whole EU, developments have been ongoing in other areas.  The 
most  recent  procurement  legislation  was  renewed  in  2014  and  includes  Directive 
2014/24/EU  on  public  procurement  (European  Union  2014)  (repealing  Directive 
2004/18/EC);  and  Directive  2014/25/EU  (European  Union  2014)on  procurement  by 
entities operating in the water, energy, transport and postal services sectors and repealing 
Directive 2004/17/EC. 

These new Directives reiterated that public procurement is a key part of the Europe 2020 
strategy for smart, sustainable and inclusive growth.  At the same time, it was emphasised 
that there is a need to ensure the most efficient use of public funds and that procurement 
markets  must  be  kept  open.    As  such,  these  Directives  were  adopted  with  the  goal  of 
simplifying  and  relaxing  rules  and  procedures  in  recognition  of  economic,  social  and 
political  trends,  together  with  budgetary  constraints.    Member  States  have  until  March 
2016  to  transpose  the  new  rules  into  national  legislation  (except  with  regard  to  e-
procurement, where the deadline is September 2018).  The new rules allow broader criteria 
to be included in the evaluation of contracts, including on the basis of: 

•  Total lifecycle cost (including carbon footprint) – similar to the method already set 
out in the Clean Vehicles Directive, but recognising progress in the area of lifecycle 
costing; 

•  Production  processes  used,  e.g.  the  employment  of  disadvantaged  people  or  the 

use of environmentally-friendly materials; 

•  Any  “abnormally  low  bid”  (Article  69,  Directive  2014/24/EU)  will  be  rejected  if  it 
indicates  a  failure  to  observe  social,  labour  law  or  environmental  protection 
obligations; 

•  Contracts  could  be  reserved  for  sheltered  employment  undertakings  whose 
objective  is  to  bring  into  the  labour  force  disabled  or  otherwise  disadvantaged 
persons  (such  as  the  long-term  unemployed  or  members  of  disadvantaged 
minorities). 

These  aspects  aim  to  give  greater  flexibility  in  procurement  decisions  and  to  take  into 
account national/regional priorities with respect to competitiveness and political settings, 
as  well  as  technological  issues.  A  more  detailed  analysis  of  the  synergies  and  overlaps 

11 Directive 1999/94/EC relating to the availability of consumer information on fuel economy and CO2 emissions 

in respect of the marketing of new passenger cars 

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transport vehicles 

between these new public procurement Directives and the Clean Vehicles Directive will be 
undertaken in Evaluation Question 12 (see Section 6.13).  

The Commission has considered a proposal to repeal the CVD on the basis that is it is no 
longer  necessary  due  to  the  above-mentioned  developments  in  the  horizontal  public 
procurement  rules  (European  Commission  2013).    However,  legal  concerns  have  been 
raised  with  respect  to  the  repercussions  of  a  repeal  of  the  CVD  on  horizontal  public 
procurement  legislation;  therefore  this  evaluation  will  help  to  determine  future  actions 
(European Commission 2014). 

2.2.  Baseline 

An important step in analysing the effects of the Directive is to set out the baseline against 
which the analysis takes place. The baseline includes quantified estimates of CO2 and air 
pollutant emissions from public sector road transport vehicles, and overall expenditure in 
the  assumed  absence  of  the  CVD.  The  baseline  development  thus  assumed  that  other 
policy developments and legislation driving the uptake of clean vehicles (e.g. Euro emission 
standards, Car and Van CO2 regulations) are already in place.  

The baseline has been based on a vehicle fleet analysis covering four representative types 
of public sector vehicles (passenger cars, vans, rigid trucks and buses) over the years 2009 
to 2014. Of particular interest for the evaluation is the period 2012-2014, over which the 
CVD has been in force12.  

As a first step we estimated the number of vehicles annually procured by the public 
sector  in  the  EU  as  a  constant  share  of  annual  new  vehicle  registrations  in  Europe;  the 
latter is provided by ACEA  (2015). Given substantial uncertainty on the total number of 
vehicle registrations from the public sector across Europe, we have developed lower and 
upper  estimates  for  the  annual  numbers  of  vehicles  procured  by  public  contracting 
authorities.  

The  lower  bound  is  based  on  an  estimate  of  the  number  of  vehicles  procured  via  the 
Tenders Electronic Daily (TED) database, which is the online version of the “Supplement 
to the  Official Journal of the  EU. According to  data from TED for the  period 2012-2014, 
there  was  a  total  of  10,535  public  procurement  actions  to  purchase  vehicles.  Data  on 
contract  awards  in  TED  typically  do  not  include  information  on  the  number  of  vehicles 
procured, although by law it is necessary to include information on the monetary value of 
the awarded contract. In order to estimate the total number of vehicles procured by vehicle 
type (passenger car, van, bus, and rigid truck) via TED, we drew upon average costs per 
vehicle derived from our survey of procurers. The survey explicitly asked procurers for both 
contract values and numbers of vehicles procured, making the estimation of typical per-
vehicle costs straightforward. We divided the total contract values for a particular vehicle 
type  given  in  TED  by  the  typical  cost  per  vehicle  obtained  from  the  survey  in  order  to 
estimate the average number of vehicles procured through TED per year. 

However, it is possible that some contracting authorities have not listed all contract details 
in TED. For example, certain Member States (e.g. UK) have set up framework agreements 
for  vehicle  procurement,  and  use  these  frameworks  to  make  many  small  procurement 
actions which do not individually require listing in TED. Therefore the estimates based on 
TED  are  only  a  conservative  estimate  of  the  number  of  vehicles  procured  by  public 
contracting authorities.  

Thus, an upper bound estimate was developed based on available data from Germany, the 
UK, France and Italy (see  Table 2-1 and Figure 2-1). Detailed data from Germany have 
been used, together with appropriate weights to give us an EU28-wide estimate. A more 
detailed explanation of how these values are derived is provided in Annex 1. 

12 Although Article 11 of the Directive stated that CVD should be transposed by 4 December 2010, the majority 

of Member States transposed much later during 2012 – see Section 5.1.  

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Table 2-1: Estimated annual number of publicly procured vehicles and their share 
of  total  annual  new  vehicle  registrations  (annual  average  for  the  period  2012-
2014)  

Passenger cars 

Vans 

Rigid trucks 

Buses 

Total  

Lower bound  

Upper bound 

 29k 

 10k 

 11k  

 4k  

53k 

0.2% 

0.7% 

5.9% 

16.8% 

0.4% 

405k 

40k 

12k 

18k 

475k 

3.4% 

2.8% 

6.4% 

75.0% 

3.5% 

Source: Own estimates on the basis of TED and KBA ( 2014) and others 

Figure 2-1: Estimates of total annual registrations of new public sector vehicles 

600000

500000

400000

300000

200000

100000

0

Upper bound

Lower bound

2009

2010

2011

2012

2013

2014

Source: Analysis by Ricardo Energy & Environment based on (ACEA 2015b) 

Average  lifetime  mileage  for  cars  and  vans  draws  on  average  estimates  developed  in  a 
recent Ricardo-AEA  study for DG  Climate Action  (Ricardo-AEA 2014).  For trucks, annual 
mileage was estimated at the average level assumed for municipal utility vehicles, taken 
from (AEA 2011). This study was also used to define average annual mileage for buses. 

Based on the vehicle registrations and vehicle mileage data, the total vehicle kilometres 
for each type of newly registered public sector vehicle were estimated for each year of the 
analysis period and were multiplied by emission factors to estimate baseline emissions of 
the public sector fleet. 

For  the  baseline  emission  factors  (see  Figure  2-2),  it  was  assumed  that  public  sector 
passenger cars and vans have the same CO2 performance as the EU average car fleet. In 
order to estimate real-world emission factors, we used data from EEA reports and datasets 
on new car and van fleet  average emissions as well as analysis on real world emissions 
(ICCT, 2014a). For rigid trucks and buses, CO2 emissions per km were set at the average 
level identified in AEA (2011).  

5 

 
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

Figure  2-2:  Assumed  average  CO2  emission  factors  of  public  sector  vehicles  by 
year of registration 

)

m
k
/
g
(

2
O
C

 210

 200

 190

 180

 170

 160

 150

 140

Vans

Cars

2009

2010

2011

2012

2013

2014

Notes: Constant emission factor assumed for trucks (485g/km) and buses (956g/km). 

Source:  Analysis  by  Ricardo  Energy  &  Environment  based  on  real-world  emissions  data 
from ICCT (2014a) and others 

Thus, in the absence of the CVD, total baseline CO2 emissions up to the end of 2014 from 
public sector vehicles procured over the 2012-2014 period in the lower bound case (based 
on estimated procurement through TED) were expected to be around 3 Mt CO2 while, in 
the  upper  bound  case  they  would  be  up  to  15  Mt  (see  Table  2  2).  Lifetime  emissions 
covering  the  whole  period  during  which  the  procured  vehicles  are  in  circulation  are 
calculated in the range of 14 to 82.4 MT.     

Table  2-2:  Baseline  total  CO2  emissions  from  public  sector  vehicles  procured 
during the period 2012-2014 (estimate) 

CO2 emissions up to 2014 (Mt CO2)  

Lifetime CO2 emissions (Mt CO2) 

Lower bound 

Upper bound 

Lower bound 

Upper bound 

Passenger 
cars 

Vans 

Trucks 

Buses 

Total 

 0.5  

 0.4  

0.7  

 1.1  

 2.8  

 7.7  

 1.5  

0.8  

 5.1  

 15.1 

 2.5  

 1.1  

 4.2  

 8.6  

 16.4 

 34.7  

 4.8  

 4.6  

 38.2  

 82.4  

Source: analysis by Ricardo Energy & Environment based on various sources 

In  the  case  of  air  pollutant  emissions  (NMHC,  NOX  and  PM)  from  public  sector  vehicles, 
with the exception of NOx emissions from diesel vehicles, the baseline scenario is based on 
the  use  of  the  relevant  minimum  Euro  standard  limit  values  for  cars,  vans,  trucks  and 
buses  applying  to  new  vehicles  at  the  time.  In  the  case  of  NOX  emissions  from  diesel 
vehicles where real-world NOx emissions can deviate vastly from test cycle emissions, real-
world emission factors from ICCT (2014; 2015a) were used. Euro standards for trucks and 
buses  are  given  as  emission  factors  in  g/kWh  of  engine  output.  A  conversion  from  CO2 

6 

 
 
 
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

emissions to assumed engine output (at an average efficiency of 0.35) was necessary in 
order  to  present  emission  factors  in  g/km.  Table  2-3  summarises  the  assumed  baseline 
pollutant emissions factors that were used.   

Table  2-3:  Assumed  baseline  pollutant  emission  factors  from  public  sector 
vehicles 

NMHC 
(g/km) 

NOX (g/km) 

PM (g/km) 

Up to 
2013 

2014 
& 
after 

Up to 
2013 

2014 

2015 & after  Up to 
2013 

2014 
& 
after 

Passenger 
cars 

Petrol  0.068  0.068  0.060 

0.060 

0.060 

0.005  0.005 

Diesel 

- 

- 

0.180 

0.6* 

0.6* 

0.005  0.005 

AFV 

0.068  0.068  0.060 

0.060 

0.005 

0.005  0.068 

Vans 

Diesel 

- 

- 

0.240 

 1.068*  

 1.055*  

0.005  0.005 

Rigid trucks 

Diesel  0.295  0.083  1.283 

 2.886**  

 0.192**  

0.013  0.006 

Buses 

Diesel  0.581  0.164  2.528 

 5.688**  

 0.379**  

0.025  0.013 

Source: * real-world values, based on data from ICCT (2014) 
** real-world values, based on data from ICCT (2015a) 

Remaining figures based on EURO limit values from DieselNet (2015) 

On the basis of the above pollutant emissions factors, Table 2-4 to Table 2-6 summarise 
the estimated pollutant emissions for the different categories of vehicles under the baseline 
scenario.  

Table  2-4:  Baseline  total  NMHC  emissions  from  public  sector  vehicles  procured 
during the period 2012-2014 (estimate) 

NMHC  emissions  up  to  end  of  2014 
(in tonnes) 

Lifetime  NMHC  emissions  (in 
tonnes) 

Lower bound 

Upper bound 

Lower bound 

Upper bound 

Passenger 
cars 

Vans 

Trucks 

Buses 

Total 

168 

- 

1,055 

1,743 

2,966 

2,379 

- 

1,145 

7,767 

675 

9,548 

- 

3,922 

8,876 

- 

4,258 

39,560 

53,366 

11,292 

13,473 

Source: analysis by Ricardo Energy & Environment based on various sources 

Table  2-5:  Baseline  total  NOx  emissions  from  public  sector  vehicles  procured 
during the period 2012-2014 (estimate) 

NOx up to end of 2014 in tonnes) 

Lifetime NOx emissions (in 
tonnes) 

Lower bound 

Upper bound 

Lower bound 

Upper bound 

Passenger 
cars 

Vans 

4,202 

3,953 

59,477 

14,557 

206,055 

16,701 

10,263 

43,356 

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

Trucks 

Buses 

Total 

10,159 

16,802 

35,117 

11,029 

74,885 

36,613 

83,139 

162,091 

144,573 

39,747 

370,535 

659,692 

Source: Analysis by Ricardo Energy & Environment based on various sources 

Table  2-6:  Baseline  total  PM  emissions  from  public  sector  vehicles  procured 
during the period 2012-2014 (estimate) 

PM  emissions  up  to  end  of  2014  (in 
tonnes) 

Lifetime PM emissions (in tonnes) 

Lower bound 

Upper bound 

Lower bound 

Upper bound 

Passenger 
cars 

Vans 

Trucks 

Buses 

Total 

38 

19 

47 

77 

180 

534 

78 

51 

343 

1,005 

137 

48 

178 

402 

766 

1,937 

203 

194 

1,794 

4,128 

Source: Analysis by Ricardo Energy & Environment based on various sources 

Finally, estimates of the baseline total public sector expenditure (purchase and operating 
costs) were estimated for the different vehicle types (see Table 2-7). These estimates have 
been taken from (Ricardo-AEA 2012).  

Table 2-7: Baseline capital costs and operating costs 

Lower bound costs (€M, 2015 prices) 

Capital costs 

Operating costs 

2012-2014  2015-2032  2012-2014  2015-2032 

Total 

 1,677  

 468  

 2,334  

 2,213  

 6,692  

- 

- 

- 

- 

- 

 1,677  

 1,008  

 2,686  

 468  

 442  

 910  

 2,334  

 1,874  

 4,208  

 2,213  

 2,235  

 4,448  

 1,230  

 5,560  

 6,790  

Upper bound costs (€M, 2015 prices) 

Capital costs 

Operating costs 

2012-2014  2015-2032  2012-2014  2015-2032 

Total 

 23,741  

 1,977  

 2,534  

 9,861  

 38,114  

- 

- 

- 

- 

- 

 23,741  

 14,275  

 38,016  

 1,977  

 1,868  

 3,845  

 2,534  

 2,034  

 4,568  

 9,861  

 9,963  

 19,824  

 6,020  

 28,140  

 34,160  

Passenger cars 

Vans 

Trucks 

Buses 

Total 

Passenger cars 

Vans 

Trucks 

Buses 

Total 

Note: costs provided are not discounted 

2.3. 

 Intervention logic 

The intervention logic describes the links and causal relationships between the problems 
and/or needs, broader policy goals, the general , specific and operational objectives that 

8 

 
 
 
 
 
 
 
 
 
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transport vehicles 

the  intervention  is  designed  to  address,  and  the  specific  actions  for  addressing  the 
identified  problems  and/or  needs  (in  graphical  form).  It  also  describes  what  the 
intervention  is  expected  to  achieve  (outputs,  results  and  impacts),  and  how  the  wider 
policy aims are linked to the specific operational objectives and the actions taken to achieve 
the interventions’ objectives by relevant actors.  

Figure 2-3 presents the intervention logic for the Clean Vehicles Directive. A discussion of 
the general, specific and operational objectives of the Directive follows.  

9 

 
 
 
 
Ex-Post Evaluation of Directive 2009/33/EC on the promotion of clean and energy-efficient road transport vehicles 

Figure 2-3: Intervention Logic – Clean Vehicles Directive 

10 

 
 
 
 
 
 
 
 
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transport vehicles 

The Impact Assessment for the revised proposal (European Commission 2007) set out the 
main environmental challenges related to transport as:  

  An excessive dependence on oil; 

  The problem of climate change caused by carbon dioxide (CO2) emissions; and  

  Health effects from air pollution caused by pollutant emissions from vehicles.  

The objective of the proposed Directive was identified in the Impact Assessment as “cleaner 
and more energy efficient vehicles in the EU” (European Commission 2007).  

2.3.1.  General objectives  

The general objective of the CVD is to “increase the energy efficiency and competitiveness 
and decrease CO2 and pollutant emissions of transport by increasing the market share of 
clean vehicles”.  

The Directive (European Commission 2009) goes into more detail and specifies that it aims 
to  “stimulate  the  market  for  clean  and  energy  efficient  road  transport  vehicles,  and 
especially  –  since  this  would  have  a  substantial  environmental  impact  –  to  impact  the 
market  for  standardised  vehicles  produced  in  larger  quantities  such  as  passenger  cars, 
buses, coaches and trucks, by ensuring a level of demand for clean and energy-efficient 
road transport vehicles  which is  sufficiently  substantial to  encourage manufacturers and 
the industry to invest in and further develop vehicles with low energy consumption,  CO2 
emissions and pollutant emissions”.  

2.3.2.  Specific objectives 

The  specific  objective  of  the  CVD  is  to  “increase  the  market  share  of  clean  vehicles  by 
stimulating their public procurement”. Whereas the general objective looks to the ultimate 
aim of the CVD to increase the market share of clean and energy efficient vehicles (whole 
fleet), the specific objective is to achieve an increase in the market share of clean vehicles 
through stimulating their public procurement.  

2.3.3.  Operational objectives 

There are three operational objectives of the CVD: 

“To internalise operational and environmental cost into public procurement criteria”. It was 
anticipated that through mandating the inclusion of lifetime costs for energy consumption, 
CO2 emissions and pollutant emissions as award criteria in the procurement of vehicles for 
public transport services, that the largest impact on the market  could be achieved when 
coupled with the best cost/benefit result.  

“Allow continued application of already developed methods” – Some Member States were 
already  actively  applying  green  public  procurement  criteria  in  the  procurement  of  road 
transport vehicles tailored to their local needs prior to the introduction of the CVD. It was 
therefore  important  to  ensure  that  such  Member  States  were  able  to  continue  to  apply 
these methods when the Directive came into force. Article 5(3) sets out three options for 
applying  environmental  criteria  in  the  public  procurement  of  road  transport  vehicles, 
covering setting of technical standards, applying weighting to environmental criteria and 
monetisation of environmental and energy impacts.  

“Ensure an appropriate level of harmonisation of determining full lifetime costs of vehicles”. 
It was anticipated that by providing harmonised criteria at the Community level (foreseen 
through  options  in  Article  5(3)),  that  the  procurement  of  vehicles  for  public  transport 
services would make a significant impact on the market.  

 
 
 
 
  
 
 
 
 
 
 
     
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

3.  EVALUATION QUESTIONS 

The evaluation questions are as follows: 

Relevance:  

1.  To what extent is increasing the market share of clean vehicles an adequate mean to 

contribute to the overall objectives of increasing the energy efficiency and 
competitiveness and decreasing CO2 and pollutant emissions of transport?  

2.  To what extent is stimulating the public procurement of clean vehicles an adequate 
mean to contribute to the overall objectives of increasing the energy efficiency and 
competitiveness and decreasing CO2 and pollutant emissions of transport?  

Effectiveness: 

3.  To what extent has the mandatory inclusion of operational lifetime environmental and 
energy impacts in the procurement decision led to an increased market share of clean 
vehicles and contributed to reducing CO2 and pollutant emissions (NOX, NMHC and 
particulate matter) from the transport sector?  

4.  To what extent has the provision of different options to include operational lifetime 

environmental and energy impacts stimulated the internalization of operational costs in 
procurement decisions, and contributed to the harmonization in determining these 
costs?  

5.  To what extent has the Directive promoted an increased awareness among the 

different stakeholders of the operational lifetime environmental and energy impacts of 
vehicles?  

Efficiency:  

6.  To what extent has the Directive generated benefits and costs for different 

stakeholders (e.g. national administrations, contracting authorities, transport 
operators, manufacturers)?  

7.  Could the effects have been achieved in a more efficient way (e.g. through other or 

additional (legislative) measures)?  

European 
Added Value:  

8.  Would it have been possible to obtain similar or better results in terms of the market 
share of clean vehicles without EU intervention, i.e. the Clean Vehicles Directive?  

9.  To what extent have the Directive and the associated Commission initiatives (e.g. 
Clean Vehicle Portal, Clean Fleets Project) initiated and/or supported a recognised 
exchange of good practices between contracting authorities in different Member 
States?  

Coherence:  

10. How well does this legislation interact with other EU policies with similar objectives, in 
particular the general transport policy framework as laid down in the 2030 framework 
for climate and energy policies, the 2011 Transport White Paper, the conclusions from 
CARS2020, pollutant emissions limits (EURO standards for light and heavy duty 
vehicles) and CO2 limits for cars, and the deployment of alternative fuel infrastructure?  

11. To what extent is the provision of multiple options to include operational lifetime 

environmental and energy impacts coherent with the objective of harmonizing the 
determination of these impacts?  

12. To what extent are the provisions of the Clean Vehicles Directive coherent, 

complementary and/or redundant with the horizontal EU procurement legislation (in 
particular 2014/24/EU and 2014/25/EU)?  

Sustainability:   13. To what extent would the market develop differently should the intervention be ceased 

partially or completely at European level? 

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4.  METHOD/PROCESS FOLLOWED 

4.1.  Method/Process 

4.1.1.  Data collection 

The  first  stage  of  this  evaluation  of  the  Clean  Vehicles  Directive  was  to  undertake  an 
extensive  data  collection.  The  main  tools  that  have  been  applied  include  a  review  of 
relevant literature, extensive stakeholder engagement (including online surveys, individual 
stakeholder  contact/interviews  and  stakeholder  workshops),  and  preparation  of  case 
studies.  Data  collection  was  undertaken  from  project  inception  (January  2015)  to  May 
2015.  

Literature review 

The  review  of  the  literature  covers  reports  and  studies  directly  related  to  Directive 
2009/33/EC,  Directives  and  their  assessment  in  the  wider  policy  context,  European 
strategy documents and work previously performed by the study team. Table 4-1 provides 
an  overview  of  the  most  relevant  literature  sources.  All  of  the  literature  is  referenced 
throughout the report, as well as in the reference list at the end of this report.  

Table 4-1: Main literature supporting the evaluation of Directive 2009/33 

Type 

Sources (list not exhaustive) 

Assessments/Moni
toring 
reports 
directly  related  to 
Directive 
2009/33/EC: 

  Monitoring  Report  of  the  Directive  2009/33/EC  on  the 
promotion of clean and energy efficient road transport vehicles 
(Ricardo-AEA and TEPR 2012) 

  The  Impact  Assessment  accompanying  the  proposal  for  the 
Clean Vehicles Directive: Impact Assessment of a Proposal for 
a  Directive  on  the  Promotion  of  Energy  Efficient  and  Low 
Emission Road Transport Vehicles, (PWC 2005) 

and 
Directives 
their  assessments 
in  the  wider  policy 
context: 

  The  evaluation  reports  on  the  impact  and  effectiveness  of 
European public procurement rules, along with the supporting 
studies  and  consultation  documents  (European  Commission 
2011) 

  Directive 2014/24/EU on public procurement (European Union 

2014) 

  Directive 2014/25/EU on procurement by entities operating in 
the  water,  energy,  transport  and  postal  services  sectors 
(European Union 2014) 

  Directive  2014/94/EU  on  the  deployment  of  alternative  fuels 
infrastructure  (European  Union  2014),  Evaluation  Report  on 
Impact and Effectiveness of EU Public Procurement Legislation 
(European Commission 2011) 

  2020  climate  and  energy  package  (European  Commission 

2009) 

  Transport White Paper (European Commission 2011) 

  REFIT exercise (European Commission 2013) 

  Conclusions from CARS2020 (European Commission 2014) 

European  strategy 
documents: 

Other EC reports: 

  Handbook  on  external  costs  of  transport  (Ricardo-AEA,  DIW 

Econ et al. 2014) 

13 

 
 
 
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

Type 

Sources (list not exhaustive) 

  Evaluation  of  Regulations  443/2009  and  510/2011  on  CO2 
emissions  from  light-duty  vehicles  (Ricardo-AEA  and  TEPR 
2015) 

The  desk  research  conducted  for  the  study  revealed  that  there  is  a  relevant  body  of 
literature  that  can  help  to  inform  some  of  the  analysis  of  the  evaluation  questions. 
However,  since  the  2012  monitoring  report,  no  further  high  level  review  of  the  Clean 
Vehicles Directive has been conducted. Conclusions emerging from the desk research have 
been  supplemented  by  the  information  collected  through  other  means  (see  following 
sections). 

Engagement with Stakeholders 

The  study  team  engaged  with  a  wide  range  of  stakeholders,  including  EU–level 
stakeholders, procurers, manufacturers, contractors and Member States. Table 4-2 below 
summarises  the  stakeholder  engagement  activities  undertaken  as  part  of  the  data 
collection for the evaluation. For more information, please see corresponding annexes.  

Table 4-2: Summary of stakeholder engagement activities 

Type 
stakeholder 

of 

Nature 
of 
engagement 

Description 

EU 
Stakeholders 

Level 

Telephone 
interviews:  12 
and a further 9 
engaged  (e.g. 
exchange 
of 
emails/ 
information) 

Discussing  views  of  EU  Level 
Stakeholders  on  the  Directive  and 
asking  questions  based  on  the  13 
evaluation questions.  

Workshop 
21 attendees 

– 

Held on afternoon  of 17th April 2015 
in Brussels.  

Procurers 

Online survey: 
547 responses 

Overview of study to date; feedback 
on participants on assessment of the 
options referred to in Article 5(3) and 
assessment  of 
the  monetisation 
methodology;  discussion  regarding 
the 
improvements 
possible 
Directive.  

to 

Questions 
information 
covering 
regarding  the  most  recently  signed 
contract  to  procure  road  transport 
vehicles;  use  of  environmental 
in  assessments;  setting 
criteria 
technical 
for 
energy 
environmental 
performance; using weighting/award 
criteria  in  assessments;  monetising 
energy  and  environmental  impacts; 
and  use  of  environmental  criteria 
prior to 2012.  

standards 
and 

Further 
information 

Annex 2 
provides an 
overview of 
interview 
responses.  

Agenda, full list 
of participants 
and summary 
of the workshop 
can be found in 
Annex 3 

Annex 4 
provides a 
summary and 
analysis of 
survey 
responses 

Telephone 
interviews:  13 

Follow-on  interviews  to  obtain  more 
in-depth  information  on  procurers’ 

Annex 5 
provides a 
summary and 

14 

 
 
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

(6 
responses) 

written 

experiences  with 
requirements of the CVD.  

applying 

the 

analysis of 
interview 
responses 

Manufacturers  Telephone 

interviews:  3 
written 
(1 
response) 

Interviews  to  identify  further  data 
relating  to  vehicles  that  had  been 
procured  publicly  since  the  start  of 
2012  and  to  determine  whether  any 
impacts of the CVD had been realised 
by manufacturers.  

Annex 6 
provides a 
summary and 
analysis of 
survey 
responses 

Contractors 

Online survey: 
65 responses 

Survey  aimed  at  capturing  data  and 
information  from  contractors  who 
have  been  awarded  contracts  for 
providing road transport vehicles.  

Annex 7 
provides a 
summary and 
analysis of 
survey 
responses 

Member 
States 

Fiches 

and 

collating 

first  used 

Fiches 
verifying 
information  from  MSs  (based  on 
those 
the  2012 
Monitoring  Report  (Ricardo-AEA  and 
TEPR,  2012))  on  implementation  of 
CVD,  supporting  actions/  measures, 
application  of  options  in  Article  5(3) 
and other views on impacts of CVD.  

in 

Inputs/updated  fiches  were  received 
from 16 Member States13.  

Workshop 

Held on morning of 17th April 2015 in 
Brussels 

Overview  of  the  study,  first  findings 
and  suggestions,  and  feedback  from 
Member States.  

Agenda can be 
found in Annex 
8 

Case studies 

The purpose  of undertaking case  studies was to support a number of  the tasks through 
providing qualitative information and illustrative examples. These include the following:  

 

Illustrative examples for the assessment of the methodology of the monetisation of 
costs in Article 6 (See Annex 9), and  

  Qualitative case studies drawing upon existing case studies, e.g. Clean Fleets, Clean 
vehicle Portal, GPP 2020 etc. – contributing to the quantification of the impacts of 
CVD (See Annex 10).  

4.1.2.  Method for the quantification of effects 

In order to assess the impacts of the Directive, it was necessary to quantify the costs and 
impacts  associated  with  procurement  of  vehicles  in  the  years  since  the  Directive  was 
transposed  comparing against the counterfactual baseline scenario developed in  Section 
2.2 describing what would have happened in the absence of the Directive. Both the baseline 
counterfactual scenario and our estimates of actual outcomes under the Directive are based 

13 Austria, Belgium, Croatia, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Poland, 

Romania, Slovakia, Sweden and United Kingdom 

15 

 
 
 
 
 
 
 
                                           
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transport vehicles 

on a model of the public fleet developed for this evaluation described in detail in Annex 1. 
The  fleet  model  makes  use  of  data  from  various  sources  that  are  used  to  calculate  the 
various inputs and outputs.  

A key issue in the development of the model was the absence of comprehensive data on 
the  number  of  vehicles  procured  by  public  authorities  across  the  EU-28.  Even  national 
datasets detailing all vehicles procured by contracting authorities in a single Member State 
are not available. We made use of available data describing annual public procurement in 
Germany,  France  and  the  UK  by  certain  subsets  of  the  public  sector,  as  well  as  recent 
estimates of the size of (parts of) the public fleet in those countries. These three countries 
(Germany,  France  and  the  UK)  represent  a  large  proportion  of  the  total  EU28  vehicle 
market on their own14. Making use of this data, it has been possible to produce estimates 
of the proportion of new vehicles that are bought by contracting authorities across the EU. 
The available data also allowed us to provide estimates of the number vehicles procured 
within the main vehicle segments covered by the Directive and considered in the impact 
assessment (passenger cars, vans, rigid trucks and buses).15 

However,  we  recognise  that  there  is  potential  for  substantial  variation  in  the  relative 
importance  of  public  procurement  in  the  Member  States  for  which  we  have  no  data. 
Therefore,  upper  and  lower  estimates  of  the  proportion  of  new  vehicles  bought  by 
contracting authorities have been produced, which are informed in part by the degree of 
cross-national variation between France, Germany and the UK. 

A  second  issue  is  that  very  little  data  is  available  on  the  types  of  vehicles  procured  by 
public authorities, or their lifetime use. Thus, our estimates of the impacts associated with 
public authorities buying and operating these  vehicles have been based on  assumptions 
that they resemble the average vehicle of the same type purchased by anyone in the EU 
(where “type” means passenger car, van, truck, or bus). We used various prior studies of 
average vehicle purchase costs, mileages, and emissions to populate the baseline in this 
way. Where available, we have substituted these generic assumptions with more specific 
information on public sector vehicles. For example, we employ evidence that the lifetime 
mileage  of  publically-owned  trucks  is  much  lower  than  the  lifetime  mileage  of  a  typical 
HDV. 

Finally, a key difficulty with estimating the effects of the Directive on the market share of 
clean vehicles and fleet average emissions was the absence of detailed data on the actual 
procurement  patterns  of  organisations  covered  by  the  Directive.  Thus,  estimating  the 
difference between the baseline and the outturn scenario fundamentally requires a method 
for determining what types of vehicles contracting authorities would have procured in the 
absence of the Directive. For this part of the analysis, we based our estimates of the effects 
of  the  Directive  on  the  analysis  of  the  results  of  the  survey  of  procurers,  in  particular 
procurers’ responses to our questions about the criteria they used for procuring vehicles, 
and  the  information  they  provided  on  the  makes  and  models  of  vehicles  they  procured 
under the Directive.  

For example, the analysis of the procurers’ survey responses indicated that, at maximum, 
the impact of the Directive was for 1% of contracting authorities to impose EURO 6/VI or 
at a time when only EURO 5/V was obligatory. Furthermore, on average this happened just 
six  months  before  EURO  6/VI  became  obligatory  and,  therefore,  the  number  of  vehicle 
procurements affected was very small. We therefore quantified air pollutant impacts in the 

14 In 2014, they accounted for nearly 60% of new passenger car registrations in the EU 28 (ICCT, 2014) 

15 German registration data indicated that public authorities purchase a negligible number of tractor-trailers, and 
therefore in the ensuing analysis we refer to numbers of rigid trucks bought by the public sector, and (where 
appropriate) compare these with rigid truck sales in the wider market. Similarly, as coach travel in the EU is 
almost entirely privatised, we refer to procurement of buses and compare this with total bus sales, not buses 
and coaches. 

16 

 
 
 
 
                                           
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

model by assuming that 1% of vehicles conform to the limit values of EURO 6/VI six months 
earlier (relative to the baseline) rather than conforming the limit values of EURO 5.  

In other cases, when such input was not available (e.g. CO2 emissions reduction), we used 
available data to compare CO2 performance of the specific makes and models of vehicles 
procurers told us they had procured under the Directive, and compared this with the typical 
performance of all vehicles that had been bought in Europe at the same time. We assumed 
that the absolute maximum improvement in CO2 performance that can be attributed to the 
Directive is equivalent to this the typical  CO2 difference between public sector vehicles and 
other vehicles since the Directive was transposed, controlling for mass.  

Energy  cost  savings  were  estimated  by  a  commensurate  reduction  in  litres  of  fuel 
consumed,  and  multiplied  this  by  prices  of  fuel  without  taxes  in  the  EU.  Details  of  the 
parameters used to perform this calculation are provided in Annex 1. 

To  monetise  the  CO2 and  pollutant  emissions  impacts  estimated  in  the  model,  the  total 
mass of each of these pollutants is multiplied by emissions cost factors taken from the EU’s 
handbook on external costs of transport (Ricardo-AEA, DIW Econ et al. 2014). Changes in 
emissions  costs  attributable  to  the  Directive  are  therefore  directly  proportional  to  the 
changes in total masses of emissions due to the Directive. The details of the parameters 
used to monetise pollutant benefits are provided in Annex 1. 

Finally, in order to estimate administrative and compliance costs of procurers and suppliers 
we  drew  on  available information  provided  from  the  survey  respondents  concerning  the 
costs  associated  with  the  Directive  and  available    data  on  the  number  of  contracts  and 
bids.  While  a  formal  Standard  Cost  Model  methodology  was  not  possible  to  follow,  an 
approach based on the logic of the SCM was applied. Data on the additional purchase prices 
of cleaner vehicles were also used to calculate compliance costs for contracting authorities.  

Using the approach described above, the impacts of the Directive (i.e. on administrative 
costs,  CO2  and  pollutant  emissions  reduction,  energy  cost  savings,  and  purchase  costs) 
were monetised to support the cost-benefit analysis. The specific assumptions used in this 
analysis  (e.g.  discount  rates  and  the  period  of  time  included)  are  indicated  under  the 
headings of the specific evaluation questions on efficiency (Section 6.7). 

4.1.3.  Answering evaluation questions 

In order to answer the evaluation questions as set out in Section 3, relevant information 
from  the  review  of  the  literature,  engagement  with  stakeholders,  case  studies  and 
quantification of impacts was drawn upon, and further analysis undertake where necessary. 
The specific approach used is also described at the start of each evaluation question (see 
Section 6).  

4.2.  Limitations – robustness of findings 

The main limitation that has affected the robustness of findings of this evaluation is the 
lack  of  existing  evidence  in  relation  to  the  implementation  of  the  Directive  and  its 
associated impacts. This is due to a number of issues, including that:  

  There is no EU level monitoring mechanism in place other than the production of 

consultancy reports; 

  There are no reporting requirements in place for Member States;  

  Few  Member  States  have  undertaken  any  monitoring  or  evaluation  of  effects  on 
their  own  in  this  respect,  and  so  there  is  a  lack  of  information  on  MS 
implementation; and 

  There  is  little  in  the  way  of  published  views/position  papers  from  stakeholders 

currently available.  

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

As  a  result  of  the  lack  of  existing  evidence  available,  one  of  main  data  sources  for  this 
study  has  therefore  been  stakeholder  engagement,  including  an  online  survey  with 
procurers  and  contractors,  and  interviews  with  EU-level  stakeholders,  procurers,  and 
manufacturers. The high reliance on stakeholder responses in this study comprised a risk. 
We thus monitored the progress in the stakeholder consultation closely. To ensure that we 
received response rates as high as possible, we translated the surveys and the emails into 
six case study languages, used personalised greetings, sent out two reminders and asked 
our contacts at city networks to distribute the links as well. For the procurers’ survey these 
measures led to a response rate of 19% for the prioritised Member States (12% for the 
rest of the EU), for the contractors’ survey we had a response rate of 3.8%. As we were 
able  to  use  contacts  obtained  from  the  TED  database  through  automated  processes  we 
were  able  to  send  out  the  survey  to  a  large  and  EU-wide  representative  sample  of 
procurement  authorities.  This  in  combination  with  the  good  response  rates  led  to  a 
sufficient amount of data to be used for a robust analysis. 

Comprehensive information/data on each of the tasks and evaluation questions could not 
be covered in the online survey as it had to be kept concise in order to avoid stakeholder 
fatigue. These gaps in the data collection through online surveys had to be addressed with 
additional individual interviews, stakeholder workshops and data collection. Using a wide 
range of different tools to carry out this evaluation  has ensured that sufficient data was 
collected to allow a sound analysis, whilst acknowledging the limitations outlined below. 

The timing of the study is an important factor influencing the quality of the data available 
for the study. Even though the Directive was due to be transposed by 4 December 2010, 
the transposition of the Directive into national law was delayed. Only in June 2013 had all 
EU-27 Member States transposed the Directive with Croatia following in January 2014. This 
means that all EU-27 Member States have now had a couple of years of experience with 
the Clean Vehicles Directive; however, the amount of data available on actual outcomes of 
this Directive is limited. Apart from the 2012 Monitoring Report (Ricardo-AEA and TEPR, 
2012),  no  newer  reports  directly  relating  to  the  observed  effects  of  the  Directive  are 
available.  The  risk  of  drawing  invalid  conclusions  due  to  this  lack  of  literature  data  is 
mitigated by an extensive data collection conducted by the project team for this study. The 
Impact  Assessment  (European  Commission  2007)  took  a  ten-year  time  horizon  in  its 
assessment of the impacts of the proposed Directive at the time. Therefore it should be 
acknowledged that it will take time for the Directive to influence the market, and to date 
less than five years have passed since its required transposition deadline (which was also 
not met in the majority of cases).  

A further limitation of this research is the issue of causality. When analysing the changes 
in numbers for clean vehicle procurement, factors other than the Clean Vehicles Directive 
have to be taken into account. Many other factors such as policies and incentive schemes 
(e.g. CO2-based taxation measures and grants for ultra-low emission vehicles, etc.) and 
other EU legislation (e.g. Passenger Car CO2 Labelling Directive or Regulations 443/2009 
and 510/2011 on CO2 emissions from light-duty vehicles) have an influence on the changes 
in  market  uptake  of  clean  road  vehicles  by  public  contracting  authorities.  Such  issues 
around causality are very common problems when dealing with ex-post evaluations of this 
nature.  In  this  study  this  has  been  addressed  as  far  as  is  possible  through  qualitative 
research based on our stakeholder engagement activities. 

A recurring issue that arose in many areas of the evaluation, including engagement with 
stakeholders and answering the evaluation questions, was the lack of clarity surrounding 
what is interpreted to be a ‘clean vehicle’. This is considered in more detail in Section 6.2.  

There are also a number of issues that are likely to limit the extent to which impacts will 
have been realised by the Directive, including:  

  Limited  number  of  vehicles  procured  publicly  –  As  discussed  in  Section  2.2 
(baseline) it is estimated that the share of the public sector vehicles in total new 
vehicle registrations could be between 0.4% and 3.5% (lower and upper bounds). 

18 

 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

The direct impacts of the Directive are therefore likely to be limited to, at maximum, 
this proportion of vehicles (see also next two points). However, one of the aims of 
the Directive was to stimulate procurement of clean and energy efficient vehicles 
more widely (i.e. beyond public procurement).  

  The proportion of vehicles procured publically that are subject to the CVD is limited 
further  as  the  Directive  only  covers  a  certain  proportion  of  the  vehicles  publicly 
procured  –  those  that  are  above  the  EU  public  procurement  thresholds  or  the 
respective national thresholds.  

  Lifetime  of  road  transport  vehicles  –  The  lifetime  of  road  transport  vehicles  is 
typically 10-15 years.  Although public authorities may not operate vehicles for their 
entire  lifetime,  this  length  of  time  (along  with  relatively  small  proportion  of  total 
vehicle market procured by public authorities) means that it  is very  unlikely that 
significant  impacts  of  the  Directive  would  have  been  experienced  by  the  vehicle 
market in the past four years.  

Specific  limitations  related  to  the  data  required  to  undertake  the  quantification  work 
necessary for this evaluation were discussed in more detail in Section 2.2 (Baseline) and 
Section 4.1.2 (method for the quantification of effects).  

19 

 
 
 
 
 
 
 
 
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transport vehicles 

5.  IMPLEMENTATION STATE OF PLAY (RESULTS) 

5.1.  Implementation of Directive 2009/33 

Transposition  of  the  Directive  into  National  Implementing  Measures  (NIMs)  -
Article  11  of  the  Directive  states  that  “Member  States  shall  bring  into  force  the  laws, 
regulations  and  administrative  provisions  necessary  to  comply  with  this  Directive  by  4 
December 2010”.  

Only three Member States transposed the Directive into National Implementing Measures 
(NIMs) by the deadline of 4th December 2010 – the Czech Republic, Denmark and Portugal. 
After  a  range  of  European  Commission  actions  (including  the  opening  of  several 
infringement cases), the remaining 24 Member States (at the time) transposed by the June 
2013.  In  July  2013  Croatia  became  the  28th  EU  Member  State,  and  subsequently 
transposed the CVD into national legislation in January 2014.  

Type of legislation - The majority of Member States (18 MSs) introduced new legislation 
when transposing the Directive, whereas the remaining Member States made amendments 
to existing procurement legislation to incorporate the new requirements.  

Thresholds  –  Application  of  CVD  -  The  Directive  states  that  the  requirements  of  the 
CVD should apply to contracts over a certain threshold (i.e. where contracting authorities 
or contracting entities are under an obligation to apply procurement procedures set out in 
Directives 2004/17/EC  and 2004/18/EC  – Article 3). At time of writing, this threshold is 
€134,000  for  central  government  authorities  and  €207,000  for  sub-central  contracting 
authorities. For operators performing public service obligations (PSOs), the threshold is to 
be chosen by Member States, but cannot exceed the threshold values set out in Directives 
2004/17/EC and 2004/18/EC.  

However, Member States are also able to set thresholds lower than those outlined above, 
whereas in other cases procurers may choose to apply the requirements of the CVD to all 
contracts  (i.e.  those  below  an  agreed  threshold),  even  in  the  absence  of  a  formal 
requirement. This means that the requirements of the CVD may be applicable to a greater 
proportion (or all) of the publicly procured vehicle fleet. 

Implementation of Article 5(3) - Article 5(3) of the Directive states that the following 
options should be used: 

“(a)  by  setting  technical  specifications  for  energy  and  environmental  performance  in  the 
documentation for the purchase of road transport vehicles on each of the impacts considered, 
as well as any additional environmental impacts; or 

(b) by including energy and environmental impacts in the purchasing decision, whereby:  

-  In  cases  where  a  procurement  procedure  is  applied,  this  shall  be  done  by  using  these 
impacts as award criteria, and  

- In cases where these impacts are monetised for inclusion in the purchasing decision, the 
methodology set out in Article 6 shall be used. ” 

Of  the  28  EU  Member  States,  25  of  them  allow  all  three  options  in  their  national 
implementing legislation (see Table 5-1).  

Table 5-1: Application of Article 5(3) in EU Member States 

20 

 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

Action taken by MS on Article 5(3) 

Member States 

Allow all of the options 

25  Member  States:  Austria,  Belgium,  Bulgaria, 
Croatia,  Cyprus,  Denmark, 
Finland, 
Germany,  Greece,  Hungary,  Ireland,  Italy,  Latvia, 
Lithuania, Luxembourg,  Malta,  Netherlands, Poland, 
Portugal, Romania, Slovakia, Spain, Sweden, United 
Kingdom 

France, 

Allow only Option 1 (i.e. setting technical 
specifications) 

Estonia 

Allow  only  option  2b  (i.e.  where  energy 
and 
are 
monetised) 

environmental 

impacts 

Slovenia 

Options  1  and  2a  (i.e.  setting  technical 
specifications  and  where  energy  and 
environmental impacts are used as award 
criteria)  

Czech Republic  

It was identified for the Monitoring Report (and reconfirmed by the research undertaken 
for the evaluation) that the main reasons behind the decision to keep all three options by 
the majority of the Member States included:  

  Enabling greater flexibility for the purchasing authority; 

  Giving  purchasing  authorities  the  ability  to  use  the  options  best  suited  to  their 
procurement  needs  /  the  ability  to  select  options  according  to  their  individual 
circumstances; and  

  Best reflects existing sustainable procurement policy within the Member State.  

Three Member States took the decision to limit the number of options available to procurers 
in  some  way.  The  reasons  behind limiting  the  options  available  were  examined  in  more 
detail. Slovenia took the decision to allow only Option 2b (where energy and environmental 
impacts are monetised). Slovenia considered that technical specifications would have to be 
amended  regularly,  therefore    causing  additional  work  for  the  ministry  in  charge  of 
updating technical standards and other green  public procurement criteria in the Decree, 
and leading to potential difficulties for the contracting authorities and uncertainty of the 
suppliers  due  to  frequent  amendments  to  legislation.  As  formula  for  the  monetisation 
methodology are provided (Annexes to the Directive), they felt there would be no need to 
update the legislation (compared with technical standard approach, which they anticipated 
would have to be updated in future years). Also, by selecting the option that mandates the 
use  of  operational  lifetime  costs,  the  ministry  rationalised  that  contracting  authorities 
would become familiar with the lifecycle costing approach and would therefore hopefully 
use similar methodologies and formula in procurement of other goods, services and works.  

The  Czech  Republic  allows  option  1  (setting  technical  specifications)  transposed  into 
national legislation) and 2a (award criteria) (was an option in existing legislation – Czech 
Public Procurement Act). These options were selected as they were seen to be the least 
demanding way of transposing the Directive. Estonia only allows Option 1 (setting technical 
standards). Their reasons for doing so were not provided16.  

16 Neither the Czech Republic nor Estonia responded to engagement attempts.  

21 

 
 
 
 
 
                                           
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transport vehicles 

Supporting measures - In terms of supporting measures implemented by the Member 
States,  few  additional  measures  directly  aimed  at  the  promotion  of  clean  and  energy 
efficient road transport vehicles had been implemented.  

Many EU Member States have implemented measures that aim to support the objectives 
of the CVD, stimulating the uptake and use of clean and energy efficient vehicles (either 
measures existing prior to the introduction of the CVD or they have been introduced after 
its  implementation).  Many  of  these  measures,  while  including  organisations  that  are 
targeted by the Directive itself, are aimed at consumers and vehicle operators in general, 
including the private sector. The 2012 Monitoring report for CVD (Ricardo-AEA and TEPR 
2012)  and  Annex  8  (Member  State  fiches)  provides  a  detailed  overview  of  supporting 
measures that have been implemented in EU Member States. These cover: 

  Programmes of support/fiscal incentives for the purchase of vehicles; 
  Programmes of support/fiscal incentives for the development of infrastructure; 
  Local access restrictions; 
  Local demand management instruments; and 
  National, regional or local vehicle taxation. 

Whilst  the  types  of  supporting  measures  mentioned  above  will  contribute  towards 
stimulating  the  uptake  and  use  of  clean  and  energy  efficient  vehicles  and  achieving  the 
aims  of  the  CVD  (increased  energy  efficiency,  CO2  emission  and  air  pollutant  emission 
reductions from road transport sector), it is unlikely that they have been implemented as 
a direct  result of the Directive with the aim of  supporting its implementation. They also 
tend not to target vehicles procured by the public sector.  

However, in our engagement with stakeholders examples were identified where selected 
Member  States  had  implemented  measures  that  are  aimed  directly  at  the  public 
procurement  of  road  transport  vehicles  within  their  Member  State,  thus  supporting 
(explicitly  or  implicitly)  the  implementation  of  the  CVD.  Table  5-2  summarises  the 
responses that were received from Member States when asked about national supporting 
actions have been implemented in their country that aim to promote the purchase of clean 
and energy efficient vehicles by public authorities or public transport operators. 

Table 5-2: Examples of measures that support the objectives of the CVD 

Member 
state 

Croatia 

Details 

The Environmental Protection and Energy Efficiency Fund regularly co-
finances the purchase of energy-efficient vehicles. During the last two 
years  the  Fund  has  co-financed  the  purchase  of  30  buses  for  public 
passenger transport powered by compressed natural gas in the city of 
Rijeka  and  16  such  buses  in  the  city  of  Zagreb.  Currently,  in  the 
implementation phase is the project of City of Koprivnica which includes 
car  sharing  system  for  the  employees  of  the  City  and  City-owned 
companies, and the purchase  of two mini buses for public passenger 
transport powered by electricity. Such projects are co-financed in the 
amount of 40% of eligible investment costs. 

Germany 

Federal Ministries have agreed that at least 10 % of all newly purchased 
vehicles by authorities  and bodies of the federal administration must 
have only low emissions (50 g CO2/km or lower). 

Latvia 

1)  Tender  “The  reduction  of  greenhouse  gas  emission  in  transport 
sector” (projects financed by Climate Change Financial Instrument).   

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transport vehicles 

UK 

The objective of the tender is the reduction of greenhouse gas emission 
by  means  of  ensuring  adjustment  of  vehicles  for  the  use  of  energy 
produced from renewable energy resources, including: 

1. supporting adjustment of vehicles for the use of fuel produced from 
renewable energy resources instead of fuel of fossil origin; 

2. supporting provision of accessibility of fuel produced from renewable 
energy  resources,  by  installing  filling  stations  for  fuel  produced  from 
renewable energy resources for project needs, only together with the 
activity referred to in Sub-paragraph 1, and financing for this activity 
shall not exceed 20% of the total financing of the financial instrument 
requested in the project application. 

2)  The  order  no.12  issued  by  the  Cabinet  of  Ministers  in  October  2, 
2012  on  order  on  purchase  or  lease  of  service  vehicles  for  central 
government institutions that determines the ceiling amounts of carbon 
dioxide emissions allowed per year in such tenders. 

The  guidance  document  produced  by  the  UK  includes  a  section  on 
weightings. It is recognised that the Directive does not specify levels 
of  weighting that should be awarded to the  environmental criteria of 
vehicle performance relative to non-environmental criteria. 

The Low Carbon Vehicle Public Procurement Programme (LCVPPP) was 
set  up  in  2007  by  the  UK  Department  for  Transport  to  stimulate  the 
market  for  lower  carbon  vehicles  through  procurement.  It  developed 
and then part funded (£1.7m) the purchase of 500 low carbon vans by 
public sector fleets. Transport Scotland has also funded a procurement 
scheme to enable vehicle users to access grant assistance to buy low 
carbon vehicles. Similar schemes in Scotland have included the Electric 
Vehicle  Procurement  Support  Scheme,  where  funding  enabled  local 
authorities  and  their  partners  to  bridge  the  gap  between  the  cost  of 
petrol  or  diesel  powered  vehicles  and  their  electric  powered 
equivalents, as well as to install charging points on public sector owned 
land to support the vehicles. 

The Department for Transport's Green Bus Fund was set up to support 
the  introduction  of  low  carbon  vehicles  by  bus  companies  and  local 
authorities. Around £85m has supported the roll out of 1250 new low 
carbon buses that will have a positive impact on the environment.17 

A  new  Low  Emission  Bus  Fund  will  provide  additional  £30  million  to 
enable local authorities and bus operators to replace existing vehicles 
with greener, cutting-edge alternatives to help clean up air quality has 
been announced for 2015/16. 

The  Department  for  Transport’s  Clean  Vehicle  Technology  Fund 
provides  grants  of  up  to  £0.5m  to  local  and  transport  authorities  for 
upgrading vehicles to reduce emissions in areas of poor air quality in 
England. The total fund available for this scheme is £5 million. To date 
it has supported over a 1000 vehicles cut their pollutant emissions. 

The  Ultra-Low  Emission  Vehicle  Readiness  project  will  fund  the 
replacement  of  over  100  plug-in  cars  and  vans  in  the  government 
vehicle fleet as part of a commitment to green transport. The £5 million 
investment will also fund take-up by the wider public sector – including 

17 https://www.gov.uk/government/collections/background-to-the-green-bus-fund in 
EndNote 

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transport vehicles 

councils, police forces and the NHS  –  of plug-in vehicles and pay for 
charge-points  to  be  installed  to  allow  the  vehicles  to  be  charged  at 
work. 

5.2.  Current situation 

As mentioned earlier, Article 10 of the Directive requires that the Commission prepares a 
report every two years on the actions taken by individual Member States to promote the 
purchase  of  clean  and  energy-efficient  road  transport  vehicles.  The  reports  should  also 
assess the effects of the Directive, especially of the options referred to in Article 5(3), and 
the  need  for  further  action,  and  include  proposals  as  appropriate.  The  first  monitoring 
report was published in October 2012 (Ricardo-AEA and TEPR 2012). However, there is no 
requirement within the Directive for Member States to monitor or report on the effects of 
the  intervention.  After  extensive  research,  it  can  be  confirmed  that  very  little  data  is 
monitored or reported on at the national level with regards to public procurement of road 
transport vehicles.  

The  2012  Monitoring  Report  attempted  to  assess  the  impacts  of  the  CVD  to  date. 
Stakeholders  at  the  time  (mid-2012)  agreed  that  the  CVD  had  had  little  impact  on  the 
market for clean vehicles, and no stakeholders were able to provide any evidence for direct 
impact on the market. This was due to a number of reasons, including that the CVD had 
only been in force for a short period of time, with implementation in a number of Member 
States being delayed until 2012 (Ricardo-AEA and TEPR 2012).   

The Monitoring Report noted that it may not be possible to notice discernible impacts even 
after a longer period of time, due to the relatively low numbers of vehicles being purchased 
by  public  authorities  in  some  Member  States.  It  was  anticipated  that  in  other  Member 
States where purchases by public authorities make up a larger proportion of total sales, 
noticeable effects might be expected in future years. However, the report identified that a 
number  of  cites/Member  States  are  already  taking  action  to  procure  clean  and  energy 
efficient vehicles prior to the implementation of the CVD, so an increased uptake of cleaner 
vehicles  by  public  authorities  might  have  been  expected  regardless  of  how  they 
implemented the Directive (Ricardo-AEA and TEPR 2012).  

Other issues were also identified in the Monitoring Report which contributed to the difficulty 
in identifying the impacts of the intervention:  

  Current  situation  in  the  vehicle  market  meant  that  it  was  harder  than  normal  to 
identify the impacts, with many public authorities cutting back on the numbers of 
vehicles bought due to the on-going public spending cuts.  

  The monitoring report was undertaken only two years following the transposition of 
the  Directive  –  therefore  making  it  very  unlikely  that  a  significant  impact  would 
have been identified at this stage.  

  As  mentioned  earlier,  the  majority  of  the  Member  States  did  not  transpose  the 
Directive  into  national  legislation  by  the  deadline,  with  the  last  Member  States 
transposing in 2012 – therefore far less than two years to realise any impacts.  

  Road  vehicles  typically  have  a  lifetime  of  10  to  15  years,  and  although  public 
authorities may not  operate vehicles for their  entire lifetime, this, along with the 
relatively small proportion of the total vehicle market procured by public authorities, 
means that it would be very unlikely that even in the best scenario that an impact 
from the Directive would have been experienced by the vehicle market in only two 
years.  

  The lack of CO2 data for HDVs at the time was identified as a barrier to applying the 
Directive to such vehicles. It was anticipated that this would change in 2013 when 
the HDV engines would be tested according to the Worldwide Harmonised Heavy-

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transport vehicles 

Duty  transient  Cycle  (measuring  air  pollutant  emissions,  CO2  emissions  and  fuel 
consumption).  However,  to  date  this  hasn’t  happened  (Ricardo-AEA  and  TEPR 
2012).  

To our knowledge, none of the EU Member States have undertaken an evaluation of the 
impacts of the implementation of CVD (transposed legislation) in their respective countries. 
The UK indicated that an evaluation of the impacts of its NIM would be completed by the 
end of 2016 (as a result of a statutory requirements to undertake such an evaluation for 
all new legislation after 5 years of implementation). Additionally, Slovakia stated that they 
had undertaken an evaluation of the public procurement more generally  (not specifically 
on legislation relating to the Clean Vehicles Directive) where emphasis has been put on the 
impact on the environment (which is most likely the case for a number of other Member 
States). As part of this evaluation, Slovakian contracting authorities were asked to state 
the  proportion  of  contracts  that  did/not  use  environmental  criteria  when  procuring  road 
transport  vehicles  (cars,  trucks,  public  transport  services,  vehicles  and  waste  collection 
services).  

Due to the lack of requirements for Member States to monitor and report on the impacts 
of the CVD, and lack of national public procurement data related to clean vehicles more 
generally,  this  evaluation  (2015)  therefore  essentially  aims  to  establish  the  current 
situation in  qualitative  and  quantitative  terms.  This  will  be  achieved  through  addressing 
the 13 evaluation questions covering relevance, effectiveness, efficiency, EU added value, 
coherence, and sustainability (see Section 6).  

5.3.  Unexpected results  

A  few  unexpected  results  related  to  the  implementation  of  the  Directive  have  been 
identified and are discussed in more detail below.  

The Directive was designed to ensure flexibility for procurers when selecting and applying 
options presented in Article 5(3). However, our analysis has revealed that the options are 
not achieving the desired results due to the way they are being applied (discussed in more 
detail in answers to the evaluation questions, Section 6):  

  Option 1 – Setting technical standards - Procurers have tended to state minimum 
standards e.g. Euro 6, which is already the latest standard for new vehicles. The 
application  of  the  CVD  in  this  respect  has  no  impact  on  the  vehicle  they  are 
purchasing,  as  it  would  have  been  purchased  anyway.    If  there  aren’t  any 
new/forthcoming  standards,  then  the  Directive  becomes  meaningless.  Procurers 
also  do  not  always  set  standards  for  all  three  of  the  required  aspects  (fuel 
consumption,  CO2  and  pollutant  emissions),  due  to  misinterpretation  of  the 
Directive. 

  Option 2a – Award criteria – Again, procurers are using the flexibility in the Directive 
when using award criteria, most often place only a small weight on environmental 
criteria  which  leads  to  these  criteria  having  very  little  effect  on  the  procurement 
decision. 

 

It  was  reported  by  stakeholders  that  the  use  of  the  monetisation  methodology 
(Option 2b) tends to lead to a preference in diesel vehicles. Case studies undertaken 
for the purposes of this evaluation confirmed that this was the case (see Annex 9 
and further discussion in the answers to the evaluation questions).  

It was reported by a manufacturer that they developed their own test cycles  for special 
service vehicles (which were previously lacking) at cost of €20,000.  It was claimed that 
this  was  as  a  direct  result  of  the  introduction  of  the  CVD  and  the  lack  of  relevant  data 
required  to  apply  its  options.  However,  this  may  be  an  isolated  case,  and  possibly  as  a 
result of other drivers.  

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5.4.  Issues  

There are a number of issues that have been identified that are likely to be of relevance 
when assessing the impacts of the Directive. These emerging issues are important in the 
context of the evaluation of the Directive and are summarised below. They are discussed 
in more detail in the context of the appropriate evaluation questions (Section 6).  

Increasing divergence between real-world CO2 emissions and those measured on 
the  NEDC  -  Evidence  exists  of  this  increased  divergence  and,  whilst  data  collection 
methods  will  differ,  the  discrepancy  over  time  in  all  cases  appears  to  be  increasing  at 
similar rates (ICCT 2014) – see Figure 5-1. Other sources, including Fonaras et al (2012) 
and Ntziachristos et al (2014) have also reported similar discrepancies. As a result of these 
discrepancies, drivers are not receiving the anticipated benefits (e.g. CO2 emissions listed 
on the label required by Directive 1999/94), as only a proportion of the emission reductions 
that have been achieved on the test cycle are being delivered in the real-world. The main 
factors  contributing  to  these  discrepancies  includes  the  NEDC  test  cycle  not  being 
representative  of  real-world  driving;  manufacturers  increasingly  using  flexibilities  within 
the test cycle; and increased application and use of energy using devices in cars that are 
used in the real-world, but which are not  operational when measuring emissions on the 
test cycle (ICCT 2013, T&E 2013). This divergence also has implications for the impacts of 
the Clean Vehicles Directive, as any identified CO2 emissions reduction benefit as a result 
of  procuring  clean  vehicles  is  therefore  likely  to  be  less  in  the  real-word  than  it  would 
appear to be if the test cycle figures were accurate. 

Figure 5-1: Divergence between real-world fuel economy/CO2 emissions and test 
cycle fuel economy/CO2 emissions for passenger cars (ICCT 2014) 

Well-to-tank CO2 emissions – For some of the clean vehicles that the CVD is trying to 
promote procurement of (those vehicles using alternative powertrains), well-to-tank CO2 
emissions associated with the production of electricity (and hydrogen) can be considered 
a significant proportion of total lifecycle emissions  (Ricardo-AEA 2013). Therefore, some 
of the emission reductions that have been achieved according to the specific CO2 emissions 
as measured on the test cycle will have been replaced by increased emissions elsewhere 

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(e.g. electric vehicles are measured to have zero CO2 emissions on the test cycle, but their 
true ‘in use’ emissions should also include CO2 emitted as part of the CO2 production of the 
electricity).  Therefore  any  emissions  reduction  benefit  identified  as  resulting  from  the 
implementation  of  the  CVD  is  likely  to  be  less  in  the  real-world  when  well-to-tank  CO2 
emissions are taken into account.   

Economic  Crisis  –  The  economic  crisis  of  the  late  2000s/early  2010s  which  affected 
economic activity in Europe will almost certainly have affected levels of procurement by 
public  authorities/entities  and  those  procuring  on  their  behalf.  The  CVD  was  being 
introduced  as  public  authorities  were  minimising  public  procurement.  Therefore  the 
number  of  road  transport  vehicles  being  publically  procured  and  that  are  subject  to  the 
requirements  of  the  Directive  is  likely  to  be  far  lower  than  would  have  been  originally 
envisaged. This is likely to have had an influence on the potential impacts that could have 
been gained to date if the level of public procurement of road transport vehicles had been 
higher and not limited by the economic crisis.  

Availability of CO2 data for HDVs - According to Article 6(2) of the Directive information 
on fuel consumption, CO2 and air pollutant emissions should, in the first instance, come 
from the results of the standardised Community test procedures used for type approval. 
For those  vehicles for  which there are no  such official tests, the data should come  from 
“widely recognised test procedures,” the results of tests for the contracting authority, or 
information supplied by manufacturers. However, for heavy duty vehicles, there is not, at 
present,  any  harmonised  community  standard  for  measuring  fuel  consumption  or  CO2 
emissions,  and  it  is  prohibitively  difficult  for  most  contracting  authorities  to  obtain 
objective, comparable data on these vehicles from other sources, for the following reasons: 

  Fuel consumption data from manufacturers will not be measured on a like-for-like 

basis. 

  Although  there  is  evidence  that  a  small  number  of  contracting  authorities  have 
created their own bespoke test procedures in order to make comparisons between 
vehicles, the resources required from contracting authorities (and from suppliers) 
to orchestrate these tests will not be available to the vast majority of contracting 
authorities. 

  Other  contracting  authorities  suggested  they  could  make  comparisons  between 
heavy  duty  vehicles  using  other  information  that  is  (sometimes)  already  in 
existence, such as performance over the SORT2 test cycle, or DIN norms. However, 
this  information  is  not  universally  available  and  the  only  contracting  authorities 
claiming  to  make  use  of  it  appeared  to  have  an  unusually  high level of  technical 
understanding which most contracting authorities probably lack. 

However,  it  should  be  noted  that  in  the  absence  of  a  common  EU-level  approach  for 
estimating  the  CO2  emissions  of  buses,  the  UITP’s  Standardised  On-Road  Test  (SORT) 
cycles  have  been  used,  which  could  potentially  be  used  in  the  future  as  a  basis  for 
developing CO2 measurements.  

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6.  ANSWERS TO THE EVALUATION QUESTIONS 

6.1.  Introduction 

This section provides answers to each of the 13 evaluation questions and constitutes the 
main part of the Evaluation Report. The responses to the evaluation questions draw upon 
the work carried out in the data collection and analysis stage and additional research where 
necessary.  

6.2.  Relevance: To what extent is increasing the market share of clean 
vehicles  an  adequate  means  to  contribute  to  the  overall  objectives  of 
increasing the energy efficiency and competitiveness and decreasing CO2 
and pollutant emissions of transport? (Q1) 

6.2.1.   Approach to answering the evaluation question  

Prior to answering this question, it is first necessary to explore what the question is actually 
asking in more detail.  

First, it is necessary to consider what is meant by the term ‘clean vehicle’ in the context of 
the question. At the simplest level, a clean vehicle is one with lower environmental impacts, 
so  it  is  clear  that  increasing  the  market  share  of  such  vehicles  will  contribute  to  the 
objectives of reducing emissions and increasing energy efficiency18. However, in order to 
move beyond this simple and not very interesting or insightful answer, it is necessary to 
consider  in  more  detail  which  types  of  vehicles  contribute  to  such  objectives.  This  is 
explored in Section 6.2.2. It is also worth noting that uncertainty over what was meant by 
the term ‘clean vehicle’ was mentioned by some EU level stakeholders as a reason for them 
having difficulty in answering the related interview question (see Annex 4).  

Second,  the  question  is  not  clear  as  to  what  is  meant  by  the  “competitiveness  …  of 
transport”.  In  the  course  of  the  engagement  with  EU  level  stakeholders,  a  number  of 
different interpretations of this question were proposed (see Annex  4). From the Impact 
Assessment  accompanying  the  revised  proposal  for  the  Directive,  it  is  clear  that  the 
“competitiveness”  to  which  the  Directive  would  contribute  is  that  of  the  EU  automotive 
sector (European Commission 2007). However, stakeholders also interpreted the question 
as  referring  to  the  competitiveness  of  EU  industry  more  generally  and  to  the 
competitiveness  of  clean  vehicles  in  the  market  place.  This  issue  is  discussed  further  in 
Section 6.2.3.  

Third, a number of stakeholders queried what was meant by the use of the word ‘adequate’ 
in the question; these stakeholders instead answered the question by replacing the word 
‘adequate’ either with the word ‘sufficient’ or ‘beneficial’ (see Annex 2). In order to ensure 
that this evaluation question is answered appropriately, both of these interpretations are 
discussed below (see Section 6.2.5), while some additional considerations with respect to 
this issue are set out in Section 6.2.4.  

In order to fully evaluate relevance, it is also necessary to consider the extent to which the 
objectives,  i.e.  those  stated  in  the  question  of  “increasing  the  energy  efficiency  and 
competitiveness and decreasing CO2 and pollutant emissions of transport” are relevant to 
the wider needs that led to the publication of the proposal for the Directive and whether 

18 It is worth noting that neither of the two proposals from the Commission for the Directive needed to define a 
‘clean vehicle’. The original proposal focussed only on vehicles weighing above 3.5 tonnes and referred to a 
pre-existing  performance  standard,  i.e.  that  of  Enhanced  Environmentally  Friendly  Vehicles  (EEVs),  as 
defined in Directive 2005/55 (European Commission, 2005a). The revised proposal focused on the mandatory 
consideration of operational lifetime costs (European Commission, 2007c). 

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these  will  continue  to  be  relevant.  While  this  is  not  explicitly  required  to  answer  the 
questions, it is important to undertake such analysis to understand the wider relevance of 
the Directive, which is needed in order to inform conclusions about the extent to which it 
still has a role to play. 

In  other  words,  the  extent  to  which  the  following  needs  are  pertinent,  and  will  remain 
pertinent, will be assessed: 

  Need to decrease CO2 emissions of transport;   

  Need to increase the energy efficiency of transport; 

  Need to decrease pollutants emissions of transport; and 

  Need to increase the competitiveness of transport. 

The pertinence of these needs is explored in Section 6.2.2.   

6.2.2.  Evaluation of the extent to which it is, and will continue to be, important to increase 
the energy efficiency and competitiveness of transport and to reduce its CO2 and pollutant 
emissions 

In order to evaluate the extent to which there is, and will continue to be, a need to reduce 
transport’s  CO2  emissions,  it  is  first  worth  underlining  that  there  remains  a  need  to 
reduce  greenhouse  gas  emissions  (GHGs)  more  generally, including  CO2  which  is  by  far 
the most common GHG emitted by the transport sector. In its most recent assessment of 
the evidence, the Intergovernmental Panel on Climate Change (IPCC) concluded that there 
was a need for “substantial and sustained reductions of greenhouse gas emissions” as the 
evidence was more conclusive than ever that the global climate is warming as a result of 
increased concentrations of GHGs in the atmosphere that are the result of human activity 
(IPCC 2013). The EU has already committed itself to delivering significant reductions in its 
GHG emissions. The Commission’s 2011 Low Carbon Roadmap set the framework for the 
development  of  EU  policy  action  to  meet  an  80  to  95%  reduction  in  GHG  emissions  by 
2050 compared to 1990 levels. The Roadmap concluded that cost-effective reductions of 
GHG emissions of between 54% and 67% by 2050 compared to 1990 could be delivered 
by the transport sector (European Commission 2011, European Commission 2011). Hence, 
in order to meet long-term economy-wide CO2 reduction targets, there is a need to reduce 
transport’s CO2 emissions.   

In  order to  evaluate whether there is, and will continue to be, a  need to improve the 
energy  efficiency  of  transport,  it  is  necessary  to  identify  what  the  required  GHG 
reductions above imply for transport in terms of improvements in vehicle efficiency. The 
Commission’s 2011 Transport White Paper explored the implications of delivering such GHG 
emissions reductions, as it took as its starting point the need to reduce transport’s GHG 
emissions  by  60%,  i.e.  the  midpoint  in  the  range  identified  by  the  Roadmap  (European 
Commission 2011). The policy option that the Impact Assessment accompanying the White 
Paper identified as its preferred option included action to reduce the CO2 emissions of all 
transport vehicles. This assumed that the average CO2 emissions from new cars would be 
only 20 g/km by 2050, compared to the target of 95 g/km in 2020, while the equivalent 
figure  for  LCVs  would  be  55g/km  compared  to  the  2020  target  of  135  g/km.  For  heavy 
duty vehicles a 40% improvement in energy efficiency was assumed by 2050  (European 
Commission 2011). Other studies have also concluded that there is a need to deliver such 
reductions from vehicles in order to meet the CO2 reduction levels assumed by the White 
Paper. A report for the European Commission’s DG Climate Action concluded that reducing 
transport’s CO2 emissions by 60% by 2050 compared to 1990 levels required reductions 
in lifecycle CO2 emissions of 80% for cars, buses and vans, and of between 60 and 75% 
for heavy goods vehicles in parallel to action to improve vehicle efficiency in other modes 
of transport (e.g. rail, air and water transport), improvements in operational efficiency and 
the decarbonisation of fuels and energy sources (Ricardo-AEA, TEPR et al. 2012).  

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For  vehicles  that  use  fossil  fuels,  reducing  the  CO2  emissions  of  road  transport  will 
necessarily  require  improving  the  fuel  efficiency,  and  therefore  the  energy  efficiency,  of 
vehicles, as the CO2 emitted is closely linked to the energy consumed. For vehicles that 
use electricity and hydrogen, this link is not as direct, as in-use CO2 emissions for these 
energy sources are zero (see Section 5.4). Hence, the energy efficiency of such vehicles 
could be relatively poor, but their in-use emissions would be unaffected. However, given 
the levels of investment that are required to decarbonise the electricity sector in particular 
(European Commission 2011), it would seem prudent to ensure that the energy consumed 
in transport as a result of its electrification is consumed as efficiently as possible. Hence, 
it can be concluded that there is a continuing need to imrpove the energy efficiency of the 
transport sector for all fuel types. 

EEA (2014), which drew on the latest evidence concerning health and air quality from the 
World  Health  Organisation  (WHO),  underlines  that  there  is  a  still  a  need  to  reduce 
pollutant  emissions,  generally,  and  those  from  transport  in  particular.  The  report 
highlighted that transport was the largest emittor of the oxides of nitrogen (NOX) and a 
significant  emitter  of  large  and  fine  particulate  matter  (PM10  and  PM2.5,  respectively).  It 
was  estimated  that  between  21%  and  30%  of  the  urban  population  of  the  EU-28  are 
exposed to concentrations of PM10 above EU air quality limit values, while the equivalent 
figures are 10% to 14% for PM2.5 and 8% to 13% for NOX. WHO has air quality guidelines 
(AQG)  for  the  same  pollutants  that  indicate  the  levels  at  which  it  believes  health  risks 
would be reduced to a minimum on the basis of the latest scientific evidence (WHO 2013). 
For some pollutants, these AQGs are tighter than the existing EU limit values. EEA (2014) 
demonstrates that over 91% of the EU’s urban population is exposed to levels of PM2.5 that 
exceed the respective WHO AQG, while the equivalent figure for PM10 is 64%19. The role of 
road transport in these exceedances is clear as the daily limit value for NOX was exceeded 
at 37% of ‘traffic’ monitoring sites20, while the equivalent figures for PM10 and PM2.5 were 
22% and 4%, respectively. Of the transport measures suggested that would contribute to 
reducing the adverse of transport on air quality, a shift to the use of cleaner vehicles was 
mentioned.   

The  need  to  increase  the  competitiveness  of  transport  was  a  theme  of  the  2011 
Transport White Paper, including the role of transport in enhancing the competitiveness of 
the  wider  economy  (European  Commission  2011).  The  need  to  strengthen  the 
competitiveness of the EU automotive sector is emphasised by the multi-stakeholder CARS 
2020 process (European Commission 2012). An earlier report from the CARS 2020 process 
also  highlighted  that  the  competitiveness  of  the  EU  automotive  industry  can  only  be 
assured if it delivers sustainable and advanced products (European Commission 2012). 

Hence,  it  can  be  concluded  that  there  remains  a  need  to  decrease  transport’s  CO2  and 
pollutant emissions, and to increase its energy efficiency and competitiveness.  

6.2.3.  The potential contribution of ‘clean vehicles’ to increasing the energy efficiency and 
decreasing the CO2 and pollutant emissions of transport 

As was discussed above, the term ‘clean vehicle’ is generally taken to mean a vehicle that 
has  less  environmental  impact.  Hence,  at  the  simplest  level,  having  more  vehicles  with 
less environmental impact should improve the energy efficiency of transport and decrease 
its CO2 and pollutant emissions. However, for the purpose of this evaluation, it is useful to 
identify  which  types  of  vehicle  might  be  considered  to  be  contributing  to  the  specified 
objectives,  and  which  therefore  might  be  considered  to  be  ‘clean’  in  the  context  of  the 
question.  

19 The proportion of the EU urban population exposed to NOX levels above the respective WHO AQG is the same 

as that for the respective EU emission limit value.  

20 ‘Traffic-related’ monitoring sites are one of four types of fixed air quality sampling points in Europe, the others 

being urban/suburban background, rural background and industrial (EEA, 2014).  

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transport vehicles 

For the purpose of evaluating the first two ‘effectiveness questions’ (see Sections 6.2 and 
6.4.1),  information  on  the  environmental  performance  of  comparable  vehicles  has  been 
gathered in order to identify the impacts of the methodology to monetise environmental 
and operational costs. This draws on the case studies set out in Annex 9. On the basis of 
the data used in these case studies, the contributions of different vehicle technologies to 
the objectives being considered in this section can be identified. As can be seen from Figure 
6-1 and the graphs presented in Annex 12, the most appropriate vehicle technology for a 
public  authority  would  differ  depending  on  whether  its  main  concern  is  air  pollution  or 
energy efficiency/CO2 emissions. This choice is also dependent on vehicle type as Euro VI 
standards for buses deliver the expected reductions in NOx emissions when in use, whereas 
this is not the case for Euro 6 standards for cars. Additionally, as the graphs only focus on 
in-use  emissions,  electric  vehicles  are  presented  as  having  zero  CO2  and  pollutant 
emissions (as would hydrogen vehicles), but this ignores the impact of upstream emissions. 
If the total lifecycle emissions of both electricity and hydrogen are taken into account, the 
benefits  of  these  technologies  over  those  of  other  vehicle  technologies  diminish  with 
respect  to  CO2  (as  was  demonstrated  in  Section  5.4).  Similar  issues  exist  for  biofuel 
vehicles.  Hence,  different  vehicles  might  be  considered  to  be  ‘cleaner’  from  different 
perspectives. 

Figure 6-1: Emissions of NOX, CO2 and the energy consumption of different types 
of bus 

Source: VTT (2013) 

The implications of this discussion are further complicated by the extent to which improved 
Euro  standards  deliver  emissions  reductions  in  practice.  In  theory  Euro  6  standards  for 
diesel cars and LCVs reduce the NOX limit value by more than half compared to Euro 5 (i.e. 
from 180 mg/km to 80 mg/km) for these vehicles. These limit values are measured on the 
test cycle (see Section 5.4). Real world tests have suggested that in practice NOX emissions 
can be six times as high as the limit value, which means that their real world emissions 
are comparable to those of Euro 5 and even Euro 4 vehicles (TNO and TU Graz 2013). 

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transport vehicles 

Such differences were noted by EU-level stakeholders in their responses to the interview 
question that corresponded to this evaluation question (see Annex 2). These stakeholders 
were generally positive that increasing the market share of clean vehicles would help to 
improve  transport’s  energy  efficiency  and  to  reduce  it  CO2  and  pollutant  emissions,  but 
many qualified their response with comments indicating that it depends on the types  of 
vehicle that were being considered. 

Hence, increasing the market share of some vehicles has the potential to contribute to the 
delivery of one or another of the objectives considered in this section, as for a particular 
objective, certain technologies are potentially more beneficial than others. For fossil fuels, 
there are benefits from diesel vehicles in terms  of  CO2  emissions and energy  efficiency, 
while petrol and to a larger extent gas vehicles generally have lower NOX emissions than 
diesel vehicles, although even here Euro VI buses can have fewer NOX emissions than gas 
buses  (see  Annex  9).  When  only  considering  in-use  emissions,  electric  and  hydrogen 
vehicles  emit  significantly  fewer  CO2  and  pollutant  emissions,  but  once  the  lifecycle 
emissions  are  also  considered,  the  benefits  over  other  vehicles  diminish.  A  further 
consideration is that for the technologies that are  comparatively less well used, such as 
gas, or relatively new on the mass market, such as electricity and hydrogen, improvements 
could be quicker, and be potentially more significant in terms of emissions and efficiency, 
than developments in the more established technologies, such as petrol and diesel.      

6.2.4.  ‘Clean vehicles’ and the competitiveness of transport 

As noted in Section 6.2, there is a lack of clarity about what the question means in relation 
to ‘competitiveness’. At the high level, competitiveness is clearly important, but practically 
it is difficult to assess the extent to which specific actions contribute to increasing it. The 
recent  evaluation  of  the  passenger  car  and  LCV  CO2  Regulations,  which  clearly  aim  to 
increase the market share of clean vehicles, was not able to conclude the extent to which 
those Regulations had had an impact on the competitiveness of the EU automotive sector. 
It did note that stakeholders, both those spoken to for the purpose of that evaluation as 
well as those who responded to other surveys, viewed the Regulations as being beneficial 
for the  competitiveness of the automotive industry.  In the  short-term, there were  more 
negative  responses,  as  a  result  of  the  costs  needed  for  the  development  of  cleaner 
technologies and the current low demand for such technologies now that they are being 
put onto the market. In the longer-term the Regulations were generally considered to be 
beneficial for competitiveness as they force the development of new technologies (Ricardo-
AEA and TEPR 2015). This latter point echoes a statement from the CARS 2020 process 
noted above about the importance of developing advanced, sustainable products for the 
competitiveness of the automotive industry (see Section 6.2.2).  

In  Ricardo-AEA  and  TEPR  (2015)  the  ‘competitiveness’  that  was  the  concern  of  the 
evaluation was explicitly that of the automotive industry. As noted by stakeholders in the 
course  of  the  engagement  undertaken  for  this  evaluation,  it  is  not  clear  to  whose 
competitiveness the question being considered here refers (see Annex 2). It was also noted 
by a stakeholder that the EU automotive sector was already competitive and did not need 
additional  measures  to  assist  it  in  this  respect.  This  statement  has  echoes  in  the  most 
recent  CARS  2020  report,  which  talks  about  taking  competitiveness  into  account  when 
developing 
legislation  does  not  adversely  affect 
competitiveness. This report also notes that the promotion of investment in technologies 
for  clean  and  energy  efficiency  vehicles  is  important  to  the  competitiveness  of  the  EU 
automotive  sector  and  that  its  leadership  globally  in  this  respect  is  being  challenged 
(European  Commission  2014).  In  other  parts  of  the  world,  there  are  various  pieces  of 
legislation  similar  to  the  passenger  car  and  van  CO2  Regulations  that  require  the 
automotive industry to develop and market more efficient vehicles (Ricardo-AEA and TEPR 
2015), which no doubt contributes to the challenge to the EU industry’s leadership in this 
respect. 

legislation  and  ensuring  that 

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transport vehicles 

A  potential  link  between  the  increased  use  of  clean  vehicles  and  other  potential 
interpretations of ‘competitiveness’ can also be identified. For example, if the use of clean 
vehicles can, or have the potential to, reduce the transport costs incurred by industry when 
the total costs of ownership are considered, this would contribute to the competitiveness 
of industries in which transport costs are significant. If cities were to increase the use of 
clean vehicles whilst reducing the use of conventional vehicles, air quality should improve, 
which in turn improves the quality of life for those living and working in the city, which can 
in turn help attract more investment and thus contribute to a city’s competitiveness.  

Hence,  while  it  is  difficult  to  quantify  changes  to  ‘competitiveness’,  it  is  clear  that 
the 
stakeholders 
competitiveness of the automotive sector, while the use of such vehicles has the potential 
to affect other types of competitiveness. 

the  development  of  sustainable,  advanced  vehicles 

link 

to 

6.2.5.  Adequate versus beneficial policies 

As noted in Section 6.2, expecting the CVD to be sufficient (i.e. ‘adequate’) to increase the 
market  share  of  clean  vehicles  is  an  ambitious  expectation.  Indeed,  the  Commission’s 
proposal  that  led  to  the  adoption  of  the  CVD  highlighted  that  promoting  the  use  of  low 
carbon  vehicles  in  public  procurement  would  reinforce  the  various  elements  of  the 
Commission’s passenger car CO2 strategy (i.e. passenger car CO2 Regulation, the CO2/fuel 
efficiency labelling Directive and CO2-based fiscal measures), while the faster introduction 
of  “cleaner  vehicles”  would  help  public  authorities  meet  their  obligations  under  the  air 
quality  Directives21.  Hence,  at  its  inception,  the  CVD  was  seen  as  part  of  a  package  or 
complementary  measures.  The  complementary  role  of  public  procurement,  if  not  of  the 
Directive specifically, was also highlighted in the Commission’s 2011 Transport White Paper 
(European  Commission  2011).  Hence,  in  relation  to  whether  the  CVD  is  ‘adequate’  or 
‘beneficial’, the assessment of the latter would appear to be more appropriate.     

6.2.6.  Conclusion on the adequacy of increasing the market share of clean vehicles as a 
means  of  contributing  to  increasing  the  energy  efficiency  and  competitiveness  and 
decreasing CO2 and pollutant emissions of transport 

The  previous  sections  set  out  some  of  the  issues  and  potential  interpretations  that  are 
important to enable this evaluation question to be answered.  

At the conceptual level, if a clean vehicle is taken to be one that has less environmental 
impact  (in  terms  of  its  CO2  and  pollutant  emissions  and  energy  use),  it  is  clear  that 
increasing  the  market  share  of  such  vehicles  has  the  potential  to  contribute  to  the 
objectives of increasing transport’s energy efficiency and of reducing its CO2 and pollutant 
emissions.  However,  as  was  discussed  in  Section  6.2.2,  different  vehicle  technologies 
contribute to different objectives in different ways, which complicates the answer to the 
question. Without defining what is meant by the term  ‘clean vehicle’, the answer to the 
question  as  to  whether  increasing  the  market  share  of  clean  vehicles  is  beneficial  to 
increasing  energy  efficiency  and  reducing  emissions  would  appear  to  be:  “It  depends”. 
However,  it  was  clear  from  the  discussion  in  Section  6.2.2  that  there  are  vehicles  that 
might be considered to be less polluting and more energy efficient than others. Hence, if 
the market share of the ‘right type’ of clean vehicle was increased, it would contribute to 
increasing  the  energy  efficiency  and  to  reducing  the  CO2  and  pollutant  emissions  from 
transport. The lack of clarity as to what can be considered to be a ‘clean vehicle’ is also 
relevant in response to other questions; these strands are brought together in Section 8.       

The discussion in Section  6.2.3 suggests that  stakeholders generally see a link between 
the development of cleaner vehicles and competitiveness, although there is a question as 
to the direction of the causality. While the development of sustainable, advanced vehicles 
is  important  to  the  competitiveness  of  the  EU  automotive  sector,  it  is  this  development 

21 Annex 14 outlines these (and other) EU policies and instruments.  

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transport vehicles 

that  leads  to  the  increased  market  share  of  clean  vehicles,  rather  than  the  other  way 
around as implied by the question. Hence, an increased share of clean vehicles could be 
taken  to  be  a  sign  of  the  competitiveness  of  the  automotive  sector,  rather  than  an 
increased market share increasing its competitiveness. On the other hand, an increased 
market share of clean vehicles has the potential to be beneficial on the competitiveness 
of the EU economy more generally, if the total costs of transport are reduced from the use 
of  more  efficient  vehicles,  and  on  cities,  as  these  improve  their  environments  and  so 
become more attractive places to invest. 

Hence, the conclusion is that while increasing the market share of clean vehicles is not an 
adequate means of contributing to the stated objectives, it can be beneficial as long as the 
market shares of the appropriate “clean vehicles” are increased.     

6.3.  Relevance: To what extent is stimulating the public procurement of 
clean vehicles an adequate mean to contribute to the overall objectives of 
increasing the energy efficiency and competitiveness and decreasing CO2 
and pollutant emissions of transport? (Q2) 

6.3.1.  Approach to answering the evaluation question  

In  this  section  we  examine  more  specifically  the  extent  that  “stimulating  the  public 
procurement  of  clean  vehicles”  –  the  main  mechanism  through  which  the  Directive  is 
expected to contribute to increasing the market share  of  clean vehicles  –  represents an 
adequate means of contributing to increasing the energy efficiency and competitiveness of 
transport and to reducing its CO2 and pollutant emissions. We also explore two additional 
elements that will assist with the understanding of the potential role of public procurement 
in delivering the stated objectives. Section 6.3.2 explores the relationship between public 
procurement  and  increasing  the  market  share  of  clean  vehicles,  while  section  6.3.3 
examines the role of public procurement in terms of meeting environmental and economic 
objectives.   

6.3.2.  Public procurement and increasing the market share of clean vehicles 

In  general  terms,  public  procurement  appears  to  have  only  a  limited  direct  role  in 
increasing  the  market  share  of  clean  vehicles.  Analysis  of  available  vehicle  registrations 
suggest  that  for  most  types  of  vehicle,  the  proportion  of  new  vehicles  procured  by  the 
public sector is relatively small compared to the size of the respective new vehicle markets. 
The exception to this is buses, of which a significant proportion – perhaps even a majority 
– are still procured by the public sector. There are a wide range of vehicles included under 
the definition of ‘rigid truck’, some of which will be almost exclusively used, if not by public 
authorities,  then  in  services  procured  by  them,  e.g.  household  waste  collection  vehicles 
(see Table 6-1).  

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transport vehicles 

Table 6-1: Estimated number and share of annual registrations of selected new 
vehicles that are procured by the public sector between 2012 and 2015 

Vehicle type 

Cars 

Vans 

Rigid trucks 
(does not 
include 
tractor-
trailers) 

Buses (does 
not include 
coaches) 

Lower  estimate 
(based  on  TED 
data)  

 29k 

 10k 

 11k 

 4k 

Higher estimate :    405k 

 40k 

 12k  

 18k 

Source: Estimates made for this report (see Section 2.2/Annex 1). Note: see section 6.4 
for discussion of the difference between the lower and upper estimates. 

In  conclusion,  in  terms  of  the  potential  direct  impact  on  the  market  for  clean  vehicles, 
public procurement has a relatively small role to play, particularly for passenger cars and 
LCVs. It has a greater direct impact in other vehicles categories, predominantly in the case 
of buses (excluding coaches) and, to a lesser extent, rigid trucks, where publicly procured 
vehicles represent a more important part of the market. For buses, the public sector has a 
potentially  significant  role  to  play,  and  so  public  procurement  is  potentially  a  lot  more 
relevant than for other vehicles.     

6.3.3.  The role of public procurement in meeting environmental and economic objectives 

While the direct contribution of public procurement to increasing the clean vehicle market 
might be small, there are other reasons for employing public procurement to increase the 
market share of clean vehicles. Such procurement, which might be labelled as green public 
procurement (GPP) or sustainable public procurement, has the potential to contribute to 
improving the environment and to improving the quality of life of citizens (not least as a 
result of environmental improvements). In adopting GPP practices, public authorities can 
also contribute to raising awareness about environmental issues amongst their citizens and 
can also take leadership by acting as an example to private consumers and businesses. 
Additionally, there is the potential to save money in the longer-term, as the higher upfront 
costs of many green products are more than covered by the cost savings generated in the 
course of their use, due to the better energy efficiency of such products, for example. The 
adoption of GPP practices at sufficient scale can also send signals to industry that there is 
a market for greener products if these are produced and therefore can help to stimulate 
industry to innovate (European Commission 2008). 

Some of these considerations were evident in the Commission’s proposal that led to the 
adoption of the CVD. It was noted that there was significant scope for improving the energy 
efficiency  of road transport vehicles and for reducing their CO2 and pollutant emissions, 
but that the widespread introduction of the relevant technologies was hampered by their 
high  purchase  prices  and  a  subsequent  lack  of  consumer  demand  for  such  vehicles. 
Furthermore it was noted that manufacturers were unlikely to  develop clean and energy 
efficient vehicles in response to local or national measures and so action at the European 
level  was  justified.  The  role  of  public  procurement  in  stimulating  the  market  for  clean 
vehicles was particularly emphasised. Encouraging investment in such vehicles by public 
authorities should help to increase the market for such vehicles and thus help to deliver 
the economies of scale that will lead to lower production costs and lower prices. In turn, 
this should help to stimulate demand more generally (European Commission 2007). The 
role  of  the  public  procurement  of  clean  vehicles  in  contributing  to  the  delivery  of  the 
objectives  of  environmental  and  energy  policy,  its  demonstration  of  leadership  and  its 
assistance  with  the  creation  of  a  market  for  clean  vehicles  have  been  noted  elsewhere 
(Clean Fleets 2014). 

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transport vehicles 

Stakeholders’  views  on  the  role  of  public  procurement  in  meeting  the  stated  objectives 
were  generally  positive  and  in  line  with  the  responses  relating  to  the  first  evaluation 
question. Several underlined that public procurement was a useful tool and that it was part 
of  a  more  comprehensive  approach  to  delivering  the  stated  objectives.  However,  it  was 
interesting to note that when asked to identify the most useful measures for stimulating 
the demand for clean and energy efficient vehicles, public procurement was not generally 
considered to be the most useful measure, which was at least partially due to stakeholders’ 
perceptions that the Directive has had little impact (see Annex 2).  

6.3.4.  Conclusion on the adequacy of stimulating the public procurement of clean vehicles 
as  a  means  of  contributing  to  increasing  the  energy  efficiency  and  competitiveness  and 
decreasing CO2 and pollutant emissions of transport 

The  direct  effects  of  public  procurement  with  respect  to  increasing  transport’s  energy 
efficiency,  decreasing  its  CO2  and  pollutant  emissions,  and  contributing  to  increasing 
competitiveness are only limited due to the small share of publically procured vehicles in 
the total vehicle market. However, the public procurement of clean products has also wider 
benefits in terms of increasing the overall market share of clean vehicles. Increasing the 
overall  market  share  of  clean  vehicles  is  recognised  as  relevant  by  stakeholders  in 
contributing  to  the  stated  objectives,  than  is  evident  simply  from  the  direct  effects  of 
publically procured vehicles on emissions and energy consumption.  Consequently, while 
stimulating  public  procurement  cannot  be  considered  to  be  an  adequate  (i.e.  sufficient) 
means of contributing to the stated objectives, it can be clearly be beneficial with similar 
caveats as for the previous question.      

6.4.  Effectiveness:  To  what  extent  has  the  mandatory  inclusion  of 
the 
operational 
procurement decision led to an increased market share of clean vehicles 
and contributed to reducing CO2 and pollutant emissions (NOX, NMHC and 
particulate matter) from the transport sector? (Q3) 

lifetime  environmental  and  energy 

impacts 

in 

6.4.1.  Approach to answering the evaluation question  

This evaluation question examines the presence and the level of impact on the market of 
clean vehicles that could be associated with the Directive. It also attempts to quantify the 
level  of  reductions  in  CO2  and  air  pollutant  emissions  that  can  be  associated  with  the 
implementation of the Directive in comparison to the baseline (presented in section 2.2).  

We combined quantitative and qualitative data collected as part of the fieldwork (surveys, 
interviews)  with  other  secondary  sources  of  information  to  develop  a  model  that  helps 
estimate the impacts of the policy. Any underlying assumptions made are explained.  

Finally, Section 6.4.4 compares the results of the evaluation with the findings of the 2007 
Impact  assessment  (European  Commission  2007a)  and  explains  the  underlying  reasons 
for the important differences in the findings of the two studies.   

6.4.2.  Analysis  of  the  impact  of  the  CVD  on  the  market  share  of  clean  vehicles,  on  CO2 
emissions and on air pollutant emissions 

The mandatory inclusion of operational lifetime environmental and energy impacts in the 
public  procurement  decisions  should  contribute  to  clean  vehicles  securing  a  significantly 
greater share of the market. According to the intervention logic this should take place as 
a result of the increasing share of clean vehicles in public procurement, as well as due to 
the effects of this on wider consumer trends. The increase in the share of clean vehicles 
should  eventually  result  in  a  certain  level  of  improvement  in  overall  transport  energy 
efficiency and CO2 and pollutant emissions from the transport sector.  

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transport vehicles 

However, the inputs from the survey of procurers and other sources suggest that important 
parts of the expected mechanisms, and the respective results have not materialised. The 
underlying reasons driving this finding are:    

  The number of vehicles procured by contracting authorities is small relative to the total 
number of vehicles procured in the wider market and the Directive only covers a certain 
proportion  of  the  vehicles  publicly  procured  (those  that  are  above  the  EU  public 
procurement thresholds or the respective national thresholds). 

  Only a small share of contracting authorities have used the monetisation methodology 
(Option 2b). Most contracting authorities chose the technical standards option, setting 
minimum  technical  standards  for  vehicles  (Option  1)  which  the  large  majority  of 
vehicles in the market already meet. Furthermore, contracting authorities using award 
criteria  (Option  2a)  most  often  place  only  a  small  weight  on  environmental  criteria 
relative to other considerations (such as price) in the procurement decision.  
In many cases, the procurers who have set stringent standards for energy efficiency 
and  emissions  performance  evidently  would  have  set  similar  standards  without  the 
Directive.  

 

  No (or very limited) CO2 emissions benefits are realised for heavy-duty vehicles as a 
result of the Directive, because the necessary comparable data on the CO2 performance 
of these vehicles is too difficult for contracting authorities to obtain in the absence of 
commonly  used  standardised  test  procedures  for  measuring  the  CO2  performance  of 
these types of vehicles. 

These points are explained in detail in the following paragraphs. 

Volume of publicly procured vehicles 

As  already  analysed  in  detail  in  section  2.2  (summarised  in  Table  6-2),  the  maximum 
estimated  number  of  new  vehicles  purchased  by  public  contracting  authorities  is  0.475 
million  per  year  (upper  estimate),  representing  3.5%  of  the  total  new  passenger  cars, 
vans, rigid trucks and buses purchased each year. As can be seen, in the case of buses 
public procurement may account for a much greater share (up to 75%) of the total vehicles 
bought.   

Table 6-2: Estimates of vehicles publicly procured on an annual basis  

Vehicle type 

Vehicles purchased under 
Directive 

Share of total vehicles purchased  

Lower 
estimate 
(‘000) 
 29k 

Passenger cars 

Upper estimate 
(‘000) 

Lower estimate  Upper estimate 

405k 

0.2% 

3.4% 

Vans 

 10k 

Rigid trucks 

 11k  

Buses 

 4k  

40k 

12k 

18k 

0.7% 

2.8% 

5.9% 

6.4% 

16.8% 

75.0% 

Total 

53k 

475k 

0.4% 

3.5% 

Source:  Ricardo  Energy  &  Environment  analysis  of  national  public  sector  vehicle 
registration/fleet data, and ACEA total vehicle registration statistics.  

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transport vehicles 

Further to that point, it should also be noted that not all vehicles procured fall within the 
scope  of  the  CVD-  the  number  of  contracts  falling  below  the  threshold  value  varies 
depending on the country, and in some cases all contracts are subject to the CVD. Thus, 
while it is expected that some contracts below the threshold may have followed the CVD 
requirements, it is also clear that not all public procurement of vehicles is covered by the 
CVD.22 

Overall, even under the least conservative assumption about the number of vehicles that 
may have been affected by the Directive, it is apparent that for passenger cars, vans, and 
rigid trucks, the effect that the Directive can have on overall vehicle purchases in the EU 
is  small  (in  nominal  terms  and  relative  to  the  total  size  of  wider  market).  For  buses, 
although  the  nominal  number  procured  by  contracting  authorities  is  small,  this  number 
constitutes a very significant proportion of the wider market (in our analysis, potentially 
as high as 75% of all buses bought). 

Effects on procurement decisions 

The  analysis  of  the  available  data  also  indicate  that  the  majority  of  contracting 
authorities  are  still  purchasing  conventionally  fuelled  vehicles.  Our  survey  and 
interviews with procurers suggest that the average improvement due to the Directive in 
vehicles’ CO2 performance has been modest, and a very small proportion of vehicles bought 
by public authorities have been better in terms of pollutant emissions than they otherwise 
would have been. Specifically, alternatively fuelled vehicles or hybrid powertrains do not 
tend to be offered by suppliers even when ambitious environmental criteria are specified, 
unless the tender specifically requests these technologies. Table 6-3 presents the share of 
different types of vehicles and powertrains procured by authorities that responded to the 
contracting authorities survey. As can be seen, 87% of the authorities  

Table 6-3: Share of different types of vehicle fuel/powertrain types procured from 
public authorities (% of contracting authorities responding) 

Conventional 
fuel/powertrain 

Electric 

Hybrid 

LPG/CNG 

Insufficient 
info 

87% 

1% 

1% 

2% 

9% 

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

Furthermore, in the case of cars and vans, the specification of environmental criteria may 
prompt  suppliers  to  offer  cleaner  ‘eco-variants’  of  conventional  models  (e.g.  with  start-
stop,  downsized  engine,  etc.)  in  their  bids.  However,  in  our  interviews  procurers  have 
reported  that  even  suppliers  with  ‘eco-variants’  in  their  model  range  have  sometimes 
chosen not to include these in their bids. Procurers also emphasised that the number of 
bids received is often low in the first place. It is therefore not necessarily the case that the 
cleanest vehicles available on the market will actually enter the competition. Consequently, 
energy  and  environmental  criteria  do  not  appear  to  have  become  significantly  more 
influential as a result of the Directive. 

In addition to that, only 13.4% of the respondents to the procurer’s survey indicated that 
they made use of the monetisation option (Option 2b) in their last contract to procure road 
transport  vehicles.  More  than  40%  stated  they  used  Option  1  (technical  standards)  and 
30% Option 2a (award criteria).  

22 Depending on the national implementing measures, contracts below thresholds may or may not legally require 
the application of the CVD’s rules. Furthermore, even if the national implementing measures do not legally 
prescribe application of the CVD rules to small contracts, contracting authorities may apply them anyway. 
Such “gold-plating” in public procurement has been observed in other sectors. 

38 

 
 
 
 
                                           
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

Figure 6-2: Environmental evaluation options applied to the public procurement 
contracts (out of 156 contracting authorities responding) 

  Option 1 - Setting technical standards for
environmental and energy performance

  Option 2a - Applying a weighting for
environmental and energy criteria in
contract evaluation

63

47

  Option 2b - Monetisation of energy and
environmental impacts

21

  None

14

0

10

20

30

40

50

60

70

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

Results  of  the  stakeholder  survey  and  feedback  from  stakeholders  gained  through 
interviews have indicated that the technical standards option (Option 1) has had very little 
effect on procurement decisions. The overwhelming majority who set a minimum standard 
for pollutant emissions indicated that they demanded a certain EURO standard.  In most 
cases  EURO  5/V  was  set  as  the  performance  requirement,  when  these  standards  were 
already  obligatory  requirements  for  light  duty  and  heavy  duty  vehicles  respectively. 
Procurers only demanded a higher EURO standard (i.e. Euro 6/VI) than was legally required 
for  new  vehicles  for  just  1%  of  vehicles  procured  using  the  technical  standards  option. 
Furthermore, these procurers demanded the higher EURO standard just six months before 
it became obligatory for all vehicles23.  

In addition, in the case of award criteria (Option 2a), environmental criteria (often including 
fuel/energy consumption) were given less than 20% weight in the large majority (75%) of 
the procurement cases. Price is usually given a greater weight (higher than 40% weighting 
in 50% of the cases examined) while other criteria (such as warranty period, provision of 
technical  support,  quality  of  design)  are  also  most  often  more  important  than 
environmental considerations.  

Figure  6-3:  Distribution  of  the  percentage  weighting  given  by  contracting 
authorities  to  environmental  and  other  criteria  when  weighting/award  criteria 

23 Some respondents to the procurer survey claimed to have set minimum standards for CO2 emissions or fuel 
efficiency, but on the whole too few responded with sufficient information for us to be able to estimate the 
typical minimum standard used. Therefore, our assessment of the effect of the technical standards option on 
CO2 and fuel efficiency is based on the information respondents’ provided about the vehicles they decided to 
purchase. 

39 

 
 
 
 
 
                                           
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

are  being  used  in  vehicle  procurement  (analysis  based  on  47  responses  from 
contracting authorities) 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Max

Max

Max

75%

50%

25%

75%

50%

25%

Min

Price

Min

Other

75%

50%
25%

Min

Environmental
criteria

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

The conclusion concerning the limited role of the CVD in terms of the demand for  clean 
vehicles is also supported by the responses of vehicle suppliers. Even though the number 
of responses is rather small, it does provide an indication of the limited role of the CVD in 
the sales of clean vehicles. 

Table  6-4:  Has  the  Clean  Vehicles  Directive  had  an 
sales/deliveries of clean vehicles? (out of 36 contractors responding) 

impact  on  your 

Types of Vehicles 

Not at all 

A little 

A 
moderate 
amount 

A great 
deal 

Don't 
know or 
NA 

Passenger cars 

Buses or coaches 

Light  (<3.5t)  commercial 
vehicles 

Heavy goods vehicles (trucks 
other  than  waste  collection 
vehicles) 
Special  service  vehicles  - 
Waste  collection  trucks  and 
services 

Special  emergency  service 
vehicles  –  e.g.  ambulances, 
fire engines etc. 

6 

5 

6 

4 

11 

5 

3 

3 

5 

5 

4 

4 

2 

2 

3 

1 

6 

2 

0 

0 

1 

2 

3 

0 

12 

15 

9 

13 

10 

12 

Source: Online Survey of Contractors– March-April 2015, Ricardo Energy & Environment 

40 

 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

Furthermore, to the extent that public procurement has shifted towards cleaner vehicles 
over time, the Directive is not the main driver of this shift. The procurers’ survey indicates 
that large number of procurers used environmental criteria even before the introduction of 
the  Directive.  A  large  part  of  the  observed  improvements  in  vehicles  performance  over 
time reflects general market trends and the effects of relevant regulation (CO2 Regulations 
for  light  duty  vehicles,  EURO  emissions  standards)  and  financial  instruments  (tax 
credits/subsidies).  Based  on  responses  received  to  the  contractors’  survey  (including 
manufacturers of vehicles and contractors selling or leasing road vehicles), such tools are 
more effective in terms of promoting the sales of clean vehicles (see Figure 6-4).  

Figure 6-4: How effective are each of the following alternative policies/measures 
in achieving the Directive’s aim to ‘increase the market share of clean vehicles’ 
compared to the CVD? (out of 31 contractors responding) 

Price-based measures (e.g. taxation or tax
credits/direct subsidies)

18

5

1

7

R&D support (e.g. grants/tax credits for
research by public/private institutions)

Support to commercialisation (e.g. financial
support)

Performance based regulations and standards
(e.g. improvement in environmental
performance of vehicles)

Demonstration and verification (e.g. supporting
testing of first time/early stage technologies)

Infrastructure provision (e.g. refuelling
infrastructure)

Technology-based regulations and standards
(e.g. specific characteristics, such as size,
shape, design etc.)

Networks and partnerships (e.g. facilitating
industry coordination)

Information-based measures (e.g. vehicle
labelling, information awareness raising etc.)

15

14

14

7

8

9

1

1

8

8

2

6

12

5

4

10

10

10

3

8

7

8

10

6

4

3

12

10

6

10

9

8

More effective

About the same

Less effective

Don't know

Source: Online Survey of Contractors– March-April 2015, Ricardo Energy & Environment 

Having said that, there are cases reported where procurement contracts of significant size 
do have an impact on the regional or national markets. For example, our interviews with 
some  local  authorities  (e.g.  Madrid,  Berlin,  Warsaw)  indicated  that  they  have  procured 
electric or CNG vehicles for the provision of urban transport services, waste collection or 
other  public  services.  However,  the  interviews  with  such  stakeholders  suggest  that  the 
CVD does not represent the driving force behind such purchasing decisions. Typically, these 
are part of the green strategies of the authorities involved and, in some cases, they are 
also linked to targeted financial support programmes by national authorities, that subsidise 
the additional costs for the purchase of such vehicles.   

41 

 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

6.4.3.  Estimation of the impact of the CVD  

On the basis of data collected and input from the survey with procurers, we were able to 
estimate the maximum level of improvements in public sector fleet emissions due to the 
introduction of the Directive. 

For  CO2  emissions,  the  analysis  is  based  on  a  cross-sectional  comparison  of  the  CO2 
performance of vehicles purchased by public authorities under the Directive, and the typical 
CO2  performance  of  similarly-sized  vehicles  purchased  in  the  wider  market  at  the  same 
time. This cross-sectional comparison serves as a means of controlling for the effect of the 
car and van CO2 regulations, which will have improved the CO2 emissions performance of 
both publically- and privately-procured vehicles. We found that public sector respondents’ 
vehicles  were  12%  more  efficient  in  terms  of  CO2  than  the  wider  market  average,  and 
respondents’  choice  of  vans  was  on  average  5%  more  efficient  (see  also  Annex  1). 
Important  assumptions  have  been  made  to  produce  these  estimates  and  therefore  it  is 
appropriate to present the results of this analysis with some caveats. These include: 

  As  we  have  already  pointed  out,  a  number  of  contracting  authorities  (around  46%) 
have  already  included  environmental  criteria  in  procurement  decisions  prior  to  the 
introduction of the CVD, and for these procurers the Directive will have had a limited 
effect on the performance of vehicles procured. Indeed, some indicated that the criteria 
they were applying before the Directive were at least as strict as those applied after 
the  Directive  was  transposed.  We  have  adjusted  our  estimate  of  the  CO2  and  air 
pollutant benefits of the Directive to take this into account. This leads to an estimated 
5.5% average CO2 reduction for vehicles and 2.3% for vans.   

  However, we have not been able to determine to what extent procurers who say they 
are currently taking energy and environmental performance into account to a greater 
extent than they did prior to the Directive would have done so in the absence of the 
Directive, due to other factors. Conceivably, all the abated emissions quantified may 
be  due  to  factors  other  than  the  Directive  such  as  a  general  effort  by  contracting 
authorities to tackle road transport CO2 and pollutant emissions more effectively, as a 
consequence  of  their  own  voluntary  effort  to  improve  or  as  a  result  of  policies  and 
incentives developed by national and local government. 

  Leaving aside the issue of the extent to which better CO2 performance of contracting 
authorities’  vehicles  (relative  to  private  sector  vehicles)  should  be  attributed  to  the 
CVD, there is still a large amount of uncertainty over the extent of the difference. Our 
survey provides us with limited numbers of vehicles in each segment to compare with 
the average in the wider market. 

For  pollutant  emissions,  our  estimate  is  based  on  an  analysis  of  the  responses  of 
contracting  authorities  who  set  technical  standards  and  the  use  of  real-world  emissions 
data (rather than type approval data). For those using pollutant emissions as award criteria 
or using the monetisation option (Option 2b), there was no relevant information provided 
by these respondents that could allow to quantify the impact on pollutant emissions (even 
though responses provide us with information on the weight given to pollutant emissions 
criteria, they include no substantive information on what the criteria were). As a result we 
have assumed the air pollutant impacts among these groups will be similar to those among 
the  group  based  on  technical  standards.    The  impact  among  those  setting  technical 
standards is very low and attributable to a very small proportion of procurers choosing to 
require EURO 6 or EURO VI prior to those standards becoming obligatory. It is reasonable 
to assume that the other two options have also had a low impact on air pollutants, because 
(1) the monetisation methodology gives very little weight to pollutants in total monetised 
costs,  and  (2)  respondents  indicating  that  they  had  used  air  pollutant  performance  as 
award criteria typically gave this a very low weight relative to price and fuel consumption.  

The figures in Table 6-5 present the estimated environmental impacts related to the CVD 
on the basis of the upper and lower level scenarios for the number of vehicles affected by 
the CVD and with reference to the period 2012-2014 that the CVD has been effectively in 

42 

 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

force. The analysis includes estimates of the impacts on air pollutants and CO2 emissions 
up until 2032 of  vehicles bought between 2012 and 2014. 2032 is the year in which all 
vehicles purchased by the end of 2014 under the policy will have been scrapped. The table 
provides also the estimated % change in comparison to the baseline estimates.  

In relation to the air pollutant impacts shown in table 6-5, these are  the consequence of 
a small number of procurers adopting EURO 6/VI standards at time when only EURO 5/V 
was obligatory and mandatory use of EURO 6/VI for new vehicles was still 6 months away. 
Therefore air pollutant impacts are only non-zero where (1) there are  differences in the 
real  world  emissions  associated  with  EURO  5/V  and  EURO  6/VI,  and  (2)  there  was  a 
transition to EURO 6 at some point before mid-2015. For example, table 6-5 indicates that 
there was no impact on NOx emissions of passenger cars. This is because NOx emissions 
limits for petrol passenger cars are the same under EURO 5 and EURO 6, and for diesel 
passenger  cars,  although  EURO  6  is  associated  with  lower  real-world  emissions  of  NOx 
than  EURO  5,  EURO  6  does  not  become  obligatory  until  September  2015,  and  so  any 
procurers imposing EURO 6 half a year before the standard becomes mandatory will have 
done so in March 2015, i.e. after the 2012-2014 window for procurement decisions which 
our analysis evaluates. 
These  estimates  should  be  considered  as  a  best-case  scenario  and,  on  the  basis  of  the 
caveats  given  above,  probably  overstate  the  actual  emissions  impact  of  the  CVD, 
Unfortunately, there are no data available that would allow for a more accurate estimate 
of the contribution, controlling for all other factors in play.   

Table 6-5: Estimated environmental impacts from the implementation of the CVD 
(effects  of  the  policy  being  in  place  from  2012-2014  in  comparison  to  the 
baseline) 

Passenger 
cars 

Vans 

Rigid 
trucks 

Buses 

All 
vehicles 

 -135 to -1917  

 -26 to -
109  

No effect  

No effect  

-5.5% 

-2.3% 

- 

- 

 -161 to -
2027  
-0.6% to -
1.7% 
 -10 to -32  

NMHC (tonnes) 

No effect  

No effect  

 -3 to -4  

 -6 to -29  

-  % of change 

to baseline 

NOX (tonnes) 

-  % of change 

to baseline 

PM  
(tonnes) 

-  % of change 

to baseline 

Total CO2 cost 
savings (million €) 
Total air pollutant 
cost savings 
(million €) 

- 

- 

> -0.01% 

> -0.01% 

> -0.01% 

No effect 

 -1 to -2  

 -41 to -45  

 -82 to -
364  

 -127 to -
455  

- 

> -0.01% 

> -0.01% 

> -0.01% 

> -0.01% 

No effect  

No effect  

 -0.10 to -
0.11  

 0 to -1  

 0 to -1  

- 

- 

> -0.01% 

> -0.01% 

> -0.01% 

 8.2 to 116.7  

 1.7 to 7.0   No effect 

No effect 

 0.0 to 0.4  

 0.01 to 
0.02  

 0.40 to 
0.43  

 0.74 to 
3.28  

 9.9 to 
123.8 
1.2 to 4.1 

Source: Own elaboration on the basis of data collected  

Note: Costs are presented in 2015 prices. A 4% discount rate is applied to costs after 2014. 

In the case of heavy-duty vehicles, our analysis suggests that the contribution of the CVD 
to  CO2  or  fuel  efficiency  improvements  is  zero.  In  the  absence  of  standard  test  cycles, 
procurers indicate that they struggle to find data they can use to compare the fuel efficiency 
of vehicles. Only a few procurers have gone through the process of specifying their own 

43 

Change in 
emissions due to 
the CVD 
CO2 (thousand 
tonnes) 

-  % of change 

to baseline 

 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

tests in order to get the relevant data. Such procurers will have had to go to great lengths 
to collect the relevant data and are therefore likely to be precisely the procurers who would 
have  imposed  stringent  fuel-efficiency  or  technology-based  standards  in  the  absence  of 
the Directive. This would be the case with the city of London authorities, for example, who 
have set technology-based standards (i.e. all new buses must be hybrids) and run their 
own  tests  on  the  fuel  efficiency  of  buses.  They  have  stated  that  the  Directive  has  no 
additional impact on their use of environmental criteria24. 

Dieselisation 

The figures in Table 6-4 do not include any effects of possible extra dieselisation (shift from 
petrol to diesel vehicles) resulting from the Directive. Additional dieselisation is a possible 
consequence  of  the  inadvertent  bias  in  the  monetisation  methodology  towards  diesel 
vehicles  (the  analysis  supporting  this  assessment  is  provided  in  Annex  9).  Therefore  an 
ancillary analysis was conducted to investigate the possible extent of dieselisation resulting 
from the Directive, and its effects on pollutant emissions. 
Analysis  of  the  procurer  survey  indicated  a  maximum  5.5%  improvement  in  the  CO2 
emissions of passenger cars and a 2.3% improvement in the CO2 emissions of vans could 
be  associated  with  the  CVD.  It  is  uncertain  to  what  extent  this  improvement  in  CO2 
emissions may have been driven by dieselisation. In the dieselisation scenario, we assume 
a certain proportion of the CO2 improvement estimated from the procurer survey is driven 
by dieselisation, based on further analysis of the survey. Therefore the approach is to hold 
the estimated CO2 benefit (from the non-dieselisation scenario) constant, but assume that 
it comes ‘at a price’ of increased air pollution (associated with extra purchases of diesel 
vehicles). In other words, our estimate of the difference between vehicle procured under 
the CVD and vehicles procured without the CVD does not change, as this is based directly 
on the procurer survey results, but  our assumption as what  explains  the CO2 difference 
(i.e. dieselisation versus efficiency improvements without dieselisation) is different in the 
dieselisation scenario. 
Further analysis of the procurer survey confirms that use of the monetisation methodology 
tends  to  be  associated  with  procurement  of  diesel  passenger  cars  rather  than  petrol 
passenger cars to a greater extent than the other two options in the Directive: the share 
of  diesel  passenger  cars  is  13%  higher  for  the  monetisation  option  than  the  weighted 
combination  of  the  other  two  options.  13%  of  procurers  use  the  monetisation  option, 
implying the extent of dieselisation is 13% of 13%, or a two percentage point increase in 
diesel’s share of publically procured passenger cars. (For other types of vehicles, i.e. vans 
and heavy duty vehicles, there is no dieselisation effect of the Directive as the vast majority 
of these vehicles (more than 99%) are already powered by diesel). 
We were also able to determine from the analysis of the procurers survey that the typical 
difference in CO2 emissions for a diesel car procured under the Directive and a similarly-
sized petrol car procured under the directive is 14% (i.e. diesel cars typically emit 14% 
less CO2 per km). This analysis is based on cars in the B and C segments, as other segments 
had either too few diesel or too few petrol cars to allow for a meaningful comparison of 
averages. Multiplying the estimated increase in diesel’s share (2%) by the typical difference 
between diesel and petrol passenger cars (14%) yields a total change in CO2 emissions of 
0.2%.Therefore,  in  the  dieselisation  scenario  a  0.2%  reduction  in  CO2  emissions  is 
associated with dieselisation, and the remaining 5.3% of the total 5.5% reduction is not. 
Dieselisation  will  have  an  adverse  effect  on  air  pollutant  emissions,  which  we  have 
estimated  through  use  of  TREMOVE  data  on  typical  CO2  and  pollutant  emissions  of 
passenger cars in the EU. The TREMOVE model includes real-world (rather than test cycle) 
emissions of typical passenger cars of different fuel types. By comparing the fleet-average 
CO2  and  pollutant  emissions  profiles  of  diesel  and  petrol  passenger  cars,  elasticities  of 
pollutant  emissions  with  respect  to  CO2  emissions  in  the  context  of  dieselisation  were 

24http://www.clean-fleets.eu/fileadmin/New_Bus_for_London_Case_Study_for_Clean_Fleets_-_final.pdf 

44 

 
 
 
 
                                           
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

estimated. Elasticities of NMHC emissions, PM emissions, and NOx emissions with respect 
to  CO2  emissions  were  then  used  in  combination  with  the  assumption  of  a  0.2% 
dieselisation-related reduction in CO2 to estimate the effect of CVD-related dieselisation on 
air pollution. 
The result in the case of the dieselisation scenario is that the modest air pollutant benefits 
associated with early adoption of EURO standards are wiped out (see Table 6-6). Instead, 
due  to  the  dieselisation  of  passenger  cars,  the  overall  impact  of  the  Directive  on  air 
pollutant emissions is adverse (increase in NOx and PM). 

Table 6-6 Estimated environmental impacts from the implementation of the CVD 
(effects  of  the  policy  being  in  place  from  2012-2014  in  comparison  to  the 
baseline) – dieselisation scenario 

Change in 
emissions due to 
the CVD 
CO2 (thousand 
tonnes) 
% of 
- 
change to baseline 

NMHC (tonnes) 

% of 
- 
change to baseline 

NOX (tonnes) 

% of 
- 
change to baseline 
PM  
(tonnes) 
% of 
- 
change to baseline 
Total CO2 cost 
savings (million 
€) 
Total air 
pollutant cost 
savings (million 
€) 

Passenger 
cars 

Vans 

Rigid 
trucks 

Buses 

 -135 to -1917  

 -26 to -109   No effect  

No effect  

-5.5% 

-2.3% 

- 

- 

 -6 to -91  

 No effect 

 -3 to -4  

 -6 to -29  

All 
vehicles 

 -161 to -
2027  
-0.6% to - 
1.7% 
 -16 to -
123  

> -0.01% 

- 

> -0.01% 

> -0.01% 

> -0.01% 

+131 to +1853 

 -1 to -2  

 -41 to -45  

 -82 to -
364  

 +7 to 
+1442  

< 0.01% 

> -0.01% 

> -0.01% 

> -0.01% 

< 0.01% 

 29 to 412  

 No effect  

 -0.10 to -
0.11  

 0 to -1  

 29 to 411  

< 0.01% 

- 

> -0.01% 

> -0.01% 

< 0.01% 

 8.2 to 116.7  

 1.7 to 7.0   No effect 

No effect 

 9.9 to 
123.8 

-2.2 to -31.4 

 0.01 to 
0.02  

 0.40 to 
0.43  

 0.74 to 
3.28  

-1.1 to -
27.7 

Source: Own elaboration on the basis of data collected  

Note: Costs are presented in 2015 prices. A 4% discount rate is applied after 2014. 

6.4.4.  Conclusions and comparison with the estimates of the impact assessment 

Overall, the findings of the analysis suggest that the Directive has had a very modest effect 
on  reducing  CO2  emissions  and  increasing  the  market  share  of  energy-efficient  and 
environmentally  friendly  vehicles.  The  positive  impact  on  air  pollutant  emissions  is  also 
extremely limited and may have actually been completely offset by dieselisation. 

We have estimated the impacts of the Directive having legal force on new procurements 
from  the  start  of  2012  to  the  end  of  2014  (2012  is  chosen  rather  than  2009,  as  most 
Member  States  did  not  transpose  the  legislation  until  2012)  (see  Table  6-7).  While  a 
fraction of the impacts of the Directive on energy costs, air pollutants and CO2 emissions 
will have been realised by the end of 2014, the majority of the impacts of the procurement 
decision made over 2012-2014 will actually be realised after 2014. Therefore, our analysis 
also includes estimates of the impacts on air pollutants and CO2 emissions up until 2032 

45 

 
 
 
 
  
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

of vehicles bought between 2012 and 2014. 2032 is the year in which all vehicles purchased 
by the end of 2014 under the policy will have been scrapped.  

Table 6-7:- Estimated market and environmental impacts of the CVD 

Policy impact during 2012-2014 

Policy impact 
during 2015-
2032 

Total 
estimated 
impacts25  

“Clean” vehicles 
procured by 
contracting 
authorities/year   

CO2 emissions 
(thousand tonnes) 
NMHC emissions 
(tonnes) 
NOX emissions 
(tonnes) 
PM (tonnes) 

2,000 to 23,000 zero-emission cars 
and vans 
(equivalent to 0.2% to 2.9% of the 
EU market for alternatively-fuelled 
vehicles, or 0.01% to 0.05% of the 
total EU market for cars and vans) 
or 
55,000 – 705,000 fuel-efficient 
conventionally-fuelled cars and vans 
(equivalent to 0.1% to 1.8% of the 
total EU market for cars and vans) 
- 
Close to zero clean rigid trucks and 
buses  
 -38 to -459  

 -123 to -1567  

 -161 to -2027  

 -1 to -4  

 -8 to -28  

 -10 to -32  

 -18 to -57  

 -105 to -354  

 -123 to -411  

 0 to 0  

 0 to -1  

 0 to -1  

Source: Own elaboration on the basis of data analysis 

Note: the final column of this table matches the figures in the final column of Table 6-5. 

Comparison with the IA results 

Our estimates of the impact of the CVD are also significantly reduced in comparison to the 
initial estimates provided in the 2007 impact assessment (European Commission, 2007) in 
relation to most of impacts.  In Table 6-8 the key estimated impacts of the implementation 
of  the  CVD  linked  to  the  two  scenarios  examined  in  the  impact  assessment  and  the 
evaluation are summarised. Given the different time periods considered in the two studies 
and the different approach used in estimating the impacts, the figures presented refer to 
the impacts for a single year in order to ensure comparability. In the case of the impact 
assessment we used the detailed figures available for 2012 while for this ex-post evaluation 
we  present  the  average  for  the  three  year  period  2012-2014.  As  a  result,  the  figures 
presented are different from those presented in Table 6-5. 

Table 6-8 - Comparison of estimated impacts of the CVD implementation against 
the 2007 Impact assessment estimates (figures refer to a single year: 2012 for 
the impact assessment, average of the 2012-2014 period for the evaluation) 

Estimated impacts of CVD 
for a single year 

IA Scenario 1 

IA Scenario 2 

Ex-post evaluation  

25 The figures in this column correspond to the total impacts presented in Table 6-5.  

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transport vehicles 

“Clean” vehicles procured by 
contracting authorities/year   

Mandatory 
internalisation of 
operational costs 
52,000 hybrid diesel 
HDVs 
220,000 gas LDVs 

Optional early 
adoption of 
EURO standards 
none 

(thousand 

-19,000 

zero 

0 HDVs, 
600 - 8,000 zero-
emission LDVs 
or 18,000 - 234,000 
“eco variant” LDVs 
 -54 to -676  

Not estimated 

Not estimated  

 -3 to -11  

-131,000 

44,000 

 -42 to -152 

-3,000 

40 

-0.1 to -0.3 

CO2  emissions 
tonnes) 
NMHC emissions 
(tonnes) 
NOX emissions 
(tonnes) 
PM emissions 
(tonnes) 

Source: Own elaboration on the basis of data analysis and (European Commission 2007a) 

The significant differences in results anticipated by the Impact Assessment and the results 
estimated for the Evaluation are mainly a result of differences in assumptions about the 
policy that would be (has been) implemented. More specifically: 

  Among the policy options considered in the Impact Assessment was legislation to 
require  all  contracting  authorities  to  use  a  type  of  monetisation  methodology  for 
every  single  vehicle  procurement  action  (IA  scenario  1).  Another  policy  option 
considered  in  the  impact  assessment  (IA  scenario  2)  was  for  the  Commission  to 
“encourage”  early  adoption  of  EURO  standards.  Neither  of  these  policy  options 
reflect  the  actual  final  provisions  of  the  Directive  that  was  eventually  adopted, 
although each bears a limited resemblance to a certain aspect of the Directive and 
its practical implementation. The differences between the impact assessment policy 
options and the actual policy adopted are explained in greater detail below. 

 

In relation to the adoption of clean vehicles, the IA scenario 1 estimates reflect a 
scenario in which monetisation of external costs is made mandatory. As a result, all 
publically procured vehicles resemble the best-performing vehicles in the market in 
terms of internalised external costs. According to the impact assessment this would 
have  meant  an  additional  52,000  hybrid  trucks  and  buses  each  year  and  an 
additional  220,000  gas  cars  and  vans  each  year  entering  the  market.  In  our 
analysis, based on the input from the surveys and interviews, we estimate that the 
actual contribution of the CVD has been much more limited, and consistent with an 
additional 600 to 8,000 zero-emissions light duty vehicles per year or an additional 
18,000  to  234,000  “eco  variant”  conventionally  fuelled  vehicles  (each  with  an 
average  10%  improvement  in  fuel  efficiency  relative  to  their  related  standard 
model).  This is because the set of options in the Directive for taking energy and 
environmental  criteria  into  account  are  substantially  less  demanding  than  the 
requirements  assumed  in  IA  scenario  1.  Rather  than  being  made  mandatory, 
internalisation of external costs through use of the monetisation methodology has 
been made optional, and few procurers have chosen to do it. Our analysis of the 
procurer survey indicates that most procurers have used the other policy options, 
and  given  little  weight  to  environmental  criteria  in  their  procurement  decisions 
(among  those  procurers  using  environmental  performance  as  award  criteria,  on 
average, procurers gave four times as much weight to price considerations as fuel 
efficiency or CO2 performance). 

 

It is also important to note that the maximum figure of an additional 234,000 eco-
variants almost certainly overstates the real effect of the CVD on the market as it 

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transport vehicles 

 

 

is a maximum figure, based on the combination of two optimistic assumptions. The 
first  assumption  is  that  the  entirety  of  the  estimated  5.5%  CO2  efficiency 
improvement  for  cars  (2.3%  for  vans)  is  attributable  to  the  CVD  rather  than 
contracting authorities improving their environmental standards over time on their 
own initiative. The second assumption is that the entirety of the 5.5% improvement 
for cars (2.3% for vans) comes from additional purchases of eco-models, i.e. the 
effect is spread very evenly over procurement decisions. 

In  terms  of  CO2  emissions  reduction,  the  instructive  comparison  is  between  IA 
scenario  1  and  the  actual  impacts.  In  IA  scenario  1,  the  aforementioned  shift  to 
hybrid  and  gas  vehicles  results  in  substantial  well-to-wheel  emissions  reductions 
(up to 46% in the case of passenger cars, against relatively moderate changes in 
purchase costs). Our analysis of the data from the procurers’ survey indicates that 
the Directive has not driven any widespread shift in powertrain technology, and any 
improvements in CO2 and fuel efficiency have been modest at best, due to the fact 
that  procurers  have  largely  opted  not  to  use  monetisation,  given  little  weight  to 
CO2/fuel  efficiency  in  procurement  decisions,  and  as  a  result  purchased  vehicles 
that are only slightly more fuel efficient than typical models on the market. On the 
basis  of  our  analysis  of  the  makes  and  models  of  vehicles  respondents  to  the 
procurer  survey  say  they  bought,  we  estimate  that,  at  most  there  is  a  5.5% 
reduction in tank to -to-wheels CO2 emissions of passenger cars associated with the 
Directive. 

In relation to pollutant emissions, the two impact assessment scenarios predicted 
pollutant emissions changes for different reasons. In the IA scenario 1, monetisation 
creates  a  large-scale  shift  to  alternative  fuels  and  powertrains  (with  100%  of 
vehicles  switching  to  CNG  or  hybrid  electric  vehicles)  resulting  in  large 
improvements  in  the  level  of  air  pollutant  emissions.  According  to  IA  scenario  2, 
procurers  would  be  given  a  “recommendation”  to  adopt  higher-than-obligatory 
EURO  standards  early,  with  50%  of  procurers  choosing  to  do  this,  resulting  in  a 
significant reduction in NOX emissions. Our analysis indicates that the actual positive 
impact of the Directive on pollutant emissions has been much more modest, and 
associated just with early adoption of EURO standards by a very small minority of 
procurers (not with any substantive technological shift). Our survey indicates that 
only 1% of procurers adopted higher-than-obligatory EURO standards early, versus 
the  50%  assumption  IA  scenario  2.  Therefore,  the  actual  air  pollutant  impacts 
resemble a much weakened form of IA scenario 1. 

In addition, some of the other assumptions made in the Impact Assessment also needed 
to be changed, to reflect better or more recent data:  

  There  are  differences  in  the  numbers  of  vehicles  procured  by  contracting 
authorities,  particularly  in  relation  to  vans  and  heavy-duty  vehicles.  The  original 
impact assessment’s estimates of public procurement relied on data from the Italian 
government which is now over 10 years old. The data underlying our own estimates 
comes  from  several  countries,  and  is  considerably  more  up-to-date,  including 
figures  recorded  after  the  onset  of  the  economic  crisis,  which  is  likely  to  have 
dampened public procurement significantly. Another development which is likely to 
have reduced the numbers of commercial vehicles procured by public authorities is 
the privatisation of public services. 

  On the other hand, the evaluation has also used lower lifetime mileage assumptions 
than the impact assessment, which tends to deflate the benefits. Most significantly, 
this evaluation assumes a total lifetime mileage for heavy duty vehicles of 375,000 
km, which, according to a DG CLIMA report on greenhouse gas emission of heavy-
duty  vehicles  (AEA  2011),  is  an  appropriate  assumption  for  heavy  duty  vehicles 
performing  a  municipal  utility  role.  The  Impact  Assessment’s  assumption  of 
1,000,000  km  would  be  more  appropriate  to  commercial  trucks  used  for  long-
distance transport, not vehicles owned by contracting authorities.  This difference 

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in lifetime mileage means that the Impact Assessment is likely to have significantly 
overestimated the emissions and energy consumption benefits of Directive. 

6.5. 
 Effectiveness:  To  what  extent  has  the  provision  of  different 
options to include operational lifetime environmental and energy impacts 
stimulated  the  internalisation  of  operational  costs  in  procurement 
decisions,  and  contributed  to  the  harmonisation  in  determining  these 
costs? (Q4) 

6.5.1.  Approach to answering the evaluation question  

This evaluation question examines the extent to which alternative options in the Directive 
to include operational lifetime environmental and energy impacts has stimulated (or not) 
the internalisation of operational costs in procurement decisions. It also assesses how the 
presence of the alternative options contributed to the harmonisation in determining these 
costs.  

The analysis has been based on: 

 

Input from the survey responses and the interviews with stakeholders (procurers 
and suppliers of vehicles involved in public procurement bids); and  

  Available data from relevant secondary sources.  

6.5.2.  Role of the provision of alternative options  

One  of  the  expected  contributions  of  the  Directive  was  that  it  would  promote  the 
internalisation  of  operational  costs  in  procurement  decisions.  More  explicitly,  the 
mandatory inclusion of lifetime costs for energy consumption, CO2 emissions, and pollutant 
emissions as award criteria in the procurement of vehicles for public transport services was 
expected  to  have  the  biggest  impact  on  the  market  and  the  best  cost/benefit  result. 
Furthermore, a great impact on the market was expected if harmonised criteria are applied 
at Community level.  

The  monetisation  method  set  out  in  Article  6  of  the  Directive  requires  contracting 
authorities to calculate operational lifetime costs of energy consumption, CO2 emissions, 
and  air  pollutant  emissions  associated  with  operating  a  vehicle.  Once  calculated,  these 
external costs are then internalised in the purchase decision.  

The introduction of alternative options was intended to enable authorities and operators 
that  have  already  developed  methods  tailored  to  meeting  local  needs  and  conditions  to 
continue  applying  these  methods.  However,  the  use  of  alternative  options  –  technical 
standards (Option 1) and award criteria (Option 2a) – do not, at least explicitly, require  
authorities  to  consider  the  respective  operational  costs  in  the  setting  of  the  relevant 
requirements and, as a result, do not ensure the internalisation of operational costs. Only 
the monetisation option (Option 2b) explicitly requires operational cost impacts to be fully 
taken into account in procurement decisions.  

In practice, among the contracting authorities, only a small share have made use of the 
monetisation  option  up  to  this  point  in  time.  Two  Member  States  (Czech  Republic  and 
Estonia)  decided  not  to  include  the  monetisation  option  in  their  National  Implementing 
Measures  while,  even  among  the  Member  States  where  the  monetisation  option  is 
available, contracting authorities tend not to make use of Option 2b. As was discussed in 
6.4.2, only 13.4% of the respondents to the procurers’ survey indicated that they used the 
monetisation option (Option 2b) in their last contract to procure road transport vehicles. 
More than 40% stated that they use Option 1 (technical standards) and 30% use Option 2 
(award criteria) (see Figure  6-2 in Section 6.4.2). The Polish government found that no 
contracting authorities it investigated had used Option 2b while an international network 
of cities (ICLEI) reported that are aware of only two examples of it ever being used. 

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transport vehicles 

The  use  of  the  alternative  options  means  that  operational  costs  are  only  indirectly 
integrated in the procurement decision process. Relevant fuel/energy consumption-related 
criteria are still considered as part of Options 1 or 2a. Among the contracting authorities 
that  made  use  of  technical  standards,  fuel/energy  consumption  standards  were  used  in 
around 40% of procurement cases. In the case of award criteria, fuel/energy consumption 
criteria were considered in 80% of cases.  

Asked to explain the reasons for not using the monetisation option, contracting authorities 
indicated that they perceived it to be too complicated and particularly demanding in terms 
of  the  information  required.  It  was  indicated  that  vehicle  performance,  environmental 
impacts, and the internalisation of external costs are also technical topics some procurers 
may  have  very  limited  knowledge  of.  It  is  also  seen  by  some  as  being  “theoretical”  or 
“academic”.  

Furthermore, among the small proportion of stakeholders who felt that they understand 
the methodology in detail, it is often viewed as being flawed. Among the 38 contractors 
that  responded  to  this  specific  survey  question,  34%  believed  that  the  monetisation 
method and associated parameters set out in the Directive are not appropriate for a good 
evaluation  of  the  energy  and  environmental  impacts,  whereas  18%  believed  otherwise 
(47% did not express an opinion). The Member State representatives for Belgium and Italy 
agreed  in  principle  that  the  methodology  was  appropriate  for  internalising  operational 
costs. However, they also pointed out that the methodology is rather complex requiring a 
set of mathematical calculations and a certain level of understanding on rather technical 
topics of vehicle performance, environmental impacts, and the internalisation of external 
costs. Many other stakeholders agreed that these issues were significant. One international 
network of city governments stated that if the methodology is to be retained, it needs to 
be substantially revised. Similar comments came from vehicle suppliers  that stated that 
the monetisation option tends to require additional information that is not always easily 
available.  

Further to that point, our analysis and feedback from stakeholders suggest that by itself 
the  monetisation  option  and  associated  methodology  does  not  always  guarantee  the 
accurate internalisation of operational costs.  More specifically: 

  The methodology does not accurately capture differences in the energy costs of vehicles 
powered  by  fuels  other  than  diesel  or  petrol.  It,  therefore,  internalises  energy  costs 
inaccurately. 

  The  methodology’s  emissions  factors  are  outdated  and  inconsistent  with  current  EU 
guidance, such as that contained in the 2014 update to the handbook on external costs 
of transport (Ricardo-AEA, TRT et al. 2014).  

  The  methodology  treats  electric  vehicles  as  being  CO2-neutral.  However,  if  the 
electricity powering these vehicles is generated from coal, the CO2 emissions of these 
vehicles would, in fact, be comparable to diesel vehicles. 

Furthermore,  when  looking  into  specific  examples  of  comparisons  between  potentially 
competing vehicles using the monetisation methodology (see Annex 9), we identified some 
weaknesses of the methodology:  

  When comparing various types of buses using different fuels and powertrains, one key 
finding was that energy efficiency considerations dominate the calculations, resulting 
in diesel technology being favoured over other technologies. Rather than offsetting the 
higher initial (purchase) costs of other cleaner vehicles (such as CNG-powered buses), 
the use of the monetisation methodology can make them appear less competitive. 

  When  comparing  the  operational  costs  of  fully-electric  vehicles  against  other 
powertrains,  the  operational  costs  of  fully-electric  cars  are  considerably  lower  than 
cars equipped with other technologies and hence electric vehicle technology is assisted 
by the fact that no emissions are attributed to it.   

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Finally, beyond the specifics of the monetisation option, the survey responses and feedback 
from interviews suggest that many contracting authorities had been using environmental 
criteria  in  their  procurement  decisions  prior  to  the  adoption  of  the  CVD.  Among  the 
contracting  authorities  surveyed,  more  than  42%  of  procurers  had  been  using 
environmental criteria in their procurement decisions and only 23% stated that they did 
not26. 

6.5.3.  Role in promoting harmonisation in determining operation costs 

Considering  the  harmonisation  in  determining  operational  costs,  the  Directive 
includes specific guidance on how the monetisation of lifetime costs should be carried out. 
However,  the  limited  use  of  the  monetisation  option  in  procurement  represents  an 
important barrier.  

Furthermore, even among those authorities that make use of the monetisation option, one 
third  (33.3%)  indicated  that  they  made  use  of  the  methodology  set  out  by  national 
legislation while 28% used  the methodology  set  out in the CVD without changes. There 
was also one case where the methodology developed by a local organisation was applied. 
This  provides  evidence  that,  even  among  those  that  make  use  of  the  monetisation 
methodology,  a  certain  level  of  variation  applies.  However,  it  is  possible  that  although 
authorities indicated that they used different methodologies, they may not be aware if the 
methodology used (i.e. national legislation) is in fact directly transposed from the Directive.  

Information  on  fuel  consumption,  CO2  and  air  pollutant  emissions  should,  in  the  first 
instance, come from the results of the standardised Community test procedures used for 
type approval (Article 6(2)). For those vehicles for which there are no such official tests, 
the data should come from “widely recognised test procedures,” the results of tests for the 
contracting authority, or information supplied by manufacturers. However, for heavy duty 
vehicles, there is not, at present, any harmonised community standard for measuring fuel 
consumption  or  CO2  emissions,  and  it  is  prohibitively  difficult  for  most  contracting 
authorities to obtain objective, comparable data on these vehicles from other sources (see 
Section 5.4 for a full description of this issue). 

Therefore, it is likely that the vast majority of contracting authorities have not been able 
to make accurate comparisons of the performance of heavy duty vehicles in terms of fuel 
consumption and CO2 emissions. 

The  small  number  of  contracting  authorities  who  currently  do  make  CO2  and  fuel 
consumption  comparisons  between  heavy  duty  vehicles,  and  then  include  these  in  the 
procurement decision, are likely to have done so without the Directive. This is because it 
requires such a significant effort to overcome the problems mentioned above and the only 
contracting  authorities  making  this  effort  do  so  because  they  are  strongly  inclined  to 
consider energy and environmental impacts anyway, regardless of the Directive. 

Furthermore,  as  we  have  seen  evidence  of  a  patchwork  of  different  approaches  to 
overcoming the lack of data, in our assessment there is currently no harmonisation in the 
way the emissions of heavy duty vehicles are taken into account. 

Discussions  with  various  procurement  authorities  suggest  that  the  existing  support  and 
guidance initiatives (CVP/CFP) have not played any role in promoting better understanding 
of the monetisation option. The majority stated that they were not aware of their existence. 

6.5.4.  Conclusion 

Concluding,  our  analysis  suggests  that  the  provision  of  alternative  options  has  led  to  a 
limited use of the monetisation option that explicitly aimed at internalising the operational 
costs.  Our  analysis  also  suggests  that  there  are  important  problems  with  the  practical 

26 A rather high percentage of respondents (35%) stated “Don’t know or not applicable”.   

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implementation of the methodology. It is both particularly demanding and complicated but 
it  is  also  not  always  effective  in  fully  and  properly  capturing  the  operational  costs 
associated with various types of vehicles. Furthermore, there is limited evidence in terms 
of promoting the harmonisation of costs.   

6.6.  Effectiveness:  To  what  extent  has  the  Directive  promoted  an 
increased awareness among the different stakeholders of the operational 
lifetime environmental and energy impacts of vehicles? (Q5) 

6.6.1.  Approach to answering the evaluation question 

This question aims to determine the effectiveness of the CVD in terms of raising/increasing 
awareness  among  different  stakeholders  of  the  operational  lifetime  environmental  and 
energy impacts of vehicles. Procurers are required to apply one of the three options set 
out in Article 5(3) of the Directive which aim to address these impacts, including via the 
use  of  technical  standards  (Option  1),  award  criteria  (Option  2a)  and  monetisation  of 
impacts (Option 2b). The ‘stakeholders’ were taken to mean primarily the procurers who 
are  required  to  apply  one  of  these  options  when  procuring  vehicles.  However,  other 
stakeholders such as contractors and manufacturers have also been considered.  

In the main, qualitative analysis has been undertaken to answer this question, relying on:  

  Responses to the procurers’ survey/interviews;  

 

Interviews with EU-level stakeholders; and  

  Additional data and information from other supporting Commission initiatives.  

6.6.2.  Promoting an increased awareness 

In order to determine whether the Directive has promoted an increased awareness among 
the  different  stakeholders,  we  considered  the  level  of  application  of  the  Directive  where 
procurers will be required to apply one of its options to consider operational lifetime energy 
and environmental impacts.  

Of the 547 respondents of the procurers’ survey, 45% stated that they had procured road 
transport vehicles since the start of 2012 (in contracts where the requirements of the CVD 
were applicable), whereas 42% had not. It could therefore be assumed that through the 
application of the requirements of the Directive by these procurers, an increased awareness 
of the operational lifetime environmental and energy impacts of vehicles could have been 
promoted  amongst  that  group,  i.e.  45%.  However,  as  has  been  identified  already  in 
sections  6.2  and  6.4.1,  42%  of  procurers  who  responded  to  the  survey  were  already 
applying  environmental  criteria  prior  to  the  introduction  of  the  CVD  (this  refers  to  all 
respondents, including those who had and had not procured road transport vehicles subject 
to  the  requirements  of  CVD  since  2012).  Of  the  respondents  who  stated  that  they  had 
procured vehicles since 2012, 52% stated that they applied the environmental criteria prior 
to 2012 and 19% stated that they did not (out of 108 respondents).  

This implies that procurers who had applied some form of environmental criteria prior to 
the  CVD  already  had  some  knowledge  regarding  operational  lifetime  environmental  and 
energy  impacts  (although  not  all  –  depending  on  the  types  of  criteria  applied).  It  is 
therefore  difficult  to  determine  the  proportion  of  procurers  who  may  have  had  their 
awareness of these impacts increased as a direct result of the Directive, rather than the 
wider use of environmental criteria in procurement activity.  

In  interviews  with  procurers,  it  was  reported  that  in  some  cases  where  environmental 
criteria were used prior to the introduction of the CVD, little has changed in terms of the 
procurement processes applied. The options presented in Article 5(3) were considered to 
be  suitably  flexible  in  that  criteria  remained  the  same  or  similar.  This  supports  the 

52 

 
 
 
 
 
 
 
 
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transport vehicles 

argument above that the CVD therefore has little or no impact on increasing awareness of 
the operational lifetime environmental and energy impacts of vehicles amongst this group 
of procurers (i.e. those who applied environmental criteria prior to the introduction of the 
CVD). 

However, it could be argued that the Directive has promoted an increased  awareness of 
the group of procurers who did not apply environmental criteria prior to 2012 (19%) but 
who  have  since  procured  vehicles  applying  the  requirements  of  the  CVD,  which  would 
require the mandatory consideration of these impacts in the procurement decision. In these 
cases, it is possible that procurers were introduced to the concept of operational lifetime 
energy and environmental impacts for the first time as a result of being required to consider 
them by the Directive.  

In  interviews  with  EU-Level  stakeholders,  one  respondent  noted  that  there  was  a  big 
difference in attitudes to the CVD in different countries. In those countries that had already 
implemented green public procurement for vehicles, such as in Sweden, there is a sense 
that the Directive is holding them back. This is due to the fact that they are already using 
measures aimed at stimulating the uptake and use of clean vehicles (both local and national 
level), and the Directive isn’t requiring them to do more. However, in the newer Member 
States, the view is generally more positive as  the Directive has  forced policy makers to 
think about green procurement in the context of vehicles. This suggests that geography is 
likely to be an issue when it is considered whether there has been increased awareness of 
the  operational  lifetime  energy  and  environmental  impacts  of  transport,  supporting  the 
views of procurers outlined above.  

Annex 10 outlines an assessment of Commission initiatives that are aimed at the promotion 
of  the  Directive.  Both  the  Clean  Vehicle  Portal  and  Clean  Fleets  project  were  developed 
specifically to complement the Directive. In 2013, a ‘user-needs assessment’ (TTR 2013) 
was  undertaken  as  part  of  the  Clean  Fleets  project27.  As  part  of  this  assessment, 
respondents were asked about their awareness of the CVD. Only 50% of respondents (41 
of 82 respondents) stated that they were aware of the CVD’s requirements. However, the 
report noted that as the Directive had been transposed into national legislation, a greater 
proportion of respondents are more likely to be aware of the Directive’s requirements in 
this way (i.e. via the National Implementing Measures). The Clean Fleets project website 
has  also  been  visited  by  over  26,000  unique  visitors28,  again  implying  some  increased 
awareness amongst procurers.  

The Clean Vehicle Portal aimed to support the CVD whilst raising awareness and supporting 
the  implementation  of  the  CVD.  The  Portal  includes  information  on  the  CVD,  which  has 
been  accessed  frequently  throughout  the lifetime  of  the  portal  (between  900  and  1,400 
times per year between 2011 and 2015 – see Annex 10). National and European workshops 
have also been facilitated by the Clean Fleets project. The majority of attendees at both 
types  of  workshop  stated  that  the  workshops  had  helped  them  to  better  apply  the  CVD 
either ‘closely’ or ‘very closely’ (see Annex 10), suggesting that there has been an increase 
in the knowledge of event attendees  in terms of how to apply the Directive.  

In  the  interviews  and  surveys  with  manufacturers  and  contractors  there  was  little  to 
suggest that the Directive had promoted awareness of the operational lifetime and energy 
impacts.  

27 Clean Fleets Project (2012-present) – aims to provide direct support and build capacity for the implementation 

of higher standards of energy and environmental performance in road transport vehicles.  

28 Figures provided by ICLEI. 

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6.6.3.  Conclusions 

It is possible that in a limited number of cases the Directive has promoted an awareness 
of the operational lifetime energy and environmental impacts amongst procurers. However, 
it is likely to be limited to those who:  

  Have  applied  the  requirements  of  the  Directive  when  procuring  road  transport 

vehicles since its’ introduction; and 

  Did not previously apply any environmental criteria in the procurement process (or 
applied  simple  environmental  criteria  which  did  not  fully  take  into  account 
operational lifetime energy and environmental impacts).  

It has also been identified that the Clean Vehicle Portal is likely to have raised awareness 
of the Directive through interested parties accessing information via the online portal.  

6.7.  Efficiency: To what extent has the Directive generated benefits and 
costs 
for  different  stakeholders  (e.g.  national  administrations, 
contracting authorities, transport operators, manufacturers)?  (Q6) 

6.7.1.  Approach to answering the evaluation question 

This evaluation question examines the costs and benefits generated by the Directive for 
different stakeholders aiming to assess whether: 

  The administrative costs to industry and procurers are proportional to the 

benefits; 

  Procuring authorities realised cost-savings as a result of taking lifetime operational 
costs into account, and these are not wiped  out by any additional  administrative 
costs; and 

  The total economic costs of transport in terms of CO2 and pollutant emissions have 
been reduced and whether these reductions have not been wiped out by increased 
costs to industry or administrative costs to government and industry.  

In  our  analysis  we  identified  and,  when  possible,  we  attempted  to  quantify  the 
administrative  and  compliance  costs  associated  with  the  implementation  of  the  CVD  for 
procurers and suppliers of vehicles. Our analysis has been based on: 

  Analysis of the survey responses 
 

interviews with affected stakeholders (procurers and suppliers of vehicles involved 
in public procurement bids) 

  available data from relevant secondary sources  

6.7.2.  Costs associated with the CVD 

In  our  assessment  of  the  costs  linked  to  the  implementation  of  the  Directive,  both 
substantive compliance costs and various types of administrative costs were considered. 
More specifically the following types were considered: 

Compliance costs:  

  Compliance  costs  for  contracting  authorities  and  transport  operators  related  to 
possible increased prices for the procurement of new vehicles but also, additional 
investment  that  may  be  required  to  support  the  operation  of  such  vehicles  (e.g. 
methane  filling  stations/electric  vehicle  charging  points).  These  are  expected,  in 
principle, to be offset by operational cost savings due to reduced fuel consumption, 
reductions in emissions and improvements to air quality, thus leading to net benefits 
over the vehicles’ life cycles.   

54 

 
 
 
 
 
 
Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

  Compliance  costs  for  the  suppliers  of  vehicles  that  may  need  to  develop  new 
technologies in order to be able to meet the new procurement criteria set by the 
contracting authorities.   

Administrative costs:  

  Monitoring  and  enforcement  costs  for  national  authorities  responsible  for  the 
implementation  of  the  Directive,  including  inspections  and  another  type  of 
information collection.   

  Administrative costs for the contracting authorities that need to take into account 
the  requirements  of  the  Directive  in  the  procurement  procedures  and  ensure 
compliance with its provisions.  

  Administrative  costs  for  the  contractors  that  will  need  to  adapt  to  the  new 
procurement  procedures,  provide  the  additional  information  requested  and, 
possibly, perform tests to demonstrate that the vehicles meet the set requirements.  

Unfortunately, data for some of the costs indicated above was not readily available and the 
respondents to the procurers survey were often unable to provide specific cost estimates. 
In  the  majority  of  cases  they  only  provided  qualitative  feedback  on  the  presence  and 
magnitude of the various types of costs. In the sections that follow we bring together the 
evidence  collected  from  various  sources  and  attempt,  whenever  possible,  to  provide 
estimates of the identified costs.   

6.7.2.1.  Compliance costs 

Our analysis suggests that, on average, contracting authorities have experienced only a 
small increase in the purchasing costs of vehicles. 

  Our analysis of the CO2 emissions reductions achieved for passenger cars and vans 
(5.5%  improvement  in  fleet  average  emissions  for  passenger  cars,  2.3% 
improvement for vans) indicates that this will only have required a 1.7% additional 
capital investment in passenger cars and 1.0% additional investment in vans. 
  For air pollutant emissions, the maximum impact is also small and associated with 
a very small proportion of contracting authorities buying vehicles with higher EURO 
standards than were obligatory at the time. 

With  respect  to  costs  of  improving  CO2  performance  the  information  provided  by 
contracting authorities is not sufficient to determine which vehicle models might have been 
procured without the Directive, or whether the Directive has had a material effect on the 
fuels and powertrains chosen by  contracting authorities. As a  result, we have taken the 
approach  of  “back-solving”  the  additional  capital  costs  required  in  order  to  achieve  the 
estimated improvement of CO2 performance. 

With  respect  to  costs  of  improving  air  pollutant  emissions,  the  procurer  survey  results 
suggest that at maximum, the impact of the Directive was for 1% of contracting authorities 
to impose EURO 6/VI or at a time when only EURO 5/V was obligatory. Furthermore, on 
average  this  happened  just  six  months  before  EURO  6/VI  became  obligatory  and, 
therefore,  the  number  of  vehicle  procurements  affected  was  very  small.  We  have  taken 
the approach of multiplying the number of “extra” EURO 6/VI vehicles procured by the cost 
differential between EURO 6/VI and EURO 5/V vehicles. 

Costs of purchase of cleaner vehicles 
As a rule, more energy-efficient vehicles cost more to purchase than less energy-efficient 
vehicles of a similar size, and very energy-efficiency vehicles are very expensive. 

In certain cases, contracting authorities reported paying up to three times higher purchase 
prices for CNG or electric vehicles (see Table 6-9: ) Examples of green procurement bids 
extracted  from  the  Clean  Fleets  project  website  suggest  that  moving  to  cleaner  vehicle 
types (electric/CNG) has typically led to significantly higher purchase prices, without taking 
into account the additional costs for charging infrastructure. However, as already indicated 

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transport vehicles 

such  purchase  decisions  are  often  part  of  a  broader  environmental/energy  efficiency 
strategy  of  the  relevant  authorities  or  organisation.  In  some  occasions  they  were  also 
partly-funded  by  relevant  national  or  regional  energy  efficiency  support  programmes, 
typically  through  the  provision  of  subsidies.  Furthermore,  our  interviews  with  procurers 
revealed that over one third of interviewees (37.5% - 6 out of 16 interviewees) stated that 
environmental  criteria  had  no  material  impact  on  their  purchase  costs,  whereas  only 
slightly less (5 out of 16) stated that there was a slight increase in costs. 

Table  6-9:  Selected  examples  of  green  vehicles  procurement  and  related 
purchase prices   

Procurement 
authority 
(Country) 

Vehicle type 

Type of 
powertrain 
procured 

Municipal  authority 
of Ghent (BE) 

Passenger cars 

Electric  and  CNG 
vehicles  

City of Vienna 
transport operator 
-Wienna Linien 
(AT) 

Microbuses 

Electric buses 

Purchase price difference 

in  comparison 

Three  times  higher  for  electric 
to 
vehicles 
purchases29; 
previous 
Additional  EUR  5,000  for  CNG 
vehicles 

Two times higher than 
comparable diesel buses & 
charging infrastructure 

Reading transport 
operator (UK)  

Buses 

CNG  

20% higher than conventional 
diesel bus 

City of Stockholm 
covering 296 
organisations (SE) 

Passenger cars and 
transport vehicles 

Electric 

Two times higher than 
comparable petrol driven 
vehicles 

Source: http://www.clean-fleets.eu  

However, it is also the case that contracting authorities could have realised modest  CO2 
benefits  through  procurement  of  more  efficient  vehicles  using  conventional  fuels  and 
powertrains. 

Taking into account the above picture, we estimated the overall capital (purchase) costs 
for the contracting authorities. To estimate the cost increase associated with improvements 
in  CO2  emissions,  we  used  available  data  on  the  price  and  CO2  performance  differences 
between  standard  and  more-fuel-efficient  variants  of  particular  models  of  vehicle.  Table 
6-10 includes examples of specific vehicle models and respective eco-variants. 

Table 6-10 : Purchase cost difference and CO2 performance improvement for eco-
variants of various types of vehicles   

Vehicle 
segment 

Standard 
vehicle 
model 

Eco variant  % increase in 
purchase cost 

% 
improvement 
in CO2 
performance 

Passenger 
cars 

Opel  Corsa 
Color 
1.4 
Edition 

Opel  Corsa 
Ecotec 
1.0 
Turbo 
ecoFLEX 
Start/Stop 
Color Edition 

11% 

16% 

Elasticity of 
purchase cost 
with respect 
to CO2 
performance 
0.67 

29 We should note that the indicated price difference seems high, given what we know about the market pricing 

for electric vans. 

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

Vehicle 
segment 

Standard 
vehicle 
model 

Eco variant  % increase in 
purchase cost 

% 
improvement 
in CO2 
performance 

3% 

10% 

Elasticity of 
purchase cost 
with respect 
to CO2 
performance 
0.33 

Volkswagen 
Club Up 

Ford  Fiesta 
1.0 
SYNC 
Edition 

Ford  Focus 
1.6  TI-VCT 
Trend 

Ford  Focus 
1.6  TI-VCT 
Trend 

VW Golf 1.6 
TDI 
Bluemotion 
Comfortline 

VW  Crafter 
30 BITDI 

Mercedes 
210 
BLUETEC 
Sprinter 
906.611 

Ford  Transit 
Custom  290 
L1H2  LKW 
VA BASIS 

Up 

Volkswagen 
Club 
Bluemotion 
Technology 
Ford 
Fiesta 
1.0  Ecoboost 
Start-Stop 
SYNC Edition 
Ford 
Focus 
1.0  Ecoboost 
Start-
99G 
Stop-System 
Trend 
Ford 
Focus 
1.0  Ecoboost 
Start-Stop-
System 
Trend 
VW  Golf  1.6 
TDI 
Bluemotion  
Technology 
Comfortline 
VW  Crafter 
BITDI 
30 
BMT 

Mercedes 
210 BLUETEC 
Sprinter 
906.611 
BLUEEFFICIE
NCY 
Ford  Transit 
Custom  290 
L2H1 LKW VA 
ECONETIC 

Vans 

3% 

6% 

0.50 

8% 

27% 

0.31 

6% 

23% 

0.28 

3% 

10% 

0.27 

2% 

4% 

8% 

5% 

0.21 

0.80 

3% 

7% 

0.45 

Source: Ricardo Energy & Environment analysis of CO2 figures and pre-tax purchase prices 
quoted on http://www.autozeitung.de/  

Taking the median elasticities (in order to remove the effects of outliers), we estimate that 
for each 1% reduction in car CO2, purchase prices increase by 0.31%, and for each 1% 
reduction in van CO2, purchase prices increase by 0.45%. 

There is no standard value for the cost of a 1% improvement in CO2. As the table above 
indicates, a 1% CO2 improvement might be achieved relatively cheaply or relatively more 
expensively depending on which models are being substituted. The range of elasticities of 
the  purchase  price  to  CO2  performance  would  be  even  larger  (i.e.  include  even  higher 
premia for CO2 reductions) if we considered switches from conventionally-fuelled vehicles 
to  alternatively-fuelled  vehicles.  But  as  contracting  authorities  are  generally  under 
pressure to minimise capital costs, it is reasonable to assume that the cost increases they 
incur are closer to the low end of the range of possible values30.   

30 We have not used the absolute minimum elasticity in each vehicle class because authorities will often be faced 
with a limited set of eco-model options, and therefore the median eco-model elasticity is more appropriate 

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transport vehicles 

Combining  our  elasticities  of  purchase  cost  to  CO2  improvements  with  our  assumed 
average CO2 improvements of 5.5% for cars and 2.3% for vans, we estimate an average 
increase in car purchase costs of 1.7% and an average increase in van purchase costs of 
1.0%. For passenger cars, this has meant additional capital costs in the range of €28.3M 
to €401.2M over 2012-2014 (€9.4M to €133.7M per annum). In the case of vans, it has 
meant additional capital costs of €4.9 million – €20.7 million over the period 2012-2014 
(€1.6 million – €6.9 million per annum). 

In order to estimate the cost increase associated with early adoption of EURO standards, 
we made use of previous studies’ estimates of the additional cost to OEMs per vehicle of 
producing  EURO  6/VI  versus  EURO  5/V  vehicles.  These  estimates  are  provided  in  Table 
6-11. 

Table 6-11 : Additional costs of producing EURO 6/VI versus EURO 5/V vehicles 

Vehicle type 

Passenger cars – petrol 
Passenger cars – diesel 
Vans – petrol 
Vans - diesel 
Heavy duty vehicles - diesel 

Additional €s  per vehicle 
of EURO 6 / VI 

70 
600 
70 
800 
4,000 

Sources: Heavy duty vehicle from (European Commission 2007a), light duty petrol vehicles 
from (European Commission 2006b), light duty diesel vehicles from (ICCT 2012) 

Note: Costs are presented in 2015 price base, to one significant figure. 

Although  these  figures  are  based  on  the  best  publically  available  data,  they  suffer  from 
two limitations. Firstly, the EURO VI figure for heavy duty vehicles and the EURO 6 figure 
for  light  duty  petrol  vehicles  is  based  on  an  ex-ante  assessment  rather  than  ex-post 
measurement.  Secondly,  all  of  these  figures  are  based  on  declared  information  (mostly 
from  manufacturers)  on  the  costs  of  components  and  are  therefore  not  necessarily 
reflective  of  the  price  increases  ultimately  paid  by  consumers.  These  figures  ultimately 
imply additional capital expenditure by contracting authorities of €0.52 - €1.42 million on 
rigid  trucks  and  buses  over  2012-2014  inclusive,  and  additional  capital  expenditure  by 
contracting authorities on cars and vans of €0.1 million - €0.9 million over the same period. 

Turning to the compliance costs for suppliers of vehicles, a rather significant 29% (11 
out of 38) of the respondents to the suppliers’ survey referred to additional manufacturing 
costs  arising  as  a  result  of  the  CVD.  However,  most  of  them  did  not  provide  specific 
information on the type of costs associated. Only two of them referred to specific product 
design activities intended to improve efficiency that could be directly linked to the CVD.   

At  the  same  time,  the  respondents  to  the  suppliers’  survey  indicated  that  public 
procurement criteria do not represent a key driver in their decision to invest in clean and/or 
energy efficient vehicles, even though they are still considered relevant. Other parameters, 
including the Euro emission standards or fuel/energy costs, do have a more important role.  

In the case of heavy duty vehicles, one manufacturer stated that developments such as 
the  CVD  had  prompted  it  to  introduce  a  hybrid  powertrain  option  to  their  truck  fleet. 
However,  in  general,  the  feedback  provided  suggests  that  such  decisions  are  strategic 
decisions and should not be considered as a direct result of the CVD. Overall we consider 
that, since the CVD does not impose specific requirements and most procurers tend to use 
standard  criteria,  it  is  reasonable  to  conclude  that  the  compliance  costs  for  suppliers  of 
vehicles directly linked with the Directive are very close to zero.   

6.7.2.2.  Administrative costs 

In terms of the costs of monitoring and enforcement for Member States, there are 
respective 
currently  no  specific 

requirements  or  obligations.  As  such, 

the 

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Ex-Post Evaluation of Directive 2009/33 on the promotion of clean and energy-efficient road 
transport vehicles 

monitoring/enforcement  costs  can  be  considered  as  zero  (or  close  to  zero).  For  the 
Commission services, there is an obligation to prepare biannual monitoring reports.  

Turning  to  the  administrative  costs  for  contracting  authorities,  a  possible 
determinant  of  the  time  and  resources  required  is  the  procurement  option  used  by  the 
contracting authorities. Comments from some stakeholders suggest that the monetisation 
Option (2b) is more time consuming although, the interviews with 16 procurers suggest 
that  in  practice,  there  are  no  significant  differences  in  terms  of  administrative  time  per 
contract (see Annex 5).  Furthermore, as already indicated, less than 13% of authorities 
have  used  the  monetisation  method  in  a  procurement  contract  since  the  start  of  2012. 
Most  often  authorities  have  opted  for  the  less  demanding  approach  of  setting  minimum 
standards (Option 1 - 40% of respondents) or considering environmental impacts as award 
criteria  (Option  2a  -  30%  of  respondents).  In  both  cases,  besides  the  possible  one-
off/adaptation costs to establish the new procedures (or update the criteria), the level of 
effort required is limited.    

The administrative costs may also vary depending on the type of vehicle procured and the 
presence,  or  not,  of  standard  criteria  (e.g.  EURO  V/VI)  that  can  be  used  by  contracting 
authorities. In the case of trucks and special purpose vehicles, such criteria do not exist 
and authorities often establish their criteria, taking into account the requirements of the 
CVD.  In  such  case,  the  additional  time  required  may  be  higher.  Specific  examples  were 
provided  of  authorities  that  went  through  an  initial  pre-trial  period  with  the  testing  of 
existing vehicles on the market before determining the purchase criteria. However, these 
are rather few cases of large cities across the EU with sizeable fleets.  

In an earlier attempt to estimate the total costs, a study by the Department of Transport 
(DfT) in the UK31 in 2011 estimated that authorities could need up to 10% additional staff 
time  for  the  first  five  years  and  5%  thereafter,  as  a  result  of  the  need  to  consider  the 
requirements  and  for  applying  one  of  the  possible  methods  of  taking  environmental 
impacts into account. These included 5% additional staff time one-off costs for establishing 
the new procedures during an initial adaptation period, and 5% additional staff time for 
implementing the procedures. That brought the total costs for the UK authorities to around 
£0.3 million on an annual basis (around EUR 0.4 million in current prices).  

Our own survey and interviews (16 written responses in total) with contracting authorities 
across the EU suggest that the additional staff time required per contract is in the range 
of 0 to 4 hours per contract[1] - with a most common value around 3 hours - due to the 
need  for  more  detailed contract  specifications  and  the  need  for  more  intensive/frequent 
discussions  with  suppliers  to  get  all  data  required.  On  the  basis  of  the  estimated  total 
number of public procurement contract per year in the range of 2,000 - 17,000[1], and an 
average  hourly  labour  cost  in  the  public  administration  of  around  20.5  Euros[2],  the 
administrative costs associated with the CVD are estimated in the range of €0.1m - €1.1m 
per year (€0.4m-€3.2m for the period 2012-2014). 

In  terms  of  the  administrative  costs  for  manufacturers/suppliers  of  vehicles, 
specific estimates on the additional time and resources required were not made available. 
The qualitative input provided suggest a mixed picture. 12 of the 38 respondents to the 
survey (31%) indicated they incurred costs related to obtaining information, including costs 
of test procedures on non-type-approved vehicles to establish their emissions impacts. One 
respondent  referred  to  a  one-off  expenditure  of  EUR  20,000  for  measure  the  fuel 
consumption  of  20  waste  collection  vehicles  in  the  context  of  a  specific  procurement 

31 DfT impact assessment  

[1] Calculated on the basis of our estimated total number of vehicles procured, divided by the average number of 

vehicles procured in each contract (27) according to the input from the procurer survey.  

[2] Total hourly labour costs in public administration, Eurostat, 2014 – Labour cost survey 

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transport vehicles 

contract for a German city.  Thus, in the case of special purpose vehicles, the absence of 
defined  fuel  economy/emission  test  cycles  means  that  suppliers  may  face  relatively 
significant  administrative  costs  in  order  to  be  involved  in  procurement  bids.  Another 
supplier referred to the need for data collection or staff training to familiarise themselves 
with the new requirements but did not provide any cost estimates.   
However, whenever authorities used the  minimum standards or award criteria approach 
(which according to the procurers’ survey  represents more than 85%  of the cases), the 
required  information  is  easily  available  and  the  additional  administrative  costs  are  very 
close to zero. The monetisation approach is more demanding – since additional information 
is required to support the relevant calculations – and vehicle suppliers often have to spend 
additional time to collect this information and fill in the relevant forms.   

Overall, in the absence of other data sources we consider it reasonable to assume that the 
typical additional time spent to provide the information required does not exceed 1 hour 
per individual bid. On that basis, given the total number of contracts (2,000-17,000), an 
estimated 4 bids per contract32 and an average hourly labour costs of €1733, we can provide 
a rough estimate of total costs for all suppliers involved in the range of €0.1 - €1.2 million 
on an annual basis (€0.4-€3.6 million over the period 2012-2014). 

6.7.3.  Benefits associated with the CVD 

The main possible benefits expected from the introduction of the CVD include:  

  Reductions in CO2 and air pollutant emissions (benefits to society); 

  Reduction in operating costs (mainly in the form of  energy /fuel savings) for the 

procurement authorities and transport operators; and  

  Benefits to suppliers and manufacturers of vehicles.  

As there are many more publically procured cars than vans and as the CO2 improvement 
for this segment has been greater, passenger cars account for a majority of these benefits.  

On  the  basis  of  the  data  available  we  have  estimated  a  maximum  level  of  5.5% 
improvement  in  the  energy  efficiency  and  CO2  performance  of  passenger  cars  and  a 
maximum 2.3% improvement in the energy efficiency and CO2 performance of vans. Such 
figures are largely in line with the feedback from the interviews with procurers, most of 
which pointed to no material changes in running costs. As already indicated, in the case of 
heavy-duty vehicles, the CO2 and energy cost impacts are most probably closer to zero, 
due to lack of necessary data for most contracting authorities to be able to make effective 
comparisons between these vehicles. 

We have quantified the energy cost savings benefits by calculating the litres of fuel saved 
in cases where these improvements imply, and then multiplying by the EU average pre-
tax  costs  of  (petrol  and  diesel)  fuel.  Monetised  CO2  benefits  can  then  be  calculated  by 
multiplying the tonnes of CO2 saved by a CO2 emissions cost factor taken from the EU’s 
2014  handbook  on  external  costs  of  transport  (Ricardo-AEA,  TRT  et  al.  2014).  The 
magnitude of the CO2 emissions benefits is roughly 25% of the magnitude of the energy 
cost benefits. 

Pollutant  emissions  benefits  have  been  realised  as  a  result  of  the  Directive  encouraging 
the early adoption of EURO standards among a very small proportion (1%) of procurers. 
On  the  other  hand,  in  the  case  of  a  possible  contribution  to  increased  dieselisation 
examined in Section 6.4 there are possible adverse effects, leading to a total increase of 

32 We assume 4 bids per contract on the basis of a general study of public procurement in Europe by PWC (PWC, 
2011).  While  this  study  did  not  isolate  procurement  of  road  transport  vehicles  in  particular,  it  found  that 
procurement actions for machinery or manufactured goods typically elicited 3-5 offers, with the mean value 
for manufactured goods being 4 bids. 

33 Total hourly labour costs for the business economy, Eurostat, 2014 – Labour cost survey 

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transport vehicles 

pollutant emissions and respective increase in costs. The per-vehicle benefits of this early 
adoption  of  EURO  standards  are  much  higher  for  buses  and  rigid  trucks,  as  they  have 
higher lifetime mileages and higher per-km air pollutant emissions than light duty vehicles.  

In  terms  of  the  benefits  to  manufacturers,  to  the  extent  that  procurers  have  incurred  a 
slight increase in purchase costs per vehicle the CVD could have had a slight positive effect 
on  manufacturer  revenue  from  the  public  sector.  However,  manufacturers  also  face 
increased costs when manufacturing vehicles with lower CO2 emissions and air pollutant 
emissions,  and it is not clear whether the additional costs will have outweighed additional 
revenues,  or  vice  versa.  (IW  Köln  2013)  claim  that  due  to  competitive  pressures,  on 
average  manufacturers  are  only  passing  through  additional  costs  from  fuel  saving 
technologies  to  a  limited  extent.  It  is  thus  conceivable  that  despite  higher  revenues, 
manufacturers’  margins  remain  unaffected  or  are  even  reduced.  Our  central  estimate  is 
that, overall, the benefits to manufacturers are close to zero.  

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Table  6-12  summarises  our  estimates  of  the  costs  and  benefits  associated  with  the 
implementation of the CVD for the period 2012-2014. They include the administrative and 
compliance costs for authorities and suppliers  of vehicles  and the benefits – in terms of 
reduction of operational costs for authorities and the total costs of transport in terms of 
CO2  and  pollutant  emissions.  We  also  present  the  figures  in  the  case  of  the  alternative 
dieselisation scenario presented earlier where the expected increase in pollutant emissions 
leads also to cost increases.  

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transport vehicles 

Table  6-12  –  Estimated  costs  and  benefits  of  the  implementation  of  the  CVD34 
during the period 2012-2014  

Total vehicles bought 
under the policy 
(thousands) 
Costs (in million €) 
(1) Administrative 
costs for authorities 

(2) Compliance costs 
for authorities 
(additional capital 
expenditure) 
(3) Administrative 
costs for suppliers 

Passenger 
cars 
 86 to 1215  

Vans 

 29 to 121  

Rigid 
trucks 
 32 to 35  

Buses 

 12 to 53  

All 
vehicles 
158 to 
1424 

 0.2 to 2.8 *  

 0.1 to 0.3 
*  

 0.07 to 
0.08 *  

 28.4 to 
402.1  

 4.9 to 
20.7  

 0.27 to 
0.30  

 0.03 to 
0.12 *  

 0.25 to 
1.12  

0.4 to 3.2 

33.8 to 
424.2 

 0.2 to 3.1 *  

 0.1 to 0.3 
*  

 0.08 to 
0.09 *  

 0.03 to 
0.13 *  

0.4 to 3.6 

(4) Compliance costs 
for suppliers 
(5) Total costs 
(1)+(2)+(3)+(4) 
Benefits (in  million €) 
(6) Operating costs 
savings 
(7) CO2 emissions 
costs savings 
(8a) Pollutant 
emissions costs 
savings (no 
dieselisation) 
(8b) Pollutant emissions 
costs savings (with 
dieselisation) 
(9a) Total benefits 
(6)+(7)+(8a) 
(9b) Total benefits 
with dieselisation 
Net benefit 
(9)-(5) 
Net benefit (with 
dieselisation) 
Benefit : cost ratio 
(9)/(5) 
Benefit : cost ratio 
(with dieselisation) 

Est. close 
to zero 
 28.8 to 
408.0  

Est. close 
to zero 
 5.1 to 
21.3  

Est. close 
to zero 
 0.4 to 0.5 

Est. close 
to zero 
 0.3 to 1.4  

 26.2 to 
370.7  

 5.3 to 
22.5  

Est. close 
to zero 

 8.2 to 116.7    1.7 to 7.0   Est. close 

Est. close 
to zero 
34.6 to 
431.0 

31.5 to 
393.2 

9.9 to 
123.8 

1.2 to 3.7 

 Est. close 
to zero 

 Est. close 
to zero 

 0.74 to 
3.28  

 0.74 to 
3.28  

 0.74 to 
3.28  

 0.74 to 
3.28  
 0.4 to 1.9  

 0.4 to 1.9  

 2.4  

-1.1 to -
28.1 

42.6 to 
521.0 

40.4 to 
489.2  

8.0 to 
89.6 

5.7 to 
57.8  
1.2 

to zero 

 0.40 to 
0.43  

 0.40 to 
0.43  

 0.40 to 
0.43  

 0.40 to 
0.43  

0.03  

 -0.02 to -
0.03  
 0.9  

No effect  

 0.01 to 
0.02  

-2.2 to -31.8 

 34.4 to 
487.8  

32.2 to 
456.0  

 0.01 to 
0.02  

 7.0 to 
29.5  

 7.0 to 
29.5  

 5.6 to 79.6    1.9 to 8.2    -0.02 to -

3.4 to 47.7    1.9 to 8.2  

 1.2  

 1.4  

1.1 

1.4 

0.9 

2.4 

1.1 

Source: Own elaboration on the basis of data analysis  

* Calculated from total assuming administrative costs are proportional to the number of 
vehicles bought 

34 All costs and benefits are subject to a 4% discount rate after 2015. Costs and benefits are assessed from the 
date the policy took effect (assumed to be 2012, when most Member States transposed the legislation) until all 
vehicles purchased under the policy to end of 2015 are scrapped (in the early 2030s). 

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transport vehicles 

6.7.4.  Conclusions on the efficiency of the CVD 

On the basis of the above analysis, the overall level of efficiency of the CVD is rather low, 
with the possible exception of the bus segment where the expected savings from pollutant 
emissions are rather sizeable. In the case of rigid trucks, our estimates suggest that the 
costs are greater than the benefits.  

In  terms  of  the  administrative  costs  to  industry  and  contracting  authorities,  these  are 
estimated to have been rather moderate (no more than € 6.8 in the case of upper bound 
scenario for the period 2012-2014; 2.3 million on an annual basis) and proportional to the 
estimated operating and overall benefits. 

The introduction of the dieselisation scenario – while in leads to costs from an increase in 
the total pollutant emissions – does not significantly affect the overall level of efficiency 
that remains generally positive.  

Focusing  on  the  public  authorities,  operating  costs  savings  do  not  appear  to  cover  the 
increased capital expenditure associated with cleaner vehicles. Since only a small share of 
public  procurement  contracts  use  the  monetisation  option,  the  operating  cost  savings 
associated  with  the  CVD  are  limited.  However,  due  to  its  perceived  complexity  and 
additional information requirements, the adoption of the monetisation at a broader scale 
could  lead  to  increased  administrative  costs  that  could  possibly  offset  some  of  the 
additional cost savings. However, these figures should be treated with caution given the 
uncertainty and the difficulty to directly link both the costs and the benefits with the CVD. 

In relation to suppliers and manufacturers, both the costs and benefits directly arising from 
the implementation of the CVD are estimated to be limited. The estimated administrative 
costs per contract are very small and compliance costs also appear to be limited, since the 
requirements set by authorities refer to vehicles that are already available in the market. 
Costs for meeting these standards are related to other pieces of legislation (CO2 Regulation, 
EURO Emission Standards, Car Labelling Directive etc.). Any benefits, if at all, appear to 
be marginal.  

We do need to note that, given the absence of detailed data and the important assumptions 
made in order to estimate costs and benefits, all quantitative assessment and comparisons 
must  be  treated  as  indicative  and  with  a  certain  level  of  caution.  Nonetheless,  the 
qualitative  input  available  from  various  stakeholders  clearly  supports  the  general 
conclusion that both the benefits and the costs associated with the CVD are small. 

6.8.  Efficiency: Could the effects have been achieved in a more efficient 
way (e.g. through other or additional (legislative) measures)? (Q7) 

6.8.1.  Approach to answering the evaluation question 

Whereas the previous question on efficiency aimed to identify the costs and benefits of the 
CVD for different stakeholders, the aim of this question is to evaluate whether the effects 
of  the  Directive  could  have  been  achieved  more  efficiently.  This  covers  both  of  the 
following: 

  Whether the same effects could have been achieved with fewer costs; and 

  Whether there could have been more effects with the same level of costs. 

The approach that was taken with respect to answering this evaluation question was largely 
qualitative  and  drew  on  evidence  with  respect  to  other  legislative  and  non-legislative 
measures covered elsewhere in the report. In this respect the following were important: 

  Other policies in place at the EU and national levels, as evaluated for question 10 

on coherence (see Section 6.11). 

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transport vehicles 

  Member  States’  supporting  actions,  as  discussed  in  Section  5  and  presented  in 

Annex 8.  

  The assessment of the complementary actions (see Annex 10).  

  Responses of EU level stakeholders (Annex 2). 

The  review  of  this  information  is  presented  in  Section  6.8.2.  Additionally,  within  the 
evaluation, a number of specific additional actions were explored, i.e.: 

  The potential to expand the scope of the Directive, or to introduce another initiative, 

to stimulate clean vehicle procurement by private fleets. 

  The  potential  to  introduce  monitoring  and  reporting  requirements  for  Member 

States relating to the Directive. 

  The potential for joint procurement, particularly cross-border joint procurement, as 

a result of its theoretical potential to reduce costs. 

These potential additional elements are discussed in Section 6.8.3. 

6.8.2.  Review of other or additional legislative initiatives  

The  first  part  of  the  exploration  of  whether  the  same  effects  might  have  been  achieved 
with fewer costs assesses the extent to which similar impacts, in terms of increasing the 
market share for clean vehicles, could have been achieved with other measures. As is clear 
from the evaluation of coherence in Section 6.11, the CVD is one of many different pieces 
of legislation that aim to contribute to achieving similar objectives in relation to improving 
air quality and to reducing CO2 emissions and energy use. However, it would be wrong on 
this  basis  to  conclude  that  the  CVD  was  not  needed,  as  the  evaluation  of  coherence 
concluded that the CVD was largely coherent with, and so broadly complementary to, the 
other legislation in place (see Section 6.11).  

For cars, there are a number of demand-side instruments, including the CVD, which work 
with the supply-side passenger car CO2 Regulation. Of these, the fuel efficiency labelling 
Directive and national taxation measures directly target potential purchasers of new cars. 
However,  purchase  costs  of  such  vehicles  remain  high,  as  the  taxation  measures  are 
usually  not  sufficient  to  make  new  vehicle  technologies  competitive  with  existing  mass 
market technologies.  In order to address this, strong fiscal measures, e.g. incentives or 
taxes  (either  at  the  Member  State  or  the  EU  level),  are  often  introduced  to  make  new 
technologies  competitive.  However,  such  measures  are  either  financially  expensive  or 
politically  difficult,  and  so  are  usually  not  applied  to  the  levels  and  extent  necessary  to 
make  new  technologies  competitive.  Hence,  requiring  the  public  procurement  of  clean 
vehicles, as the CVD is intended to do, is an alternative, more politically-feasible and less 
costly  means  of  increasing  the  market  for  new  technologies  in  cars  and  thus  reducing 
production costs and prices. For heavy duty vehicles, the CVD is potentially more important 
in  stimulating the  demand  for  cleaner  vehicle  technologies,  as  there  is  currently  no  EU-
level, supply-side legislation to require the development of such vehicles. 

It should also be noted in this respect that the public procurement of ‘greener’ products is 
considered  to  have  wider  benefits  than  simply  increasing  the  market  share  of  such 
products.  Green  public  procurement  is  considered  to  be  an  appropriate  policy  measure 
where there are barriers to the wider uptake of greener products, as discussed in Section 
6.3.2. Given the potential benefits of the use of clean vehicles from the perspective of the 
environment,  but  also  as  a  result  of  their  potentially  lower  total  cost  of  ownership  (as 
discussed  in  Sections  6.2.2  and  6.2.3),  coupled  with  their  low  uptake,  there  are  wider 
benefits that are difficult to quantify that arise from stimulating the public procurement of 
clean vehicles.   

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An alternative to EU or Member State legislation might have been to implement an initiative 
at  the  European  level,  such  as  those  discussed  in  Annex  3,  instead  of  the  Directive. 
However, it is clear from the discussion in that Annex, and also that of Section 6.10, that 
while such initiatives can support the implementation of the Directive, they are unlikely to 
have  as  wide  a  reach  as  a  legislative  measure.  Hence,  it  is  unlikely  that  a  Commission 
initiative could have achieved the effects of the Directive with fewer costs. 

The  EU-level  stakeholders  that  were  interviewed  for  this  evaluation  had  few  views  on 
whether  the  Directive  could  have  been  implemented  more  efficiently.  However,  it  was 
suggested that a Directive that had a real obligation, i.e. a Directive that did not allow for 
business-as-usual  in  many  cases,  or  one  that  was  designed  in  a  simpler  manner,  could 
have  been  more  effective,  and  thus  efficient  (see  Annex  2).  The  inclusion  of  a  simpler 
approach  in  the  Directive  was  a  recommendation  of  the  Clean  Fleets  project,  which 
produced its final recommendations at about the same time as this evaluation was being 
concluded.  The  project  proposed  that  a  standardised  definition  of  a  clean  vehicle  be 
introduced, with a defined minimum level of performance. It was argued that this would 
(Clean Fleets 2015): 

  Make it clear that meaningful environmental improvement was achieved; 

  Be easy to use; 

  Provide a focus for the market beyond the public sector (as the public sector has a 
relatively small share of the many vehicle markets; see Table 6-3 in Section 6.4); 

  Be easy to communicate, thus addressing the perceived complexity of the current 

Directive (see Section 6.4.1).  

The  recommendations  noted  that  such  definitions  must  be  ambitious,  in  order  that  real 
immediate  improvement  is  achieved,  and  progressively  tightened  over  time,  in  order  to 
remain relevant and to act as a market driver. It was also recommended that, in order to 
ensure  that  the  Directive  stimulated  the  uptake  of  technologies  other  than  fuel-efficient 
diesel vehicles, that an ‘advanced clean vehicle’ should be defined and that a target for the 
minimum proportion of such ‘advanced clean vehicles’ should be set for public fleets by a 
fixed date.            

6.8.3.  Review of potential additional initiatives covered within the evaluation  

The  first  potential  addition  to  the  Directive  that  was  addressed  directly  within  the 
evaluation was the potential to expand the scope of the Directive, or to introduce an 
additional  initiative,  to  the  procurement  of  vehicles  by  private  fleets.  This  was 
explored with stakeholders within the evaluation. Several stakeholders argued that it would 
be a potentially useful approach to extend the Directive to some private fleets, as many of 
these were large and so  extending the Directive to these  would increase the number of 
vehicles  covered.  It  was  also  noted  that  such  fleets  had  a  responsibility  to  reduce  the 
environmental  impacts  of  their  operations.  However,  it  was  recognised  by  many 
stakeholders  that  there  were  practical  challenges  to  expanding  the  Directive  to  private 
fleets, not least as such fleets were different to public fleets and so any relevant provisions 
would need to be well thought through. It was also argued that large fleets would already 
take  account  of  vehicle  performance  in  the  course  of  their  purchase  decisions  and  so 
legislation in this area was not needed. Instead of expanding the scope of the Directive, 
other stakeholders argued that the focus should be on improving the current CVD in the 
first instance (see Annex 4).  

At the stakeholder workshop, it was noted that the trend is towards cities owning fewer 
and  fewer  vehicles  and  instead  procuring  services  that  rely  on  private  fleets.  Hence,  if 
consideration was to be given to expanding the scope of the Directive, it could be expanded 
to all services that are  procured by  cities that have a  significant transport  element (see 
Annex  3).  The  final  recommendations  of  the  Clean  Fleets  project  proposed  a  similar 
extension to the scope of the Directive, i.e. to “all operators of public services which involve 

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the use of vehicles as a major component of the contract”, as well as to those companies 
sub-contracted by the main contractor (Clean Fleets 2015). 

A more comprehensive assessment was undertaken to identify the potential to introduce 
monitoring and reporting requirements for Member States relating to the Directive 
(see  Annex  13).  There  were  conflicting  views  on  the  adequacy  of  the  existing  reporting 
requirements,  as  most  stakeholders  and  some  Member  States  believed  that  these  were 
inadequate, although some Member States disagreed. The main issue raised in relation to 
additional reporting requirements, both by those who thought the existing requirements 
were and were not adequate, was how more reporting requirements would be delivered in 
practice in a proportionate way. If reporting requirements were too prescriptive, there is 
clearly a risk that the administrative costs would increase significantly. On the other hand, 
more  monitoring  on  the  part  of  Member  States  would  provide  more  information  on  the 
application and impacts of the Directive in order to inform evaluations such as this and, 
subsequently, potential revisions to the Directive. Consequently, at least in the short-term, 
it  would  be  useful  for  Member  States  to  report  on  the  application  and  impacts  of  the 
Directive in a manner that is sufficiently consistent for comparisons to be made between 
Member States, but sufficiently flexible that it does not impose excessive administrative 
burden on Member States.  In this respect, the Commission could consider developing a 
template for the reporting of the CVD as part of the reporting requirements of either the 
public procurement Directives or the alternative fuels infrastructure Directive. However, in 
either case, the use of the template by Member States would be voluntary, and so each 
national authority could be left to decide whether or not to report on the impacts of the 
CVD using this format. Such an approach is likely to deliver more consistent, comparable 
and complete information than a less prescriptive approach.      

There  has  been  interest  in  joint  procurement  as  a  result  of  its  perceived  potential  to 
reduce  costs,  and  therefore  increase  the  efficiency  of  public  procurement.  While  joint 
procurement was not mentioned in the Directive itself, the Clean Vehicle Portal included 
provisions to facilitate joint procurement, which was not the first time that an EU initiative 
had  considered  joint  procurement  as  a  potential  way  of  reducing  the  costs  of  procuring 
clean vehicles and, in the longer-term, also of reducing administrative costs. According to 
available information about the PROCURA and COMPRO projects, which finished in 2008 
and 2009 respectively, both had initially aimed to further cross-border, joint procurement, 
but neither was eventually successful in this respect. The COMPRO project reported upon 
two successful examples of joint procurement for transport, but both were within countries 
and neither involved road transport vehicles. Two of the case studies developed within the 
Clean  Fleets  project  focus  on  joint  procurement,  but  again  within  a  particular  country, 
rather than cross-border procurement (see Annex 11). For the work undertaken for this 
evaluation, we were unable to identify many activities on cross-border procurement, apart 
from  an  ongoing  attempt  to  set  up  common  procurement  for  hydrogen  buses  and  an 
initiative  launched  by  the  city  of  Paris  to  procure  electric  buses  and  refuse  collection 
vehicles with other major European cities (City of Paris 2015). 

The original Clean Vehicle Portal had a forum with the aim of bringing together users for 
the purpose of joint procurement, but this was not well used. The revised version of the 
Portal,  which  will  go  live  in  the  second  half  of  2015,  will  include  functionality  and  more 
information  to  encourage  joint  procurement.  Within  the  Clean  Fleets  project,  joint 
procurement  has  not  been  a  main  focus  of  the  project,  as  potential  users  ranked  other 
issues of higher importance in the project’s initial user needs assessment (see Annex 11).         

No  EU  level  stakeholder  that  was  interviewed  for  this  evaluation  was  aware  of  any 
innovative  or  joint  procurement  activities  that  had  been  implemented  as  a  result  of  the 
CVD. Several noted joint procurement was difficult and mentioned issues that were raised 
by the final report of the COMPRO project in 2009, including different legal and cultural 
environments  within  countries.  COMPRO  called  for  the  exploration  of  different  financial 
instruments, such as the EIB’s Elena (European Local ENergy Assistance) facility, as well 

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transport vehicles 

as continued support from the Commission for common procurement in order to overcome 
the barriers. At the meetings with Member States and stakeholders that were held as part 
of this evaluation, few had any views on joint procurement, although those that did noted 
similar challenges to those mentioned already. A stakeholder noted that support from the 
Commission  was  important,  such  as  that  currently  being  provided  under  the  Public 
Procurement Innovation instrument, while another suggested that rather than full cross-
border procurements, joint expressions might be sufficient (see Annex 3).  

6.8.4.  Conclusion on whether the effects could have been achieved more efficiently 

It was not possible to identify an alternative, politically-feasible approach that might have 
delivered the desired effects of the Directive with fewer costs.  While fiscal incentives or 
taxation measures could help to stimulate the market for clean vehicles, the former would 
increase costs, while the latter are often politically difficult. Hence, the CVD, in targeting 
public sector procurement, is an efficient instrument compared to the potential legislative 
alternatives.  While  some  of  the  EU’s  complementary  initiatives  do  focus  on  public 
procurement, such as the Clean Vehicle Portal, Clean Fleets and GP 2020, it is difficult to 
foresee that such initiatives would be able to reach as many organisations as the Directive 
does. It should also be noted that using public procurement as a means of increasing the 
market share of clean vehicles delivers wider benefits that are both difficult to quantify, 
and which would not be delivered to the same extent by other measures.  

It  was  proposed  that  making  the  Directive  simpler  would  make  it  more  efficient,  as  the 
impacts  could  increase  as  the  costs  reduce,  e.g.  by  defining  what  is  meant  be  a  ‘clean 
vehicle’.  This  approach  would  also  address  some  of  the  issues  mentioned  in  previous 
questions  with  respect  to  the  lack  of  clarity  as  to  the  types  of  vehicles  for  which  the 
Directive is aiming to stimulate the market.  

Overall, it might be concluded that extending the scope of the Directive to private fleets 
could increase the impacts of the Directive, although it would be important to identify the 
extent  to  which  this  would  bring  added  value  compared  to  existing  practices  within  the 
industry. If the purchase of ‘clean vehicles’ is standard, or at least  widely undertaken in 
large fleets, the impacts of expanding the scope of the Directive to such fleets could be 
minimal, and not worth the additional costs. The extension of the scope of the Directive to 
a wider selection of contracts procured by public authorities, i.e. to those in which the use 
of vehicles is a major component, could be considered. Again, though, it would be worth 
identifying the extent of the potential in this respect, and also to examine the legal and 
practical issues associated with the definition and operation of the relevant contracts, e.g. 
how to ‘define’ a major component, the extent to which such an approach would deliver 
change or just a shuffling of vehicles between contracts. 

The  introduction  of  reporting  requirements  on  Member  States  needs  to  balance  the 
potential  significant  additional  administrative  burden  on  Member  States  from  too 
prescriptive requirements with the need to understand the application and impacts of the 
Directive in order to inform the future direction of the policy. Hence, an appropriate way 
forward  to  deliver  consistent,  comparable  and  complete  information  could  be  for  the 
Commission to develop a template for voluntary  reporting under the  CVD, which will be 
incorporated  as  part  of  the  reporting  requirements  of  either  the  public  procurement 
Directives or the Alternative Fuels Infrastructure Directive. This would provide a framework 
for  Member  States  to  use,  if  they  wish  to,  but  would  increase  the  chances  of  any 
information that is received being consistent, comparable and complete. 

With  respect  to  joint,  cross-border  procurement,  the  practical  challenges,  not  least 
different legal and cultural environments in different Member States, still appear to provide 
a barrier to  such procurement,  even though in the longer-term  such  procurement  could 
lead  to  reduced  vehicle  purchase  costs  and  in  the  longer-term  reduced  administrative 
costs. Additionally, there are financial barriers to the procurement of clean vehicles, which 
might be overcome through the use of different financing mechanisms, such as those of 
the  EIB.  Consequently,  it  might  be  beneficial  for  the  Commission  to  further  explore  the 

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extent  to  which  the  short-term  barriers  to  cross-border  joint  procurement  might  be 
overcome through the use of different finance measures, perhaps via the EIB.      

6.9.  European Added Value: Would it have been possible to obtain similar 
or better results in terms of the market share of clean vehicles without EU 
intervention, i.e. the Clean Vehicles Directive? (Q8) 

6.9.1.  Approach to answering the evaluation question 

This question seeks to determine whether the results of the CVD could be achieved (similar 
or better) without EU intervention (i.e. the CVD).  

The approach taken to answering this evaluation question was largely qualitative and drew 
on evidence from:  

  Surveys and interviews with procurers;  

  Responses of EU-level stakeholders; and  

  Member State Fiches, in particular information on supporting actions.  

6.9.2.  Evidence on achieving similar or better results with EU-level action 

As  has  already  been  identified  in  the  first  question  on  effectiveness  (Section  6.2),  the 
impacts of the CVD have been found to be limited in terms of increasing the market share 
of clean vehicles and of decreasing  CO2 and pollutant emissions. This suggests that it is 
likely that similar results would have been achieved without taking action at the EU level, 
i.e. by not introducing the CVD.  

It was identified that 45% of procurers responding to our survey (Annex 4) had procured 
road transport vehicles since the start of 2012 where the requirements of the CVD were 
applied, indicating that they were introduced to the concept of operational lifetime energy 
and environmental impacts in procurement. However, it was also identified that in many 
cases  procurers  had  been  applying  environmental  criteria  in  some  form  prior  to  the 
introduction of the CVD. Some Member States and cities stated that existing green public 
procurement policies for vehicles were likely to be unaffected by the Directive’s existence 
or  its  potential  repeal  (see  Annex  2).  When  interviewed,  procurers  stated  that  in  most 
cases  the  same  types  of  vehicles  were  being  purchased  as  before  (see  Annex  5).   
Manufacturers  also  indicated  that  they  thought  there  had  been  very  little  effect  on  the 
choices of fuels and power trains, fuel consumption, or prevailing Euro Standards, and that 
other  factors  are  more  likely  to  affect  vehicle  purchase  choice  over  time,  such  as  the 
adoption  of  Euro  Emission  Standards,  LDV  CO2  Regulations  or  market  trends  more 
generally  (interviews  in  Annex  6).  This  evidence  supports  our  assessment  that  similar 
results would have been achieved without the CVD.  

In  the  limited  cases  where  environmental  criteria  were  not  commonly  used  prior  to  the 
introduction of the CVD, awareness of these issues may have been increased. However, 
whilst addressing the needs of the Directive to increase awareness, there is no evidence 
to suggest that this increased awareness has led to the achievement of any of the general, 
operational or specific objectives of the Directive. Interviews with procurers support this 
as  those  procurers  who  did  not  apply  environmental  criteria  prior  to  the  introduction  of 
CVD stated that they also did not feel that there was a significant change in the types of 
vehicles being procured (Annex 5).  

It was also considered whether the introduction of the CVD was likely to have had greater 
impacts in some Member States compared to others, due to the differences in the level of 
use of environmental criteria prior to the introduction of the CVD. However, the analysis 
of procurer survey results could not support this theory, as there was no clear divide in 
terms of respondents who stated that they did or did not apply environmental criteria prior 

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transport vehicles 

to  the  introduction  of  the  CVD  and  the  Member  State  that  they  came  from.  As  the 
application of environmental criteria in procurement decisions was voluntary prior to the 
introduction  of  the  CVD,  it  is  therefore  likely  that  their  use  by  procurers  was 
determined/promoted by the organisation rather than the Member State.  

Few  EU-level stakeholders interviewed had  any views as to whether it would have been 
possible to obtain similar or better results without the Directive. Again, this was partly due 
to  the  perceived  lack  of  results  from  the  implementation  of  the  Directive,  which  also 
indicates  that  it  is  likely  that  similar  results  would  have  been  achieved  without  EU 
intervention.  

A number of EU-level stakeholders noted that the Directive is part of a package of measures 
and as a result other measures could also be used to increase the market share of clean 
vehicles,  such  as  improving  the  passenger  car  CO2  Regulation  and  making  it  more 
stringent,  tax  incentives  and  more  central  government  support  to  regional  and  local 
authorities, which could lead to the achievement of better results. It was also suggested 
that  more  effort  should  go  into  looking  at  how  the  purchase  of  clean  vehicles  might  be 
supported financially, for example, with mechanisms set up by the European Investment 
Bank  (EIB).  However,  a  couple  of  stakeholders  did underline  the importance  of  the  role 
that public procurement has to play in increasing the market share of clean vehicles.  

Despite the evidence suggesting that similar results would have been achieved without the 
introduction of the CVD (i.e. no clear benefits), discussions with stakeholders revealed that 
they would prefer to retain the Directive.  

Many stakeholders at the Member State and stakeholder meetings (Annexes 9 and 3) and 
participating in EU-level stakeholder interviews (Annex 2) were against a full repeal of the 
Directive.  It  was  suggested  by  one  that  the  Directive  would  become  more  useful  in  the 
years to come, as a wider range of vehicles that might be considered to be ‘clean’ come 
onto the market. It was also felt by stakeholders that repealing the Directive would give 
the  wrong  political  message,  and  that  the  focus  should  instead  be  on  making  it  more 
effective  and  ensuring  that  it  delivers  better  results.  As  mentioned  previously  in  this 
evaluation, the need to define what is meant by ‘clean vehicle’, and addressing issues with 
the effectiveness of the environmental criteria options will be pertinent in delivering better 
results.  

Its  retention  is  also  justified  as  it  is  one  of  many  measures  that  are  part  of  a  broader 
package of supply-side and demand-side policy tools to further develop the market of clean 
vehicles.   

6.9.3.  Conclusions on whether results could have been achieved without EU intervention 

We expect that it is the case, supported by feedback from various stakeholders, that the 
Directive has had little impact in many countries (where similar approaches were already 
being  used).  However,  elsewhere,  where  such  practices  had  not  been  established,  it  is 
likely to have had more of an impact, although the evidence that we collated on this was 
not  conclusive.  The  analysis  of  effectiveness  suggests  that  there  may  have  been  some 
impacts, although these are likely to have been limited. Our assessment of EU added value 
therefore leads us to the conclusion that similar effects could have been achieved without 
the Directive.  

However,  despite  the  lack  of  clear  benefits,  stakeholders  have  stated  a  preference  for 
retaining the Directive, although with improvements focussing on making it more effective 
and delivering better results.  

6.10.  European Added Value: To what extent have the Directive and the 
initiated  and/or  supported  a 
associated  Commission 

initiatives 

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recognised exchange of good practices between contracting authorities in 
different Member States? (Q9) 

6.10.1. Approach to answering the evaluation question 

The analysis undertaken to answer this question draws primarily on the assessment of the 
associated  Commission  initiatives  (see  Annex  11).  This  assessment  focused  on  the  two 
projects specified in the question, i.e. the Clean Vehicle Portal and the Clean Fleets project, 
and was based on a review of project literature and other outputs, as well as engagement 
with the respective lead contractors and selected project participants. In addition to these 
two projects, another three were identified and reviewed that were considered to have the 
potential to help with answering the necessary questions. These were: GPP 2020, which 
was an ongoing project and two older projects, PROCURA and COMPRO, which finished in 
2008 and 2009, respectively. In addition, questions about the Clean Vehicle Portal and the 
Clean Fleets project were asked of various stakeholders in different sets of interviews that 
were undertaken for the purpose of the wider evaluation, including EU level stakeholders 
(see Annex 2), Member States (Annex 8) and procurers (Annex 4).  

6.10.2. Evidence of the initiation or support of the exchange of good practices 

The  assessment  of  the  complementary  initiatives  showed  that  the  exchange  of  good 
practice on the public procurement of clean vehicles is one of the main elements of two 
projects that were ongoing at the time of writing: Clean Fleets and GPP 2020 (see Annex 
11).  The  former  focused  on  road  transport  vehicles;  in  an  assessment  of  the  needs  of 
potential users that informed the activities of the project, the exchange of good practice 
was identified as an important focus. The good practice case studies on the Clean Fleets 
website  have  been  downloaded  over  6,300  times,  while  the  presentations  from  the 
project’s  workshops,  which  also  focused  on  the  exchange  of  good  practice,  have  been 
downloaded more than 8,500 times. Hence, there appears to be a demand for good practice 
examples. 

This demand is also being met in the GPP 2020 project. While the project focuses on the 
procurement  of  a  range  of  low  carbon  products,  it  covers  low  carbon  vehicles  and  case 
studies  of  practical  examples  are  an  important  feature  of  the  project.  Good  practice 
examples were also being developed under the second phase of the Clean Vehicle Portal, 
which was also ongoing at the time of writing. It is also worth noting that both the Clean 
Fleets  project  and  GPP  2020  are  led  by  ICLEI,  which  has  a  procurement  forum  which 
enables  users  to  discuss  aspects  of  green  procurement  and  on  which  information  about 
these  two  projects  was  circulated35.  The  final  report  of  the  PROCURA  project  has 
recommended the provision of information on best practice. 

Outside of those who are involved in or who are aware of these projects, there was less 
awareness of any ongoing good practice exchange. Only two Member State representatives 
(from Poland and the UK) were aware of the Clean Fleets project, Poland had uploaded a 
guide  from  the  project  onto  its  national  procurement  website.  The  eventual inclusion  of 
good practice examples on the Clean Vehicle Portal potentially has a wider reach, as things 
stand, as seven Member State representatives were aware of the Portal, and two (Poland 
and Slovakia) noted that it was used, respectively, in training events and by contracting 
authorities.  In  Poland,  there  was  also  awareness  of  another  EU  initiative,  the  TOPTEN 
project36,  as  a  result  of  the  involvement  in  that  project  of  a  national  organisation. 
Additionally, a couple of the procurers interviewed for the project made reference to the 
usefulness of case studies and being able to obtain information on different types of vehicle 
(see  Annex  5).  EU  level  stakeholders  were  generally  unaware  of  either  the  Clean  Fleets 

35 procurement-forum.eu 

36  This project focuses on providing ‘top ten’ EU and national lists for a range of products, including cars and 

LCVs, rated according to their environmental performance; see www.topten.eu 

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project or any related good practice exchange, while engagement with cities did not reveal 
any good practice exchange other than that which was undertaken as part of one of the 
projects (see Annex 2). 

A number of Member States, including Latvia, Poland and Sweden, felt the need to include 
worked examples, and in some cases examples of bad practice, in guidance documents to 
support  the  implementation  of  the  national  legislation.  The  Netherlands  is  planning  to 
develop such guidance. While not being ‘good practice’ as such, the development of such 
examples  highlights  that  it  was  felt  that  there  was  a  need  to  provide  support  to  public 
authorities  on  the  application  of  the  Directive’s  provisions.  Both  Estonia  and  Poland 
mentioned  that  the  provision  of  more  information  on  good  practice  examples  would  be 
useful (see Annex 8). 

6.10.3. Conclusion  on  the  extent  to  which  the  Directive  and  the  associated  Commission 
initiatives have initiated and/or supported the exchange of good practice 

It does appear that there is a demand for case studies and information on good practice 
generally with respect to the procurement of clean vehicles. From the evidence presented 
above,  it  can  be  concluded  that  some  of  the  associated  Commission  initiatives  have 
supported the exchange of good practice, while others have the potential to, once these 
elements  of the respective projects have been further developed. As  one of the aims of 
both the Clean Vehicle Portal and the Clean Fleets project was to complement the Directive, 
and as Article 8 of the Directive requires the Commission to “facilitate and structure the 
exchange  of  …  best  practices”,  it  might  also  be  concluded  that  the  Directive  itself  has 
supported  such  an  exchange.  In  this  respect,  it  is  also  worth  noting  that  some  of  the 
Member States have included worked examples of the application of the evaluation criteria 
in guidance that has been developed to accompany the respective national legislation.  

The extent to which these projects, and thus by implication the Directive, have initiated 
an exchange of good practice is more difficult to assess. For the purpose of differentiating 
between the terms ‘support’ and ‘initiation’, we assume that the former refers to exchange 
within the project and  directly as a  result of the Directive,  while the  latter refers to the 
exchange of good practice beyond the exchange that has been supported. No stakeholder 
was able to identify an exchange of good practice that was not associated with one of the 
projects  discussed  in  this  section,  which  suggests  that  the  initiation  of  the  exchange  of 
good practice has not yet been achieved.   

6.11.  Coherence: How well does this legislation interact with other EU policies 
with similar objectives,  in particular the  general transport policy framework  as 
laid  down  in  the  2030  framework  for  climate  and  energy  policies,  the  2011 
Transport  White  Paper,  the  conclusions  from  CARS2020,  pollutant  emissions 
limits (EURO standards for light and heavy duty vehicles) and CO2 limits for cars, 
and the deployment of alternative fuel infrastructure? (Q10) 

6.11.1.  Approach to the evaluation question 

The purpose of this evaluation question is to determine how well the CVD complements, 
and interacts with other EU policies/legislation with similar objectives. The general, specific 
and operational objectives of the CVD were outlined and discussed in Section 2.3 in the 
Intervention Logic (European Commission 2007). Overarching strategies; CO2 legislation; 
infrastructure, fuel and energy carrier policies; end-of-life vehicle policies; and air quality 
and noise legislation have all been considered.  

6.11.2. Assessment of how well CVD interacts with other policies/instruments  

Table 6-13 provides an overview of how well the CVD interacts with other EU policies and 
instruments. Each of the relevant policies and instruments are described in more detail in 
Annex 14. 

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Table 6-13: Summary of interaction between the CVD and other EU policies with 
similar objectives 

Policy tool/initiative  How well CVD interacts with policy/instrument 
OVERARCHING STRATEGIES 
Europe 2020 Strategy  

Targets  for  reducing  CO2  and  energy  efficiency  –  CVD  aims  to 
contribute towards achieving targets 
Targets to reduce GHG emissions – CVD aims to contribute towards 
achieving targets 

2030 Framework for 
Climate and Energy 
Policies  
Transport White Paper  

CARS 21 Final Report  

Strategy for reducing 
Heavy-Duty Vehicles’ fuel 
consumption and CO2 
emissions  
Sustainable Development 
Strategy 

Thematic Strategy on Air 
Pollution  

The 7th Environmental 
Action Programme (EAP)  
Clean Air Programme for 
Europe  

European Energy 
Security Strategy  

CO2 LEGISLATION 
Passenger car CO2 
Regulation (443/2009)  

LCV CO2 Regulation 
(510/2011)  

Directive relating to the 
availability of consumer 
information on fuel 
economy and CO2 
emissions in respect of 
the marketing of new 
passenger cars (“Car CO2 
Labelling Directive” - 
1999/94/EC)  

High-level GHG reduction targets and 10 specific goals for competitive 
and resource efficient transport system – CVD aims to contribute to 
achieving GHG reduction targets, although conflict exists with goal on 
aiming  to  half  the  use  of  conventionally  fuelled  vehicles  (when 
monetisation methodology is applied, tends to favour diesels).  
Strategic vision for automotive sector, including the purchase of clean 
and fuel efficient vehicles and deployment of alternative powertrains 
– CVD aims to contribute towards achieving this vision.  
Vision also acknowledges the lack of HDV CO2 data and how this needs 
to  be  addressed  –  if  addressed  this  will  also  enable  the  CVD  to  be 
more applicable to the purchase of ‘clean’ HDVs with the availability 
of appropriate data.  
Policy framework for reducing fuel consumption and CO2 from HDVs 
(proposals forthcoming) – CVD also addresses procurement of clean 
HDVs, but is hindered by the lack of data. New policy in this area will 
address this.  
Targets including those aimed at preventing/reducing environmental 
pollution and increasing market share of environmental technologies 
and  eco-innovations  –  CVD  aims  to  contribute  to  achieving  these 
targets.  
Strategy  aimed  to  encourage  shift  towards  less  polluting  modes  of 
transport, alternative fuels, reduced congestion and internalisation of 
externalities  into  transport  costs  –  CVD  aims  to  contribute  towards 
achieving these objectives 
Sets out three high-level environmental protection objectives – CVD 
aims to contribute towards achieving these objectives.  
Proposes  legislation  to  reduce  harmful  emissions  in  the  long  terms. 
Also aims to address difficulties in achieving air  quality standards  – 
Where authorities tailor the use of the CVD to their local needs (i.e. 
use of Options 1 or 2a), they may be able to address local air quality 
issues related to transport through procurement of cleaner vehicles. 
However,  there  are  issues  with  the  use  of  Option  2b  and  achieving 
local air quality standards (if diesel vehicles are procured).  
Includes aims to shift towards alternative fuel and improved energy 
efficiency in transport to reduce EU dependence on oil – CVD aims to 
contribute towards these aims.  

Supply-side  measure  setting  fleet-wide  average  target  for  CO2 
emissions of passenger cars – CVD aims to promote the procurement 
of vehicles with lower CO2 emissions.  
Supply-side  measure  setting  fleet-wide  average  target  for  CO2 
emissions of LCVs - CVD aims to promote the procurement of vehicles 
with lower CO2 emissions. 
Demand-side  measure  requiring  the  provision  of  CO2  emission 
information for new passenger cars – CVD complements this Directive 
by promoting the procurement of clean vehicles in public sector 

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Aimed  at  reducing  CO2  from  road  transport  vehicles  –  CVD 
complements  the  use  of  these  instruments  by  stimulating  the 
purchase of clean and energy efficient vehicles.  

Policy tool/initiative  How well CVD interacts with policy/instrument 
Fiscal instruments 
introduced at national 
level to reduce CO2 from 
road transport vehicles 
INFRASTRUCTURE, FUEL AND ENERGY CARRIER POLICIES 
Directive on the 
deployment of 
alternative fuels 
infrastructure 
(2014/94/EU)  
Renewable Energy 
Directive (RED) 
(2009/28/EC)  
Fuel Quality Directive 
(FQD) (2009/30/EC)  

Includes  goal  for  increasing  the  share  of  energy  from  renewable 
sources  in  transport  sector  -  CVD  complements  this  goal  by 
stimulating the procurement of clean and energy efficient vehicles 
Targets  for  reducing  GHG  intensity  of  fuels  and  lower  air  pollutant 
emissions - CVD complements these targets through stimulating the 
procurement of clean and energy efficient vehicles 

Framework for deployment of alternative fuels infrastructure – which 
will support CVD by ensuring appropriate infrastructure is in place so 
that  CVD  can  stimulate  the  purchase  of  clean  and  energy  efficient 
vehicles (including AFVs).  

END-OF-LIFE VEHICLES 
End-of-Life Vehicle (ELV) 
Directive (2000/53/EC)  

Directive 2006/66/CE on 
batteries 

Aims to prevent or reduce waste from vehicles – possible conflicts with 
CVD depending on the types of vehicles procured and implications for 
recycling and recovery at end of life.  
Targets for recycling of vehicle batteries – possible conflicts with CVD 
depending  on  the  types  of  vehicles  procured  and  implications  for 
recycling and recovery at end of life.   

AIR QUALITY AND NOISE LEGISLATION 
Regulation 715/2007/EC 
on type approval - 
LDVs(European 
Commission 2007) 
Regulation 595/2009 
(European Commission 
2009)on type approval – 
HDVs 
Air Quality Directive on 
Ambient Air Quality 
(AQD) (2008/50/EC)  

Supply-side  measure  setting  Euro  5/6  standards  (air  pollutant 
emissions)  for  light  passenger  and  commercial  vehicles  -  CVD 
complements these standards by stimulating the procurement of clean 
and energy efficient vehicles 
Supply-side  measure  setting  Euro  VI  standards  (air  pollutant 
emissions)  for  heavy  duty  vehicles  -  CVD  complements  these 
standards  by  stimulating  the  procurement  of  clean  and  energy 
efficient vehicles 
Sets air quality limit/target values for range of air pollutants – Where 
authorities tailor the use of the CVD to their local needs (i.e. use of 
Options 1 or 2a), they may be able to address local air quality issues 
related  to  transport  through  procurement  of  cleaner  vehicles. 
However,  there  are  issues  with  the  use  of  Option  2b  and  achieving 
local air quality standards (if diesel vehicles are procured).   
Provides a basis for developing measures to reduce noise, including 
from transport – CVD aims to contribute towards reducing noise from 
transport  where  it  is  an  issue,  through  the  ability  to  include  other 
criteria in the assessment of proposals, including noise.  

Environmental Noise 
Directive (END) 
(2002/49/EC)  

6.11.3. Conclusions 

The  Clean  Vehicles  Directive  largely  complements  other  EU  policies  and  legislation  with 
similar objectives. The overarching objectives of EU policy and legislation strive to increase 
environmental  protection,  reduce  GHG  emissions  and  attain  energy  security.  The  CVD 
complements a range of other policies and legislation that work together to achieve these 
objectives, including both supply and demand-side measures in the transport sector.  

The CVD is the only piece of legislation that aims to increase the market share of clean and 
energy efficient vehicles through their public procurement, so does not replicate or overlap 
with any other policies in this respect.   

Whilst the objectives of the CVD are largely complementary with the objectives of other 
EU policies with similar objectives, it is the outcome of applying the provisions of the CVD 
that seem to be contradictory. Specifically the application of the monetisation methodology 
and its subsequent unintentional preference for the selection of diesel vehicles. A number 

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of Member States have not met required air quality targets (particularly in relation to NO2 
concentrations)  as  specified  in  the  Ambient  Air  Quality  Directive,  and  real-world  NOX 
emissions  have  also  been  found  to  be  higher  than  expected,  which  has  contributed  to 
concerns surrounding transport and local air quality.  In particular, there is concern that 
the  increased  market  penetration  of  diesel  vehicles  in  recent  years  across  the  EU  has 
contributed to this failure to meet NO2 targets. Therefore air quality is perhaps more of an 
issue now compared to when the Directive was introduced.  

In particular this raises issues with how the CVD interacts with:  

  Transport  White  Paper  (European  Commission  2011)  –  specifically  goal  1,  which 
aims to half the use of ‘conventionally-fuelled’ cars in urban transport by 2030;  

  End-of-life vehicles Directive (European Commission 2000) – depends on the impact 
that CVD has on the procurement of alternatively fuelled vehicles and implications 
for recovery and waste; and  

  Air Quality Directive (European Commission 2008) – conflicts arise when authorities 
attempt  to  address  local  air  quality  problems  (aiming  to  meet  air  quality  targets 
and limit values). Contracting authorities face problems when they apply the CVD’s 
monetisation  methodology  in  publicly  procuring  road  transport  vehicles,  which 
results in the selection of diesel vehicles, whose use can be detrimental in achieving 
local air quality objectives, particularly in relation to NO2.  

6.12.  Coherence:  To  what  extent  is  the  provision  of  multiple  options  to 
include operational lifetime environmental and energy impacts coherent 
with  the  objective  of  harmonising  the  determination  of  these  impacts? 
(Q11) 

6.12.1. Approach to answering the evaluation question 

This coherence question aims to determine the extent to which the provision of multiple 
options to include operational lifetime environmental and energy impacts (i.e. the three 
options set out in Article 5(3)) is coherent with the objective of harmonizing the 
determination of these impacts.  

The approach to answering this question is largely qualitative and has drawn on evidence 
from: 

  Responses to the procurer survey and interviews; and  

 

Interviews with EU level stakeholders.  

6.12.2. Providing multiple operational lifetime energy and environmental impact and the 
objective of harmonizing determination of these impacts 

The Directive as adopted in 2009 differs greatly from the Commission’s initial proposal for 
a Clean Vehicles Directive (European Commission 2005), which proposed that a quota of 
heavy-duty vehicle purchases should be clean vehicles. This proposal was rejected and a 
new  proposal  created  in  2007  (European  Commission  2007).  This  2007  proposal  took  a 
different  approach  and  focused  on  the  monetisation  of  the  energy  and  environmental 
impacts  as  a  means  for  taking  account  of  these  impacts  in  the  procurement  decision. 
However, this did not preclude any other award criteria that were deemed necessary from 
being  used.  This  version  also  expanded  the  scope  of  the  proposal  to  all  road  transport 
vehicles  procured  by  public  authorities.  An  Impact  Assessment  was  subsequently 
performed (European Commission 2007).  

However, when the Directive was adopted in 2009, Article 5(3) set out three  options for 
taking account of energy and environmental impacts in the procurement decision, rather 
than just the monetisation methodology presented in the 2007 proposal. The co-legislators 
intended that providing this flexibility (allowing energy and environmental impacts to also 

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be taken account of in procurement decisions through technical specifications and award 
criteria) was deemed important to enable public authorities and operators to select options 
that best suited local environmental issues and priorities.  

The three options as set out in Article 5(3) of the Directive were described in Section 5.1. 
As revealed in that section on the implementation of the Directive, 25 out of the 28 EU 
Member States allowed all three options to be used by procurers. The main reasons cited 
by Member States for this were to ensure flexibility in the application of the Directive for 
procurers; enabling procurers the ability to use options best suited to their procurement 
needs/individual  circumstances;  and  reflecting  existing  sustainable  procurement  policy 
where it was applied prior to the Directive.  

Evidence from procurers (in the survey and interviews) suggests that CVD has been applied 
in procurement actions in a varied manner across the EU. 40% of procurers responding to 
the survey stated that they set technical standards (Option 1). 30% applied a weighting 
for  energy  and  environmental  criteria  in  the  contract  evaluation  (Option  2a),  whereas 
13.5%  stated  that  they  applied  the  monetisation  methodology  (Option  2b).  When 
interviewed, procurers revealed that they used a variety of the options depending on what 
type  of  vehicle  they  were  procuring.  For  example,  one  procurer  used  the  monetisation 
methodology for passenger cars and minimum standards for trucks and special vehicles - 
the  main  reason  for  the  use  of  minimum  standards  in  this  case  was  the  lack  of 
environmental data for these vehicle types.  

The  application  of  each  of  the  options  in  procurement  decisions  (procurer  surveys  and 
interviews) was previously discussed in Section 6.2. A summary is provided below:  

  Setting  technical  standards  (Option  1):  The  majority  of  procurers  setting 
minimum standards stated that they demanded a certain EURO standard (in most 
cases Euro 5/V). Procurers only demanded a higher EURO standard than was strictly 
obligatory  for  new  vehicles  for  1%  of  vehicles  procured  using  the  technical 
standards  option.  Furthermore,  these  procurers  demanded  the  higher  EURO 
standard just 6 months before it became obligatory for all vehicles. It can therefore 
be considered that this option has had very little effect on procurement decisions. 
It became apparent from the surveys and interviews with procurers that some were 
unaware  of  the  requirement  to  set  minimum  standards  for  energy  consumption, 
emissions of CO2, and emissions of NOX, NMHC and particulate matter. This led to 
a large variation in terms of the aspects for which standards were set, with only 5% 
of procurers who applied Option 1 in their last contract covering all three (3 out of 
63  survey  respondents).  However,  in  some  cases  this  may  be  due  to  a  lack  of 
available data, i.e. CO2 data for HDVs.   

  Applying  award  criteria  (Option  2a):  Environmental  criteria  (often  including 
fuel/energy consumption) were given less than 20% weight in the large majority 
(75%)  of  the  procurement  cases.  Price  is  usually  given  a  greater  weight  (higher 
than  40%  in  50%  of  the  cases  examined)  while  other  criteria  (such  as  warranty 
period,  provision  technical  support,  quality  of  design)  are  also  most  often  more 
important  than  environmental  considerations.  Again,  variation  in  the  weightings 
applied,  and  weighting  of  environmental  criteria  in  comparison  to  other  criteria 
means  that  there  is  little  harmonisation  in  the  determination  of  impacts  within 
Option 2a.  

  Monetisation  of  impacts  (Option  2b):    The  least  used  of  all  of  the  options. 
However,  as  the  method  for  applying  the  monetisation  option  is  set  out  in  the 
Directive, there is less scope for contracting authorities to take varying approaches 
to applying the option to procurement, thus ensuring harmonisation of the impacts 
(assuming that the method and parameters set out in the Directive are used).  

The  variation  in  the  minimum  technical  standards  and  award  criteria  set  when  applying 
Options 1 and 2a by procurers implies that there is little harmonisation within each of the 
options. Furthermore, the provision of the three options in the Directive, and subsequent 

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transposition  of  all  three  into  25  national  implementing  measures  further  supports  the 
conclusion that there is little coherence with the objective to harmonise the determination 
of these impacts.  

6.12.3. Conclusions 

The  Directive  states  that  the  “procurement  of  vehicles  for  public  transport  services  can 
make a significant impact on the market if harmonised criteria are applied at Community 
level”.  However,  providing  multiple  options  to  include  operational  lifetime  energy  and 
environmental impacts in the Directive has led to the majority of Member States directly 
transposing  all  of  these  options  into  national  implementing  measures.  Procurers  have 
subsequently  used  all  three  options  to  varying  degrees  when  procuring  road  transport 
vehicles.  

Therefore  the  provision  of  multiple  options  to  include  operational  lifetime  energy  and 
environmental impacts cannot be considered coherent with the objective of harmonising 
the determination of these impacts. Due to the variation in which the first two options are 
applied by procurers, it can also be considered that there is little harmonisation of impacts 
within each of the options.  

The results from the procurer surveys and interviews demonstrated that the three options 
are  often  applied  in  very  different  ways,  with  varying  effects  on  the  resulting  procured 
fleet. If the objective is to harmonise the determination of these impacts, then the number 
of options available to procurers should be reduced while at the same time providing more 
detailed guidance on what is required in applying that selected option.  

Whilst the provision of three options is not considered to be coherent with the objective of 
harmonising  the  determination  of  these  impacts,  the  benefits  of  providing  these  three 
options should be recognised - primarily the retention of flexibility which is appreciated by 
Member States and procurers who can use the most appropriate option to take into account 
local needs and objectives. However, this flexibility can also be abused ensuring that little 
impact is had on the procurement decision.  

6.13.  Coherence: To what extent are the provisions of the CVD coherent, 
complementary  and/or  redundant  with  the  horizontal  EU  procurement 
legislation (in particular 2014/24/EU and 2014/25/EU)? (Q12) 

6.13.1. Approach to answering the evaluation questions 

This coherence questions aims to determine whether the provisions set out in the CVD are 
coherent, complementary and/or redundant with horizontal EU procurement legislation. A 
largely  qualitative  assessment  has  been  undertaken,  focussing  on  a  comparison  and 
analysis of the legislative texts.  

6.13.2. Coherence of provisions of CVD with horizontal EU procurement legislation 

Public  procurement  rules  set  the  way  public  authorities  and  public  utility  operators 
purchase  goods,  works  and  service.  It  is  therefore  important  to  set  up  specific  contract 
award  procedure  and  standards  to  ensure  that  public  procurement  is  made  in  the  most 
rational,  transparent  and  fair  manner.  The  European  Sustainable  Consumption  and 
Production and Sustainable Industrial Policy Action Plan (European Commission 2008) set 
out  the  legal  framework  for  public  procurement  whilst  aiming  to  change  the  way  we 
consume,  produce  and  promote  environmental  and  energy  efficient  products,  including 
through green public procurement (GPP). The EU GPP criteria for transport were updated 
in  2012  and  public  procurement  for  all  sectors  was  updated  in  2014  in  the  public 
procurement directive 2014/24/EU (PPD). Procurement by entities operating in the water, 
energy,  transport  and  postal  services  sectors  are  addressed  in  Directive  2014/25/EU 
(European Union 2014) and repealing Directive 2004/17/EC.  

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Directive  2014/24/EU  sets  out  common  EU  standards  on  public  contracts  to  boost  fair 
competition and ensure best value for money. It introduces new award criteria that place 
more emphasis on environmental considerations, social aspects and innovation. To identify 
the  most  economically  advantageous  tender  the  contract  award  decision  should  not  be 
based on price or remuneration only but should also be possible to assess value for money 
on the basis of other factors depending on the service or product concerned.  

The relevant provisions are listed below: 

•  Best price-quality ratio (Article 67, Directive 2014/24/EU) can consider qualitative, 
environmental and social criteria such as technical merit, aesthetic and functional 
characteristics,  accessibility,  environmental  and 
innovative  characteristics, 
qualification and experience of staff assigned to performing the contract, after-sales 
service and technical assistance, delivery conditions such as delivery date, delivery 
process  and  delivery  period  or  period  of  completion.  This  is  similar  to  including 
energy and environmental impacts in the purchasing decision as set out in the Clean 
Vehicles Directive; 

•  Lifecycle cost (including carbon footprint) (Article 68, Directive 2014/24/EU) shall 
be considered over the life cycle of a product, service or work. Costs that can be 
considered  are  related  to  acquisition,  use,  maintenance  and  end  of  life.  Other 
environmental externality impacts such as emissions of greenhouse gases and of 
other pollutant emissions and other climate change mitigation costs can be included 
as additional costs if they can be monetised. This is similar to the method already 
set  out  in  the  Clean  Vehicles  Directive,  but  recognising  progress  in  the  area  of 
lifecycle costing; 

•  Production  processes  used,  e.g.  the  employment  of  disadvantaged  people  or  the 
use of environmentally-friendly materials are considered to be linked to the subject-
matter of the contract; 

•  Any  “abnormally  low  bid”  (Article  69,  Directive  2014/24/EU)  will  be  rejected  if  it 
indicates  a  failure  to  observe    EU  labour  law  or  environmental  protection 
obligations; 

•  Contracts  could  be  reserved  for  sheltered  employment  undertakings  whose 
objective  is  to  bring  into  the  labour  force  disabled  or  otherwise  disadvantaged 
persons  (such  as  the  long-term  unemployed  or  members  of  disadvantaged 
minorities). 

Therefore,  Directive 2014/24/EU has been developed to reinforce the  value for money37 
focus of Government procurement and to increase competitiveness by making the public 
procurement process faster, less costly and more effective. Procurers are as a result now 
able to set social and environment aspects as key requirements for a winning bid, such as 
certification/labels  of  social/environmental  characteristics,  factors  directly  linked  to  the 
production  process  and  full  life  cycle  costing  that  could  promote  more  sustainable 
procurements, which could appear initially more costly but might save money over the long 
term.  

Overall, the scope of Directive 2014/24/EU is much broader in scope in comparison to the 
CVD. It includes social aspects and new rules on the overall bid process and it is not focused 
(understandably)  on  vehicles  and  road  transport.  On  the  other  hand,  both  the  Directive 
2014/24/EU and the CVD have a coherent approach as they both aim to stimulate energy-
efficiency by taking into account lifetime environmental and energy impacts when awarding 
successful bids.  

37 Value for money is defined as “the best mix of quality and effectiveness for the least outlay over the period of 

use of goods or services bought” 

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Similarly, Directive 2014/24/EU and the CVD are coherent in  that Directive 2014/24/EU 
requires  that  the  contract  award  decisions  shall  be  based  on  the  most  economically 
advantageous tender and that the most economically advantageous tender from the point 
of view of the contracting authority shall be identified using different approaches. First, the 
best  price-quality  ratio  shall  be  assessed  on  the  basis  of  criteria  including  qualitative, 
environmental and/or social aspects linked to the subject-matter of the public contract in 
question. Second, Directive 2014/24/EU states that the contracting authority shall specify, 
in the procurement documents, the relative weighting which it gives to each of the criteria 
chosen  to  determine  the  most  economically  advantageous  tender.  Third,  the  most 
economically  advantageous  tender  should  be  identified  using  a  cost-effectiveness 
approach, such as life cycle costing. “Article 68” and “Article 83” of Directives 2014/24/EU 
and 2014/25/EU respectively, i.e. “life cycle costing” approach, is the one area that mainly 
overlaps with the CVD, although these articles, while setting conditions for the monetising 
method to be used, do not stipulate a concrete method. Section 3 of these articles, states 
that  “whenever  a  common  method  for  the  calculation  of  life-cycle  costs  has  been  made 
mandatory by a legislative act of the Union, that common method shall be applied for the 
assessment of life-cycle costs”, and refer to a list of such legislative acts in Annex XIII. 
The only legislative act listed in mentioned Annex is Directive 2009/33/EC (CVD).  Thus, 
the  CVD  is  mentioned  and  included  in  the  most  recent  Public  Procurement  Directive, 
making  it  a  complementary  part  of  the  legislation.  In  fact,  if  the  CVD  was  abolished, 
Directive 2014/24/EU would not give any concrete guidance on how to carry out a whole 
life  cost  assessment  or  which  standard  values  should  be  used  in  performing  the 
calculations.  The  total  lifecycle  approach  mentioned  in  Directive  2014/24/EU  is  also 
voluntary,  whereas  the  application  of  one  of  the  options  outlined  in  Article  5(3)  (which 
includes the monetisation option) of the CVD is mandatory. Therefore there would be no 
mandatory  requirement  to  consider  using  total  lifecycle  approach  at  all  in  the  public 
procurement of road transport vehicles.  

There was little awareness of the new horizontal EU procurement legislation amongst EU-
level stakeholders. However, one stakeholder stated that they believed that the CVD was 
complementary  to  the  horizontal  legislation  –  this  is  due  to  the  fact  that  Directive 
2014/24/EU  does  not  contain  an  obligation  to  take  account  of  environmental 
considerations, whereas this is the case for the CVD. It was also noted that this approach 
was in line with the Commission’s stated aim of setting public procurement obligations on 
a sector-by-sector basis.  

6.13.3. Conclusions 

In conclusion, the CVD can be considered complementary to the horizontal EU Procurement 
legislation.  Whilst  Directives  2014/24/EU  and  2014/25/EU  set  out  the  broader  public 
procurement requirements enabling procurers to take into consideration a range of criteria 
(including environmental) and total lifecycle costs (voluntary), the CVD sets out the specific 
requirements  in  more  detail  for  the  road  transport  sector,  including  the  monetisation 
methodology (as set out in Article 6) (the use of one of three options is mandatory). If the 
CVD were to be abolished, it is likely that contracting authorities would find it more difficult 
to set qualitative and environmental award criteria since, as due to the broad nature of the 
Directive 2014/24/EU, there will be less guidance and reference to suitable values to use 
when performing calculations (see Section 6.14.4 for more discussion on potential impacts 
if  Directive  were  repealed).  In  the  absence  of  mandatory  requirements  to  consider  the 
environment,  such  considerations  risk  being  ignored  as  a  result  of  economic  pressures. 
Therefore,  it  is  more  correct  to  say  that  the  provisions  of  the  CVD  are  coherent  and 
complementary to the  horizontal EU legislation as it addresses  the procurement  of  road 
transport vehicles specifically, meeting the Commission’s aim of setting public procurement 
obligations  on  a  sector-by-sector  basis.  In  addition,  through  the  mandatory  inclusion  of 
operational lifetime environmental and energy  impacts in the procurement decision, the 
CVD aims to contribute to the way in which we consume and promote environmental and 

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energy efficient products through green public procurement (GPP) which is one of the main 
aims of the horizontal EU procurement legislation.     

6.14.  Sustainability: To what extent would the market develop differently 
should  the  intervention  be  ceased  partially  or  completely  at  European 
level? (Q13) 

6.14.1. Approach to answering the evaluation question 

The  approach  to  answering  this  question  can  be  considered  from  a  couple  of  different 
perspectives. First, given that the aim of the Directive was to increase the market share of 
clean vehicles, if the market consisted only of clean vehicles, the Directive  would clearly 
cease  to  have  an  effect.  In  this  case,  its  repeal  would  have  no  impact  on  the  market. 
Consequently, in order to explore this aspect, evidence was collated on the proportion of 
the  new  vehicle  market  that  can  be  considered  to  consist  of  clean  vehicles,  which  must 
also reflect the challenges of identifying which vehicles should be considered to be clean, 
as discussed in Section 6.2.2.  

The  second  perspective  is  to  take  the  information  on  the  impacts  of  the  Directive,  as 
discussed  in  Section  6.2,  and  assess  the  extent  to  which  continuing  impacts  of  this 
magnitude will affect the market share of clean vehicles. If these impacts are minimal, it 
might be concluded that repealing the Directive would have little impact on the market. 
The wider rationale for the Directive, particularly its focus on public procurement, will also 
need  to  be  considered  in  this  respect  (as  discussed  in  Section  6.3.3).  Additionally,  the 
views of stakeholders interviewed or otherwise engaged for this project will be taken into 
account. These two perspectives will be considered in turn in Section 6.14.2. 

In addition to a complete repeal, the question also asks about a partial repeal. As can be 
seen  by  the  evaluation  of  the  first  effectiveness  question  (see  Section  6.2),  the 
monetisation  methodology,  i.e.  option  2b  in  Article  5(3),  has  potentially  the  most 
significant  impact  on  the  market.  It  is  also  worth  noting  in  this  respect  that  the 
Commission’s  proposal  that  eventually  led  to  the  adoption  of  the  CVD  proposed  that 
monetisation was the only option allowed for taking account of energy and environmental 
impacts  (European  Commission  2007).  Engagement  with  the  Commission  early  in  the 
project suggested that an evaluation of retaining only this option in a revised Directive was 
potentially of interest. Hence, the exploration of the partial repeal of the Directive assumed 
that the only option retained for the consideration of energy and environmental effects in 
the public procurement of clean vehicles was the monetisation methodology required by 
option 2b of Article 5(3) of the Directive. This will also be considered in Section 6.14.3. 

6.14.2. The role of the CVD in the development of the market for clean vehicles  

In order to identify the proportion of the new vehicle market that might be considered to 
consist of clean vehicles, it is important to identify information on the existing market share 
of such vehicles. The most comprehensive data on the new vehicle market in the EU are 
for passenger cars and LCVs, as a result of the monitoring requirements of the passenger 
car and LCV CO2 Regulations. The most recent monitoring report from the EEA showed that 
the number of alternatively-fuelled cars has not exceeded 4% of the new car market since 
2000, while the figure for 2013 was only 2.4%. The definition of alternatively-fuelled car 
used by the EEA was broad, i.e. any car that was not a petrol or a diesel car; no judgement 
was made on whether these might be considered to be ‘clean vehicles’. The sales of new 
alternatively-fuelled cars have been dominated each year by gas vehicles (LPG and natural 
gas;  see  Figure  6-5).  Only  1.5%  of  new  LCV  registrations  were  alternatively-fuelled  in 
2013, and again gas vehicles made up a significant proportion of this figure (EEA 2014). 
However, it must be noted that even for petrol and diesel vehicles, some will be considered 
to  be  ‘cleaner’  than  others  and  potentially  comparable  (or  even  better)  in  terms  of 
emissions  or  energy  consumption  than  some  of  the  alternatively-fuelled  vehicles  (see 
Section 6.2.2). 

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Figure 6-5: Number of new registrations of alternatively fuelled cars in the EU-27 
in 2013    

Source: EEA (2014), based on the registrations given in Table 3.5 of this report 

Identifying  comparable  information  for  other  modes  of  road  transport  is  more  difficult. 
Information  on  total  registrations  of  buses,  coaches  and  heavy  commercial  vehicles  is 
published frequently by ACEA, but this does not distinguish those vehicles using alternative 
fuels. Information on the gas vehicle stock in Europe is published by the NGVA, but this 
relates to the whole fleet, not just new vehicles. Figures for 2014 suggest that there are 
only 13,000 buses and 9,000 trucks using gas in Europe38. For the sake of comparison, the 
most recent figures from DG MOVE on the total stock of these vehicles in the EU suggest 
that in 2012 there were 816,100 buses and 34 million goods vehicles  (although this figure 
is likely to be dominated by LCVs); (European Commission 2014). Consequently, it appears 
unlikely  that  shares  of  alternatively-fuelled  vehicles  in  the  market  for  new  buses  and 
commercial vehicles will be significantly higher than in the new car market.  Additionally, 
as discussed in Annex 11, there is a need for new vehicles to continue to become more 
fuel efficient and to reduce their CO2 and pollutant emissions.  Hence, it is clear that the 
EU new vehicle market cannot be considered to consist of 100% clean vehicles, particularly 
given the long-term improvements that are needed. 

Evidence on the impact of the Directive was presented in the discussion of the first question 
on effectiveness (see Section 6.2). This demonstrated that the impact of the Directive on 
the market to date has been relatively small, even under the most generous assumptions. 
Hence, it might be concluded that repealing the Directive would have little impact on the 
market.  This  was  indeed  the  conclusion  of  some  of  the  EU  level  stakeholders  that  were 
interviewed as part of the evaluation. To support this conclusion, it was noted that some 
Member States and some cities had been adopting green public procurement policies for 
vehicles prior to the adoption of the Directive and that such approaches were likely to be 
unaffected both by the Directive’s existence and its potential repeal (see Annex 2). 

However, concluding from this discussion that the Directive should be repealed ignores to 
some extent the original purpose of the Directive. As was discussed in Section 6.3.3, green 
or sustainable public procurement is considered to be an appropriate policy measure for 

38 Downloaded from www.ngvaeurope.eu/european-ngv-statistics on 4 June 2015 

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stimulating  markets  where  there  are  barriers  to  the  wider  uptake  of  greener  or  more 
sustainable  products.  This  message  was  reinforced  by  the  2014  horizontal  public 
procurement Directives, as these set out the framework to enable public procurers to take 
account of environmental considerations, including the monetisation of operational costs 
(see  Section  6.13).  However,  these  Directives  do  not  require  that  environmental 
considerations be taken account in procurement in the way that the CVD requires these to 
be taken account of in the procurement of vehicles. As set out in Section 6.2.2, there is 
still  a  need  to  improve  the  environmental  performance  of  road  transport.  Given  the 
potential benefits of the use of clean vehicles in this respect, but also as a result of their 
potentially lower total cost of ownership (as discussed in Sections 6.2.2 and 6.2.3), coupled 
with their low uptake, there is clearly still a need to stimulate the market for clean vehicles. 
While the repeal of the CVD would not prevent environmental considerations being taken 
into account in the course of the public procurement of vehicles, this would no longer be 
required. As was argued in Section 6.13.3, repeal of the CVD also risks making it more 
difficult  for  procurers  to  take  account  of  environmental  considerations  in  the  course  of 
procuring vehicles. Hence, there is still a rationale for requiring the public procurement of 
vehicles to take account of environmental considerations in order to stimulate the market 
for clean vehicles, as the Directive aims to do.  

In this respect, it is worth noting that both at the Member State and stakeholder meetings 
that were undertaken for this evaluation, as well as in the EU level stakeholder interviews, 
many participants were against a full repeal of the Directive (see Annexes 2, 3 and 9). At 
least one argued that the Directive would become more useful in the years to come, as a 
wider  range  of  vehicles  that  might  be  considered  to  be  ‘clean’  come  onto  the  market. 
Others noted that repealing the Directive would give the wrong political message, and that 
the  focus  should  instead  be  on  making  it  work  better.  It  was  also  underlined  that  the 
Directive had contributed to raising awareness of the public procurement of clean vehicles, 
particularly in those Member States and cities that were not previously taking account of 
energy and environmental considerations when purchasing road transport vehicles. 

6.14.3. The implications of retaining option 2b (monetisation) as the only option  

The  implication  of  retaining  only  the  monetisation  option  can  be  seen  in  the  work 
undertaken in support of the first effectiveness question (see Section 6.2 and Annex 9) by 
the fact that the application of the monetisation methodology tends to lead to the purchase 
of diesel vehicles, instead of petrol, gas or biofuel vehicles.  Hence, the  retention of this 
option at the expense of the others would not contribute to increasing the market share of 
vehicles  using  gas  or  biofuels,  and  indeed  could  effectively  act  as  a  barrier  against  the 
public  procurement  of  such  vehicles.  The  methodology  also  leads  to  results  in  favour  of 
electric vehicles, where these are included, but this is at least partially due to the fact that 
the in-use emissions of these vehicles are considered to be zero, which ignores emissions 
generated from the production of the electricity used, as well as differences in emissions 
associated with the production and disposal of such vehicles (see Section 5.4). As discussed 
in Section 6.2.2, some diesel buses (e.g. Euro VI buses) do indeed appear to have very 
low  levels  of  pollutant  emissions  compared  to  buses  using  other  types  of  technology. 
However, even these diesel buses do not perform as well as buses with other technologies 
with  respect  to  CO2  emissions  and  energy  consumption.  A  number  of  stakeholders  also 
raised the preference of the methodology as it currently stands for diesel vehicles and the 
lack of consideration of wider emissions associated with electric vehicles as issues in the 
event that this was the only option retained in the Directive (see Annex 2).   

6.14.4. Conclusion on the extent to which the market would develop differently should the 
Directive be repealed partially or completely at the European level 

On the basis of the above discussion, the full repeal of the Directive is unlikely to have a 
significant,  immediate,  practical  impact  on  the  market.  This  is  largely  a  result  of  its 
relatively low level of measurable impact to date, rather than it having achieved its original 
objective. However, to conclude from this that the Directive should be repealed is to ignore 

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its original intention, the ongoing challenges of reducing CO2 and pollutant emissions from 
road transport and the guidance that the Directive and the associated initiatives provide in 
this respect. Together, these argue for a retention of a mandatory requirement to account 
for environmental considerations in the public procurement of vehicles in order to stimulate 
the market for ‘clean’ vehicles. The main way in which public procurement increases the 
market of clean vehicles, as discussed in Section 6.3.3, is to provide a signal to industry 
that there is a market for clean technologies and thus to encourage innovation. For cars 
and LCVs, given the other instruments in place (see Section 6.11) and the relatively small 
shares of these vehicles that are publicly procured (see  Table 6-1 in Section 6.3.2), the 
role  of public procurement is likely to be less important than other measures in directly 
increasing  market  shares.  However,  the  other  benefits  of  public  procurement,  including 
increasing  environmental  awareness  and  providing leadership  on  environmental  matters 
(see Section 6.3.3), can still be delivered through the public procurement of cars and LCVs. 

For buses and some heavy duty vehicles, such as household waste collection vehicles, local 
authorities  are  important  procurers,  if  not  of  the  vehicles,  then  of  services  using  these 
vehicles (see  Table 6-1 in Section  6.3.2). Additionally, for such vehicles complementary 
legislation that requires manufacturers to improve the fuel efficiency and to reduce the CO2 
emissions from these vehicles is not in place (see Section 6.11). Hence, the market signal 
provided by the public procurement of these vehicles is potentially stronger than for cars 
and  LCVs.  As  was  noted  in  the  stakeholder  workshop,  ‘clean’  technologies  have  only 
relatively  recently  begun  to  be  introduced  for  heavier  duty  vehicles,  and  so  moving 
forward, the Directive may have a greater role to play. However, there is still the issue of 
the availability of the necessary data for such vehicles (as discussed in Section 6.2).       

A partial repeal of the Directive, at least one that retains only the existing monetisation 
methodology, would lead to the procurement being inadvertently biased towards diesel, 
and  potentially  electric  vehicles  as  well,  where  such  versions  of  these  vehicles  exist. 
However, there are issues, as discussed in Section 6.2.2, in considering these vehicles to 
be ‘clean’. Additionally, it is worth noting that diesel tends to be the dominant technology 
in the heavy duty sector in particular, and so the added value of retaining legislation that 
effectively favours the dominant technology is questionable. Hence, in order to identify the 
extent to which the partial repeal of the Directive would impact on the market for clean 
vehicles, it is first important to identify of which clean vehicles the Directive is aiming to 
increase the market share. This will be discussed further in Section 7.   

The  conclusion  with  respect  to  the  partial  repeal,  i.e.  retaining  only  the  monetisation 
methodology,  is  valid  in  relation  to  the  methodology  as  it  stands.  If  the  monetisation 
methodology  was  to  be  amended  in  any  way,  it  should  have  a  different  impact  on 
purchasing  decisions  and  thus  a  different  effect  on  the  market.  However,  without  an 
indication  of  what  such  amendments  might  be,  it  is  not  possible  to  conclude  what  the 
effects of an amended methodology, or its repeal, might be.  

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7.  CONCLUSIONS 

On the basis of the analysis presented in Section 6, in this section we present the main 
conclusions  arising  in  relation  to  each  of  the  overall  evaluation  questions  (relevance, 
effectiveness, efficiency, EU added value, coherence and sustainability).  

7.1.  Relevance 

  The needs at which the Directive is targeted, i.e. the need to decrease transport’s 
CO2  and  pollutant  emissions  and  to  increase  its  energy  efficiency  and 
competitiveness, are pertinent, and are likely to remain pertinent in the future.  

  Overall, targeting publicly procured vehicles is considered to be a relevant tool to 
increase the energy efficiency and to reduce the CO2 and pollutant emissions from 
road transport. Even though stimulating the public procurement of clean vehicles is 
not by itself sufficient to achieve these objectives, it is still beneficial. While publicly 
procured vehicles represent a small share of the overall vehicle market, there is still 
a case for using public procurement to stimulate the market for clean vehicles, as 
part of a more comprehensive approach to delivering the stated objectives.  

  Furthermore,  in  the  case  of  specific  categories  of  vehicles  (such  as  buses)  the 
potential for stimulating the market for clean vehicles is significantly greater.  

 

It  is  argued  that  (and  there  is  theoretical justification  for)  ‘stimulating  the  public 
procurement  of  clean  vehicles’  has  the  potential  to  contribute  to  increasing  the 
competitiveness of the wider EU economy and of cities, although difficult to prove 
in practice.    

  However, in addition to the small market share of publicly procured vehicles, the 
extent of the contribution of the Directive to increasing the energy efficiency of and 
reducing the CO2 and pollutant emissions from transport also depends on whether 
the focus is on the ‘right type’ of clean vehicle. This is an aspect that is currently 
not  clearly  defined  by  the  Directive  and  for  which  there  are  very  different 
approaches followed by contracting authorities.  

7.2.  Effectiveness 

  Our estimates of the impacts of the CVD – on the basis of available evidence and a 
set  of  important  assumptions  –  suggests  that  these  are  much  more  limited  than 
was  initially  expected.  Furthermore,  the  estimated  impacts  of  up  to  5.5%  CO2 
emissions  reduction  for  passenger  cars  and  2.3%  for  vans  in  comparison  to  the 
baseline represent a best-case scenario, which, most probably, does not take full 
account of the impact of other relevant policies in place (such as the passenger car 
CO2  Regulation).  Our  analysis  suggests  that  the  impacts  directly  associated  with 
the Directive are more limited, although it has not been possible to get more precise 
estimates. 

 

In  addition,  the  analysis  suggests  that,  in  terms  of  air  pollutant  emissions,  the 
contribution  may  even  be  negative,  as  a  result  of  the  tendency  of  some  of  the 
options (see below) being biased towards diesel vehicles.   

  A key underlying reason for limited effectiveness of the Directive is the absence of 
a  definition  of  what  a  “clean  vehicle”  is  and  of  relevant  provisions  for  minimum 
requirements (e.g. limit values in terms of fuel/energy consumption, CO2 and air 
pollutant  emissions)  that  contracting  authorities  should  meet  when  setting  their 
requirements. In their absence, it is very often the case that contracting authorities 
set requirements that can be met by the majority, if not all, vehicles on the market.      

  Another  key  issue  related  to  the  implementation  and  the  effectiveness  of  the 
Directive  is  the  perceived  complexity  of  the  monetisation  methodology  and  the 
much greater preference by public authorities for the use of the other options given 

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in  the  Directive.  On  the  one  hand,  the  monetisation  methodology  is  the  most 
effective approach in terms of ensuring the internalisation of the operational costs 
and its more widespread use could ensure a greater level of harmonisation in the 
approach  followed  by  authorities.  On  the  other  hand,  in  its  current  form,  the 
monetisation option is perceived to be complicated and demanding by a large share 
of  authorities.  In  addition,  our  analysis  suggests  that,  in  its  current  form,  it  has 
certain limitations and weaknesses.  

  The  absence  of  any  harmonised  community  standard  for  measuring  fuel 
consumption or CO2 emissions in the case of heavy duty vehicles, the category of 
vehicles where public procurement has the greatest potential, means that is difficult 
for  most  contracting  authorities  to  obtain  objective,  comparable  data  on  these 
vehicles.  As  a  result,  there  are  possible  missed  opportunities  for  contracting 
authorities to select the most appropriate vehicles.  

7.3.  Efficiency 

  The estimated overall  benefit to cost ratio of the Directive is relatively low. Total 
expected benefits of the policy – reflecting CO2 and pollutant emissions reduction 
and fuel efficiency savings - are estimated to be in the range of €42.6 to €521.1 
million, against total costs of around €34.6 to €431.0 million. The low cost benefit 
ratio is expected as the direct impacts associated with public procurement are very 
limited. In most respects the Directive acts in a complementary way to other policy 
tools  (e.g.  CO2  and  emissions  requirements,  car-labelling  etc.)  and  any  wider 
benefits cannot be quantified.  

  At  the  same  time,  the  administrative  costs  associated  with  the  Directive  are 
relatively limited (less than €2.3 million on an annual basis). Our analysis suggests 
that this is primarily a reflection of the limited use of the monetisation methodology 
and the fact that in most cases the information/data required is readily available.  

 

It is not clear that the impacts of the Directive could have been achieved in a more 
efficient way through additional measures or initiatives, as there was – and indeed 
still is – a rationale for using public procurement to stimulate the market for cleaner 
vehicles.  The  analysis  suggests  that  there  are  certain  aspects  that  need  to  be 
addressed  in  that  respect,  including  the  need  to  simplify  those  aspects  of  the 
Directive  that  are  currently  considered  to  be  complex  and  demanding  by  public 
authorities as mentioned above. 

7.4.  EU Added Value 

  Based on the assessment of effectiveness and feedback from various stakeholders, 
it is  likely  that  the  limited  impacts  estimated  to  have  been  achieved  by  the  CVD 
could have been achieved without EU intervention, i.e. the Directive.  

  However, despite the lack of clear benefits, stakeholders have stated a preference 
for  retaining  the  Directive,  although  with  improvements  focussing  on  making  it 
more effective and delivering better results. Stakeholders believed that a repeal of 
the Directive would give out the wrong political message. Secondly they generally 
felt that a mechanism to stimulate the purchase of clean vehicles was still required 
(as barriers to their uptake still exist) and that public procurement is still potentially 
useful in this respect. Finally, stakeholders thought that the Directive may become 
more useful and relevant over time as more clean vehicles come onto the market.  

  There  is  some  evidence  to  suggest  that  the  Directive  and  the  accompanying 

initiatives have supported best practice exchange.    

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7.5.  Coherence 

  The Clean Vehicles Directive largely complements other EU policies and legislation 
with similar objectives. The overarching objectives of EU policy and legislation strive 
to increase environmental protection, reduce GHG and air pollutant emissions and 
attain  energy  security.  The  CVD  complements  a  range  of  other  policies  and 
legislation that work together to achieve these objectives, including both supply and 
demand-side measures in the transport sector. 

  The  Directive is broadly  coherent  with most  other relevant policies, including the 
Public  Procurement  Directives,  although  there  are  challenges  with  respect  to  air 
quality, and a lack of coherence with the 2011 Transport White Paper’s objective of 
phasing out conventionally-fuelled cars. Contracting authorities face problems when 
they apply the CVD’s monetisation methodology in publicly procuring road transport 
vehicles,  which  results  in  the  selection  of  diesel  vehicles,  whose  use  can  be 
detrimental in achieving local air quality objectives, particularly in relation to NO2.  
Therefore,  provisions  such  as  the  monetisation  methodology,  may  on  certain 
occasions contradict with EU air quality targets, as it does not lead to the purchase 
of the types of vehicles that are most advantageous to reducing pollutant emissions 
in urban areas.  

  The  fact  that  the  Directive  allows  for  multiple  alternative  options  is  not  coherent 

with the objective of harmonising the determination of these impacts. 

7.6.  Sustainability 

  A full repeal of the Directive would be unlikely to have significant practical impacts 
on  the  market  and  the  current  level  of  demand  for  clean  vehicles.  However,  the 
wider benefits – and the broader message – provided by public procurement would 
be lost.  

  Furthermore, in the case of the heavy duty vehicle (HDV) sector, particularly buses, 
waste collection vehicles and other HDVs primarily used by/in the service of public 
authorities, the potential impact would probably be greater as there is a lack of a 
wider policy framework to reduce the CO2 emissions of these vehicles.  

  A  partial  repeal  –  i.e.  retaining  only  the  monetisation  methodology  in  its  current 
format  –  would  bias  towards  diesel  vehicles,  which  tend  to  be  the  dominant 
technology in the HDV market anyway, and those technologies that (inaccurately) 
have zero emissions, as these are measured on the test cycle.      

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8.  RECOMMENDATIONS 

On the basis of the conclusions of the analysis we present a set of general – high–level – 
and more specific practical recommendations.  

8.1.  General recommendations 

  The  Directive  should  be  retained:  Despite  the  limited  benefits  of  the  CVD  to 
date,  there  is  supporting  evidence  identified  throughout  this  evaluation  that 
suggests that the Directive should be retained rather than repealed. Firstly, there 
continues  to  be  a  need  to  address  the  stated  objectives  of  the  CVD,  including 
reducing CO2 and air pollutant emissions, and increasing energy  efficiency of the 
transport sector and competitiveness (see Section 6.2.2). It is agreed that public 
procurement is a tool that can be beneficial in helping to achieve these objectives 
(as discussed in Section 6.3.3) - encouraging investment in clean vehicles by public 
authorities should help to increase the market  for  such vehicles and thus help to 
deliver  the  economies  of  scale  that  will lead  to  lower  production  costs  and  lower 
prices. In turn, this should help to stimulate demand more generally. Additionally, 
it was identified that there are currently no alternative (more efficient) measures 
that are able to stimulate the market for clean vehicles (see Section 6.8.2), which 
would  further  support  retaining  the  Directive.  Stakeholders  consulted  for  this 
evaluation also stated their preference and reasons for retaining the Directive taking 
action at the EU level, as outlined in the conclusions above. While the repeal of the 
CVD would not prevent environmental considerations being taken into account in 
the course of the public procurement of vehicles, this would no longer be required. 
It is likely that contracting authorities would find it more difficult to set qualitative 
and  environmental  award  criteria  since,  as  due  to  the  broad  nature  of  Directive 
2014/24/EU,  there  will  be  less  guidance  and  reference  to  suitable  values  to  use 
when  performing  calculations.  In  the  absence  of  mandatory  requirements  to 
consider  the  environment,  such  considerations  risk  being  ignored  as  a  result  of 
economic  pressures.  Hence,  there  is  still  a  rationale  for  requiring  the  public 
procurement of vehicles to take account of environmental considerations in order 
to stimulate the market for clean vehicles, as the Directive aims to do. It is therefore 
our assessment that a repeal of the Directive would not be the best action to take, 
but that it should be retained.  

  The Directive needs to be amended: The analysis conducted for this evaluation 
suggests that in its current form the CVD is not particularly cost-effective. However, 
as discussed in the point above, it is still a useful tool for stimulating the market for 
vehicles using cleaner technologies forming part of a broader package of  supply-
side and demand-side policy tools. It is evident that there is scope for improvements 
to be made to the Directive that would increase its effectiveness and efficiency. This 
could  include  changes  to  the  scope  of  the  Directive  but  also  changes  to  its 
mechanisms, including the monetisation options. There is also an evident need to 
improve  the  level  and  quality  of  information  and  data  available  that  will  support 
future monitoring of its effectiveness and efficiency (see Specific Recommendations 
below for further information).   

8.2.  Specific recommendations 

  There needs to be more clarity as to what can be considered to be a clean 
vehicle: Clarification is required on which types of vehicles might be considered to 
be ‘clean’ and what should be the aims of the Directive in this respect. This could 
require  the  introduction  of  specific  provisions  setting  minimum  requirements  for 
contracting authorities (see also next point).  

  Encourage  higher  levels  of  ambition  with  regards  to  clean  vehicles 
purchased  required  by  the  Directive:  In  order  to  encourage  higher  levels  of 

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ambition, the Directive could set higher standards that more ambitious contracting 
authorities  might  meet.  More  specifically,  if  all  of  the  alternative  options  for 
including  energy  and  environmental  considerations  are  retained,  the  following 
elements might be considered to ensure that the Directive delivers environmental 
improvements (also helping to define ‘clean’ vehicles): 

o  Option 1: Explicitly set out the minimum technical specifications to be used, 

e.g.: 

  For pollutant emissions: any future Euro 7/VII standard, if these are 
eventually  introduced,  or  any  relevant  standards  arising  from  the 
light duty real driving emissions (RDE) test that is to be implemented. 
Voluntary emission schemes and standards should also be included 
as  soon  as  they  are  introduced  (with  a  clear  distinction  towards 
existing Euro 6 vehicles). 

  For  CO2  emissions:  For  LDVs,  these  could  be  the  next  target  as 
agreed in the respective Regulations, e.g. 95 gCO2/km for cars and 
147 gCO2/km for LCVs (to be amended as new targets are introduced 
in  the  respective  Regulations);  for  HDVs,  minimum  technical 
specifications could be developed once the EU monitoring mechanism 
for HDV CO2 emissions has been put in place.  

o  Option 2a: Explicitly state the minimum weighting that has to be applied to 
energy and environmental considerations if these are used as award criteria.  

o  Option 2b: Revise the monetisation methodology to address issues such as 
fuel  prices,  emissions  cost  factors  and  real  world  emissions  and  the  other 
ambiguous elements and better align the emphasis of the methodology with 
the three environmental objectives of the Directive.  

Clearly, the feasibility of any such approach will need to be analysed in more detail, 
and  any  changes  made  would  need  to  ensure  that  they  adequately  promote  the 
procurement of what has been more clearly defined as ‘clean vehicles’.   

  Facilitate  the  use  of  the  monetisation  option  (if  this  is  retained):  While  it 
can/could be considered appropriate to maintain the alternative options, it is also 
important to promote the use of the monetisation option as this is the only option 
that  explicitly  internalises  operational  costs.  This  requires  actions  to  address  the 
(perceived)  complexity  of  the  approach.  Potential  supporting  actions  to  consider 
include:  

o  Ensure that contracting authorities are equipped with a user-friendly tool for 
performing the calculations. The Clean Fleets Lifecycle Costing Tool  (Clean 
Fleets  2014)  is  an  existing  spreadsheet  tool  capable  of  performing  the 
monetisation  calculations,  but  its  effectiveness  might  be  substantially 
increased if it were converted into a web-based tool and then more widely 
publicised (potentially even referenced in the legislation itself).  

o  Use the information that is to be reported under the forthcoming monitoring 
mechanism  for  the  CO2  emissions  of  heavy  duty  vehicles  to  guide  the 
procurement of more fuel efficient heavy duty vehicles.  It is essential that 
objective,  comparable  information  is  available  on  the  CO2  impacts  and 
energy efficiency of these vehicles. 

o  Ensure  that  the  information  on  the  Clean  Vehicle  Portal  fulfils  its  aim  of 
providing comprehensive data on vehicle emissions as a one-stop-shop. As 
the  Portal  is  being  amended  at  the  time  of  writing,  it  is  not  possible  to 
comment on the extent to which this new version meets the needs. However, 
contracting  authorities  should  be  able  to  find  emissions  data  for  different 
vehicles in a comprehensive and accessible way. Maintaining information in 

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such  a  centralised  manner  may  not  be  an  easy  or  cheap  task,  but  if  the 
monetisation methodology is to be retained, its effectiveness will be linked 
to  the  ease  with  which  contracting  authorities  can  find  the  appropriate 
information to input into it. 

o  Further  build  on  the  Commission  initiatives  that  have  been  undertaken  to 
date,  particularly  the  Clean  Vehicle  Portal  and the  Clean  Fleets  project,  in 
order  to  facilitate  the  exchange  of  practices  and  experience,  to  promote 
greater understanding of any revised requirements of the Directive, and to 
facilitate cross-border joint procurement.   

  Future  consideration  of  Well-To-Wheels  (WTW)  emissions:  In  order  to  be 
able to compare the full environmental impacts of vehicles, there is a need to take 
account of WTW emissions. This issue is also relevant for other EU legislation, such 
as  the  passenger  car  CO2  Regulation,  the  fuel  efficiency  label  etc.  It  should  be 
considered whether it is possible to introduce an approach, e.g. a WTW factor that 
could  be  applied  in  a  common  way  in  complementary  EU  legislation,  where  it  is 
appropriate.   

  Extend the scope of the Directive: The scope of the Directive could be extended 
by lowering the threshold values. However, the benefit to cost ratio of such a change 
will  need  to  be  examined  in  greater  detail.  The  expansion  of  the  scope  of  the 
Directive to all contracts procured by public authorities that have a major transport 
element,  and  possibly  to  private  fleets,  might  be  considered.  Both  of  these 
approaches have the potential to increase the impacts by increasing the numbers 
of  vehicles  covered  by  the  Directive,  but  it  would  need  to  be  ensured  that  the 
approach was efficient once the scale of the potential impacts and costs have been 
considered. 

  Resolve the challenges posed by the lack of, or inaccurate data: A lack of 
information  or  a  means  of  discriminating  between  vehicles  on  the  basis  of  their 
energy consumption and emissions is a challenge. All new cars and LCVs, and all 
engines used in HDVs, have to meet the latest Euro emission standards (i.e. 6 and 
VI, respectively), and so unless a city has the resources and technical capacity to 
undertake  its  own  dedicated  tests,  there  is  no  room  for  a  city  to  differentiate 
between vehicles on the basis of their pollutant emissions. For cars and LCVs, test 
cycle  information  on  fuel  consumption  and  CO2  emissions  is  available  for 
conventionally-fuelled  vehicles,  but  this  information  for  alternatively-fuelled 
vehicles is less accurate as there is a greater need to take account of lifecycle and 
embedded emissions in order to accurately determine which type of technology is 
better  in  this  respect.  Also,  for  those  cars  and  LCVs  for  which  CO2  and  fuel 
consumption  data  is  available,  there  is  the  additional  issue  of  the  discrepancy 
between  real  world  and  test  cycle  emissions.  For  HDVs,  information  on  CO2 
emissions and fuel use is often not available in a consistent manner for most cities 
(again, other than those that have the resources and capacity to do their own tests). 
Our understanding is that many of these are issues have already been identified as 
important by the Commission and relevant action is being taken to address them. 
If this proves not to be the case, or is considered to not eventually be possible, it 
will  be  important  to  provide  at  least  more  guidance  to  contracting  authorities  in 
order to ensure that they are aware of how to apply the CVD in such cases.     

  Introduce a voluntary framework to facilitate Member State reporting: One 
of the challenges with understanding the effectiveness – and therefore efficiency – 
of  the  Directive  is  the  lack  of  knowledge  on  its  impacts,  and  indeed  costs.  It  is 
important not to introduce requirements that would incur excessive administrative 
costs  on  Member  States,  hence,  it  would  be  useful  to  introduce  a  framework  for 
Member State reporting in which Member States would be encouraged to report on 
the  impacts  of  the  Directive  in  a  consistent  and  comparable  manner.  This  would 
facilitate future evaluations and inform future amendments to the Directive. 

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  Explore  whether  there  is  the  potential  for  a  Commission  initiative  to 
facilitate  cross-border,  joint  procurement:  As  barriers  to  cross-border  joint 
procurement remain, and the costs of vehicles with some clean technologies remain 
high, it would be useful to explore whether there is the potential to use financial 
instruments (i.e. not grants) to help  overcome the high initial administrative and 
capital costs associated with the cross-border, joint procurement of clean vehicles. 
In  this  respect,  the  potential  use  of  instruments  developed  by  the  EIB  might  be 
explored. 

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9.  ANNEX  1:  DETAILS  OF  BASELINE  SCENARIO  AND  APPROACH  TO  QUANTIFYING 

IMPACTS 

9.1.  Estimation of volumes of publicly procured vehicles 

As there is no European database on new registrations or vehicle stock by type of owner, 
an  estimate  of  annual  public  sector  vehicle  purchases  was  developed  based  on  use  of 
Member  State  public  vehicle  fleet  and  registration  statistics  in  combination  with  ACEA 
figures on new registrations (which aggregate public and private) across the EU. 

Even  national-level  data  on  the  extent  of  public  sector  registrations  and  purchases  of 
vehicles  is  severely  limited:  for  many  Member  States,  it  appears  that  no  data  has  been 
published on this topic, and for other Member States the data is usually incomplete insofar 
as  it  only  refers  to  vehicles  held  by  certain  parts  of  the  public  sector  (such  as  central 
government administration) rather than all contracting authorities. 

The  estimate  of  total  public  procurement  used  in  this  evaluation  is  therefore  based  on 
available data for a limited number of Member States, namely Germany, Italy, France and 
the United Kingdom. Where these datasets refer to only parts of the public sector, we have 
extrapolated a total public sector number from these figures by scaling them according to 
the numbers of employees in different sections of the public sector. 

These Member States include some in which the extent of the public sector is large relative 
to the typical Member State (e.g. France) and some in which it is relatively small (e.g. the 
UK).  Accordingly,  we  have  found  that  there  is  a  significant  amount  of  cross-national 
variation in the number of vehicles in public ownership versus private ownership. Because 
our estimate of the public sector’s share of vehicle purchases is based on averaging across 
these Member States, it accounts for cross-national variation in the relative extent of public 
procurement, at least to the extent possible with the available data. 

Unfortunately,  the  sample  does  not  include  any  Eastern  European  Member  States,  as 
relevant  data  for  these  Member  States  was  unavailable.  The  method  used  nonetheless 
aims at representativeness for those Member States to the extent that this is possible given 
available  data:  the  method  consists  in  multiplying  ACEA  figures  on  total  annual 
registrations (which include Eastern Europe) by a factor representing the public sector’s 
share of total procurement. Although that factor is based on data from Western European 
Member States, the Member States in question comprise a mixture of Member States with 
relatively large and relatively small public sectors. Eastern European Member States, like 
Western  European  Member  States,  comprise  a  mixture  of  Member  States  with  public 
sectors that are large relative to the EU average, and others that have small public sectors 
relative to the EU average. 

9.1.1.  Estimation  of  factors  representing  contracting  authorities’  share  of  total 
procurement 

For  some Member States, data is available on the number  of vehicles held in the public 
fleet,  but  not  the  rate  at  which  these  vehicles  are  renewed,  and  so  there  is  no  direct 
information as to the number of new registrations or purchases each year. Because vehicle 
stock  in  the  public  sector  may  be  renewed  at  a  different  rate  to  the  private  sector,  the 
public sector share of vehicle stock will not necessarily be the same as the public share of 
annual procurement. Therefore, in the analysis described below, the first step is to estimate 
the  public  share  of  vehicle  stock  in  different  Member  States,  and  the  second  step  is  to 
adjust this proportion to account for the difference between public share of stock and public 
share of registrations. 

Step one - estimating contracting authorities’ share of vehicle stock 

For  passenger  cars,  estimates  of  public  sector  stock  were  taken  from  (IFRAP,  2010)  for 
Italy and France, (KBA 2014) for Germany, and (Fleet News 2015) for the United Kingdom. 
Where  figures  are  provided  only  for  public  administration  or  central  government 

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administration, an extrapolation has been made to scale these figures up on the basis of 
public sector employment (in central administration versus more generally) so that they 
represent the entire public sector. Total stock (public and private) in each Member State 
is taken from ACEA. These figures indicate a large variability in the extent of public stock, 
ranging  from  below  0.04%  in  the  UK  up  to  1.7%  in  Italy.  The  average  value  (1.0%)  is 
taken forward as the assumed average value for the EU. 

Table  9-1:  Comparisons  of  annual  public  sector  passenger  car  stock  across 
Member States 

Total stock 

Of which public 
administration 

Germany 

Italy 

France 

UK 

Passenger cars 

43,851,230 

37,078,000 

32,555,000 

 29,611,489 

133,879 

150,000 

(central 
administration) 

142,000 
(central 
administration) 

- 

Of which total public sector  

363,663 

626,760 

477,445 

13,266  

% Public admin 

% Public sector (scaled 
estimate) 

% average public sector 
stock across countries 

(employment-
scaled 
estimate) 

0.31% 

0.83% 

(employment-
scaled estimate) 

(council car 
fleet) 

0.40% 

1.69% 

0.44% 

1.47% 

- 

0.04% 

1.01%* 

Note: * upper bound estimates for Europe-wide share of public sector vehicles in new registrations 

Source: Ricardo  Energy &  Environment analysis  of: ACEA registration  statistics;  (IFRAP, 
2010); (KBA 2014); (Fleet News 2015). 

For vans and rigid trucks, data on public stock in Germany is derived from (KBA 2014) and 
for  the  UK  it  is  taken  from  (Fleet  News,  2015).  The  EU  wide  estimate  is  based  on  the 
average value of the German and UK data. 

Table  9-2:  Comparisons  of  public  sector  van  and  rigid  truck  stock  in  UK  and 
Germany 

Total stock 

Of which public 
administration 

Of which total public sector  

% Public admin 

% Public sector  

Germany 

UK 

Germany 

UK 

Vans 

Rigid trucks 

2,345,752 

3,471,280 

283,457 

473,932 

58,453 

- 

9,148 

- 

158,779 
(employment-
scaled 
estimate) 

2.5% 

6.8% 

36,978 
(council fleet) 

24,849 
(employment-
scaled estimate) 

23,080 
(council fleet) 

- 

1.1% 

3.2% 

8.8% 

- 

4.9% 

Upper bound estimate 

3.9% 

6.8% 

Source: Ricardo Energy & Environment analysis of (Fleet News, 2015) and (UK Department 
for Transport 2015) for UK figures, Ricardo Energy & Environment analysis and elaboration 
on (KBA 2014) for German figures. 

Step two - estimating contracting authorities’ share of new vehicle purchases 

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The German vehicle registration authority provides data (KBA 2014) on new registrations 
and vehicle stock by economic sector which can be used to derive a relationship between 
the  public  sector  share  of  stock  and  the  public  sector  share  of  registrations  (i.e.  an 
assumption as to the relative difference in rates of vehicle renewal in the public sector and 
the wider market). 

The results of this comparison (Table 9-3) suggest that the stock of public sector passenger 
cars  gets  renewed  around  three  times  as  often  as  the  average  German  vehicle  stock, 
whereas the van and truck stock get renewed less often than the average fleet. 

Table 9-3: Data on share  of vehicle stock and  new vehicles registrations in the 
German public administration 

% of vehicle stock registered to 
‘public administration, defence 
and social security’  (KBA 2014) 

% new registrations in ‘public 
administration, defence and social 
security’  (KBA 2014) 

Ratio of new registrations share 
to vehicle stock share 

Passenger cars 

0.3% 

Vans 

2.5% 

Rigid trucks 

3.2% 

1.0% 

1.8% 

3.0% 

3.37 

0.72 

0.93 

Source: Ricardo Energy & Environment analysis based on (KBA 2014) 

The ratios in the final row of Table 9-3 are therefore used to adjust the figures in the final 
rows of Table 9-1 and Table 9-2 to produce an estimate of the total EU wide public sector 
share of new vehicle registrations (Table 9-4). 

Table  9-4:  Estimate  of  EU  wide  public  sector  share  in  vehicle  stock  and  new 
vehicles registrations  

Passenger cars 

Estimate of % of public sector in 
total EU vehicle stock  

Estimate of % of public sector in 
total EU new registrations 

1.0% 

3.4% 

Source: Ricardo Energy & Environment analysis 

Buses 

Vans 

3.9% 

2.8% 

Rigid trucks 

6.8% 

6.4% 

As  national  datasets  do  not  adequately  distinguish  between  publically  and  privately 
procured buses, a different method is used to produce an EU-level estimate of the number 
of buses procured by contracting authorities. 

Long-distance road passenger transport services, i.e. coach services, are privatised across 
Europe (van de Velde, 2009). Therefore we assume contracting authorities purchase only 
buses, not coaches. New bus registrations represent around 76% of new bus and coach 
registrations  (AEA  2011),  therefore  we  multiply  ACEA’s  figures  on  total  bus  and  coach 
registrations by 76% to obtain the total number of new buses in Europe each year. This is 
in  turn  multiplied  by  a  factor  representing  the  share  of  bus  procurement  performed  by 
contracting  authorities  or  procured  to  perform  public  service  obligations  (PSOs),  rather 
than bought by private operators for non-PSO routes. Properly representative data on the 
extent  of  publically-  rather  than  privately-provided  bus  transport  is  not  available,  due 
perhaps  to  the  fact  that  these  services  are  variously  provided  by  local  government, 
publically-owned corporations, and privately-owned companies under different regulatory 
arrangements  in  different  Member  States.  In  a  recent  survey  of  72  major  organisations 
providing  surface  passenger  transport  in  European  cities,  57%  were  publically-owned 
(Boitani, Nicolini, & Scarpa, 2010). A UITP survey of passenger transport operators (UITP, 

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2012) indicated that around two-thirds were publically owned. As neither of these surveys 
were  designed  to  achieve  fully  representative  samples  and  no  further  information  is 
available on the extent of PSOs, there is high amount of uncertainty over the proportion 
of  buses  that  fall  into  scope  of  the  CVD  and  therefore  we  set  our  least-conservative 
estimate  of  the  possible  extent  of  public  procurement  somewhat  higher,  at  75%,  to 
represent the most “optimistic” assumption (the more pessimistic assumption is provided 
by our analysis of TED data). 

Table 9-5: Estimated public sector bus procurement  

Buses and coaches – total annual registrations 

Buses – estimated total annual registrations 

Buses – proportion procured by public sector or for performing 
public service obligations (high assumption) 

Buses  procured  by  contracting  authorities  or  transport 
operators performing PSOs per year 

Evaluation estimate 

31,000 

24,000 

75% 

18,000 

Source: Ricardo Energy & Environment analysis based on ACEA registration data; (Boitani, 
Nicolini, & Scarpa, 2010); (UITP, 2012); and (AEA 2011). 

9.1.2.  Estimation of the total number of publically procured vehicles 

Having estimated contracting authorities’ share of new vehicle purchases, the final step is 
simply to multiply this share by the number of new vehicle registrations in each year as 
reported by ACEA.  

Table 9-6 Estimated number of publically procured vehicles 

Cars 

Van 

Truck 

Bus 

2012 

2013 

2014 

Average 
per year 

% of all 
registrations 
2012-2014 

409k 

403k 

403k 

405k 

39k 

11k 

17k 

39k 

12k 

18k 

43k 

11k 

18k 

40k 

12k 

18k 

3.4% 

2.8% 

6.4% 

75% 

9.2.  Estimation of volumes of publically procured vehicles procured via 
TED 

Sections 2.2 and 6.4 explain that the estimated number of vehicles publically procured via 
TED  is  used  as  a  conservative  lower  bound  estimate  of  the  number  of  vehicles  that  are 
actually affected by CVD rules, given that the legislation only obliges contracting authorities 
to apply those rules to contracts over a certain value. This section describes how TED data 
has been used to estimate the total number of vehicles procured through TED (for each 
vehicle type). 

The  first  stage  was  to  estimate  total  numbers  of  contracts  in  each  vehicle  category  by 
performing  a  keyword  search  on  all  contracts  for  vehicle  procurement.  Table  9-4 
summarises the results. Note that the keywords fire, refuse, sweep, tractor, special were 
also categorised under truck. 

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Table 9-7 Numbers of contracts in TED for purchasing different types of vehicle 

Vehicle type 

Number of contracts 

Car 

Van 

Bus 

Truck 

1555 

524 

1481 

4986 

Source: Ricardo Energy & Environment analysis of data extracted from TED 

Data on contract awards in TED typically does not include information on the  number of 
vehicles procured, although by law it necessarily includes information as to the monetary 
value of the awarded contract. Therefore in order to estimate of the number of  vehicles 
procured in each vehicle type (passenger car, van, bus, and rigid truck) it is necessary to 
divide the total expenditure found in TED by an estimated typical cost per vehicle. 

The typical cost estimates that were used in this part of the analysis are derived from the 
survey of procurers – the survey explicitly asked procurers for both contract values and 
numbers  of  vehicles  procured,  making  the  estimation  of  typical  per-vehicle  costs 
straightforward. The following average values per procured vehicle were identified: 

Table 9-8 Estimated typical prices of vehicles procured by contracting authorities 

Vehicle type 

Passenger cars 

Buses/coaches 

Light commercial vehicles 

Truck 

Special service vehicles - waste collection trucks and services 

Special emergency service vehicles - ambulances, fire engines 
etc. 

Average value per vehicle 

€ 24,603 

€ 252,806 

€ 22,769 

€ 136,371 

€ 172,604 

€ 232,865 

Source:  Ricardo  Energy  &  Environment  analysis  of  procurer  survey.  Note:  prices  are 
presented in real terms, with a price base of 2015 

Based on the value of each tender divided by the average contract value per vehicle, an 
estimate of the number of vehicles procured for each vehicle type can be obtained. Table 
9-9 summarises the results. 

Table 9-9 Estimated number of vehicles publically procured via TED  

Cars 

Van 

Truck 

Bus 

2012 

2013 

2014 

23k 

10k 

8k 

3k 

29k 

7k 

11k 

4k 

34 

12k 

13k 

5k 

Average 
per year 

% of all 
registrations 
2012-2014 

29k 

10k 

11k 

4k 

0.2% 

0.7% 

5.9% 

16.8% 

9.3.  Summary of public procurement volume analysis 

A  summary  table  of  the  final  estimates  of  total  procurement  of  vehicles  by  contracting 
authorities (both through TED, and more generally) is given in the Table 9-10. These are 
compared with the original impact assessment figures. 

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Table 9-10- Comparison of IA and evaluation assumptions in relation to the total 
number of vehicles procured on an annual basis  

Impact 
Assessment 
assumption 

Evaluation 
assumption 
procured via TED 

Evaluation 
assumption: total 
public procurement 

Passenger cars 

Vans 

Heavy  duty 
vehicles 

110,000 

110,000 

(freight) 

35,000 

Buses and coaches 

17,000 

29 

10 

11 

4 

405 

40 

12 

18 

Source: Ricardo Energy & Environment analysis (see paragraphs and tables above) 

9.4.  Other key parameters considered in the analysis 

Lifetime vehicle mileages are a key parameter in determining the overall energy cost, CO2 
emissions and air pollutant emissions impacts in the analysis. We have drawn on recent 
studies  of  vehicle  lifetimes  and  mileages  for  our  estimates.  For  cars  and  vans,  we  have 
combined data on vehicle survival rates (in the form of a distribution over time since the 
vehicle was purchased) and mileages (again in the form of a distribution over time since 
the vehicle was purchased) from a recent study for the European Commission  (Ricardo-
AEA and TEPR 2015). For heavy duty vehicles, the data come from another recent study 
for  the  European  Commission  (AEA  2011).  Note  that  our  mileage  assumption  for  rigid 
trucks  differs  very  significantly  from  the  assumption  used  by  PWC  in  the  2007  impact 
assessment.  Ours  is  an  appropriate  assumption  for  heavy  duty  vehicles  performing  a 
municipal  utility  role.  The  Impact  Assessment’s  assumption  of  1,000,000  km  would  be 
more  appropriate  to  commercial  trucks  used  for  long-distance  transport,  not  vehicles 
owned by contracting authorities. 

Table 9-11-: Assumed vehicle mileages (in km) and lifetimes, by vehicle type 

Vehicle type 

Impact Assessment 
assumptions 

Evaluation assumptions 

Passenger car 

16k × 10 years = 160k 

Average 133k - 208k depending 
on fuel type 

Van 

21k × 10 years = 210k 

Average 197k 

Rigid truck (impact 
assessment: heavy duty 
non-passenger vehicle) 

Buses (impact assessment: 
buses and coaches) 

100k × 10 years = 1,000k 

25k × 11 years = 275k 

80k × 10 years = 800k 

50k × 15 years = 750k 

Source: Ricardo Energy & Environment analysis: Rigid truck assumptions taken from profile 
of  “municipal  utility”  vehicle  in  (AEA  2011);  Buses  taken  from  profile  of  buses  in  (AEA 
2011); passenger cars taken from profiles used in (Ricardo-AEA and TEPR 2015). 

The impact assessment also made use of estimates available in 2007 of the social costs of 
CO2 and air pollutant emissions. We have made use of more up-to-date estimates of these 
costs,  which  are  generally  higher.  In  particular,  we  take  the  EU-wide  central  estimates 
from the 2014 update to the EU’s handbook on external costs of transport (Ricardo-AEA, 
DIW Econ et al. 2014). 

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Table  9-12  :  Comparison  of  emissions  cost  factors  used  in  the  IA  and  the 
evaluation 

Impact Assessment assumption 

Evaluation assumption 

 (2005 prices) 

(2015 prices) 

CO2 (€/kg) 

NMHC (€/g) 

NOX (€/g) 

PM (€/g) 

0.02 

Not modelled 

0.0044 

0.0871 

0.072 

0.0016 

0.0111 

0.0414 

Source: Ricardo Energy & Environment analysis; evaluation emissions factors taken from 
(Ricardo-AEA, DIW Econ et al. 2014) 

Finally,  fuel  costs  (excluding  tax)  for  each  year  of  the  analysis  period  are  taken  from 
(European Commission 2015d).  

Table 9-13: Average European fuel prices in € per litre (excl. taxes and duties) 
for each year of the analysis period 

Diesel  

Petrol  

2009 

2010 

2011 

2012 

2013 

2014 

2015 onwards 

0.49 

0.60 

0.74 

0.79 

0.73 

0.68 

0.55 

0.46 

0.57 

0.68 

0.74 

0.69 

0.65 

0.52 

Source: (European Commission 2015d) 

Note: prices are presented in real terms, with a price base of 2015 

After 2015, we assume prices stay the same as in 2015 (Fuel prices are constantly in flux 
and  difficult  to  project  into  the  future).  The  energy  costs  implied  by  our  fuel  costs  are 
shown in Table 9-14 alongside the impact assessment predictions.  

Table 9-14: Comparison of energy costs (€/GJ) used in the IA and the evaluation 

Impact  Assessment  assumption 
(2005 prices) 

Evaluation  assumption  (average  values 
2012-2040, in 2015 prices) 

Diesel 

Petrol 

16 

15 

16 

17  

Source: Ricardo Energy & Environment analysis; original impact assessment 

9.5.  Estimation of passenger car and vans CO2 effects 

For passenger cars and vans, our method consists in looking at the vehicles procured under 
the CVD and comparing them with the wider market in terms of CO2 performance. Doing 
this  allows  us  to  estimate  an  overall  improvement  in  performance  without  data  on  the 
specific choices between sets of alternative vehicles that procurers faced – data which are 
not available to us. 

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We fully acknowledge that vehicles procured by public authorities may differ in terms of 
CO2  performance  from  the  wider  market  for  a  number  of  reasons  other  than  the  CVD, 
including, most crucially: 

(1) Different needs of the public sector in terms of the size of vehicles needed (for 
example, the public sector might need more medium cars and fewer estates) 

(2) Greater emphasis on total cost of ownership in public procurement regardless 
of the Directive 

In order to control for the effect of the first point, instead of just comparing average CO2 
emissions of all passenger cars bought by public authorities with average  CO2 emissions 
bought in the wider market, we calculated the average CO2 performance in each individual 
mass  segment  A,  B,  C,  D,  E.  (Sample  sizes  for  typical  CO2  performance  in  the  other 
segments were too small to facilitate meaningful analysis). Therefore we were comparing 
the CO2 performance of publically procured vehicles with the CO2 performance of privately 
procured vehicles of the same size, and eliminating the effect of differences in the typical 
sizes of public and private vehicles from our estimate of the effect on performance.  

After controlling for differences in the mass (segment) distribution of vehicles, we found 
that public sector respondents’ vehicles were 12% more efficient in terms of CO2 than the 
wider market average, and respondents’ choice of vans was on average 5% more efficient. 
Figure 9-1 shows the average CO2 emissions of contracting authorities’ vehicles versus the 
average emissions performance of vehicles procured in the wider market at the same time, 
per vehicle segment. 

Figure  9-1:  CO2  emissions  by  vehicle  segment  -  cars  procured  by  contracting 
authorities 2012-2015 versus cars procured in the wider market at the same time 

200
180
160
140
120
100
80
60
40
20
0

)

m
k
/
g
(

s
n
o
i
s
s
i
m
e

2
O
C

A

B

C

D

E

Weighted
average

Segment average

Public vehicle, 95% limit

Public vehicle, weighted average

Public vehicle, 95% limit

Source: Ricardo Energy & Environment analysis of procurer survey 

Note:  confidence  intervals  are  computed  as  if  CO2  emissions  of  vehicles  are  normally 
distributed. As a number of the vehicles in the sample are fully electric (and therefore have 
zero emissions) the sample is in fact bimodally distributed, and not normal, therefore the 
confidence intervals probably overstate the actual uncertainty in the estimates. Also note 
that  although  the  average  emissions  of  public  vehicles  in  segment  E  are  higher  than 

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average  emissions  in  the  wider  market,  the  confidence  intervals  indicate  this  could  be 
nothing more than sampling variation. 

Figure 9-2: CO2 emissions for vans procured by contracting authorities 2012-2015 
versus vans procured in wider market at same time 

)

m
k
/
g
(

s
n
o
i
s
s
i
m
e

2
O
C

300

250

200

150

100

50

0

Segment average

Public vehicle, 95% limit

Public vehicle, weighted average

Public vehicle, 95% limit

Weighted average

Source: Ricardo Energy & Environment analysis 

Note:  confidence  intervals  are  computed  as  if  CO2  emissions  of  vehicles  are  normally 
distributed. As a number of the vehicles in the sample are fully electric (and therefore have 
zero emissions) the sample is in fact bimodally distributed, and not normal, therefore the 
confidence intervals probably overstate the actual uncertainty in the estimates. 

These figures must be treated with caution because they are based on small sample sizes 
from an unknown sampling frame, and respondents to our survey gave somewhat limited 
descriptions of the exact make and model of each vehicle procured, and therefore we have 
had to make assumptions about exactly which specific model of the vehicle was chosen. 

The  second  issue  (greater  emphasis  on  total  cost  of  ownership  in  public  procurement 
regardless of the Directive) essentially means that any difference in the CO2 performance 
of vehicles of a similar size might be entirely attributable to greater emphasis on total cost 
of ownership in public procurement independent of CVD effects. Therefore, we believe that 
it is entirely possible that the actual effect of the CVD on CO2 performance is as low as 0%. 
On  the  other  hand,  a  more  optimistic  view  on  the  CVD’s  effects  would  be  that  the  CO2 
performance differential we currently observe between public and private sector is entirely 
attributable to the effect of the CVD. 

One  indication  we  have  from  the  survey  about  the  maximum  extent  to  which  the  CVD 
might  have  actually  changed  the  public  sector’s  approach  to  CO2  efficiency  is  that 
approximately 54% of respondents indicated that the environmental criteria they had in 
place with respect to CO2 were at least as strict in 2012. Therefore, rather than taking the 
full 12% public-private differential in CO2 for passenger cars as our maximum estimate of 
the  CVD’s  effects,  we  have  taken  12%  multiplied  by  the  percentage  of  respondents 
indicating  that  they  had  tightened  environmental  criteria  over  time  (46%)  to  obtain  a 
maximum  estimate  of  5.5%.  For  vans,  performing  a  similar  calculation,  the  answer  we 
obtain is 2.3%. 

We  emphasise  that  the  46%  of  respondents  who  have  tightened  CO2  criteria  over  time 
may have done so for reasons other than the CVD. These could include national initiatives 
to buy more clean vehicles, or a greater focus on operating costs in the public sector as a 

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result of the economic crisis. Therefore, we still regard it as entirely possible that the actual 
effect of the CVD on CO2 performance was 0%. 

Table 9-15 summarises the estimated impacts on CO2 performance of publically procured 
vehicles in the evaluation versus those included in the impact assessment. 

. 

Table  9-15:  Comparison  of  IA  and  evaluation  assumptions  used  to  estimate 
impact on CO2 emissions  

Impact 
Assessment 
assumption 
Internalisation of 
costs scenario 
46% reduction in cost 
of WTW GHG 
emissions  

Evaluation 
assumption 

Source of 
evaluation 
assumption 

Maximum 5.5% 
improvement in 
TTW CO2 emissions 

Passenger 
cars 

Change in CO2 
performance 

Associated 
change in 
purchase costs 

Vans 

Heavy 
duty 
freight 
vehicles 

Buses 
and 
coaches 

Associated 
change in 
purchase costs 

Change in CO2 
performance 
Associated 
change in 
purchase costs 
Change in CO2 
performance 
Associated 
change in 
purchase costs 

9.0% increase 

1.7% increase 

Change in CO2 
performance 

4.7% increase in WTW 
GHG emissions 

Maximum 2.3% 
improvement in 
TTW CO2 emissions 

23% increase 

1.0% increase 

20% reduction in 
WTW GHG emissions  

12% increase 

13% reduction in 
WTW GHG emissions 

14% increase 

No change in CO2 
performance 

Analysis of 
stakeholder 
feedback 

Analysis of 
procurer survey 

Observed 
relationship 
between CO2 
performance and 
purchase costs 

Analysis of 
procurer survey 

Observed 
relationship 
between CO2 
performance and 
purchase costs 

Source: Ricardo Energy & Environment analysis 

9.6.  Estimation of air pollutant benefits effects 

9.6.1.  Air pollutant benefits 

Available evidence on this is drawn from those applying the minimum standards option. 
We  assume  effects  would  have  been  similar  for  procurers  applying  the  other  commonly 
used option (award criteria). 

Many respondents to the survey had adopted EURO standards as minimum criteria for local 
air  pollution,  but  the  vast  majority  were  simply  applying  the  EURO  standard  that  was 
already  obligatory.  Only  1%  of  procurers  demanded  a  EURO  standard  that  had  been 
defined but not yet made obligatory, and on average this was demanded 6 months before 
the standard became obligatory. 

Therefore we have modelled the effect of EURO standards being introduced 6 months early 
for 1% of all procured vehicles. This was done by assuming that new vehicles’ air pollutant 

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emissions  performance  is  in  line  with  ICCT  estimates  of  real-world  NMHC,  NOx  and  PM 
emissions per km.  

9.6.2.  Dieselisation 

Additional  dieselisation  is  a  possible  consequence  of  the  inadvertent  bias  in  the 
monetisation  methodology  towards  diesel  vehicles  (the  analysis  supporting  this 
assessment  is  provided  in  Annex  9).  Therefore  an  ancillary  analysis  was  conducted  to 
investigate the possible extent of dieselisation resulting from the Directive, and its effects 
on pollutant emissions.  As described in the main text of the  report,  our estimate of the 
extent of Dieselisation is based on analysis of the procurer survey. 

In the dieselisation scenario it is assumed that a 0.2% reduction in CO2 emissions comes 
from dieselisation. This is a small part of the overall reduction in CO2 emissions (recall that 
the  overall  reduction  is  5.4%).  Dieselisation  will  have  an  adverse  effect  on  air  pollutant 
emissions,  which  we  have  estimated  through  use  of  TREMOVE  data  on  typical  CO2  and 
pollutant emissions of passenger cars in the EU. 

The  TREMOVE  model  includes  real-world  (rather  than  test  cycle)  emissions  of  typical 
passenger  cars  of  different  fuel  types.  We  extracted  the  per-km  average  CO2  and  air 
pollutant  emissions  factors  of  the  EU  parc  in  2010  from  the  TREMOVE  model,  and  used 
these to estimate the air pollutant impact of abating CO2 if done by substituting a typical 
petrol vehicle with a typical diesel vehicle. 

By comparing the fleet-average CO2 and pollutant emissions profiles of diesel and petrol 
passenger  cars,  elasticities  of  pollutant  emissions  with  respect  to  CO2  emissions  in  the 
context of dieselisation were estimated. The elasticities are shown in Table 9-16  

Table 9-16 – Difference between test cycle and real world emissions on the basis 
of TREMOVE model and derived elasticities 

Differences in real-world emissions 

CO2 
-12% 

NOx 
79% 
Source: Ricardo Energy & Environment analysis of TREMOVE data 

PM 
1911% 

NMHC 
-89% 

Elasticity of pollutant emissions 
with respect to CO2 emissions 
NOx 
NMHC 
-6.7 
7.6 

PM 
-162.3 

The elasticities of NMHC emissions, PM emissions, and NOx emissions with respect to CO2 
emissions  were  then  used  in  combination  with  the  assumption  of  a  0.2%  dieselisation-
related reduction in CO2 to estimate the effect of CVD-related dieselisation on air pollution. 

The result is that dieselisation wipes out the modest air pollutant benefits associated with 
early adoption of EURO standards. Instead, due to the dieselisation of passenger cars, the 
overall impact of the Directive on air pollutant emissions is adverse (with the monetised 
additional air pollutant costs of the policy being in place from 2012 to 2014 amounting to 
€2.2M to €31.4M). Results of the dieselisation scenario (which still includes the air pollutant 
benefits associated with early adoption of EURO standards) are given in detail in section 
6.4.3. 

9.6.3.  Summary of assumptions and comparison with Impact Assessment 

Table 9-17 summarises the evaluation assumptions on air pollutant effects and contrast 
these with those made in the Impact Assessment. 

Table  9-17:  Comparison  of  IA  and  evaluation  assumptions  used  to  estimate 
impact on air pollutant emissions  

Impact 
Assessment 
assumption 

Evaluation assumptions 

EURO 
standards 

Other changes 

Source of 
evaluation 
assumptions 

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Internalisation of 
costs scenario 

Passenger 
cars 

100% switch to 
CNG; 
Large improvement 
in air pollutant 
emissions 

100% switch to 
CNG; 
Small adverse effect 
on air pollutant 
emissions 

100% switch to 
hybrid electric; 
Large improvement 
in air pollutant 
emissions 

Vans 

Heavy 
duty 
freight 
vehicles, 
buses and 
coaches 

1% adopt 
EURO 6/VI 
early 
(on 
average, 6 
months 
early) 

Central scenario 
assumes no extra 
Dieselisation. 

Dieselisation 
scenario assumes 
small proportion of 
improvement in 
CO2 comes from 
switching from 
petrol to diesel 
vehicles 

No extra 
dieselisation as 
petrol represents a 
negligible portion 
of purchases of 
these vehicle 
types 

Analysis of 
procurer survey 

Analysis of 
procurer survey 

Analysis of 
stakeholder 
feedback 

Source: Ricardo Energy & Environment analysis 

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10.  ANNEX 2: EU LEVEL STAKEHOLDER INTERVIEWS 

EU-level  stakeholder  groups  were  contacted  in  order  to  invite  them  to  participate  in 
telephone interviews, including city networks, fuel and energy associations, manufacturer 
associations, procurers and fleet owners, NGOs and consumer associations.  The purpose 
of these interviews was to ask them about their views as part of the evaluation.  Twelve 
were interviewed and a further nine were engaged (but not interviewed) (see Table 10-1). 
Several did not respond or declined the opportunity to be interviewed as a result of a lack 
of  knowledge  of  the  Directive  and  its  impacts.  All  organisations  were  contacted  at  least 
twice.  EU-Level  stakeholders  were  asked  questions  closely  linked  to  the  13  evaluation 
questions (as set out in Section 3).  

Table 10-1: Summary of engagement with EU-Level Stakeholders 

Category  of 
stakeholder 

have 
a 

Interviewed 
or 
provided 
written 
response 
(11) 

been 
Have 
engaged,  but 
no  interview 
was 
undertaken 

No response  

to 

Declined 
be 
interviewed, 
and  have  not 
provided 
a 
written 
response 

CEMR,  EMTA, 
Eurocities, 
POLIS 

Cell 

Fuel 
Industry 
Association  

City networks  ICLEI 

and 

Fuel 
energy 
associations 

EBA  (biogas), 
EBB 
(biodiesel), 
EBTP 
(biofuels),  EHA 
(hydrogen), 
Eurelectric 
(electricity), 
FCH-JU 
(fuel 
cells),  Eurobat 
(batteries) 

Manufacturer 
associations, 
vehicles 

ACEA,  NGVA 
(gas vehicles) 

CLEPA 
(suppliers) 

(public 

UITP 
transport), 
LeaseEurope 
(leasing 
companies),  

Procurers, 
fleet owners 

Users, 
consumers, 
environment 

AEGPL  (LPG), 
ASFE 
(synthetic 
fuels), 
CONCAWE 
(fossil 
EFOA 
oxygenates), 
ePURE 
(renewable 
ethanol) 

fuels), 
(fuel 

JAMA,  EUCAR 
(research), 
EARPA 
(research 
organisations) 

Fuels  Europe 
(fossil 
fuels), 
but  circulated 
request to their 
members 

KAMA, ERTRAC 
(research) 

IRU (haulage) 

T&E 
(environment) 

ECF  (climate), 
FIA (drivers) 

BEUC 
(consumers) 

The views of the EU-level stakeholders as expressed during the interviews are summarised 
by question in this Annex. Additionally, the views of some cities are also covered here, as 
some of the city networks that were approached passed on the questionnaire to selected 
members  of  their  respective  networks.  The  questions  that  were  asked  in  the  EU  level 
stakeholder  engagement  can  be  found  in  the  respective  boxes  below.  Some  of  these 

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questions  focused  on  specific  evaluation  questions,  while  others  focused  on  different 
issues.  For  each  question  asked,  we  make  it  clear  in  the  respective  box  the  evaluation 
question  to  which  it  relates.  This  section  only  reports  on  the  findings  of  the  EU  level 
stakeholder interviews; the responses are analysed when discussed in the context of the 
respective evaluation questions in the main report.  

Question 1: In your view, is increasing the market share of clean vehicles an adequate 
means of: 

a) Increasing the energy efficiency of transport? 
b) Increasing the competitiveness of transport? 
c) Decreasing transport’s CO2 and pollutant emissions? 

This question is effectively:  

Evaluation Question 1: To what extent is increasing the market share of clean vehicles 
an  adequate  mean  to  contribute  to  the  overall  objectives  of  increasing  the  energy 
efficiency  and  competitiveness  and  decreasing  CO2  and  pollutant  emissions  of 
transport? 

In order to be sure that all elements of Evaluation Question 1 were addressed, interviewees 
were asked separately for their views on the three separate elements of the question, as 
presented in the box above.  

Many  interviewees  believed  that  the  questions  were  either  not  clear  or  too  simple.  A 
number questioned the use  of the  word ‘adequate’ in essence arguing that if ‘adequate’ 
was  taken  to  mean  ‘enough’  then  the  answer  to  the  questions  could  not  be  ‘Yes’,  as 
increasing the market share of clean vehicles is not the only way to achieve the specified 
aims. However, if ‘adequate’ was taken to mean ‘beneficial’, the respective answers were 
more likely to be ‘Yes’. Others commented that the question was difficult to answer as it 
was  not  clear  what  was  meant  by  a  ‘clean  vehicle’,  with  different  vehicle  technologies 
contributing  differently  to  the  stated  aims.  In  relation  to  the  specific  sub-questions,  the 
responses  were  more  positive  for  energy  efficiency  (sub-question  a)  and  emissions  (c; 
indeed many respondents did not make a distinction between their responses to these two 
questions), than for competitiveness (b).  

Interviewees  generally  agreed  that  increasing  the  market  share  of  clean  vehicles  would 
increase  the  energy  efficiency  of  transport  (sub-question  a),  although  many  of  these 
positive responses were qualified or conditional. In this respect, interviewees highlighted 
that it depended which technology was being substituted and what it was being substituted 
by,  with  some  highlighting  that  electric  vehicles  (including  those  using  hydrogen)  were 
more  efficient,  while  others  mentioned  gas  vehicles  in  this  respect.  Additionally,  it  was 
noted that sometimes a vehicle with less conventional pollutants uses more energy, e.g. 
with some changes in previous Euro standards  for buses, which underlines that there is 
not always an automatic correlation between a clean and an energy efficiency vehicle.  It 
was also noted that the energy efficiency of some technologies is developing faster, and 
has more potential to deliver than others, particularly the technologies that are currently 
less  common  (e.g.  electricity,  gas,  etc.).  Others  highlighted  that  increasing  the  market 
share of clean vehicles only partially delivered this aim as other measures could also be 
used and that a comprehensive approach was important. Similarly interviewees generally 
agreed that increasing the market share of clean vehicles would decrease transport’s CO2 
and pollutant emissions (sub-question c), although with many of the same caveats as were 

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mentioned  in  relation  to  energy  efficiency.  The  need  to  take  account  of  well-to-wheel 
emissions was also noted in this respect. 

There was a less conclusive response with respect to whether increasing the market share 
of clean vehicles would improve transport’ competitiveness (sub-question b). This was at 
least  partially  to  do  with  the  phrasing  of  the  question,  as  many  considered  it  to  be  too 
vague, e.g. it was not clear whether the ‘competitiveness’ that was being referred to was 
that  of  the  EU  automotive  industry,  of  EU  industry  more  generally,  of  clean  vehicles 
compared to “other” vehicles or of cities. Some responded positively if the question referred 
to the competitiveness  of the  EU automotive industry, while others noted that the main 
driver of the competitiveness of this industry was the fact that it was simply a competitive 
sector  and  so  additional  measures  were  not  needed  in  this  respect.  Other  interviewees 
interpreted  the  question  as  referring  to  the  clean  vehicles  themselves.  Even  with  this 
interpretation responses were mixed, as some argued that the current, relatively high costs 
of  purchase  of  clean  vehicles  demonstrated  that  these  vehicles  were  not  competitive, 
whereas others argued that many were, or at least will be in the future, once the total cost 
of ownership has been taken into account. In the latter case, it was then argued that there 
would be benefits for the competitiveness of EU industry more generally.   

Question 2: In your view, which of the following measures do you consider to be most 
important, and which potentially useful, in terms of stimulating demand for clean and 
energy efficient vehicles?  
a)  Legislation  to  improve  the  efficiency  of  vehicles,  e.g.  the  EU’s  car  and  van  CO2 
Regulations 
b) Vehicle taxation in favour of clean and energy efficient vehicles 
c)  Requiring  that  energy  and  environmental  considerations  are  taken  account  of  in 
public procurement 
d) Providing subsidies for the purchase of clean and energy efficient vehicles 
e) Providing information to potential users on the benefits of clean and energy efficient 
vehicles 
f)  Legislation/policies  to  reduce  emissions  in  urban/highly  populated  areas,  e.g.  low 
emission zones 
g) Other, please? 

This question aims to identify views in order to inform:  

Evaluation Question 2: To what extent is stimulating the public procurement  of clean 
vehicles  an  adequate  mean  to  contribute  to  the  overall  objectives  of  increasing  the 
energy efficiency and competitiveness and decreasing  CO2 and pollutant emissions of 
transport? 

The most important instruments identified by stakeholders for stimulating the demand for 
clean  and  energy  efficient  vehicles  were  vehicle  taxation  (option  b)  and  legislation  to 
improve the fuel efficiency of vehicles (a), followed by urban policies (f) and subsidies (d); 
requiring  that  energy  an  environmental  considerations  were  taken  account  of  in  public 
procurement (c) and the provision of information (e) were not seen as being as important. 
Those  who  considered  vehicle  taxation  to  be  most  important,  and  also  to  some  extent 
subsidies and urban policies, argued that these were important as they directly affect the 
price that users pay. On the other hand, those that favoured legislation on fuel efficiency 
(and also to a lesser extent urban policies) argued that these were most important as they 

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delivered certainty. It was noted that a way of overcoming the absence of a common EU-
level  approach  for  estimating  the  CO2  emissions  of  buses  was  to  use  the  UITP’s 
Standardised On-Road Test (SORT) cycles. As a result of the explanations for option c (i.e. 
requiring  that  energy  and  environmental  considerations  are  taken  account  of  in  public 
procurement), it was clear that stakeholders’ respective poor views on the effectiveness of 
the Directive was a significant reason for the low importance assigned to this option (see 
response to question 4), as elsewhere there were more positive views about the potential 
role of public procurement (see response to question 3). A distinction was also made by 
vehicle type, as it was considered to be good to require public procurers to consider the 
environmental impacts of buses in their purchase decisions. With respect to information, 
the relatively low importance was due to a belief that there was already a fairly high level 
of  awareness  about  different  vehicle  technologies,  although  a  couple  of  stakeholders 
suggested  that  information  about  the  relative  total  costs  of  ownership  need  to  be 
communicated better. The stakeholders noted that there were ‘other’ measures that were 
also  important:  measures  to  development  infrastructure  for  clean  vehicles  (mentioned 
twice),  credits  to  encourage  their  development,  purchase  and  use      and  by  setting 
incentives for bus operators to reduce emissions throughout the term of their public service 
obligation (rather than simply prior to tendering).           

Question  3:  In  your  view,  is  stimulating  the  public  procurement  of  clean  vehicles  an 
adequate means of: 

a) Increasing the energy efficiency of transport? 
b) Increasing the competitiveness of transport? 
c) Decreasing transport’s CO2 and pollutant emissions? 

This question is effectively:  

Evaluation Question 2: To what extent is stimulating the public procurement  of clean 
vehicles  an  adequate  mean  to  contribute  to  the  overall  objectives  of  increasing  the 
energy efficiency and competitiveness and decreasing  CO2 and pollutant emissions of 
transport? 

The  only  difference  between  question  3  and  the  first  question  (and  between  Evaluation 
Questions 1 and 2) is that this question refers to  “stimulating the public procurement of 
clean vehicles” rather than “increasing the market share of  clean vehicles”.  In response 
many stakeholders answered in a similar way as they had done to the first question (see 
above)  and  some  simply  referred  the  interviewer  to  their  previous  answers.  These 
arguments  will  not  be  repeated  here.  Those  that  responded  with  respect  to  public 
procurement generally underlined that it was a good means of either meeting the stated 
aims or more generally of increasing the market share of clean vehicles. Other respondents 

Question 4: Is the Directive effective in delivering the above impacts? 

This question aims to contribute of the evaluation of ‘effectiveness’, generally (in terms 
of  whether  the  objectives  of  the  Directive  have  been  met),  rather  than  any  of  the 
specific evaluation question.  

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again noted that public procurement delivered the stated aims as part of a wider approach, 
although  one  argued  that  public  procurement  was  counter  to  competitiveness,  as  it 
artificially stimulated demand.        

The majority of responses to question 4 were negative, although it was also noted that this 
was difficult to assess. The reasons provided for the negative responses included: 

  Until recently there have been few relevant vehicles available on the market, so the 

Directive was in place before the vehicles existed. 

  The complexity of the Directive. 
  The stakeholder had not seen any evidence of its impacts. 
  Applying  the  methodology  leads  to  the  purchase  of  diesel  vehicles,  particularly 

buses. 

  The monetisation methodology prioritises fuel consumption and CO2 emissions over 
pollutant emissions, even though in many cities air quality is a major problem. 
  The application of the monetisation methodology in the course of procurement is 
not how procurers decide on which vehicles to buy. Such a methodology would be 
applied before the decision to procure in order to decide which type of vehicle to 
procure. A procurer would then launch a procedure to buy vehicles with the chosen 
technologies. 

Several respondents said that the Directive had had no impact in the Member State with 
which they were most familiar or in the cities that they represented, although some of the 
city representatives did note that the Directive (or at least their involvement in the Clean 
Fleets project; see Annex 10) had influenced the way in which they procured some vehicles. 

Those  who  were  more  positive  about  the  effects  of  the  Directive  argued  that  it  had 
succeeded in focusing attention on green public procurement in the vehicle sector.  

Question  5:  Could  the  effects  of  the  Directive  have  been  achieved  at  less  cost  (e.g. 
through other or additional measures)? 

This question is effectively:  

Evaluation  Question 7:  Could  the  effects have  been achieved in a more  efficient way 
(e.g. through other or additional (legislative) measures)?  

Stakeholders  had  few  views  as  to  whether  the  effects  of  the  Directive  could  have  been 
achieved at least cost (question 5). The main reasons for this were the perceived lack of 
effects (see above) and a lack of knowledge of the costs associated with the Directive. It 
was underlined again by a few stakeholders that the Directive is only one of many pieces 
of  legislation  that  aim  to  deliver  the  same  objectives.  Other  stakeholders  discussed 
deficiencies  in  other  legislation  in  response  to  this  question,  notably  the  discrepancy 
between  real  world  and  test  cycle  emissions  as  measured  for  the  passenger  car  CO2 
Regulation and the lack of similar legislation for heavy duty vehicles. It was also argued 
that the impacts would have increased (and therefore the efficiency improved) if there had 
been a real obligation in the Directive or if the legislation had been a Regulation that was 
directly applicable in Member States. Another stakeholder argued that there was a risk that 
the efficiency of the Directive could be adversely affected if it resulted in investment in less 
mature technologies.     

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Question 6: Would it have been possible to obtain similar or better results in terms of 
increasing the market share of clean vehicles without the Clean Vehicles Directive? 

This question is effectively:  

Evaluation Question 8: Would it have been possible to obtain similar or better results in 
terms  of  the  market  share  of  clean  vehicles  without  EU  intervention,  i.e.  the  Clean 
Vehicles Directive? 

As  with  question  5,  few  stakeholders  had  any  views  as  to  whether  it  would  have  been 
possible to obtain similar or better results without the Directive (question 6). Again, this 
was  partly  due  to  the  perceived  lack  of  results  from  the  Directive.  In  response  to  this 
question a number of stakeholders again noted that the Directive is part of a package of 
measures and as a result other measures could also be used to increase the market share 
of clean vehicles, such as improving the passenger car CO2 Regulation and making it more 
stringent,  tax  incentives  and  more  central  government  support  to  regional  and  local 
authorities (see also the answers to question 2, above). It was also suggested that more 
effort  should  go  into  looking  at  how  the  purchase  of  clean  vehicles  might  be  supported 
financially, e.g. with mechanisms set up by the EIB. A couple of stakeholders did, however, 
underline the important role that public procurement has to play in increasing the market 
share of clean vehicles. It was suggested that clean vehicles would be introduced without 
the Directive, but over a longer time period.   

Question  7:  Are  you  aware  of  any  exchange  of  good  practices  between  contracting 
authorities  in  different  Member  States  that  have  been  initiated  or  supported  by  the 
Directive or the associated initiatives (i.e. Clean Vehicle Portal, Clean Fleets Project)? 

This question aims to contribute to:  

Evaluation  Question  9:  To  what  extent  have  the  Directive  and  the  associated 
Commission initiatives (e.g. Clean Vehicle Portal, Clean Fleets Project) initiated and/or 
supported a recognised exchange of good practices between contracting authorities in 
different Member States? 

Even  though  both  the  Clean  Vehicle  Portal  and  Clean  Fleets  project  were  mentioned  in 
question  7,  only  one  stakeholder  referred  to  the  good  practice  exchange  that  has  been 
undertaken  in  the  course  of  the  Clean  Fleets  project  (see  Annex  10).  Generally, 
stakeholders responded that they were not aware of any good practice exchange between 
contracting authorities in Member States. In relation to the Portal more generally, some 
thought that it was a good idea, but that it was not easy to use; others questioned whether 
it was up-to-date (as mentioned in Annex 10, the Portal had not been recently updated at 
the time of writing). One challenge with respect to the Portal that was mentioned was that 
of keeping it sufficiently up-to-date and relevant for 28 national markets, particularly when 
there were some similar national websites in place. 

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It was suggested by one stakeholder that there was a need to widen the reach of projects 
such  as  Clean  Fleets  to  the  majority  of  EU  cities  that  do  not  become  involved  in  such 
projects. 

Question  8:  To  what  extent  are  the  provisions  of  the  Clean  Vehicles  Directive 
complementary  to,  or  made  redundant  by,  the  new  horizontal  EU  procurement 
legislation? 

This question is effectively:  

Evaluation  Question  12:  To  what  extent  are  the  provisions  of  the  Clean  Vehicles 
Directive  coherent,  complementary  and/or  redundant  with  the  horizontal  EU 
procurement legislation (in particular 2014/24/EU and 2014/25/EU)? 

Few  stakeholders  were  sufficiently  familiar  with  the  provisions  of  the  horizontal  EU 
procurement legislation to be able to answer question 8. The two that  believed that the 
CVD was complementary with the horizontal legislation, as the latter  did not contain an 
obligation to take account of environmental considerations, whereas the CVD was one of 
the  few  obligations in  this  respect.  It  was  noted  that  this  approach  was  in line  with  the 
Commission’s stated aim of setting public procurement obligations on a sector-by-sector 
basis. 

Question  9:  In  your  view,  would  the  market  develop  differently  if  the  Directive  was 
partially or completely repealed? 

This question aims to contribute to answering:  

Evaluation  Question  13:  To  what  extent  would  the  market  develop  differently  should 
the intervention be ceased partially or completely at European level? 

Question 9 was another that many stakeholders had difficulty in answering, again partially 
as a result of the perceived lack of impact discussed above. A number of stakeholders said 
that it would give the wrong political message if the Directive was completely repealed and 
so  argued  that  it  should  be  improved  instead,  although  one  stakeholder  did  suggest 
replacing the Directive with a legislative framework that drew on California’s zero emission 
vehicle mandate. Another stakeholder argued that the Directive should be simplified along 
the  lines  of  the  approach  taken  in  Sweden,  where  a  clean  vehicle  is  defined  and  this 
definition is then used in public procurement decisions and is increasingly being adopted 
in the private sector.  Other views  were that the repeal of the  Directive would not make 
any difference at all to the market, particularly in those Member States and cities that had 
been taking action to clean their vehicle fleets, while another suggested that the market 
would  probably  develop  more  slowly  in  the  absence  of  the  Directive.  A  couple  of 
stakeholders highlighted the importance of the awareness raising aspect of the Directive, 
particularly  amongst  those  local  authorities  that  were  not  previously  taking  account  of 
energy and environmental considerations when purchasing road transport vehicles.  

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Question  10:  In  your  view,  would  the  market  develop  differently  if  the  only  option 
provided by the CVD for including energy and environmental impacts in the purchasing 
decision  was  the  harmonised  monetisation  methodology  for  the  calculation  of 
operational lifetime costs? 

This question aims to contribute to answering:  

Evaluation  Question  13:  To  what  extent  would  the  market  develop  differently  should 
the intervention be ceased partially or completely at European level? 

There were stronger views (compared to question 9) in response to question 10 about how 
the  market  might  develop  if  only  the  monetisation  methodology  was  retained.  In  this 
respect,  several  stakeholders  suggested  that  the  market  would  be  likely  to  move  in  a 
negative  direction  (considering  the  stated  aims  that  were  the  subject  of  question  1,  as 
discussed above) if only the monetisation option was retained, as a result of the application 
of this methodology generally favouring diesel vehicles (see Annex 9). A number of issues 
were raised in relation to the methodology, including:  

  There is not enough weight given to environmental factors, whereas more weight 
is given to energy efficiency. This is an issue for cities that have air quality problems 
and so are trying to reduce their NOX and particulate emissions. 
It uses a hypothetical cost of fuel, rather than a real one. 

 
  There is no consideration of well-to-wheel emissions. This favours electric vehicles 
as these have no in-use emissions and ignores how the electricity is produced. In 
this  way,  there  is  no  advantage  of  using  sustainable  biofuels  over  conventional 
fuels.  
It is relatively complex, which can lead to it being implemented incorrectly.  

 

It was suggested that the existence of such issues questioned whether a rigid, top-down 
approach to such a methodology was appropriate. A number of stakeholders felt that an 
appropriate monetisation methodology could be useful, as long as it could be agreed. 

Question 11: A potential future action might be to expand the scope of the CVD, or for 
the Commission to introduce another initiative, in order to stimulate the uptake of clean 
and energy efficient vehicles in large, privately-operated fleets. 
a) In your view, would it be appropriate to expand the scope of the CVD to stimulate 
the uptake of clean and energy efficient vehicles in large, privately-operated fleets? 
b)  In  your  view,  would  it  be  appropriate  for  the  Commission  to  introduce  another 
initiative  to  stimulate  the  uptake  of  clean  and  energy  efficient  vehicles  in  large, 
privately-operated fleets? 
c) If you think that either of the above would be appropriate, what form might this take? 

This  question  does  not  directly  address  an  evaluation  question,  but  was  taken  into 
consideration in response to:  

Evaluation  Question 7:  Could  the  effects have  been achieved in a more  efficient way 
(e.g. through other or additional (legislative) measures)?  

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Typical responses to question 11 on the potential expansion of the scope of the Directive 
to private fleets were that this would make sense as these fleets are large and have a role 
and responsibility to reduce their emissions,  but that it was not clear how this might be 
achieved in practice.  It  was noted that these fleets are different to public fleets, so any 
provisions would have to be well thought through. One stakeholder suggested extending 
the  scope  of  the  Directive  to  light  commercial  vehicles,  while  another  suggested  that 
private fleets should be required to at least look at the options of using clean vehicles. On 
the other hand, it was suggested by a couple of stakeholders that rather than expanding 
the scope of the Directive, at this point the focus should be on making the provisions of 
the Directive work better, particularly the monetisation methodology. It was also suggested 
that it would be appropriate to apply the Directive to large privately-owned bus fleets that 
compete for public tenders, as long as it was clear the level of environmental performance 
that should be reached. Another suggested that business calculations already take account 
of  taxation  and  car  performance  and  so  an  additional  measure  in  this  respect  was  not 
appropriate. 

Some responses mentioned the importance of other measures for cleaning private fleets, 
including addressing the difference between real world and rest cycle emissions that affect 
the  passenger  car  CO2  Regulation  (as  mentioned  above),  local  prohibitions  on  the  most 
polluting vehicles, the harmonisation of tax incentives at the EU level, vehicle taxation in 
favour of more efficient vehicles and the use of financial incentives, generally.   

Question  12:  We  are  interested  in  identifying  whether  there  have  been  innovative 
approaches to procurement or joint procurement activities that have been implemented 
as a result of the Directive. 
a)  Are  you  aware  of  any  innovative  or  joint  procurement  activities  that  have  been 
implemented as a result of the Directive? 
b) In your view, are innovative and/or joint procurement activities encouraged and/or 
facilitated by the Directive? 

This  question  does  not  directly  address  an  evaluation  question,  but  was  taken  into 
consideration in response to:  

Evaluation  Question  9:  To  what  extent  have  the  Directive  and  the  associated 
Commission initiatives (e.g. Clean Vehicle Portal, Clean Fleets Project) initiated and/or 
supported a recognised exchange of good practices between contracting authorities in 
different Member States? 

Beyond the references to joint procurement in the context of the Clean Fleets project (see 
Annex 10), no stakeholder was aware of any innovative or joint procurement activities that 
had been implemented as a result of the Directive, while none had any views on whether 
such  activities  are  encouraged  or  facilitated  by  the  Directive.  A  couple  of  stakeholders 
mentioned some joint procurement that had been undertaken, or were being planned, e.g. 
in Sweden (see Annex 10) and potentially a group of regional authorities to buy hydrogen 
vehicles, but did not believe that any of these were the result of the Directive. A number 
of  stakeholders  noted  that  joint  procurement  was  difficult,  even  within  a  country, 
particularly when non-standard vehicles were being bought.    

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Question 13: Currently, there are no reporting requirements on Member States within 
the Directive; the Directive only requires the Commission to produce regular monitoring 
reports on the impact of the Directive. 
a) Do you think that the current monitoring and reporting provisions on the Commission 
are adequate for the effective assessment of the impacts and operation of the Directive? 
b)  Would  introducing  monitoring  and  reporting  obligations  on  MS  contribute  to  the 
effective assessment of the impacts and operation of the Directive in a cost-effective 
way? 

This  question  does  not  directly  address  an  evaluation  question,  but  was  taken  into 
consideration in response to:  

Evaluation  Question 7:  Could  the  effects have  been achieved in a more  efficient way 
(e.g. through other or additional (legislative) measures)? 

Question 13 was asked in order to inform the development of options for the assessment 
presented  in  Annex  13  with  respect  to  the  introduction  of  potential  monitoring  and 
reporting  requirements  on  Member  States.  The  majority  of  stakeholders  felt  that  the 
current reporting requirements were inadequate; most of the remainder did not express a 
view.  Hence,  most  supported  some  form  of  reporting  obligation  on  Member  States.  A 
couple of stakeholders argued that the lack of reporting requirements on Member States 
was one of the reasons why the Directive had not been effective, as if they had no reporting 
obligations it reduced the motivation for action. It was also argued that without reporting 
from the Member States, it was difficult to have the information to properly inform revisions 
to the Directive.  

Suggestions for Member State reporting included: 

  Member  States  should  be  required  to  report  on  the  implementation  of  the 

Directive at regular intervals, say every three years. 

  Member States be required to report on clean transport activities more generally, 

which would include the CVD. 

  Use the Clean Vehicle Portal to facilitate Member State reporting. 

  Use the alternative fuels infrastructure Directive to support reporting under the 
CVD, as the latter could be seen as a mechanism to implement the former.  

On  the  other  hand,  a  representative  from  a  city  was  not  convinced  that  reporting 
requirements on Member States would achieve much, as even within individual countries, 
where lists of procurers known, it takes a long time to bring all the necessary information 
together.      

Concluding remarks 

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A number of stakeholders provided general remarks rather than answering the questions 
addressed  above,  while  some  others  made  concluding  remarks  at  the  end  of  their 
respective  interviews.  In  the  former  category,  one  stakeholder  stated  that  they  agreed 
with most of the comments made at the workshop, particularly  that public procurement 
should  be  a  driver  for  the  electrification  of  transport.  Another  responded  that  their 
members had seen little impact from the Directive and that the monetisation methodology 
had caused a fair amount of confusion, as it is complicated, focuses on in-use emissions 
only and often leads to the choice of diesel vehicles, which is contrary to the EU’s wider 
objectives of reducing oil dependency and the wider climate and environmental objectives.  

Another  stakeholder  noted  that  there  was  a  big  difference  in  attitudes  to  the  CVD  in 
different  countries.  In  those  countries  that  had  already  implemented  green  public 
procurement for vehicles, such as in Sweden, there is a sense that the Directive is holding 
them back. However, in the newer Member States, the view is generally more positive as 
the Directive has forced policy makers to think about green procurement in the context of 
vehicles.  

It  was also argued that the Directive should be applied to the Commission, as it should 
lead by example. This would demonstrate the leadership that is needed. It was suggested 
by  another  that  the  Directive  needs  to  provide  a  strong,  clear  legislative  pathway;  this 
might  be  more  painful  politically  in  the  short-term,  but  it  would  deliver  a  clearer  policy 
framework.   

Another stakeholder noted the contractual challenges faced by operators that use buses 
with  new  technologies,  particularly  the  length  of  contracts  during  which  buses  are 
operated, the uncertainty associated with technological developments and the period over 
which returns on investments can be  recouped. For  electric buses, additional challenges 
were the need to install recharging points, train staff and exploit bus depots differently, 
which were not always appreciated by public authorities. It was argued that the EU’s clean 
vehicle procurement legislation needs to be implemented alongside a range of other actions 
to reduce emissions. Finally, it was noted that a distinction might be made between a ‘clean 
fleet’, which focuses on reducing air pollutant emissions, and a ‘green fleet’ in which the 
focus is on reducing CO2 emissions.          

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11.  ANNEX  3  -  WIDER  EU  STAKEHOLDER  WORKSHOP  –  AGENDA,  ATTENDEES  AND 

SUMMARY 

The study team organised and delivered a half-day stakeholder workshop on Friday 17th 
April 2015 in Brussels aimed at wider EU stakeholders (afternoon session). A background 
paper was circulated including details of the study, the methodology, summary of the tasks 
(including progress to date) and key questions (where appropriate).   

Invitations to attend the workshop were sent to 59 stakeholder across a range of interest 
areas, of which 21 attended. 

The  agenda,  full  list  of  participants  and  summary  of  the  Stakeholder  workshop  can  be 
found in this Annex.   

Agenda 

  Welcome (EC) 

Wider EU Stakeholder Workshop Agenda 

  Overview of the ongoing evaluation study (Ricardo-AEA/TEPR) 

 

 

 

Implementation of the CVD (Ricardo-AEA/TEPR) 

Task 8: An assessment of the options referred to in Article 5(3) (Ricardo-AEA/TEPR) 

Task 9: Assessment of the methodology for monetised costs (Ricardo-AEA/TEPR) 

  Comments of participants 

 

Possible improvements to the Directive – addressing the evaluation questions and 
developing policy recommendations (Ricardo-AEA/TEPR) 

  Summary and wrap-up (EC) 

Attendees 

Name 

Organisation 

European Commission 

Van Honacker, Mr Hugues (Chair)   DG MOVE 

Fernandez Garcia, Mr José (Chair)  DG MOVE 

Önel, Mr Kemal 

Van de Schouw, Mr Guus 

DG MOVE 

DG MOVE 

Contractors 

Brannigan, Ms Charlotte 

Ricardo-AEA 

Skinner, Mr Ian 

TEPR 

Luckhurst, Mr Stephen 

Ricardo-AEA 

Representing Member States 

Uhlik, Mr Krisztián  

Asplund, Mr Erik  

Ågren, Ms Ulrika  

Finnish Transport Safety Agency (Trafi) 

Swedish Transport Agency (Transportstyrelsen) 

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Moran, Mr Bob  

Representing 
Consumers 

Aab, Ms Liz 

Industry  and 

UK Office for Low Emission Vehicles (OLEV) 

Alliance for Synthetic Fuels in Europe (ASFE) 

Brangeon, Mr Victor 

Federation Internationale de ľAutomobile (FIA) 

Caramizaru, Ms Aura 

Eurelectric 

Cervilla, Mr Luis 

Alliance for Synthetic Fuels in Europe (ASFE) 

Di Stefano, Ms Amalia 

Dolejsi, Mr Petr 

CLEPA 

ACEA 

Maedge, Mr Matthias 

Natural & bio Gas Vehicle 

Association (NGVA Europe) 

Reijalt, Ms Marieke 

European Hydrogen Association (HyER) 

Scarsi, Mr Gian Carlo 

Eurelectric 

Schroeder, Mr Rene 

Association of European Automotive and Industrial Battery 
Manufacturers 

Vega, Mr Nicolas de la 

Euro Biogas Association (EBA) 

Witkamp, Mr Bert 

Carroll, Mr Chris 

The European Association for Electromobility (AVERE) 

European Consumers' Organisation (BEUC) 

Representing 
local/city 
government and city networks 

Barrera, Ms Gabriela 

Catlow, Mr Ian 

Greater London Authority (GLA) 

Clement, Мг Simon 

Local Governments for Sustainability (ICLEI) 

Ericson, Mr Jonas 

City of Stockholm 

Flin, Mr Cédric 

Köhler, Ms Dagmar 

Council of European Municipalities and the Regions (CEMR) 
(CCRE – Francais) 

European  Cities  and  Regions  networking  for  innovative 
transport solutions (POLIS) 

Neirotti, Mr Ivan 

EUROCITIES 

Summary of the workshop 

Welcome 

Mr Van Honacker (DG MOVE, Unit C.1) welcomed participants and gave an introduction to 
the purpose of the workshop and the evaluation. 

Overview of the ongoing evaluation study 

The contractors gave a presentation on  

  Overview of the ongoing  evaluation study 

o  Aims/objectives 
o  Tasks 
o  Methodology (including progress to date with tasks) 

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  Implementation of the CVD 

o  Overview of MS fiche info 

  Task 8: An assessment of the options referred to in Article 5(3) – status 

of options allowed in transposed legislation. 
o  Overview of task, its aim and method 
o  Options allowed in each MS/included in NIMs 
o  Snapshot of survey feedback on which options had been used in 

procurement actions. 

  Task 9: Assessment of the methodology for monetisation of costs 

o  Overview of task, its aim and method 
o  Description of the monetisation methodology 
o  Feedback from MS fiches / Interviews / Surveys 
o 

Initial calculations/case studies 

Round table discussion 

city 

Local 
governments 
and networks 

ICLEI also conducted a survey on the monetisation methodology, and found that 
almost nobody had applied it. ICLEI had discovered only two applications of it, 
and in one of those cases, there was just a single tender. 

The  methodology  is  complex,  and  not  understood  by  procurers  and  suppliers. 
ICLEI is sceptical that anyone will apply a methodology this complex. 

Furthermore, ICLEI suspects it will not have the impact procurers want it to have. 
The procurers who might want to apply it are presumably ones with a progressive 
approach to clean vehicles. But these people will realise that the monetisation 
methodology will not yield the desired result. 

It was argued that a major issue with the methodology is the predominance of 
energy efficiency over pollutant emissions. It was argued that improving energy 
efficiency should be seen as a means to an end, rather than an end in itself – 
the end is to improve CO2 and pollutant emissions. Therefore if the methodology 
is retained it needs to be substantially revised. 

The  methodology  also  cannot  be  applied  to  certain  heavy  duty  vehicles  at 
present. 

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Industry  and 
consumers 

Some stakeholders in this group argued that cities will find that the monetisation 
parameters in the directive will not relate to their perspective. In principle, they 
were  in  favour  of  allotting  costs  to  pollutant  emissions  –  but  argued  that  the 
explanation and tools provided in the Directive are not helpful. It was felt that 
the monetisation option currently causes more confusion than help. 

A stakeholder representing an alternative fuel technologies was concerned that 
the Directive’s monetisation methodology had no positive impact whatsoever on 
their technology, despite CO2 benefits. 

Some stakeholders felt that the Clean Vehicle Portal was inadequate as a means 
of  helping  their  technology  to  succeed,  because  it  did  not  contain  details  of 
vehicles using their technologies. If Contracting Authorities were to search the 
portal for vehicles with the alternative fuel technologies in question, they would 
reportedly only see Diesel vehicles. 

It was argued that a key question that ought to be considered at this point is 
whether energy efficiency or CO2 is the more important issue. One stakeholder 
argued that a target of 95g  CO2 per km could be met with currently available 
alternative fuel technology. 

Stakeholders  representing  alternative  fuels  also  raised  the  issue  of  how  CO2 
emissions should be dealt with for heavy duty vehicles. 

Stakeholders  drew  attention  to  the  fact  that  clean  vehicle  technology  had 
developed  significantly  in  recent  years  –  and  called  for  this  progress  to  be 
reflected  in  the  monetisation  calculations.  In  particular,  it  was  felt  that  the 
calculations  should  reflect  the  fact  that  the  total  cost  of  ownership  of  certain 
alternatively  fuelled  vehicles  may  now  be  lower  than  Diesel  vehicles.  Certain 
spreadsheet  tools  already  exist  for  helping  buyers  to  calculate  the  cost  of 
ownership of buses, for example. 

One  of  the  stakeholders  in  this  group  underlined  that  a  key  objective  of  the 
Directive is to stimulate the market for clean vehicles. 

The City of Stockholm owns only 0.2% of all vehicles running in Stockholm. It is 
possible that Stockholm is an extreme example, but in general, cities own fewer 
and fewer vehicles. Therefore, it was argued, the actions city governments take 
on their own fleets will not influence the market on their own. 

To attempt to influence the market, Stockholm made a simple definition of what 
a clean vehicle  is; 95g  CO2  per km. (With  biofuels,  the value  is allowed  to be 
slightly higher). Last year,  23%  of all  cars  sold in  the city of Stockholm  were 
below  this  95g  limit.  The  city  led  the  way  in  achieving  this  outcome.  The 
simplicity of the definition made it possible for private companies to adopt it for 
their  own  fleets.  In  most  cases  it  was  adopted  voluntarily,  although  in  some 
cases  the  companies  were  pushed  a  bit  by  the  city’s  transport  procurement 
department.  The  criteria  have  spread  from  company  to  company;  some 
companies have made it  a requirement  of their  business partners. The city  of 
Stockholm therefore argued that a simple definition is better than a complicated 
but accurate one. 

city 

Local 
governments 
and networks 

Chair 

The chair pointed out that the impacts of the Directive go beyond cities – they 
include  greater  visibility  of  clean  vehicles,  for  example  among  customers  of 
public transport, or passers-by who see clean municipal vehicles. The Directive 
also has an impact on the fleets beyond its formal scope. 

city 

Local 
governments 
and networks 

One  of  the  stakeholders  in  this  group  reiterated  that  the  number  of  vehicles 
owned publically is decreasing as the number of public services being outsourced 
increases. They suggested that if the scope of the CVD were changed, one area 
in which it could be expanded is to cover vehicles used in the provision of services 
which governments have outsourced to the private sector. 

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Another stakeholder in this group suggested that there needed to be a discussion 
about what the definition of a clean vehicle ought to be, and that this definition 
should not focus solely on CO2. 

Industry  and 
consumers 

One of the stakeholders in this group asked if compliance with this Directive is 
really so different to the requirements procurers currently have to comply with 
as a result of other legislation. 

city 

Local 
governments 
and networks 

Stakeholders in the cities group advised that the basic idea of green procurement 
is not new. There are three examples of sector-specific green procurement law: 
Energy  Star,  the  energy  performance  of  buildings,  and  the  Clean  Vehicles 
Directive.  What  is  different  about  the  Clean  Vehicles  Directive,  one  of  these 
stakeholder argued, is the Directive’s degree of complexity. It was felt to be “far 
more complicated” than sector-specific green procurement legislation elsewhere. 

Chair 

The chair asked stakeholders to provide their views on whether the Directive still 
provides  added  value,  and  if  it  can  be  improved,  or  whether  it  should  be 
repealed.  

city 

Local 
governments 
and networks 

One of the stakeholders stated that a Clean Vehicles Directive is better than no 
Clean Vehicles Directive, even if it is weak in the standards it sets. Simply having 
the  Directive  in  existence  sends  an  important  message.  But  it  can  be 
strengthened enormously. 

It  was  argued  that  the  main  potential  improvement  would  be  a  definition  of 
“Clean Vehicle” – a definition that gets stricter over time, and is more ambitious 
than the car and light van CO2 regulations. 

Another potential improvement is to expand the scope to cover privatised public 
services. 

Another issue is cleaning  up old vehicles in cities  –  they are  responsible  for a 
large share of pollution. Some sort of obligation to remove highly polluting older 
vehicles would potentially be very important. 

Chair 

The city of Brussels banned the use of taxi vehicles which are more than seven 
years old. Buses and taxis make up a small proportion of all vehicles in cities, 
but their annual mileages are especially high, and in this sense their impact tends 
to be higher than other vehicles. 

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Industry  and 
consumers 

In the context of remarks about “cleaning up” older vehicles, it was suggested 
that  cleaner  burning  fuels  such  as  paraffinic  fuels  should  be  considered  by 
procurers when making their procurement decisions. 

Eco-driving programmes to improve fleet emissions were also mentioned in this 
context.   

Some  stakeholders  in  this  group  also  stated  that  the  Directive  is  better  than 
having nothing. 

One of the stakeholders stated that with electric vehicles, it is only recently that 
vehicles  have  begun  to  come  onto  the  market  which  are  interesting  from  the 
perspective of this Directive.  The  utility  of the Directive for these  vehicles will 
increase exponentially over the next 3, 5, and 10 years as new vehicles come on 
to the market. 

Further remarks were made by stakeholders in this group who felt that the Clean 
Vehicles  Portal  may  not  be  doing  enough  to  encourage  people  to  look  at 
alternatively  fuelled  vehicles.  A  stakeholder  reported  difficulty  in  finding  any 
electric  buses  or  alternatively-fuelled  trucks  on  it.  This  stakeholder  was 
concerned that contracting authorities might look at this portal, be discouraged 
by  the  search  results,  and  then  just  return  to  their  known  suppliers  of 
conventionally fuelled vehicles. 

Stakeholders underlined the importance of regularly updating price information 
on the Clean Vehicles Portal, because it compares the prices of vehicles using 
mature  technology  and  vehicles  which  are  ‘experimental’  and  subject  to 
relatively rapid changes in price. One stakeholder also suggested providing some 
indication of expected future prices, since (for example) experts have forecast 
various trajectories for future battery prices. 

Stakeholders asked that the Directive not be repealed without something better 
being brought in to replace it. 

Stakeholders also underlined that it was also important to pay attention to the 
supply side – one suggested that the Portal could be made more attractive by 
adding  more  pictures,  and  that  vehicle  suppliers  should  be  encouraged  to  be 
more active here. 

A  stakeholder  representing  gas  vehicles  stated  that  there  was  a  very  broad, 
mature  technology  offering  in  this  area,  but  sales  remain  low,  and  the  only 
means  of  improving  them  is  through  public  procurement.  This  stakeholder 
commented that procurement of this technology should not be taken for granted 
and  that  it  needed  to  be  supported,  otherwise  the  segment  could  die.  It  was 
pointed out that the Alternative Fuels Infrastructure Directive has mandated the 
build-up of electric and gas infrastructure to support these technologies in future. 
It was argued that Diesel vehicles, by contrast, needed no more support. 

A stakeholder representing the City of  Stockholm  reiterated that the city only 
possesses  0.2%  of  the  fleet  in  the  city.  Half  of  that  fleet  comprises  special 
vehicles which non-government actors would not be interested in buying. (Buses 
are  different,  because  public  entities  have  a  large  impact  in  that  segment, 
procuring  about  half  of  all  buses  in  Europe.)  For  passenger  and  light  duty 
vehicles, this stakeholder argued that we should consider which groups ought to 
be targeted. The city of Stockholm works with taxi drivers and craftsmen, and 
uses its procurement power to change their vehicle fleet. The city uses incentives 
or “nudges” (like allocation  of delivery windows)  that  can change the delivery 
market.  A  significant  diffusion  in  practices  also  takes  place  from  company  to 
company.  
And  things  have  been  helped  by  the  national  government  putting  out  a 
framework for deciding what is and isn’t a clean vehicle. 

This stakeholder suggested that there might be some difficulties in agreeing a 
definition  of  a  “clean  vehicle”  elsewhere,  including  difficulty  in  getting  vehicle 
manufacturers to agree among themselves on a common definition. Stockholm’s 

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Local 
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transport vehicles 

definition of “clean vehicle” also might be slightly too ambitious for all Member 
States to attain; it includes EURO 6 among other requirements. 

One of the city networks stated that it would be necessary to take into account 
the known problems with EURO 6. And not all cities will be able to impose the 
same access restrictions on cars as Stockholm, for example. 

It was suggested that a common understanding of what is a “clean vehicle” could 
help cities work with transport operators. The Commission has previously done 
work on fleet recognition schemes. 

Stakeholders also underlined the importance of coordinating efforts in this area 
with the air quality package and with action on retrofitting, for example. 

Another  stakeholder  commented  that  the  immediate  problem  with  the 
methodology in the Directive is that air quality needs to be weighted much more 
heavily. 

city 

Local 
governments 
and networks 

A stakeholder representing the Greater London Authority (GLA) commented that 
although  it  does  not  own  its  bus  fleet,  the  city  regulates  what  the  (private) 
operators of that fleet can buy or use. There are 8,000 buses in London, so the 
city has significant buying power. The number of black taxis is probably about 
15,000, and in addition there are many more private hire vehicles which the city 
regulates. 

It was stated that although the numbers of vehicles publically procured are small 
in proportion to the number on the road, they have a disproportionate impact on 
the emissions in the middle of a city. 

The  GLA  has  various  other  policy  levers  for  tackling  emissions,  including 
congestion  charging,  and  restricted  access  to  London’s  Low  Emissions  Zone. 
These are acknowledged to have not been enough on their own to achieve the 
air quality obligations on London, which is why the Mayor has proposed an Ultra-
Low  Emissions  Zone  from  2020.  That  would  entail  requirements  on  both 
passenger cars and heavy vehicles to meet certain EURO standards. 

The Greater London Authority does not have an answer on what the  impact of 
the  Directive  has  been  in  London.  The  city  stated  that  it  is  already  aiming  to 
create as clean a fleet as it can, and that it is probably slightly ahead of others 
on clean procurement, so unless the Directive becomes much more ambitious it 
is unlikely to have an effect on what London is doing. 

One  of  the  city  networks  commented  in  response  to  this  that  London  and 
Stockholm  are  not  the  target  audiences  for  this  Directive.  Nevertheless,  the 
Directive should not hinder these cities from taking progressive action. 

According to one of the city networks, sustainable fleet management certification 
schemes  are  a  very  powerful  potential  tool  for  procurers  when  procuring 
services. Procurers can set award criteria for contractors having this certification. 

It  was  also  suggested  that  providing  national  centres  of  expertise  in  clean 
vehicles would help contracting authorities make better procurement decisions. 
Public  authorities  are  unlikely  to  be  experts  in  clean  vehicles,  and  they  won’t 
have access to the information others have. In case of Sweden and UK, there 
are particular bodies that can provide that info; they know about various issues 
such as how different fuels perform in different duty cycle. 

Chair 

The chair asked how effective the Clean Vehicles Portal was. 

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city 

Local 
governments 
and networks 

Some stakeholders highlighted issues with keeping the data in the Clean Vehicle 
Portal  –  and  portals  more  generally  –  up-to-date.  A  Belgian  study  conducted 
around 10 years ago had concluded that it was difficulty to keep these portals 
updated frequently enough. 

Some  stakeholders  had  observed  problems  in  their  country  with  the  Clean 
Vehicles Portal – such as being unable to find some vehicles, because they have 
been given “wrong” names (i.e. different names to what they are sold under in 
that particular country). Data on costs, emissions, and total cost of ownership 
was also alleged to be lacking. 

It was acknowledged that there are difficulties with accessing the data needed 
to  populate  the  portal.  This  is  especially  the  case  with  vehicles  that  are  not 
passenger cars, especially buses and freight vehicles. 

There was some discussion of various national-level Portals with similar functions 
to  the  Clean  Vehicles  Portal,  such  as  ecoscore.be,  which  is  more  tailored  to 
specific national requirements in Belgium. 

In  Sweden, there is a  national portal  which gets updated once  or twice a day 
because that is felt to be the level of updating activity that is necessary to keep 
the portal useful. 

A  consumer  organisation  commented  that  it  has  not  followed  the  Directive  in 
great detail, but in regards to potential repeal, its position is that it is in favour 
of initiatives that support government or private company uptake of clean fleets. 
This is because consumers are currently often priced out of the clean vehicles 
market.  They  are  therefore  in  favour  of  initiatives  that  encourage  uptake  and 
drive  down  prices.  If  there  are  problems  with  the  Directive,  their  suggestion 
would probably be to fix the problems. Repeal would send out a poor political 
signal,  i.e.  that  public  authorities  are  losing  interest  in  procurement  of  clean 
vehicles. 

Industry  and 
consumers 

Industry  and 
consumers 

Further stakeholders from this group agreed that repealing the Directive would 
be a mistake. 

One stakeholder suggested that the definition of clean vehicles could have up to 
two  elements:  CO2  benefits,  or  pollutant  emissions  benefits,  or  both.  Another 
stakeholder  underlined  the  importance  of  allowing  different  powertrains  to  be 
considered as well as different fuels – and asked that the definition be consistent 
with technology neutrality. 

In  the  national  frameworks  required  by  the  Alternative  Fuel  Infrastructure 
Directive,  public  procurement  is  mentioned  as  a  tool.  One  stakeholder  stated 
that infrastructure itself remains a problem, but this is the responsibility of the 
Member States. 

Another  issue  with  making  fleets  cleaner  is  retrofitting.  One  stakeholder 
suggested that this issue should be tackled in stages. 

On joint procurement, one stakeholder stated that their understanding was that 
procurement  was  already  “a  headache”  and  that  joint  procurement  was  even 
more difficult. 

One stakeholder stated that they originally had high expectations for the portal, 
but  from  their  perspective,  it  had  suffered  several  problems.  One  of  these 
problems with the hardware supporting the portal. Another was that knowledge 
of the portal could have been better; it was argued that levels of usage of the 
Portal  were  low,  in  part  due  to  knowledge  of  it  not  being  disseminated  very 
successfully. 

One  stakeholder  noted  that  the  Directive  refers  to  the  impacts  of  vehicles  as 
costs, which implies that someone will pay for them. 

Chair 

The Chair invited attendees to discuss the question of who should bear the costs 
of paying for clean vehicles. 

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Member 
States  

Industry  and 
consumers 

Mr Moran from OLEV stated that in the UK, it is UK taxpayers who take up the 
brunt of the cost. Since 2010, OLEV has spent close to £1bn in clean vehicles 
including about £500m  for cars  and  vans,  helping to bridge the gap  for those 
who  want  to  adopt  early.  OLEV  has  also  spent  £25m  on  green  taxis,  £25  on 
green  trucks,  and  made  further  investments  in  infrastructure,  among  other 
expenditure. 

Mr Moran acknowledged that the demand side is essential. 

The  UK  will  review  the  Directive  next  year.  At  the  moment  though,  the  OLEV 
position is that providing £1bn in incentives appears to be the best action. 

Some  stakeholders  suggested  that  it  might  be  appropriate  to  make  finance 
available  from  the  EIB  or  link  regional  development  funds  to  vehicle 
procurement.  Clean  vehicles  have  lower  operating  costs  but  higher  purchase 
costs, potentially justifying the use of these funding/finance instruments. Some 
governments which are currently not looking at options for clean vehicles might 
then be encouraged to take an interest in them. In some Member States, EURO 
I and even EURO zero buses are still common. 

One stakeholder made further remarks on the Clean Vehicles Portal, stating that 
a meeting had been held to discuss it 2-3 years ago but that recommendations 
raised at that meeting had not been taken forward. This stakeholder stated that 
the  portal  completely  fails  to  represent  certain  types  of  alternatively  fuelled 
vehicles  and  recommended  that  the  Portal  be  taken  offline  The  stakeholder 
suggested that maintaining a Portal to a sufficient standard requires formidable 
amounts of effort and resource. Emissions, operating costs and purchasing costs 
all  need  to  be  clearly  explained,  and  payback  periods  for  alternatively  fuelled 
vehicles  should  be  shown,  to  illustrate  the  fact  that  sufficient  mileage  makes 
them economically competitive choices. 

A stakeholder representing the gas vehicle segment argued that large amounts 
of  financial  support  were  not  necessarily  required,  and  that  infrastructure 
constraints could also be readily overcome if the vehicles were procured. 

city 

Local 
governments 
and networks 

A stakeholder representing one of the cities networks agreed that the question 
of  who  should  pay  for  the  clean  vehicles  was  key,  and  stated  that  legislation 
cannot just pass all costs on to cities and other procurers. And the clean vehicles 
Directive is just one among a number of policies on uptake on clean vehicles. 

It was remarked that the total cost of ownership of some electric vehicles is now 
close to parity with conventional vehicles. But procurers can struggle to procure 
on the basis of total cost of ownership, partly due to the difficulty making the 
calculation, and partly because of way public budgets are managed and split up 
(for  example  fuel  costs  are  sometimes  dealt  with  separately  to  other  costs  of 
ownership). 

One stakeholder suggested it might help if procurers could be given the option 
of making regular, small, manageable payments. 

One  of  the  city  networks  also  remarked  that  it  sees  an  increasing  number  of 
comments from cities the real-world emissions profiles of the vehicles they buy 
do not resemble the “promised” emissions profiles. 

Some cities are now saying they will set targets such as 25% of their fleet being 
“clean”, but others cannot afford to do this. 

city 

Local 
governments 
and networks 

Upon a question for clarification by DG MOVE, the City of Stockholm advised that 
it uses a professional services company that scans the market for company cars 
every day. Although this costs money, Sweden sees it as a very helpful service. 
There is no statute forcing the creation of this information. Similar services are 
probably available in other Member States. 

It  was  also  remarked  that  because  progress  is  being  made  on  reducing  CO2 
emissions from new cars, a target such as the 95g limit used in Sweden might 
not remain relevant for very long. 

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Chair 

The Chairman pointed out that Commission colleagues in DG CLIMA are already 
giving consideration to how to move forward with the  CO2 Regulations beyond 
2020. 

The  chairman  noted  that  there  was  a  clear  view  among  attendees  that  the 
Directive should not be repealed. 

Possible improvements to the Directive – addressing evaluation questions and 
developing policy recommendations 

The contractors gave a further presentation on topics related to: 

  possible improvements to the Directive;  
 
 

the specific Evaluation questions in this study; and  
the issues raised by COM (2013) 214. 

Contractors  Mr Skinner suggested beginning by discussing the relevance of the Directive to 

the achievement of the Commission’s objectives. 

Local 
city 
governments 
and 
networks 

A stakeholder representing the City of Stockholm remarked that he was confident 
that cities have a role in creating the market for clean vehicles, but that they can’t 
do it alone, and one Directive isn’t enough – complementary measures are needed, 
at  local  and  national  levels  and  possibly  at  the  EU  level.  In  Sweden,  national 
measures to stimulate clean  vehicle procurement  are  redundant,  not by design, 
but because cities are taking the lead with tools they have at their disposal and 
national governments don’t. In Sweden, the city of Stockholm is closer to private 
companies and it is actively targeting their behaviour. 

A  stakeholder  representing  the  Greater  London  authority  remarked  that 
harmonisation in the way impacts are determined seemed problematic, and might 
not be possible. For example, one should consider the different impacts that occur 
when running vehicle son flat routes versus hilly routes. Sufficient flexibility to take 
into account local demands and experimentation at a local level. This stakeholder 
asked if a single formula would really be capable of doing this. 

Several  attendees  around  the  room  indicated  that  they  agreed  that  while  some 
degree of harmonisation at an EU level was desirable, harmonisation “at a detailed 
level” may not be. 

One of the city networks  remarked  that a unified,  coherent signal needed to be 
sent to vehicle suppliers – as 28 different sets of criteria wouldn’t make sense in a 
globalised  vehicle  market.  It  was  also  stated  that  it  would  be  easier  to  achieve 
“balance” if energy efficiency was not the main focus of quantifying impacts. 

Industry  and 
consumers 

One of the stakeholders suggested that “clean” and “energy efficient” is somewhat 
contradictory. The legislation is called the clean vehicles Directive, not the energy 
efficient vehicles Directive, and its design should reflect that. 

Another stakeholder suggested that as an alternative to effectively setting quotas 
for purchase of clean vehicles, their procurement could be stimulated by altering 
prices. Vehicle taxes are one potential instrument for doing this. At present, road 
taxes are already somewhat proportional to emissions. This stakeholder asked why 
vehicle taxes could not be used to incentivise improvements in emissions. Others 
in the room suggested that measures like that may be beyond DG MOVE’s remit. 

One stakeholder remarked that these taxes might amount to tens of thousands of 
euros per vehicle. One stakeholder stated that this would just be commensurate 
with the impacts of their emissions. 

A  stakeholder  urged  DG  MOVE  to  communicate  and  collaborate  with  other  DGs 
(e.g.  ENER,  CLIMA),  as  it  was  felt  that  the  issue  cannot  be  tackled  from  the 
transport perspective in isolation. 

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Chair 

DG MOVE thanked the stakeholders for their suggestions. 

Contractors  Mr Skinner asked if the Directive had resulted in increased awareness 

Local 
city 
governments 
and 
networks 

One of the cities remarked that the Directive has resulted in increased awareness 
in the newer Member States.  

A  city  network  noted  that  some  cities  in  their  network  were  unaware  of  the 
Directive. 

Contractors  Mr Skinner suggested discussing the questions on efficiency. 

Local 
city 
governments 
and 
networks 

The stakeholder representing the city of Stockholm noted that almost 20% of new 
cars bought in the city were below 95g CO2 per km. In light of that success, it was 
suggested  that  Stockholm’s  model  should  at  least  be  tested  in  more  Member 
States. 

Contractors  Mr Skinner suggested discussing added value. How could the added value of the 

Directive be improved? 

Local 
city 
governments 
and 
networks 

One  of  the  city  networks  commented  that  all  of  the  recommendations  given  by 
stakeholders so far would improve added value. 

Contractors  Mr  Skinner  suggested  discussing  coherence,  including  coherence  with  other 

procurement legislation. 

city 
Local 
governments 
and 
networks 

One  of  the  city  networks  comments  that  the  current  design  of  the  Directive  is 
meant  to  make  it  entirely  compatible  with  existing  horizontal  procurement 
legislation, which currently provides no obligations on Member States specific to 
individual sectors. So the Directive is entirely complementary with that legislation. 
The  possibilities  for  lifecycle  costing  in  public  procurement  are  also  entirely 
compatible across the CVD and other EU public procurement legislation. 

DG MOVE 

Mr Önel asked about joint cross-border procurement, and what could be done at  
EU level to facilitate it. 

city 
Local 
governments 
and 
networks 

One of the city networks commented that this idea has been incredibly difficult to 
push at EU level for many years. The problems include difficulties in aligning the 
needs of different procurers. There are also language barriers and legal difficulties. 
One thing that might help, it is argued, is providing money. This is happening with 
Public  Procurement  Innovation  projects  –  the  EU  pays  a  certain  amount  of  the 
procurement  value  as  an  incentive.  This  is  arguably  crucial  to  making  joint 
procurement attractive. Paris is reportedly building a network for this. 

Another of the city networks argued that cross border procurement increases effort 
and time massively, and does not bring overall costs down, according to members 
of  the  city  network.  Nevertheless,  there  is  felt  to  be  a  benefit  to  collaborating 
across borders when doing innovating things, as this shares risks and potentially 
pushes development in a new direction. 

One of the city networks also commented that there may be legal issues with joint 
procurement in the context of current EU legislation. According to this stakeholder, 
joint procurement activities can conflict with the Public Procurement Directive when 
a contract is developed after competitive tender and additional parties enter the 
agreement after the competition. If this increases the volume of goods purchased 
significantly, this can be illegal. At the same time, for joint procurement efforts, 
joining at a late stage like this may make sense. 

The  Fuel  cells  and  Hydrogen  Joint  Undertaking  has  been  looking  at  joint 
procurement  possibilities.  Prices  in  this  segment  are  coming  down,  and  with 
subsidies,  we  are  now  approaching  “normal”  prices.  There  is  an  initiative  for 
collecting first commitments of interest in purchasing buses in quantities of tens 
or  hundreds.  These  alignments  do  seem  to  bring  costs  down.  Therefore,  one 
stakeholder  argued,  it  may  not  be  necessary  to  go  as  far  as  organising  joint 
procurement – joint expressions of interest from procurers might help.  

Industry  and 
consumers 

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transport vehicles 

Contractors 

Let’s  discuss  the  points  raised  by  the  Commission’s  Communication,  i.e.  COM 
(2013) 214, in response to the 2012 report on the Directive. 

One of the city networks commented that whatever happens with the revision of 
the Directive, cities should be closely involved in designing it, as they will be largely 
responsible for implementation. 

One  stakeholder  commented  that  the  20:20:20  targets  have  to  be  considered 
together  with  these  objectives,  and  that  change  to  the  Directive  should  not  be 
discussed  without  knowing  what  is  going  to  happen  with  the  deployment  of 
alternative fuels, for example. 

Local 
city 
governments 
and 
networks 

Industry  and 
consumers 

Summary 

Chair 

The  chairman  offered  the  following  remarks  to  sum  up  contributions  made  by 
attendees: 

It’s important to note that the objective of the Directive is to stimulate the market 
for clean vehicles (although there  may  now be some controversy as to what this 
means  –  in  particular  whether  it  should  include  energy  efficiency).  Since  2009, 
things have evolved, and our thinking process has gone further. Perhaps it is time 
to revise or define the concept of a clean vehicle as attendees suggest. In any case, 
there seems to be a consensus that the Directive shouldn’t be repealed, It should 
be improved on a number of fronts instead. 

The Directive is thought to be complex. And awareness of it at a local level is poor. 
But I am sure that public authorities know the national legislation exists, and they 
will know that ignorance of the law would not exempt them from having to apply it. 

The monetisation methodology seems to be too complex and gives predominance 
to energy efficiency criteria. 

Another factor criticised was the difficulty of getting data on heavy duty vehicles. 

The  monetisation  methodology  has  no  positive  impact  on  natural  gas  vehicles  – 
hence the question of what ought to be more important, energy or CO2? 

Cities own fewer and fewer vehicles themselves. But they procure services which 
rely  on  private  fleets,  and  this  procurement  might  be  brought  into  scope  of  the 
Directive. 

A weak Directive is still felt to be better than no legislation in this area. 

Cleaning up older vehicles has also been highlighted as an important idea, as has 
eco-driving. 

Cities  may  need  help  to  purchase  these  vehicles  in  conditions  where  there  is 
currently no supply of them, so we must also look at the supply side, and provide 
positive  signals  there,  for  example  through  the  deployment  of  alternative  fuel 
infrastructure (and Directive 2014/94/EU). At the same time, the demand side is 
essential. 

The clean vehicles portal has been criticised, and suggestions have been made to 
update it or to put it offline. There are doubts about its usefulness in light of lacking 
data, and  the existence  of  better national databases. Public authorities procuring 
vehicles are not the experts in clean vehicles, which is why there is a need for better 
portal information. 

Mandating  minimum  fleet  shares  of  alternatively-fuelled  vehicles  was  also 
suggested. 

Technological neutrality concerning powertrains was also mentioned. 

It was suggested to review the Directive in multiple stages. 

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On funding, we had suggestions that procurement could be supported through the 
EIB or the regional development fund. 

The role of Member States in terms of taxation as a lever for encouraging uptake of 
clean vehicles was also discussed. 

The  Directive  seems  to  need  an  overhaul,  but  it  won’t  be  enough  on  its  own  – 
complementary national legislation is important. 

Harmonisation at EU level is appreciated, but should not go into excessive detail. 

Joint procurement could be a means of bringing prices down. 

The involvement of stakeholders in this process is very important. 

The thinking process  will  continue  –  and  attendees are  invited to provide  further 
comments to the consultants. 

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transport vehicles 

12.  ANNEX 4 – ONLINE PROCURER SURVEY 

A detailed survey tailored to authorities that have procured road transport vehicles since 
2012 was developed. Due to the number of potential procurers in EU Member States, five 
countries were agreed  with the Commission for prioritising the data collection, including 
Germany, Hungary, Italy, Spain, and the UK.  

A  total  of  4,520  unique  email  addresses  for  procurers  were  identified  in  the  Tenders 
Electronic Daily (TED) database39. Potential respondents from all 28 Member States were 
invited to take part in the survey.  Apart from the email addresses that were used to send 
out  the  online  surveys,  additional  data,  such  as  contract  values  and  types  of  procured 
vehicles were identified in order to be used in our quantitative analysis.  

The  questionnaire  included  a  range  of  open  and  closed  questions  covering  the  following 
themes: 

 

Information regarding the most recently signed contract to procure road transport 
vehicles; 

  Use of environmental criteria in assessments; 

  Setting technical standards for environmental and energy performance; 

  Using weighting/award criteria in assessments; 

  Monetising energy and environmental impacts; and  

  Use of environmental criteria prior to 2012.  

Drafts  of the  survey were agreed with the Commission before they  were translated and 
made  available  on  an  online  platform  in  six  languages  (English,  German,  Hungarian, 
Italian, Spanish, and French40). Translated surveys were  subsequently pilot tested (with 
Member  State/City  contracts)  and  updated.  The  links  to  the  finalised  surveys  were  sent 
out to the list of contacts obtained from the TED database in mid-March 2015. Respondents 
were given approximately six weeks to respond to the survey (two email reminders were 
sent).  

In addition to the direct mail out to procurement contacts, city networks were approached 
and  asked  to  distribute  the  survey  to  their  members.  Polis  Network,  Eurocities,  Local 
Governments for Sustainability (ICLEI), and The European Network for Rural Development 
(CEMR/CCRE), all agreed to circulate the surveys to their European networks/members.  

Table 12-1 provides a summary of the number of responses by prioritised Member State 
and the rest of the EU. The overall response rate of 19.1% amongst prioritised Member 
States can be considered satisfactory considering the mass nature of the emails to send 
out the survey links.  

Table 12-1: Number of responses for the procurers’ survey 

Country 

Contracting 
Authorities (TED) 

No. of responses   Response rate 

United Kingdom 

173 

Germany 

Hungary 

Italy 

1,479 

111 

155 

22 

311 

15 

34 

12.7% 

21% 

13.5% 

21.9% 

39 Tenders European Daily (TED) - http://ted.europa.eu/TED/main/HomePage.do  

40 French was also included to ensure wider language coverage.  

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transport vehicles 

Spain 

Rest of EU 

147 

2,455 

Total  

4,520 

24 

141 

547 

16.3% 

5.7% 

12.1% 
for 
MSs) 

(19.7% 
prioritised 

Source: Online Survey of Procurers – March-April 2015, Ricardo-AEA 

The  table  shows  a  satisfactory  response  rate  of  19.66%  across  the  prioritised  Member 
States  (and  12%  across  all  countries).  Germany  was  the  Member  State  with  by  far  the 
most  contacts  available  through  the  TED  database  which  corresponds  to  the  number  of 
tender award notices. Together with Italy, Germany also had an above average response 
rate. The lowest response rates of the prioritised countries had the UK with roughly 13%. 
As expected the response rate for the rest of Europe was significantly lower (only 6%) due 
to language barriers. 

In the following we will discuss the results from the main questions of the survey. 

What kind of organisation do you represent? 

Figure 12-1: Respondents - Type of organisations represented 

Central government
3%

Regional government
10%

Other
21%

Administrative public 
bodies
4%

National, regional and 
local bodies
2%

Emergency services 
organisation
15%

Local government
45%

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

With regards to the type of organisation that the respondent was representing, the most 
(45%)  were  from  local  government.  This  was  followed  by  ‘other’  (21%),  emergency 
services organisations (15%), and regional government (10%) (Figure 12-1). 

“Other”  types  of  authorities  included:  public  transport  operators,  water/gas  utility 
authorities,  waste  management  service  provider,  state-owned  companies,  procurement 
service providers. 

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Which Member State is your organisation based in? 

The following table gives an overview of the responses for each Member State country 
that took part in the survey sorting from highest number of responses to the lowest 
number of responses. 

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transport vehicles 

Table 12-2: Numbers of respondents by Member State 

Country 

Number of responses  Country 

Number of 
responses 

  Germany 
  Italy 
  France 
  Spain 
  United Kingdom 
  Sweden 
  Hungary 
  Belgium 
  Austria 
  Denmark 
  Lithuania 
  Netherlands 
  Croatia 

311 
34 
25 
24 
22 
21 
15 
13 
11 
10 
8 
7 
6 

  Czech Republic 
  Finland 
  Ireland 
  Poland 
  Luxembourg 
  Estonia 
  Slovakia 
  Bulgaria 
  Romania 
  Slovenia 
  Greece 
  Latvia 
  Serbia 

6 
5 
5 
5 
4 
3 
3 
2 
2 
2 
1 
1 
1 

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

The most responses were received from Germany, followed by Italy and France (although 
not a priority Member  State, the survey was  also available in French).   Responses were 
received from all EU 28 Member States, with the exception of Malta, Portugal and Cyprus41. 
One  contribution  was  obtained  from  a  non-EU  country  (Serbia),  however,  no  Serbian 
authority was contacted directly. 

41 Surveys were not sent to any contacts within Cyprus directly, due to no contract award 

notices being made since the start of 2012.  

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transport vehicles 

How is procurement organised in your organisation? 

Figure 12-2: Organisation of procurement (547 out of 547) 

Completely centrally organised (100% 
central) (e.g. dedicated procurement 
department within your organisation)
36%

Completely non-
central
7%

Do not know
3%

Mostly non-central 
(<25% central)
8%

Mixed between 
central and non-
central (25-75% 
central)
20%

Mostly centrally 
organised (>75% 
central)
26%

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

The  most  common  approach  to  procurement  amongst  respondents  was  ‘completely 
centrally-organised’  (36%),  followed  by  ‘mostly  centrally-organised’  (26%)  and  a  ‘mix 
between  centrally  and  non-centrally  organised’  (20%).  This  shows  a  clear  trend  from 
centrally organised to non-centrally organised procurement. 

Has your organisation procured road transport vehicles under a contract which was 
subject  to  the  requirements  as  set  out  in  the  Clean  Vehicles  Directive  since  the 
start of 2012? 

In order to determine the level of procurement activity affected by CVD, respondents were 
asked  to  confirm  whether  they  had  procured  road  transport  vehicles  subject  to  the 
requirements of the  Directive since the start of 2012. Less than half of the respondents 
(249, 46%) stated that they had (Figure 12-3).  

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transport vehicles 

Figure 12-3: Procurement cases since the start of 2012 (547 out of 547) 

300

250

200

150

100

50

0

  Yes

  No

  No Response

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

Which model(s) of vehicle did you procure, and how many did you procure? 

To get an overview of the distribution of vehicle types being procured, procurement 
authorities were asked to state which quantities and models of vehicles were procured in 
their last contract. This information was then used to group the vehicles into seven 
different categories. The following table (Table 12-3) provides an overview of the 
quantities and types of vehicles for all EU28 countries that data was received from 
including the number of procurers that have responded. 

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Table 12-3: Type of vehicles procured by type of vehicle 

Country  Number 

of 
procure
rs 

EU28 

Austria 

Belgium 
Croatia 

Czech 
Republic 
Denmark 
Germany 

Spain 
Estonia 
Finland 
France 
Hungary 
Ireland 
Italia 
Latvia 

Lithuania 

Luxembourg 

Netherlands 

Poland 

Romania 

Slovakia 

Slovenia 

Sweden 

United 
Kingdom 

507 

9 
12 
5 
6 

9 
297 

22 
1 
5 
22 
15 
5 
32 
1 

7 
4 
7 
4 
2 
3 
2 
18 
18 

Passeng
er car 

Van  Rigi

d 
truc
k 

Tracto
r 
trailer 

2,208 

294 

147 

11 

- 

11 
4 
- 

1 

- 
- 
- 

- 
1,678 

- 
171 

- 
- 
6 
8 
- 
- 
95 
- 

4 
- 
- 
- 
- 
- 
321 
81 
- 

24 
- 
- 
3 
- 
10 
64 
- 

3 
- 
- 
- 
- 
- 
- 
18 
1 

1 

- 
- 
- 

- 
65 

6 
- 
5 
- 
18 
4 
40 
- 

- 
- 
2 
- 
- 
4 
- 
2 
- 

- 

- 
- 
- 

11 
- 

- 
- 
- 
- 
- 
- 
- 
- 

- 
- 
- 
- 
- 
- 
- 
- 
- 

Coac
h 

Bu
s 

Vocation
al 

7  1,03
6 
- 

- 
- 
- 
- 

- 
- 
- 

- 
- 
-  243 

34 
- 
- 
- 
- 
- 
-  191 
7 
4 
- 
70 
3  346 
- 
- 

- 
- 
- 
- 
- 
- 
- 
- 
- 

- 
- 
- 
80 
- 
- 
- 
65 
- 

23 

- 

- 
- 
- 

- 
8 

- 
- 
1 
- 
- 
8 
6 
- 

- 
- 
- 
- 
- 
- 
- 
- 
- 

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

Of the procurers responding to the survey, passenger cars were by far the most commonly 
procured vehicles (58% of all vehicles) followed by busses (27%). Other vehicle types were 
procured in much smaller quantities. 

All 

Insuf
fi-
cient 
data 

84 

- 

52 

- 
- 

3,8
10 
2 

63 
4 
- 

1 
2 

- 
- 
- 

12 
2,1
67 
64 
- 
12 
6  208 
- 
29 
- 
92 
23  576 
- 

- 

- 
7 
- 
- 
- 
2 
- 
80 
- 
- 
- 
4 
-  321 
-  166 
- 
1 

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Which  of  the  following  environmental  evaluation  options  did  you  apply  in  this 
contract? 

-  Setting technical standards for environmental and energy performance (e.g. 

minimum standards) 

-  Applying  a  weighting  for  environmental  and  energy  criteria  in  contract 

evaluation (e.g. award criteria) 

-  Monetisation (e.g. costing) of energy and environmental impacts 

As  identified  in  desk  research  and  engagement  with  Member  States,  25  of  the  28  EU 
Member  States  allow  the  use  of  all  three  options  (1,  2a)  and  2b))  in  their  National 
Implementing  Measures  (NIMs).  The  Czech  Republic  allows  options  1  and  2a),  Estonia 
enables option 1, and Slovenia allows option 2b) only.  

In order to determine which options have been used in practice, respondents were asked 
to identify which of the three options they applied in their most recent contract to procure 
road transport vehicles (see Figure 12-4.  

Figure  12-4:  Application  of  Article  5(3)  environmental  criteria  options  in  most 
recent contract from the start of 2012 (156 out of 249) 

70

60

50

40

30

20

10

0

  Setting technical
standards for
environmental and
energy performance
(e.g. minimum
standards)

  Applying a weighting
for environmental and
energy criteria in
contract evaluation
(e.g. award criteria)

  Monetisation (e.g.
costing) of energy and
environmental
impacts

  None

  Other

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

The  majority  of  the  procurement  authorities  (40%,  63)  stated  that  they  set  technical 
standards (Option 1). 30% (47) applied a weighting for energy and environmental criteria 
in the contract evaluation (Option 2a), whereas 13.5% (21) stated that they applied the 
monetisation methodology (Option 2b). Fourteen  respondents didn’t apply any evaluation 
option and 11 applied options other than the ones outlined in the Directive. No examples 
were given for other evaluation options. 

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transport vehicles 

When  setting  technical  standards  for  environmental  and  energy  performance, 
which environmental criteria did you include in this contract? 

The  respondents  that  had  applied  technical  standards  (Option  1)  were  asked  about  the 
environmental  criteria  that  were  applied  in  more  detail.  The  figure  below  shows  which 
criteria were applied in the latest contract. 

Figure  12-5:  Setting  technical  standards  (Option  1)  -  Environmental  criteria 
included in the contract (63 out of 63) 

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

In  most  cases  Euro  emission  standards  were  applied  (35%).  This  is  followed  by  CO2 
emissions  (20%)  and  Fuel/energy  consumption  (18%).  The  figure  shows  discrepancies 
between  how  the  legislation  is  set  out  and  the  numbers  for  the  different  options.  The 
Directive  specifies  that  at  least  the  three  following  environmental  criteria  have  to  be 
considered for the operational energy and environmental impacts: 

1.  Energy consumption; 

2.  Emissions of CO2; and 

3.  Emissions of NOX, NMHC and particulate matter 

Only in 19 out of 63 cases all three environmental criteria were taken into consideration. 
For the rest of the contracts only one or two of the options were considered. 

When  using  weighting/award  criteria  in  contract  evaluation,  what  was  the 
percentage  weighting  given  to  environmental  criteria  compared  to  other  tender 
evaluation criteria in this contract? 

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Figure 12-6: Weightings used for different award criteria (Option 2a) (40 out of 
47) 

45%

40%

35%

30%

25%

20%

15%

10%

5%

0%

Average weighting of
Environmental criteria

Average weighting of Price Average weighting of Other

category

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

An analysis of the applied weighting factors showed that almost 43% of weight on average 
was given to price compared to 16% for environmental criteria. Other weighting criteria 
have a high impact (38%) and include warranty periods, technical parameters, delivery, 
maintenance and running costs.  

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transport vehicles 

When using weighting/award criteria in contract evaluation, which environmental 
criteria did you include in this contract? 

Figure  12-7:  Weighting  (Option  2a)  -  Environmental  criteria  included  in  the 
contract (46 out of 47) 

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

For  environmental  criteria  used  when  applying  the  weighting  methodology  the  Fuel 
consumption  is  the  most  commonly  used  criteria  when  applying  award  criteria  (Option  
2a)(22%)  followed  by  CO2  emissions  (17%)  and  Euro  emission  standards  (15%)  (see 
Figure 12-5). 

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transport vehicles 

What  was  the  percentage  weighting  given  to  specified  environmental  criteria 
(where used)? 

Figure  12-8:  Percentage  weighting  for  specified  environmental  criteria  (Option 
2a) (27 out of 47) 

Other

Noise

Additional emission pollutant criteria - Other

Additional emission pollutant criteria - Non-methane
hydrocarbons (NMHCs)

Additional emission pollutant criteria - Particulate
matter (PM)

2%

2%

Additional emission pollutant criteria - Nox

3%

12%

12%

16%

Euro Emission Standards

25%

Fuel/energy consumption

17%

CO2 emissions

8%

0%

5%

10%

15%

20%

25%

30%

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

Figure 12-8 shows the average weightings for different environmental criteria used from a 
sample  of  27  respondents.  Euro  emission  standards  were  given  the  highest  weighting 
factor (25%), followed by fuel/energy consumption (17%), Noise (16%).  CO2 emissions 
are found in the midfield with 8%. 

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When monetising energy and environmental impacts, what methodology did you 
use in this contract? 

Figure 12-9: Methodology used to monetise impacts (Option 2b) (18 out of 21) 

Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

Only 21 out of 249 respondents that procured a vehicle since 2012 actually had applied 
the monetisation methodology. Out of those stating they applied the option, most of the 
respondents (44%) used the methodology as set out in the national legislation – however, 
it is not possible to determine from the survey whether the methodology used differs from 
the  Directive,  or  has  been  transposed  directly  as  set  out  in  the  Directive  into  National 
Implementing Measures. Thirty-three percent used the methodology set out in the Clean 
Vehicles Directive directly including the same parameter values. Only one respondent each 
have  used  a  local/organisational  guidance  or  the  Clean  Vehicles  Directive  but  applying 
different parameter values. 

When  purchasing  road  transport  vehicles  before  2012,  did  you  include 
environmental criteria in your assessments? 

Figure 12-10: Use of environmental criteria before 2012 (366 out of 547) 

180

160

140

120

100

80

60

40

20

0

  Yes

  No

  Don't know or not
applicable

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Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

Forty-two  percent  of  all  survey  respondents  stated  that  they  had  applied  environmental 
criteria prior to 2012 (before requirements of CVD were widely applied) whereas 23% (85 
respondents) had not.  In 34% (126)  of all cases the respondent  stated that they didn’t 
know or the questions was not applicable. 

Were the environmental criteria that were applied before 2012 more or less strict 
than the ones used in your most recent contract? 

Figure 12-11: Strictness of environmental criteria applied before 2012 

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Source: Online Survey of Procurers – March-April 2015, Ricardo Energy & Environment 

When asked if the environmental criteria that were applied before 2012 were stricter or 
less strict than in the recent contract, for all criteria the answer option “About the same” 
was the most common, followed by “Less strict” and then “More strict”. For Euro emission 
standards the highest percentage of respondent answered “More strict” compared to the 
other criteria. The option “other” environmental criteria was only selected for 63 out of 155 
respondents. Examples that were given were recycling or country-specific eco labels. 

Do you have any further comments related to this survey? 

We received 31 comments regarding the survey in general. Raised issues were: 

-  A  number  of  respondents  questioned  the  usefulness  of  applying  environmental 
criteria to special vehicles such as firefighting vehicles. While firefighting vehicles 
do not necessarily fall under the Clean Vehicles Directive this section was also used 
to raise criticism against the Euro Emission Standards regarding special vehicles. 
One case were reported where exemptions were needed from national authorities 
as a fire fighting vehicle couldn’t comply with the Emission Standards. 

- 

- 

It was criticised that the legislation was designed for the purchase of vehicles and 
not the situation of long-term leases. 

It  was  suggested  that  the  questionnaire  should  be  translated  into  more  national 
languages as local governments struggle with answering the questions in English. 

Furthermore the comment section was used to go more in detail about specific clean vehicle 
purchases and emphasizing over-compliance with the directive (e.g. applying the CVD for 
cases under the threshold value). 

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13.  ANNEX 5 – PROCURER INTERVIEWS 

Follow-up interviews were carried out with selected procurers from a number of different 
EU  Member States. Along with the invitation to participate in an interview, an interview 
guide was sent out with additional questions to the online survey. Interviews were carried 
out  with  13  procurers.  Out  of  these  13  interview  partners  10  provided  a  completed 
interview guide. In addition 6 procurers completed the guide but were unable to do a phone 
interview (see Table 13-1). In total we received 16 written contributions. In the following 
the results from the questionnaire as well as the phone interviews will be discussed. 

Table 13-1: Interviews with Procurers 

Number 
procurers 
contacted 

of 

Number 
interviews 
completed 

of 

Written 
contribution 
only 

Declined 

No response 

97 

13 

6 

22 

57 

Interview guide 

In contrast to the online procurers’ survey that referred to the latest procurement contract 
the procurers’ interview guide included more general questions about the procurement of 
road vehicles. 

The 16 written contributions were received from a range  of Member  States as  shown in 
Figure 13-1.  

Figure  13-1:  Completed  procurer  interview  guides  by  Member  State  (written 
contributions) 

Slovenia, 1

Italy, 1

Hungary, 1

Ireland, 1

Lithuania, 1

Finland, 1

Poland, 1

Germany, 9

Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

Most respondents were from Germany due to the high number of German procurer contact 
details available. Seven other  responses were  received,  from Poland, Finland, Lithuania, 
Slovenia, Italy, Hungary and Ireland. 

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Please indicate which of the following environmental criteria you have applied when 
procuring road transport vehicles in contracts identified above since the start of 
2012. 

Figure 13-2: Use of Article 5(3) environmental criteria options since the start of 
2012 

14

12

10

8

6

4

2

0

Setting technical standards
for environmental and
energy performance
(minimum standards)

Applying a weighting for
environmental and energy
criteria in contract
evaluation (award criteria)

Monetisation (costing) of
energy and environmental
impacts

Source: Procures Interview Guides – May 2015, Ricardo-AEA 

Most of the respondents had applied minimum technical standards (Option 1) (12) followed 
by weighting criteria (Option 2a) (10). Monetisation (Option 2b) was the criteria least used 
(7) which supports the results from the online survey. The responses revealed that in some 
cases more than one criteria was applied. Four of the respondents applied all three options 
in the same contract. 

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In  your  opinion,  would  you  have  purchased  the  same  vehicles  (or  equivalent  in 
terms  of  environmental  impacts)  without  the  requirement  to  use  environmental 
criteria? 

Figure 13-3: Difference in purchase decisions for different vehicles 

Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

For all vehicle types the answer that the same vehicle would have been purchased without 
using environmental criteria was either more common (3 cases) or the same (3 cases) as 
the number of respondents answering in the negative. For none of the vehicle types the 
option no was more frequently used as yes. See the section below on telephone interviews 
where the reasons are behind these effects is explored in more detail. 

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To  what  extent  was  the  CVD  a  driving  factor  in  your  decision  to  introduce 
environmental criteria? 

Figure  13-4:  CVD  as  driving  factor  in  procurer’s  decision  to  introduce 
environmental criteria in the procurement decision 

12

10

8

6

4

2

0

Only factor

Significant factor

Slight factor

No influence

Don't know or
N/A

Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

Most respondents (10 out of 16) answered that the CVD was a significant factor in their 
decision to introduce environmental criteria. For each of the following answers: that the 
CVD was the only factor; a slight factor; or had no influence; there were two respondents 
each.  

Did  applying  environmental  criteria  have  an  effect  on  your  purchase  or  running 
costs? 

Figure 13-5: Application of environmental criteria and effect on  purchase costs 

7

6

5

4

3

2

1

0

Significant
increase in
costs

Slight increase
in costs

No material
impact

Slight
decrease in
costs

Significant
decrease in
costs

Don’t know / 
NA

Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

For  purchase  costs  most  procurers  (6)  responded  that  environmental  criteria  had  no 
material impact on their purchase costs followed by a slight increase in costs (5). All other 
options were selected by 2 or less respondents. 

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Figure 13-6: Application of environmental criteria and effect on running costs 

9

8

7

6

5

4

3

2

1

0

Significant
increase in
costs

Slight increase
in costs

No material
impact

Slight
decrease in
costs

Significant
decrease in
costs

Don’t know / 
NA

Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

For running costs half of the respondents stated that there was no material impact, all 
other options only selected by 2 or less procurers. 

How  easy/difficult  has  it  been  for  your  organisation  to  apply  the  environmental 
criteria to the procurement of new road transport vehicles? 

Figure 13-7: Ease of applying environmental criteria to procurement of new road 
transport vehicles 

12

10

8

6

4

2

0

Very easy

Easy

Difficult

Very difficult

Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

The  majority  of  the  respondents  (11)  stated  that  it  was  easy  for  them  to  apply 
environmental criteria. Three procurers stated that it was difficult. One respondent each 
selected “very easy” and “very difficult”. 

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In your experience, has the administrative time spent per contract increased due 
to the inclusion of environmental criteria? 

Figure  13-8:  Reported  increases  in  administrative  time  per  contract  due  to 
inclusion of environmental criteria 

Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

For all three options most procurers stated that there was no increase in administrative 
time per contract, or that they did not know/not applicable. . Fewer respondents felt that 
administrative time had increased.  

In  your  opinion,  are  there  differences  in  the  administrative  effort  required  for 
different types of vehicles? 

Figure  13-9:  Are  there  differences  in  the  administrative  effort  required  for 
different types of vehicles? 

9

8

7

6

5

4

3

2

1

0

Yes

No

Don't know

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Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

Half of the respondents (8 out of 16) stated that in their opinion there was no difference 
in administrative efforts between different vehicle types. Six respondents stated that there 
was, whereas two respondents had no opinion on the question. 

When  setting  environmental  criteria,  did  you  apply  any  guidance  or  other 
documentation? 

Figure 13-10: Use of guidance documents when setting environmental criteria 

Source: Procures Interview Guides – May 2015, Ricardo Energy & Environment 

Most  respondents stated that they had used EU GPP guidance (10) or local government 
guidance (9) when setting environmental criteria. Less than half of the procurers applied 
organisational guidance. As for the Clean Fleets project and the Clean Vehicle Portal, they 
were only used by two of the respondents each. 

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Telephone Interviews 

In total, 13 procurers were interviewed from a variety of organisations (majority from local 
authorities.  Vehicles  were  procured  at  scales  both  below  and  above  the  organisation’s 
relevant threshold value for EU-wide tender. 

The chart below (Figure 13-11) shows the distribution of interview candidates by Member 
State. Again a large number of the respondents (6) were from Germany, 2 interviews were 
carried out with Hungarian procurers. Furthermore one interview each was conducted for 
Poland, Finland, Lithuania, Spain and Ireland. 

Figure 13-11: Number of telephone interviews by Member State 

Lithuania, 1

Spain, 1

Hungary, 2

Finland, 1

Poland, 1

Ireland, 1

Germany, 6

Source: Procures Phone Interviews – May 2015, Ricardo Energy & Environment 

Depending on their answers in the procurers interview guide the interviewees were asked 
an individual set of questions. Where no interview guide was received the interview had a 
loose structure around a number of topics essential for our analysis. In the following we 
will elaborate on these different topics in detail. 

Use of environmental criteria in assessments (options presented in Article 5(3)) 

The process of choosing which environmental criteria option to use in assessments was not 
always very transparent. A number  of interviewees  were not aware that they had three 
options  to  choose  from  (as  set  out  in  Article  5(3)  of  the  Directive).  Reasons  provided 
included  that  the  legislation  text  was  confusing  to  them  or  that  they  had  received 
instructions from an organisational or regional level to use a certain criteria. An additional 
analysis of the national legislation showed that in all cases all three options were indeed 
available to interviewees. 

Several interviewees chose to use a combination of two or even all three options. 

One  procurer  stated  that  they  were  using  different  methodologies  for  different  vehicle 
types:  monetisation  for  passenger  cars  and  minimum  standards  for  trucks  and  special 
vehicles  due  to  the  lack  of  environmental  data  for  these  vehicle  types.  In  this  case  the 
procurer was not aware of the option to apply weighting. 

Setting minimum technical standards (Option 1) 

Minimum technical standards (Option 1) were applied in most cases due to the perceived 
simplicity  of  the  option.  In  a  lot  of  cases  Euro  standards  were  used  as  the  minimum 

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standards  for  pollutant  emissions.  A  couple  of  procurers  had  only  set  this  minimum 
standard and were not aware that minimum standards for CO2 emissions and fuel/energy 
consumption had to be set as well. 

Applying award criteria (Option 2a) 

In the cases were weighting/award criteria (Option 2a) were applied the weighting factors 
for  environmental  criteria  range  between  6%  and  40%.  In  the  cases  where  the 
environmental  criteria  weighting  was  specifically  low  the  interviewees  were  asked  to 
elaborate  on  the  reasoning  behind  choosing  these  factors.  The  interviewees  stated  that 
they did acknowledge that the number was rather low and would have no or only a marginal 
effect  on  the  outcome  but  they  perceived  other  factors  to  be  more  important  in  the 
procurement decision – the flexibility in the Directive enables this to happen. Putting more 
weight on environmental factors in the future was not considered. 

One Hungarian procurer described a case where his organisation had applied weighting for 
environmental criteria but was reprehended by the tender authorities on the grounds that 
these  restrictions  were  against  the  concept  of  free  competition.  In  this  case  the 
procurement  authorities  decided  to  only  apply  the  newest  Euro  standard  as  a  minimum 
criteria for future tenders. A separate Hungarian stakeholder commenting that he did not 
feel that tender authorities understood the aims of the CVD and could thus not efficiently 
enforce the set rules. 

Monetisation of impacts (Option 2b) 

Most interviewees (8 out of 12) had not applied the monetisation option when assessing 
contracts. Many felt that it required some specialist knowledge to perform the required unit 
conversions etc. Some questioned the usefulness of the monetisation approach which they 
felt was ‘academic’, and the single values for external costs detached from the reality that 
air  pollution  issues  are  geographically  unevenly  spread  and  procurers  in  highly  polluted 
regions need to attach greater significance to emissions performance than procurers in less 
polluted regions. In the case of Hungary the data for the calculation of operational lifetime 
costs is missing from the national legislation text which makes it an obstacle for Hungarian 
procurers to apply it. 

Given  the  Directive’s  requirement  to  include  energy  consumption,  several  interviewees 
indicated  that  they  required  bidders  to  use  the  MJ/Litre  values  set  out  as  part  of  the 
monetisation  procedure  for  converting  fuel  consumption  into  energy  consumption.  One 
interviewee felt that this conversion made the process unnecessarily complex and that the 
analysis should be limited to CO2. 

One suggestion for improving the monetisation methodology was that the monetary value 
per unit of energy should not be based on diesel or petrol but on the respective fuels/energy 
types. 

Effects and Impacts of the Clean Vehicles Directive 

Few interviewees had introduced environmental criteria entirely due to the requirements 
of  the  CVD.  Several  were  using  environmental  criteria  before  the  introduction  of  the 
legislation (which was also the case in the survey with procurers), although in most cases 
the  tendering  procedures  were  modified  in  order  to  meet  specific  requirements  of  the 
Directive  in  terms  of  specifying  emissions,  energy  consumption  and  CO2  as  separate 
criteria. 

Interviewees often felt that setting environmental criteria was ‘good practice’ and in most 
cases didn’t constitute significant extra effort. They therefore often apply the same criteria 
to tenders below the EU threshold value. 

While  generally  having  a  positive  attitude  towards  the  Directive,  interviewees  felt  that 
CVD’s impacts on their procurement decisions had been fairly limited. In most cases the 
same vehicles as before were being procured. One reason for this was that environmental 
criteria  had  been  considered  prior  to  the  introduction  of  the  CVD  and  there  was  no 

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significant change to their procurement procedures. However, procurers that didn’t apply 
environmental criteria prior to the introduction of the CVD also did not feel that there was 
a significant change in vehicles being procured. Reasons mentioned were that minimum 
technical  standards  could  be  very  relaxed  or  that  award  criteria/weighting  factors  were 
low.  As  the  Directive  is  not  very  prescriptive  in  these  areas,  interviewees  felt  that  the 
directive was rather ineffective. 

When  asked  if  they  had  seen  a  shift  in  their  vehicle  fleets  towards  alternative  vehicle 
technologies due to the implementation of the CVD, many procurers stated that they had 
not. The reason given was the high purchase costs of these vehicles. For electric vehicles 
the  purchase  costs  were  stated  to  be  two  to  three  times  higher  than  for  conventional 
vehicles. This meant that in open calls where all fuel types were allowed the alternative 
technologies would always loose on price. In reality these open calls are very rare anyway 
as a lot of the tenders already specify the desired fuel type. The municipalities that had 
procured  alternative  vehicle  technologies  had  put  out  specific  tenders.  The  decision  to 
procure clean vehicles, however, was not driven by the CVD but by strategic decisions on 
the city level. One example given was the Clean Air for Warsaw initiative. 

A shift was only observed towards more energy efficient vehicles which also makes sense 
from a financial perspective as most of the procurers were taking running costs into account 
regardless of the methodology used for applying environmental criteria. 

Additional administrative effort 

When asked about the potential additional administrative effort per contract to apply the 
CVD, the answers were very varied. While a lot of the respondents didn’t think there was 
any  additional  time  spent  on  it,  the  times  given  for  the  cases  where  there  was  some 
additional  effort  ranged  between  10  minutes  and  4  hours  per  contract  on  average.  This 
number was highly dependent on the number of offers per contract. While in some cases 
(e.g. special vehicles) only one offer was received there were cases (e.g. passenger cars) 
where the number of offers was significantly higher. Some respondents therefore felt that 
there was a difference in administrative efforts for different types of vehicle. The most time 
consuming part mentioned was the communication with the potential contractors to receive 
the  relevant  data.  Especially  in  cases  were  the  tenders  were  written  in  an  unclear  way 
misconceptions could lead to significant delays in the tender process. One case in Hungary 
was reported where the process was delayed for 1.5 years as the issue had to be decided 
in court. 

One  suggestion  that  was  made  by  several  interviewees  to  significantly  reduce 
administrative effort was to centralise procurement processes. Due to small municipalities 
having to procure their road vehicles on their own, a lot of the employees writing the tender 
calls  and  evaluating  the  bids  have  to  cover  a  wide  range  of  goods  and  are  no  vehicle 
experts. This missing practice makes it very time consuming for them to apply the CVD. 

Use of Guidance and Commission Initiatives 

Most  interviewees  stated  that  they  had  only  used  the  national  legislation  or  the  Clean 
Vehicles Directive directly for guidance. More than half of the respondents had never heard 
of the Clean Vehicles Portal or the Clean Fleets Project. The interviewees that had accessed 
the  Clean  Vehicles  Portal  found  it  helpful  as  a  first  overview  on  the  performance 
characteristics  of  low-emission  cars  and  vans.  For  trucks,  interviewees  stated  that  they 
found  the  portal  of  little  use.  Some  of  the  interviewees  also  looked  at  the  Clean  Fleets 
Project.  A  German  interviewee  felt  that  this  was  of  limited  use  as  a  large  share  of  the 
information provided was not available in German. 

Suggested Improvements 

The  discussions  showed  that  a  lot  of  the  interviewees  had  trouble  with  interpreting  the 
legislation. Especially the monetisation methodology was often perceived as too complex. 
In only one case it was reported that a workshop on how to apply the CVD was attended. 
In  order  for  the  Directive  to  reach  its  full  potential  training  on  how  to  apply  it  was  felt 

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necessary. This is especially true for authorities that procure a wide range of goods and 
thus are not vehicle experts. 

Furthermore it was suggested that the Member States needed to give feedback on tenders 
to ensure that the legislation is applied correctly. 

When asked whether, if able to decide, they would repeal, amend or keep the Directive as 
it is,  most  interviewees  said  they  would  keep  it  as  is,  suggesting  that  any  difficulties  in 
implementation are not an issue of the Directive per-se, but general issues about lack of 
data  for  the  vehicle  category  to  be  procured,  or  issues  with  processes,  expertise  and 
knowledge gathering within the relevant procuring organisations. 

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14.  ANNEX 6 – MANUFACTURER INTERVIEWS AND QUESTIONNAIRES 

Stakeholder  consultation  of  manufacturers  took  place  through  distribution  of  a  written 
questionnaire, as well as telephone interviews with a number of manufacturers. ACEA, the 
European Automobile Manufacturer’s Association, provided input on behalf of its members 
by answering our general survey. 

Although 15 manufacturers were contacted, only four were able to participate either in a 
telephone interview or by sending a completed questionnaire within two months of being 
contacted.  Two  manufacturers  declined  to  participate.  Full  details  of  the  total  response 
received are given in Table 14-1. 

Table 14-1: Response rates for the procurers' survey 

Number 
contacted 

Number 
of 
interviews 
completed 

Declined 

Written 
contribution 
only 

No 
response 

Indicated interest, 
did not send any 
response in time 

15 

3 

2 

1 

5 

4 

Although  it  was  initially  conceived  that  there  would  be  a  quantitative  analysis  of 
questionnaire  responses,  owing  to  the  low  number  of  responses  and  the  fact  that  most 
manufacturers preferred to provide their input in the form  of a telephone interview, the 
analysis in the remainder of this section consists of a combined summary of the information 
gained from telephone interviews and the two written contributions received. The analysis 
is arranged under topic headings. 

Data on sales/deliveries to contracting authorities 

Manufacturers were asked whether they had specific details of the numbers and types of 
vehicles sold to contracting authorities, in order for us to determine whether we might be 
able to use this information to estimate the extent of public procurement of vehicles in the 
EU,  or  measure  the  effects  of  the  Directive  in  terms  of  the  energy  and  environmental 
performance  of  vehicles  procured  by  contracting  authorities.  The  manufacturers  mostly 
stated that this information is not available, for various reasons. 

Neither of the light duty vehicle manufacturers were able to provide us with data on the 
number of publically procured vehicles. One of them stated that this was because calls for 
tenders are sometimes not published by the public bodies who ultimately use the vehicles, 
but  instead,  third  party  organisations  organise  procurement  on  their  behalf  on  a  large 
scale. In other cases, vehicles are sometimes sold to dealerships rather than end users. 

The  heavy  duty  vehicle  manufacturers  were  only  able  to  share  a  limited  amount  of 
information with us. One of these manufacturers estimated that the share of heavy duty 
vehicles sold to the public sector in Germany was around 10%, and was able to provide 
numbers  of  special  purpose  vehicles  procured  in  Germany  in  total  and  by  municipal 
governments  in  Germany.  Neither  of  the  contacts  at  the  two  heavy  duty  manufacturers 
was able to provide any figures on buses. 

Impacts on types of vehicles procured by contracting authorities 

Notwithstanding the lack of precise quantitative evidence available to them, manufacturers 
were  asked  whether  they  thought  the  Directive  had  affected  contracting  authorities’ 
decisions with respect to the types of vehicles bought. The manufacturers indicated that 
they  thought  there  had  been  very  little  effect  on  choices  of  fuels  and  powertrains,  fuel 
consumption, or prevailing EURO standards. One of light duty vehicle manufacturers stated 
two reasons for this: the Directive’s rules for taking energy and environmental impacts into 
account  are  too  loose,  and  the  legislation  is  poorly  understood.  The  heavy  duty  vehicle 
manufacturers also stated that the lack of standardised community test procedures meant 
that the Directive could not have had an effect on fuel consumption or CO2 performance of 
heavy duty vehicles.  

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More than one of the manufacturers also drew attention to the fact that other factors have 
affected  the  choices  of  contracting  authorities  over  time  –  the  adoption  of  new  EURO 
standards, the light duty vehicle CO2 Regulations, and “market trends”. One of the heavy 
duty  vehicle  manufacturers  was  sceptical  that  the  Directive  was  responsible  for  any 
significant  effort  by  contracting  authorities  to  purchase  vehicles  with  higher  EURO 
standards than were strictly obligatory at the time. 

Effects  on  manufacturing  scales  and  significance  of  CVD  in  driving  investment 
decisions 

The light duty vehicle manufacturers indicated that legislation other than CVD was one of 
the main forces driving strategic investment decisions. One stated that the Directive had 
not  resulted  in  any  noticeable  technological  shift  and  the  other  stated  that  it  had  not 
impacted investment decisions at all. 

The  heavy  duty  vehicle  manufacturers  also  stated  that  the  Directive  had  not  had  any 
material effect on the uptake of new technology. One of the  reasons stated for this was 
that  the  Directive  leaves  contracting  authorities  with  the  option  of  specifying  lax 
environmental standards that allow “anything” to be bought. 

Manufacturers also indicated that they thought fuel prices and deployment of  alternative 
fuel infrastructure had a much more significant effect on their strategic decision-making 
(in the case of alternative fuel infrastructure, one manufacturer indicated that they thought 
deployment of such infrastructure was a powerful force in theory, but that in practice, it 
was  hardly  being  done).  One  of  the  light  duty  vehicle  manufacturers  stated  that  fleet 
owners  already  place  importance  on  total  cost  of  ownership  and  this  also  affected  the 
manufacturers’ strategy. 

Costs and unintended effects resulting from the Directive 

The light duty vehicle manufacturers indicated that the Directive had not had any effect on 
their costs. One said that the administrative work of supplying information about vehicles’ 
energy  and  environmental  performance  was  something  manufacturers  were  already 
required to do before the Directive. 

The two heavy duty vehicle manufacturers suggested that the Directive had created some 
(unforeseen and unintended) costs for them. 

One of the heavy duty vehicle manufacturers stated that the Directive had contributed to 
contracting authorities expressing interest in the idea of hybrid electric trucks, and asking 
manufacturers to offer such vehicles. However, this manufacturer stated that the additional 
interest had yet to translate into any additional sales, as hybrid drivetrains roughly double 
the cost of the vehicle chassis and contracting authorities are not willing to pay such high 
premia  for  them.  This  manufacturer  suggested  that  the  Directive  may  have  been 
responsible  for  manufacturers  investing  in  new  production  lines  in  order  for  them  to  be 
able to offer vehicles with alternative powertrains. But given the low numbers of vehicles 
purchased which use these alternative powertrains, the Directive had done nothing to drive 
down per-vehicle costs of manufacture. 

The other heavy duty vehicle manufacturer stated that in Germany, the introduction of the 
Directive  had  led  to  confusion  among  contracting  authorities,  causing  some  of  them  to 
delay or postpone their purchases, and also led to an incident in which the manufacturer 
had to make a one-off investment of €20,000 in order to participate in a bid to supply a 
municipal government. Both of these issues were ultimately caused by the fact that there 
is no standardised community test for fuel consumption of heavy duty vehicles, and some 
contracting authorities in Germany are confused as to how to react, given that the Directive 
requires  them  to  take  the  energy  efficiency  of  vehicles  into  account  in  procurement 
decisions.  Some  contracting  authorities  have  reacted  simply  by  deciding  that  it  is 
impracticable  to  compare  heavy  duty  vehicles  for  fuel  consumption  as  part  of  the 
procurement process, and procured on the basis of price alone. Others, though, have felt 
compelled to define their own test cycles and ask manufacturers to subject their vehicles 

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to these cycles in order to qualify for biding. In particular, government of the city of Berlin 
orchestrated its own test of waste disposal trucks’ fuel consumption, and the manufacturer 
claimed that it cost €20,000 for them to send 20 of their vehicles to be tested on this cycle. 
After  other  German  cities  invited  the  manufacturer  to  participate  in  other,  differently 
defined  cycles,  the  manufacturer  decided  it  was  unsustainable  for  it  to  continue 
participating  in  these  tests,  and  stopped.  The  manufacturer  now  writes  to  contracting 
authorities who ask for information on fuel consumption per kilometre letting them know 
that  there  is  no  standardised  way  of  measuring  this  for  heavy  duty  vehicles.  Allegedly, 
other manufacturers choose instead to respond to these requests with their own figures on 
fuel consumption. 

Effectiveness of the Directive versus other policy measures 

Manufacturers generally portrayed the Directive as being less effective at reducing CO2 and 
pollutant  emissions  and  increasing  the  market  share  of  clean  vehicles  than  many  other 
policy measures. 

“Price-based measures (e.g. taxation or tax credits/direct subsidies)” was often singled out 
as a particularly effective measure. More than one manufacturer suggested it had the most 
influence on achieving the relevant objectives. 

Manufacturers generally believed that R&D support (in the form of grants or tax credits for 
research by public or private institutions) was more effective, as is (financial) support to 
commercialisation, and deployment of alternative fuel infrastructure. 

“Performance  based  regulations  and  standards  (e.g.  improvement  in  environmental 
performance of vehicles)” were generally felt to be at least as effective as the Directive, if 
not more. 

There was no consensus as to whether demonstration and verification efforts were more 
or  less  effective  than  the  Directive.  There  was  also  no  consensus  on  the  relative 
effectiveness of networks and partnerships. 

“Information based measures” such as labelling were generally felt to be as effective as 
the Directive, with one manufacturer stating that they were less effective. 

ACEA’s comment was that “The market uptake of energy efficient vehicles is depending on 
a number of factors and depend on concrete situation on a given market. For some markets 
in  the  EU  certain  measures  have  more  impact  that  the  others,  there  is  no  one-fit-all 
solution.  As  the  key  decision  of  the  consumers  is  price,  one  can  derive  that  taxation  is 
probably the most influencing one in general.” 

Effects of repeal of the Directive, and recommendations on reform 

All the manufacturers directly commenting on the possible effects of repealing the Directive 
stated that the effects would be “neutral” or “of no major importance” to them. The reason 
given for this was that the Directive currently has no measurable effect on them that they 
are aware of. 

However,  as  a  caveat  to  this,  the  manufacturer  claiming  the  Directive  had  confused 
procurers  of  heavy  duty  vehicles  in  Germany  suggested  that  the  Directive  should  be 
suspended  until  there  was  a  standard  for  measuring  fuel  consumption  of  these  vehicles 
has been defined and rolled out. 

ACEA were opposed to extending the scope of the legislation to cover large private fleets, 
and  stated  that  the  owners  of  these  fleets  were  already  sensitive  to  energy  efficiency 
concerns as part of their assessments of total cost of ownership. 

One  of  the  light  duty  vehicle  manufacturers  recommended  that  a  certain  set  of 
considerations be taken into account in any future definition of the term “clean vehicle”. 
These  included  that  the  definition  should  be  simple  and  readable  in  order  to  gain 
acceptance, and also “rely upon existing and available criteria (Euro regulation, Euro CO2 
target for vehicle).” 

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15.  ANNEX 7 – CONTRACTOR ONLINE SURVEY 

A survey was also developed aimed at capturing data and information from the contractors 
who have been awarded contracts for providing (selling or leasing) road transport vehicles 
(including manufacturers and other suppliers). The link to the online survey was sent out 
to all 1,713 contractor contacts identified (unique email addresses identified via the TED 
database),  and  was  available  online  for  a  period  of  two-weeks  in  May  2015.The  survey 
received  65  completed  responses.  An  overview  of  responses  to  the  contractor  survey  is 
provided below. 

BACKGROUND INFORMATION 

Which Member State is your organisation based in? 

The  table  below  (Table  15-1)  shows  the  number  of  responses  received  for  the  online 
contractors’ survey from different Member States. 

A total of 66 responses were received for the online contractors’ survey. Most respondents 
belonged to organisations based in either the United Kingdom (30%) or Germany (29%). 
The remainder of the respondents were distributed between other Member States.  

Table 15-1: Number of respondents for the contractors’ survey by Member State 

Member state 

No. of responses 

Percentage 

Belgium 

Bulgaria 

Czech Republic 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Malta 

Netherlands 

Other 

Poland 

Romania 

Sweden 

United Kingdom 

Grand Total 

2 

1 

1 

19 

1 

1 

2 

1 

2 

2 

2 

1 

2 

2 

5 

2 

20 

66 

3% 

2% 

2% 

29% 

2% 

2% 

3% 

2% 

3% 

3% 

3% 

2% 

3% 

3% 

8% 

3% 

30% 

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

Do you manufacture vehicles? 

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To get an overview of the type of organisations the respondents were representing (and 
to  target  later  questions),  we  asked  respondents  if  they  manufactured,  sold  or  leased 
vehicles. 23 (35%) of the 66 respondents stated that they manufactured vehicles.  

Figure 15-1: Do you manufacture vehicles?  

70.00%

60.00%

50.00%

40.00%

30.00%

20.00%

10.00%

0.00%

No

Yes

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

Do you sell or lease road transport vehicles to public contracting authorities or to 
operators providing government-subsidised public transport services?   

The  next  set  of  questions  were  specifically  targeted  towards  respondents  who  sold  or 
leased vehicles. 

Forty-six  respondents  sold  or  leased  vehicles.  11  of  them  sell  to  ‘public  contracting 
authorities’,  9  of  them  lease  to  ‘public  contracting  authorities’,    19  sell  to  ‘operators 
providing government-subsidised public transport services’, 8 lease to ‘operators providing 
government-subsidised public transport services’ and 17 of them stated they did ‘none’ of 
the above.  

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Figure  15-2:  Respondents  who  sell  or  lease  road  transport  vehicles  to  ‘public 
contracting authorities’ or to ‘operators providing Government-subsidised public 
transport services’ 

20

15

10

5

0

Yes- we sell to contracting authorities

Yes- we sell to operators providing government-subsidised public transport services

Yes- we lease to contracting authorities

Yes- we lease to operators providing government-subsidised public transport services

No- None of the above

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

Approximately how many vehicles do you sell or lease in total per year? 

To get an overview of the size of the respondents’ business, we asked them the number of 
vehicles  they  typically  sell/lease  per  annum.  Twenty  four  contractors  responded  to  this 
question, out of which 14 respondents leased vehicles and 23 of them sold vehicles (Note: 
some respondents did both).  

Of the respondents who sold vehicles, most respondents (10) stated 100-1,000 vehicles 
per annum, whereas 7 of the respondents sold ‘0-10’, 2 sold ‘10-100’, 2 sold ‘1,000-10,000’ 
and 2 sold ‘more than 10,000’ vehicles per annum. 

Of the respondents who leased vehicles, most respondents (6) stated that they leased ‘0-
10’ vehicles per annum, whereas 4 leased ‘10-100’ , 3 leased ‘100-1,000’, 1 leased ‘more 
than 10,000’, and 0 leased ‘1,000-10,000’ vehicles per annum.   

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Figure  15-3:  Number  of  vehicles sold  or  leased  in  total  by  the  respondents  per 
year (24 out of 46) 

12

10

8

6

4

2

0

Sales per annum

New leases per annum

0-10

10-100

100-1,000

1,000-10,000

10,000 10000+

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

Which of the following types of vehicles do you currently sell/lease (select all that 
apply)? 

To get an overview of the distribution of vehicle types being sold/leased by contractors, 
respondents were asked the details of the vehicle segments and fuel types sold/leased by 
them. The following table (Table 15-2) provides an overview of the vehicle segments and 
fuel types sold/leased by the respondents. ‘Passenger car’ segment is currently the most 
sold/leased  and  type  of  fuel  preferred  across  different  segments  is  ‘diesel’.  No  fuel  cell 
vehicle has been sold/leased by the contractors surveyed.  

Table 15-2: Details of type of vehicle segment and fuel type sold/leased by the 
respondents (46 out of 46) 

Types of Vehicles 

Passenger Cars 
Buses or Coaches 
Light (<3.5t) Commercial Vehicles 
Heavy  goods  vehicles  (trucks 
other 
collection 
vehicles) 
Special  service  vehicles  -  Waste 
collection trucks and services 

than  waste 

Special 
service 
emergency 
vehicles  –  e.g.  ambulances,  fire 
engines etc. 
Other 

Petrol  Diesel  Electric  Hybrid  Fuel 
cell 
0 
0 
0 
0 

4 
0 
0 
1 

6 
4 
9 
7 

6 
0 
4 
0 

5 
0 
2 
0 

0 

2 

0 

9 

6 

3 

0 

0 

1 

1 

0 

0 

0 

0 

0 

Other 

0 
0 
0 
0 

0 

0 

1 

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

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Approximately how many vehicles do you manufacture in total per year? 

The next two questions were specifically targeted towards respondents who manufactured 
vehicles. 

To get an overview of the size of the respondents’ business, we asked them the number of 
vehicles  they  typically  manufactured  per  annum  twenty  three  contractors  responded  to 
this  question,  out  of  which  9  manufactured  ‘100-1,000’  vehicles  per  annum,  1  of  them 
manufactured ‘0-10’ vehicles per annum, 6 manufactured ‘10-100’ vehicles per annum, 3 
manufactured ‘1,000-10,000’ vehicles per annum and 2 manufactured ‘more than 10,000’ 
vehicles per annum. 

Figure  15-4:  Number  of  vehicles  manufactured  by  the  respondents  per  annum 
(21 out of 23) 

10

9

8

7

6

5

4

3

2

1

0

0-10

10-100

100-1,000

1,000-10,000

10,000+

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

Which of the following types of vehicles do you currently manufacture? 

To get an overview of the distribution of vehicle types being manufactured by contractors, 
respondents were asked the details of the vehicle segments and fuel types manufactured 
by them. The following table (Table 15-3) provides an overview of the vehicle segments 
and fuel types manufactured by the respondents. 

The most commonly manufactured vehicle segment is ‘special service vehicle’ segment and 
the most common fuel type across different segments is ‘diesel’.  

Table 15-3: Details of type of fuel and vehicle segment currently manufactured 
by the contractors 

Types of Vehicles 

Petrol  Diesel  Electric  Hybrid  Fuel cell 

Other 

Passenger Cars 

1 

2 

2 

1 

0 

0 

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Buses or Coaches 

Light  (<3.5t)  Commercial 
Vehicles 

vehicles 
goods 
Heavy 
(trucks  other  than  waste 
collection vehicles) 

Special  service  vehicles  - 
Waste collection trucks and 
services 

Special  emergency  service 
vehicles – e.g. ambulances, 
fire engines etc. 

Other 

0 

1 

0 

6 

5 

6 

0 

13 

1 

0 

4 

3 

1 

0 

0 

1 

0 

0 

3 

0 

2 

5 

0 

0 

1 

0 

0 

1 

0 

0 

1 

0 

0 

0 

0 

0 

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

IMPACT OF CLEAN VEHICLES DIRECTIVE 

In your opinion, have the requirements of the CVD had an impact on the types of 
vehicles  (e.g.  model,  fuel  type  etc.)  that  are  procured  publically  (e.g. 
governments/public bodies etc.)? 

Both manufactures and contractors who sell/lease vehicles were asked their opinion of the 
impact of CVD on the types of vehicles that are procured publically.  

Impact on fuel type- Most (15) believe that there was a small effect on the type of fuel 
of the vehicle that was procured by public/Government bodies, 10 believe there was a little 
or no effect, and 6 believed that CVD had a large effect. The rest (5) had no opinion on 
that matter.  

Impact on vehicle model- Most respondents (14) believe that there was a small effect 
on the model of vehicle that was procured by public/Government bodies, 12 believe there 
was a little or no effect, and 6 believe there was a large impact. The rest (4) had no opinion 
on that matter.  

Impact  on  Euro  emission  standards-  Most  respondents  (17)  believe  that  CVD  had  a 
large effect on Euro emission standards of vehicle that was procured by public/Government 
bodies. 5 believe that there was a small effect while 8 believe there was a little or no effect. 
The rest had no opinion on that matter.  

Other factors- 2 of the respondents believe that CVD had a large effect on other factors 
of  vehicle  that  was  procured  by  public/Government  bodies.  4  believed  that  there  was  a 
small effect while 5 believed there was a little or no effect. The rest (25) had no opinion 
on that matter. 

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Figure 15-5: Impact of CVD on the types of vehicles (e.g. model, fuel type etc.) 
that are publically procured 

Other

Euro standards (if
applicable)

Vehicle models

Vehicle fuel types

Don’t know or NA

Large effect (noticeable
change in purchasing
choices)

Small effect

Little or no effect (tend to
be purchasing
similar/same vehicles)

0.0

20.0

40.0

60.0

80.0

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

In your opinion, how significant has implementation of the Clean Vehicles Directive 
been on your strategic/investment decisions in clean and energy efficient vehicles 
in these markets? 

In order to understand the contractors’ views on the impact of Clean Vehicles Directive, 
both manufactures and contractors who sell/lease vehicles were asked their opinion of how 
significant the impact of CVD has been on their strategic/investment decisions in clean and 
energy efficient vehicles in different markets.  

Passenger cars: Most of the survey respondents (6) believe that implementation of CVD 
has  had  little  or  no  impact  on  their  strategic/investment  decisions  in  clean  and  energy 
efficient  vehicles  in  the  passenger  cars  market  whereas  4  of  them  believe  it  has  had  a 
moderate to high level of influence. The rest have no opinion on this matter.  

Light  (<3.5t)  commercial  vehicles:  Most  of  the  survey  respondents  (5)  believe  that 
implementation  of  CVD  has  had  a  moderate  to  high  level  of  influence  on  their 
strategic/investment decisions in clean and energy efficient vehicles in the light commercial 
vehicles market whereas 4 of them believe it has had little or no impact. The rest have no 
opinion on this matter.  

Buses and Coaches: Most of the survey respondents (8) believe that implementation of 
CVD has had a moderate to high level of influence on their strategic/investment decisions 
in  clean  and  energy  efficient  vehicles  in  the  bus  and  coach  market  whereas  6  of  them 
believe it has had little or no impact. The rest have no opinion on this matter.  

Heavy  goods  vehicles  (trucks  other  than  waste  collection  vehicles):  Most  of  the 
survey respondents (7) believe that implementation of CVD has had little or no impact on 

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their  strategic/investment  decisions  in  clean  and  energy  efficient  vehicles  in  the  heavy 
goods vehicles market whereas 5 of them believe it has had a moderate to high level of 
influence. The rest have no opinion on this matter.  

Special service vehicles - Waste collection trucks and services: Most of the survey 
respondents (12) believe that implementation of CVD has had little or no impact on their 
strategic/investment decisions in clean and energy efficient vehicles in the special service 
vehicles market whereas 9 of the survey respondents believe that implementation of CVD 
has had a moderate to high level of influence. The rest have no opinion on this matter.  

Special emergency service vehicles – e.g. ambulances, fire engines etc.: Most of 
the survey respondents (8) believe that implementation of CVD has had little or no impact 
on their strategic/investment decisions in clean and energy efficient vehicles in the special 
emergency  service  vehicles  market  whereas  4  of  the  survey  respondents  believe  that 
implementation of CVD has had a moderate to high level of influence. The rest have no 
opinion on this matter.  

Figure  15-6:  Significance  of 
implementation  of  CVD  on  respondents’ 
strategic/investment decisions in clean and energy efficient vehicles in different 
markets 

18

16

14

12

10

8

6

4

2

0

Passenger cars

Buses or coaches

Light (<3.5t)
commercial
vehicles

Heavy goods
vehicles (trucks
other than waste
collection
vehicles)

Special service
vehicles - Waste
collection trucks
and services

Special 
emergency 
service vehicles –
e.g. ambulances, 
fire engines etc.

Not at all

A little

A moderate amount

A great deal

Don't know or NA

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

In  your  opinion,  has  the  Clean  Vehicles  Directive  had  an  impact  on  your 
sales/deliveries of clean vehicles? 

In order to understand the contractors’ view on the impact of clean vehicles directive, both 
manufactures  and  contractors  who  sell/lease  vehicles  were  asked  their  opinion  of  the 
impact of CVD on their sales/deliveries of clean vehicles. 

Passenger cars:  Most of the survey respondents (9) believe that implementation of CVD 
has had little or no of influence on their sales/deliveries of clean vehicles in the passenger 

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cars market whereas 2 of them believe it has had a moderate to high level of influence. 
The rest (12) have no opinion on this matter.  

Buses and Coaches: Most of the survey respondents (8) believe that implementation of 
CVD has had little or no of influence on their sales/deliveries of clean vehicles in the bus 
and  coach  market  whereas  2  of  them  believe  it  has  had  a  moderate  to  high  level  of 
influence. The rest (15) have no opinion on this matter.    

Light (<3.5t) commercial vehicles: Most of the survey respondents (11) believe that 
implementation of CVD has had little or no of influence on their sales/deliveries of clean 
vehicles in the Light (<3.5t) commercial vehicles market whereas 4 of them believe it has 
had a moderate to high level of influence. The rest (9) have no opinion on this matter.   

Heavy  goods  vehicles  (trucks  other  than  waste  collection  vehicles):  Most  of  the 
survey respondents (9) believe that implementation of CVD has had little or no of influence 
on their sales/deliveries of clean vehicles in the heavy goods vehicles market whereas 3 of 
them believe it has had a moderate to high level of influence. The rest (13) have no opinion 
on this matter.   

Special service vehicles - Waste collection trucks and services: Most of the survey 
respondents (15) believe that implementation of CVD has had little or no of influence on 
their sales/deliveries of clean vehicles in the special service vehicles market whereas 9 of 
them believe it has had a moderate to high level of influence. The rest (10) have no opinion 
on this matter.  

Special emergency service vehicles  – e.g. ambulances, fire engines etc.: Most of 
the  survey  respondents  (9)  believe  that  implementation  of  CVD  has  had  little  or  no  of 
influence  on  their  sales/deliveries  of  clean  vehicles  in  the  special  emergency  service 
vehicles market whereas 2 of them believe it has had a moderate to high level of influence. 
The rest (12) have no opinion on this matter 

Figure 15-7: Impact of CVD on respondents’ sales/deliveries of clean vehicles 

16

14

12

10

8

6

4

2

0

Passenger cars

Buses or coaches

Light (<3.5t)
commercial
vehicles

Heavy goods
vehicles (trucks
other than waste
collection
vehicles)

Special service
vehicles - Waste
collection trucks
and services

Special 
emergency 
service vehicles –
e.g. ambulances, 
fire engines etc.

Not at all

A little

A moderate amount

A great deal

Don't know or NA

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

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Have  you  incurred  any  costs  (€)  as  a  result  of  the  implementation  of  the  Clean 
Vehicles  Directive  (e.g.  through  providing  information  on  your  vehicles’  total 
lifetime energy consumption, CO2 emissions and pollutant emissions etc.)? 

Most  (16)  of  the  respondents  did  not  incur  additional  costs  related  to  manufacturing 
whereas  11  of  them  incurred  these  costs.  The  rest  (9)  did  not  have  an  opinion  on  this 
matter.  

Most (15) of the respondents did not incur additional costs related to obtaining information, 
including for example costs of test procedures on non-type-approved vehicles to establish 
their emissions impacts whereas 12 of them incurred these costs. The rest (9) did not have 
an opinion on this matter 

Most  (16)  of  the  respondents  did  not  incur  additional  costs  related  to  administration  or 
compliance whereas 10 of them incurred these costs. The rest (10) did not have an opinion 
on this matter.  

Figure 15-8: Costs incurred due to the implementation of CVD (38 out of 66) 

18

16

14

12

10

8

6

4

2

0

Additional costs related to
manufacturing

Additional costs related to obtaining
information, including for example
costs of test procedures on non-
type-approved vehicles to establish
their emissions impacts?

Yes

No

NA

Other costs related to
administration or compliance?
(please specify)

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

In your opinion, does the monetisation method and associated parameters set out 
in  the  Directive  provide  a  good  evaluation  of  the  energy  and  environmental 
impacts? 

Out of the 38 respondents, Most (18) of them did not have an opinion on the monetisation 
method  and  associated  parameters.  13  of  them  believed  that  monetisation  method  and 
associated parameters  set out in the Directive  was not a good  evaluation of the  energy 
and environmental impacts, whereas 7 respondents believed that it was a good evaluation 
method.  

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Figure 15-9: Opinion on the monetisation method and associated parameters set 
out in the Directive as a good evaluation of the energy and environmental impacts 
(38 out of 66) 

20

18

16

14

12

10

8

6

4

2

0

Don't know

No

Yes

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

ALTERNATIVE APPROACHES TO ACHIEVING THE AIMS OF THE CVD AND 
CHANGES TO THE DIRECTIVE 

In  your  opinion,  how  effective  are  each  of  the 
following  alternative 
policies/measures in achieving the Directive’s aim to ‘increase the market share of 
clean vehicles’ compared to the CVD? 

In  order to understand the contractors’  view on the  alternative approaches to achieving 
the aims of the CVD and changes to the Directive, the respondents were asked their opinion 
of the effectiveness of the following alternative policies/measures to ‘increase the market 
share of clean vehicles’ compared to the CVD. 

R&D support (e.g. grants/tax credits for research by public/private institutions): 
Most of the respondents (15) were of the opinion that R&D support is more effective than 
CVD to ‘increase the market share of clean vehicles’. 7 believed that it has about the same 
effect whereas 1 believed that it was less effective. The rest (8) had no opinion on that 
matter.  

Demonstration and verification (e.g. supporting testing of first time/early stage 
technologies): Most of the respondents (12) were of the opinion that demonstration and 
verification measures are more effective than CVD to ‘increase the market share of clean 
vehicles’. 5 believed that it has about the same effect whereas 4 believed that it was less 
effective. The rest (10) had no opinion on that matter.  

regulations  and  standards  (e.g. 

Performance  based 
in 
environmental  performance  of  vehicles):  Most  of  the  respondents  (14)  were  of  the 
opinion that performance based regulations and standards are more effective than CVD to 
‘increase the market share of clean vehicles’. 9 believed that it has about the same effect 
whereas 2 believed that it was less effective. The rest (6) had no opinion on that matter.  

improvement 

Technology-based regulations and standards (e.g. specific characteristics, such 
as  size,  shape,  design  etc.):  Most  of  the  respondents  (10)  were  of  the  opinion  that 
technology-based regulations and standards are  less effective than CVD to ‘increase the 
market share of clean  vehicles’.  8 believed that it has about the same  effect  whereas  7 
believed that it was more effective. The rest (6) had no opinion on that matter.  

Price-based measures (e.g. taxation or tax credits/direct subsidies): Most of the 
respondents (18) were of the opinion that price-based measures are more effective than 

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CVD to ‘increase the market share of clean vehicles’. 5 believed that it has about the same 
effect whereas 1 believed that it was less effective. The rest (7) had no opinion on that 
matter.  

Support to commercialisation (e.g. financial support): Most of the respondents (14) 
were  of  the  opinion  that  support  to  commercialisation  is  more  effective  than  CVD  to 
‘increase the market share of clean vehicles’. 8 believed that it has about the same effect 
whereas 1 believed that it was less effective. The rest (8) had no opinion on that matter.  

Information-based  measures  (e.g.  vehicle  labelling,  information  awareness 
raising etc.):  Most of  the respondents (10) were of the  opinion that information-based 
measures are less effective than CVD to ‘increase the market share of clean vehicles’. 10 
believed that it has about the same effect whereas 3 believed that it was more effective. 
The rest (8) had no opinion on that matter.  

Infrastructure  provision  (e.g.  refuelling  infrastructure):  Most  of  the  respondents 
(10)  were  of  the  opinion  that  infrastructure  provisions  are  more  effective  than  CVD  to 
‘increase the market share of clean vehicles’. 10 believed that it has about the same effect 
whereas 3 believed that it was less effective. The rest (8) had no opinion on that matter.  

Networks  and  partnerships  (e.g.  facilitating  industry  coordination):  Most  of  the 
respondents (12) were of the opinion that networks and partnerships has about the same 
effect as CVD to ‘increase the market share of clean vehicles’. 4 believed that it was more 
effective whereas 6 believed that it was less effective. The rest (9) had no opinion on that 
matter.  

Figure 15-10: Effectiveness of the alternative policies/measures in achieving the 
Directive’s aim to ‘increase the market share of clean vehicles’ compared to the 
CVD (32 out of 66) 

20
18
16
14
12
10
8
6
4
2
0

More effective

About the same

Less effective

Don't know

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

In  your  opinion,  how  effective  are  each  of  the 
following  alternative 
policies/measures in achieving the Directive’s aim to ‘reduce road transport’s CO2 
and pollutant emissions’ compared to the CVD? 

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In order to understand the contractors’ view on the alternative approaches to achieving the aims of 
the CVD and changes to the Directive, the respondents were asked their opinion of the effectiveness 
of the each of the following alternative policies/measures in achieving the Directive’s aim to ‘reduce 
road transport’s CO2 and pollutant emissions’ compared to the CVD.  

R&D support (e.g. grants/tax credits for research by public/private institutions): 
Most of the respondents (14) were of the opinion that R&D support is more effective than 
CVD to ‘reduce road transport’s CO2 and pollutant emissions’. 6 believed that it has about 
the same effect whereas 2 believed that it was less effective. The rest (9) had no opinion 
on that matter.  

Demonstration and verification (e.g. supporting testing of first time/early stage 
technologies): Most of the respondents (13) were of the opinion that demonstration and 
verification  measures  are  more  effective  than  CVD  to  reduce  road  transport’s  CO2  and 
pollutant emissions’. 7 believed that it has about the same effect whereas 3 believed that 
it was less effective. The rest (8) had no opinion on that matter.  

regulations  and  standards  (e.g. 

Performance  based 
in 
environmental  performance  of  vehicles):  Most  of  the  respondents  (13)  were  of  the 
opinion that performance based regulations and standards are more effective than CVD to 
‘reduce  road  transport’s  CO2  and  pollutant  emissions’.  10  believed  that  it  has  about  the 
same effect whereas 2 believed that it was less effective. The rest (6) had no opinion on 
that matter.  

improvement 

Technology-based regulations and standards (e.g. specific characteristics, such 
as  size,  shape,  design  etc.):  Most  of  the  respondents  (12)  were  of  the  opinion  that 
Technology-based regulations and standards has about the same effect as CVD to ‘reduce 
road transport’s CO2 and pollutant emissions’. 8 believed that it was more effective whereas 
4 believed that it was less effective. The rest (7) had no opinion on that matter.  

Price-based measures (e.g. taxation or tax credits/direct subsidies): Most of the 
respondents (16) were of the opinion that price-based measures are more effective than 
CVD to ‘reduce road transport’s CO2 and pollutant emissions. 7 believed that it has about 
the same effect whereas 1 believed that it was less effective. The rest (7) had no opinion 
on that matter.  

Support to commercialisation (e.g. financial support): Most of the respondents (12) 
were of the opinion that support to commercialisation is more effective than CVD to ‘reduce 
road transport’s CO2 and pollutant emissions. 9 believed that it has about the same effect 
whereas 1 believed that it was less effective. The rest (9) had no opinion on that matter.  

Information-based  measures  (e.g.  vehicle  labelling,  information  awareness 
raising etc.): Most of the respondents (11) were of the opinion that Information-based 
measures has about the same effect as CVD to ‘reduce road transport’s CO2 and pollutant 
emissions’.  4  believed  that  it  was  more  effective  whereas  8  believed  that  it  was  less 
effective. The rest (8) had no opinion on that matter.  

Infrastructure  provision  (e.g.  refuelling  infrastructure):  Most  of  the  respondents 
(11) were of the opinion that Infrastructure provision has about the same effect as CVD to 
‘reduce  road  transport’s  CO2  and  pollutant  emissions’.  10  believed  that  it  was  more 
effective whereas 2 believed that it was less effective. The rest (8) had no opinion on that 
matter.  

Networks  and  partnerships  (e.g.  facilitating  industry  coordination):  Most  of  the 
respondents (14) were of the opinion that networks and partnerships has about the same 
effect as CVD to ‘reduce road transport’s CO2 and pollutant emissions’. 3 believed that it 
was  more  effective  whereas  4  believed  that  it  was  less  effective.  The  rest  (10)  had  no 
opinion on that matter.  

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Figure 15-11: Effectiveness of the alternative policies/measures in achieving 
the Directive’s aim to ‘reduce road transport’s CO2 and pollutant emissions’ 
compared to the CVD 

18
16
14
12
10
8
6
4
2
0

More effective

About the same

Less effective

Don't know

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

In your opinion, how significant has the influence of each of the following factors 
been  in  determining  your  strategic  decisions  since  2012  on  investment  in  clean 
and/or energy efficient vehicles? 

In  order to understand the contractors’  view on the alternative approaches to achieving 
the  aims  of  the  CVD  and  changes  to  the  Directive,  ,  the  respondents  were  asked  their 
opinion  of  how  significant  has  the  influence  of  each  of  the  following  factors  been  in 
determining  their  strategic  decisions  since  2012  on  investment  in  clean  and/or  energy 
efficient vehicles. 

Requirements  for  contracting  authorities  to  take  energy  and  environmental 
criteria  into  account  (CVD):  Most  of  the  respondents  (13)  were  of  the  opinion  that 
Requirements  for  contracting  authorities  to  take  energy  and  environmental  criteria  into 
account  (CVD)  had  a  moderate  or  great  deal  of  influence  in  determining  their  strategic 
decisions  since  2012  on  investment  in  clean  and/or  energy  efficient  vehicles  while  12 
believed that it had little or no influence. The rest (6) had no opinion on that matter.   

EU Car and Van CO2 Regulations: Most of the respondents (10) were of the opinion that 
EU Car and Van CO2 regulations had a moderate or great deal of influence in determining 
their strategic decisions since 2012 on investment in clean and/or energy efficient vehicles 
while  8  believed  that  it  had  little  or  no  influence.  The  rest  (13)  had  no  opinion  on  that 
matter.   

EURO Emission Standards: Most of the respondents (21) were of the opinion that EURO 
emission standards had a moderate or great deal of influence in determining their strategic 
decisions  since  2012  on  investment  in  clean  and/or  energy  efficient  vehicles  while  5 
believed that it had little or no influence. The rest (5) had no opinion on that matter.   

Vehicle taxation  and  subsidy in favour  of  energy  efficiency  vehicles: Most  of the 
respondents (12) were of the opinion that Vehicle taxation and subsidy in favour of energy 
efficiency vehicles had a moderate or great deal of influence in determining their strategic 

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decisions  since  2012  on  investment  in  clean  and/or  energy  efficient  vehicles  while  11 
believed that it had little or no influence. The rest (7) had no opinion on that matter.   

Fuel/energy costs: Most  of the  respondents  (15) were of the  opinion that fuel/energy 
costs  had  a  moderate  or  great  deal  of  influence  in  determining  their  strategic  decisions 
since 2012 on investment in clean and/or energy efficient vehicles while 11 believed that 
it had little or no influence. The rest (5) had no opinion on that matter.   

Deployment of alternative fuel infrastructure: Most of the respondents (18) were of 
the opinion that deployment of alternative fuel infrastructure had a little or no influence in 
determining  their  strategic  decisions  since  2012  on  investment  in  clean  and/or  energy 
efficient vehicles while 8 believed that it had moderate or great deal of influence. The rest 
(5) had no opinion on that matter.   

Consumer perceptions: Most of the respondents (11) were of the opinion that consumer 
perceptions had a little or no influence in determining their strategic decisions since 2012 
on  investment  in  clean  and/or  energy  efficient  vehicles  while  9  believed  that  it  had 
moderate or great deal of influence. The rest (10) had no opinion on that matter.   

Figure  15-12:  Influence  of  the  factors  in  determining  your  strategic  decisions 
since 2012 on investment in clean and/or energy efficient vehicles (32 out of 66) 

14

12

10

8

6

4

2

0

Requirements
for contracting
authorities to
take energy
and
environmental
criteria into
account  (CVD)

EU Car and Van
CO2
Regulations

EURO Emission
Standards

Vehicle
taxation and
subsidy in
favour of
energy
efficiency
vehicles

Fuel/energy
costs

Deployment of
alternative fuel
infrastructure

Consumer
perceptions

Not at all

A little

A moderate amount

A great deal

Don't know or NA

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

In your opinion, what would be the effect on your business if the Clean Vehicles 
Directive were repealed? 

Most (17) of them believed if the CVD were repealed, there would be a neutral effect while 
5 of the respondents believed it would have a strong or somewhat positive effect. 3 of the 
respondents  believed  that  it  would  have  a  strong  or  somewhat  negative  effect  on  their 
business. The rest had no opinion on that matter.  

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Figure 15-13: Effect on respondent’s business if the Clean Vehicles Directive were 
repealed (32 out of 66) 

18

16

14

12

10

8

6

4

2

0

Strong negative
effect

Somewhat
negative effect

Neutral effect

Somewhat
positive effect

Strong positive
effect

Don't know

Effect of a repeal on my business 

Source: Online Survey of Contractors – March-April 2015, Ricardo Energy & Environment 

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16.  ANNEX 8 - MEMBER STATE REPRESENTATIVE’S WORKSHOP – AGENDA 

The study team organised and delivered a half-day stakeholder workshop on Friday 17th 
April  2015  in  Brussels  aimed  at  Member  State  representatives  (morning  session).  A 
background paper was circulated including details of the study, the methodology, summary 
of the tasks (including progress to date) and key questions (where appropriate).   

Representatives  from  8  Member  States  attended  the  workshop,  including  those  from 
Finland, France, Germany, Hungary, Romania, Spain, Sweden, and United Kingdom.  

Please see below for the agenda.   

Agenda 

Wider EU Stakeholder Workshop Agenda 

 

Introduction to the purpose of the meeting and the evaluation (EC) 

  Presentation on the external study being conducted, first findings and 
suggestions, background information in the discussion paper (Ricardo-
AEA/TEPR) 

  Tour de Table, discussion on the paper and presentation prepared by the 

consultants and general discussion 

  Summary and outlook (EC) 

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17.  ANNEX 9: ASSESSMENT OF THE METHODOLOGY FOR MONETISATION OF COSTS 

17.1.  Introduction 

Task 9 of this study was to undertake an assessment of the monetisation methodology as 
set out in Article 6 of the Directive in terms of its relevance and effectiveness. 

The  use  of  the  monetisation  methodology  requires  contracting  authorities  to  calculate 
operational  lifetime  costs  of  energy  consumption,  CO2  emissions,  and  air  pollutant 
emissions associated with operating a vehicle. Once calculated, these external costs are 
then  internalised  (included)  in  the  purchasing  decision.  Executing  the  methodology 
requires  the  contracting  authority  to  acquire,  for  each  vehicle  under  consideration,  data 
on: 

  The vehicle’s fuel consumption (or, in the case of electricity, energy consumption) 

per kilometre 

  CO2 emissions per kilometre, and 

  Air pollutant emissions per kilometre (including, at a minimum, NOX, particulate 

matter, and non-methane hydrocarbons). 

Article 6(2) states that this information should, in the first instance, come from the results 
of  the  standardised  Community  test  procedures  used  for  type  approval.  But  for  those 
vehicles  for  which  there  are  no  such  official  tests,  the  data  should  come  from  “widely 
recognised  test  procedures,”  the  results  of  tests  for  the  contracting  authority,  or 
information supplied by manufacturers. 

This information is then combined with various parameters in the Directive to compute the 
lifetime operational costs. Specifically, the following calculations must be followed: 

CO2 and pollutant emissions costs: 

The operational lifetime CO2 costs are calculated as: 

CO2 emissions (kg/km) × CO2 emissions cost factor (€/kg) × Lifetime mileage of 
vehicle (km) 

The Directive states that the CO2 emissions cost factor should be between 0.03 €/kg and 
0.04 €/kg, but also gives contracting authorities the option of applying a value up to twice 
this amount (i.e. up to 0.08 €/kg). The Directive also sets out assumptions on the lifetime 
mileages  of  passenger  cars,  light  commercial  vehicles,  buses,  and  heavy  duty  vehicles. 
These should form the basis for the calculation if the mileage is “not otherwise specified”. 

For  air  pollutant  emissions,  the  methodology  is  essentially  the  same,  but  the  Directive 
specifies  different  emissions  cost  factors  for  NOX,  particulate  matter,  and  non-methane 
hydrocarbons. 

Energy costs: 

Energy costs are calculated as follows: 

Energy consumption (MJ/km) × Price of energy (€/MJ) × Lifetime mileage of vehicle 
(km) 

If the energy consumption of the vehicle is not “given directly”, but instead  specified in 
units of volume or mass of fuel consumed per kilometre, this should be converted to units 
of MJ/km by multiplying the fuel consumption by the energy content of the fuel (MJ per 
unit of volume or mass). The energy contents of different fuels are specified in an annex 
to the Directive.  

Notably, the Directive states that “a single monetary value per unit of energy shall 
be used. This single value shall be the lower of the cost per unit of energy of petrol or 

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diesel  before  tax  when  used  as  a  transport  fuel”.  Therefore  the  actual  market  prices  of 
alternative fuels such as natural gas or bioethanol are not used in the calculations. 

Flexibility and specificity to local circumstances: 

The  Directive  allows  contracting  authorities  to  make  the  emissions  cost  factors  in  the 
Directive up to 100% larger, and permits discretion in specifying the lifetime mileage of 
vehicles.  Since  all  the  external  costs  are  proportional  to  mileage,  this  factor  effectively 
determines the weight given to the external costs versus any other costs included in the 
purchasing decision. 

17.2.  Assessment – overview of effects and issues 

Our  assessment  of  the  relevance  and  effectiveness  of  the  monetisation  methodology  is 
based  mainly  on:  a  review  of  the  intervention  logic,  consultation  with  stakeholders 
(including  contracting  authorities,  suppliers,  manufacturers,  and  Member  States),  and  a 
case study approach to understanding what results the methodology tends to generate and 
the reasons for these tendencies. 

The main positive effects of the methodology can be summarised as follows: 

  Because the monetisation methodology  requires contracting authorities to gather 
data on lifetime energy and environmental impacts of vehicles, use this data, and 
let  it  guide  their  decisions,  it  forces  some  degree  of  awareness  of  these  impacts 
among contracting authorities. 

  The methodology also has the effect of internalising lifetime operational costs. The 
representatives of the Belgian and Italian governments both agreed in principle that 
the methodology was appropriate for internalising operational costs. However, each 
stated that there were significant issues with the details of the methodology. Many 
other stakeholders agreed that these issues were significant, and one international 
network  of  city  governments  stated  that  if  the  methodology  is  to  be  retained,  it 
needs to be substantially revised if it is to be made effective. 

There are, however, a number of issues with the monetisation methodology which have 
hindered its effectiveness as a tool for internalisation of external costs. These are explained 
in detail in the remainder of this section, with reference to feedback from stakeholders as 
well as reference to our case study analyses where appropriate. 

Some stakeholders made targeted technical criticisms of the methodology, and we were 
able  to  confirm  the  existence  of  these  issues  with  our  case  study  analyses.  Other 
stakeholders expressed scepticism about the utility of having a monetisation methodology 
in general. We have considered the merits of these arguments as well, also in the context 
of the insights gained from the case studies. 

Issue 1: The methodology is perceived to be overly complex, and appears to be very rarely 
applied in practice. 

Executing  the  monetisation  methodology  requires  contracting  authorities  to  gather  data 
and  then  perform  several  mathematical  calculations  on  that  data.  Furthermore,  vehicle 
performance,  environmental  impacts,  and  the  internalisation  of  external  costs  are  also 
technical topics procurers may have very limited knowledge of. 

Several stakeholders suggested that the monetisation methodology was too complex for 
contracting  authorities  to  use.  Indeed,  available  evidence  suggests  that  it  is  applied  in 
practice  very  rarely.  The  Polish  government  found  that  no  contracting  authorities  it 
investigated had used it; an international network of cities discovered only two examples 
of it ever being used. The survey of procurers for this project showed that approximately 
14% of them claimed to have used it, which may overstate the true extent of its use, as it 
might be the case that the contracting authorities who did not respond to our survey are 
generally less engaged with the Directive and therefore even less likely to go to the effort 
of applying the monetisation methodology to their procurement processes. 

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Issue 2: The guidance the legislation provides on the monetisation methodology is unclear 
or insufficient in some respects. 

Some nuances of the methodology were felt to be insufficiently explained in the legislation 
by some stakeholders. 

A  technical  research  institute  with  good  knowledge  of  the  Directive  stated  that  the 
monetisation  methodology  fails  to  specify  how  the  CO2  emissions  of  biofuels  should  be 
treated.  From  one  perspective,  the  lack  of  prescriptive  guidance  offers  contracting 
authorities flexibility in their approach. However, for uninformed  contracting authorities, 
the lack of guidance may simply lead to doubts over how to proceed, and discourage use 
of the methodology. 

Issue 3: Differences in the market prices of different fuels are effectively ignored. 

The monetisation methodology effectively instructs contracting authorities to assume that 
all vehicle fuel (or electricity) has the same per-megajoule cost. (This cost is based on the 
pre-tax cost of either diesel or petrol fuel, whichever is cheaper at the time.) In reality, 
there  are  significant  differences  in  the  market  prices  of  different  fuels,  and  these 
differences  have  significant  effects  on  operating  costs.  The  monetisation  methodology 
therefore  obscures  operating  cost  benefits  or  disadvantages  of  certain  fuels.  The  case 
studies in section 17.3 demonstrate that this is a very significant issue for the methodology. 

Issue 4: Local differences in the external cost of pollutant emissions are ignored. 

Local costs of pollution can vary significantly with population density, geography, climate 
etc. For example, the same amount of pollution will cause fewer adverse health impacts in 
sparsely  populated  rural  areas  than  in  urban  centres  where  more  people  are  affected. 
Moreover, stakeholders have pointed out that authorities operating vehicles in areas which 
are already struggling to meet EU air quality threshold values may feel the need to weigh 
air pollutant emissions more strongly than those authorities experiencing few issues with 
air quality. 

Issue 5: Monetised energy costs are far higher than pollutant emissions costs.  

In  general,  application  of  the  monetisation  methodology  results  in  estimates  of  energy 
costs that are far greater than the estimated costs of pollutant emissions.  This leads to 
results that some stakeholders view as problematic. For example, in comparisons between 
diesel  vehicles  and  gas  vehicles,  typically  the  monetised  pollutant  emissions  benefits  of 
gas technology are insufficient to compensate  for the fact that it is less energy-efficient 
than diesel. One research institute commented that even a EURO I bus would outperform 
a  CNG  bus  when  the  two  are  compared  with  the  monetisation  methodology  (our  own 
analysis indicated that this was the case if the value chosen for the energy content of gas 
was from the high end of the range, but not if the value was chosen from the low end of 
the range. See case study 1, below, for our comparison of CNG and EURO I diesel buses). 
Stakeholders representing city governments have expressed their concern at this result – 
since  many  of  Europe’s  cities  face  air  quality  problems  and  governments  often  seek  to 
address these problems partly with their own vehicle fleet. 

Some government stakeholders have recommended giving local air pollutant emissions a 
greater “weight” in the calculations relative to monetised energy impacts. Since the point 
of monetisation is to weight different impacts according to their actual economic costs, the 
calls  to  add  more  “weight”  to  pollutant  emissions  have  to  be  understood  either  as  (1) 
arguments  that  the  energy  cost  and/or  local  air  pollutant  emissions  cost  factors  are 
inaccurate, or (2) a complete rejection of monetisation. 

Other  stakeholders  have  challenged  the  entire  idea  of  including  energy  costs  alongside 
emissions  costs  in  the  monetised  impacts.  Energy  efficiency,  it  has  been  argued,  is  “a 
means to an end, not an end in itself” – i.e. according to this argument, energy efficiency 
should be valued only insofar as it results in lower carbon emissions. However, EU policy 

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acknowledges that the impacts of energy consumption go beyond carbon emissions, and 
include (for example) energy security impacts. 

Issue 6: Emissions costs (based on 2007 prices) have not been indexed to inflation. 

The emissions cost factors in the Directive were specified in 2007 prices and have not been 
updated  since  the  Directive  was  written.  Therefore  the  importance  of  emissions  costs 
relative to other costs,  including energy  costs,  is being eroded  over time.  The  Eurozone 
GDP  deflator  index  increased  by  approximately  9%  between  2007  and  2014.  Therefore 
emissions costs are arguably already being undervalued by around 9% just due to inflation.  

Issue 7: The emissions costs factors in the Directive need to be updated in light of technical 
progress. 

Stakeholders including national governments have acknowledged that the state-of-the-art 
on  valuing  emissions  has  moved  on  since  the  Directive  was  written.  In  particular,  new 
evidence and analysis has been used to put forward new estimates of the societal costs of 
carbon emissions and local air pollutant emissions. 

Issue 8: Well-to-tank emissions are ignored 

At present, the text of the monetisation methodology seems to imply that electric vehicles 
should be assumed to be CO2-neutral, but that if the electricity powering these vehicles is 
produced from coal, the CO2 emissions of these vehicles would in fact be comparable to 
diesel  vehicles.  Some  stakeholders  have  suggested  that  CO2  emissions  should  be 
considered on a well-to-wheel basis, although this would probably add to the complexity 
of  the  methodology.  Adding  to  the  difficulty  of  implementing  this  is  the  fact  that  CO2 
emissions certification procedures for new vehicles are currently based on tank-to-wheel 
emissions only, and well-to-wheel emissions have not been addressed at this level.  

Issue 9: There is no harmonised community standard for measuring the CO2 emissions of 
heavy duty vehicles 

One of the most frequently-occurring comments from stakeholders was that there is not, 
at present, any harmonised community standard for measuring the fuel consumption or 
CO2  emissions  of  heavy  duty  vehicles.  Some  calculation  models  are  under  development 
such as VECTO42 […] but these models and their usage aren’t validated and regulated yet. 

The  Polish  government  stated  that  this  meant  the  monetisation  methodology  cannot  be 
applied  to  heavy  duty  vehicles.  Others  suggested  that  the  lack  of  a  harmonised  test 
procedure had weakened the methodology (implying it was not completely impossible to 
apply it) because contracting authorities would be reliant on whatever data manufacturers 
provided – data which might not be comparable across vehicles, or even accurate. Finally, 
one  research  institute  noted  that  it  had  managed  to  make  comparisons  between  heavy 
duty vehicles using the monetisation methodology because it had built up its own dataset 
on the CO2 performance of various buses by subjecting them to a common test procedure.  

Issue  10:  it  may  not  be  desirable  to  model  the  energy  and  environmental  impacts  of 
vehicles in diverse situations with “a single formula”. 

One employee of a major city government was sceptical about the possibility of specifying 
a  single  monetisation  methodology  that  was  appropriate  to  all  circumstances.  This 
stakeholder felt that harmonisation in determining costs may be problematic because there 
needs  to  be  sufficient  flexibility  to  take  into  account  local  demands,  and  also  to  allow 
experimentation.  Vehicles  running  on  flat  routes  perform  quite  differently  to  vehicles 

42  “The  Commission  has  developed  a  computer  simulation  tool,  VECTO,  to  measure  CO2  emissions  from  new 
[heavy duty] vehicles. With the support of this tool the Commission intends in 2015 to propose legislation 
which  would  require  CO2  emissions  from  new  HDVs  to  be  certified,  reported  and  monitored.”  European 
Commission. 
from 
http://ec.europa.eu/clima/policies/transport/vehicles/heavy/index_en.htm. 

Heavy-Duty 

"Reducing 

Vehicles." 

emissions 

(2015). 

from 

CO2 

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transport vehicles 

running on routes with hills, for example, and so local circumstances may dictate that a 
variety of different approaches are needed to quantify environmental impacts accurately. 
This issue is a common one for vehicle emissions (or fuel consumption) test procedures, 
including the standard New European Driving Cycle used for certifying CO2 and air pollutant 
emissions performance for new cars and vans. 

17.3.  Assessment – case studies 

Several case studies – worked examples of comparisons between vehicles on the basis of 
monetised costs – were undertaken in order to aid the assessment of the methodology.  

The case studies were designed so as to illustrate the working of the methodology, provide 
evidence as to the results it typically generates, and substantiate (or not) claims made by 
stakeholders about limitations and issues associated with the methodology as it currently 
stands. Some of the case studies also demonstrate what would happen if the methodology 
were altered in specific ways, in order to substantiate our recommendations on how specific 
flaws in the methodology could be mitigated. 

Case study 1: A comparison between buses using various fuels and powertrains 

This  case  study  presents  some  of  the  typical  consequences  of  using  the  monetisation 
methodology to estimate operational costs and makes comparisons between vehicles using 
different  fuels  and  powertrains.  In  this  case  study,  the  monetisation  methodology  was 
applied in exactly the way specified in Article 6 of the Directive. 

The case study compares various types of buses. The emissions data for these bus types 
comes from VTT Technical Research Centre of Finland, who have built up a dataset  (VTT 
2015)  describing  typical  performance  of  different  types  of  buses  by  subjecting  multiple 
vehicles to the Braunschweig City Driving Cycle, averaging results from these tests across 
vehicles of the same type.  

Two types of diesel vehicle are included in this comparison: one EURO I and one Enhanced 
Environmentally Friendly Vehicle (“EEV”, a standard which lies between EURO V and EURO 
VI). Various other types of buses with alternative fuels and powertrains were also included.  

The  main  point  demonstrated  by  the  results  of  this  case  study  is  the  advantage  diesel 
enjoys over other technologies due to its greater energy efficiency. 

Calculations 

The standard parameters and mileages stated in the Directive were used. Where the CVD 
parameters have been  stated in terms of  ranges, we used the average value within the 
range. 

Energy costs, costs of CO2 emissions, and costs of air pollutant emissions were calculated 
using  the  formulae  laid  out  in  the  introduction  to  this  annex  (section  17.1).  For  most 
vehicles,  the  available  data  described  vehicles’  fuel  consumption  rather  than  energy 
consumption  per  kilometre.  Therefore,  in  accordance  with  the  instructions  in  Article 
6(1)(a), each vehicle’s energy consumption in MJ/km was calculated by multiplying per-
kilometre fuel consumption by the energy content of each fuel. 

For completeness, the energy content parameters (which are prescribed in the Directive) 
are reproduced here: 43 

Table 17-1  Energy content of fuels used in case studies 

Energy content of fuels 

43 Note that for natural gas and biogas, the Directive specifies a permissible range for the 
energy  content.  For  the  case  studies,  the  mean  value  of  that  range  was  used,  i.e.  35.5 
MJ/Nm3. 

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Fuel 

Diesel 
Petrol 
Natural Gas / Biogas 
Liquefied Petroleum Gas (LPG) 
Ethanol 
Bioethanol 
Biodiesel 
Emulsion fuel 
Hydrogen 

Energy content 
36 MJ/litre 
32 MJ/litre 
33 – 38 MJ/Nm3 
24 MJ/litre 
21 MJ/litre 
21 MJ/litre 
33 MJ/litre 
32 MJ/litre 
11 MJ/Nm3 

Article 6(1)(a), second indent, states that the price of energy should be the lower of the 
cost per unit of energy of petrol or diesel when used as a transport fuel. At the time of the 
calculation, the pre-tax cost of diesel was lower than the cost of petrol.44  

Table 17-2 Monetary value of energy used in case studies 

Monetary value of energy 

Lower of: pre-tax petrol price, 
pre-tax diesel price 

0.0214 €/MJ 

Emissions cost factors and assumed lifetime mileages of vehicles were also taken from the 
Directive. Note that for CO2, the case studies assume a cost of 0.035 €/kg (i.e. the mean 
value of the range specified in the Directive). 

Table 17-3 CO2 and pollutant emissions cost factors used in case studies 

CO2 and pollutant emissions cost factors 

Pollutant 

Cost per unit mass 

NOX 
Non-methane hydrocarbons (NMHCs) 
Particulate matter 
CO2 

0.004 €/g 
0.001 €/g 
0.087 €/g 
0.03 – 0.04 €/kg 

Table 17-4 Lifetime mileages of vehicles used in case studies 

Lifetime mileages of vehicles 

Vehicle category 

Passenger cars (M1) 
Light commercial vehicles (N1) 
Heavy goods vehicles (N2, N3) 
Buses (M2, M3) 

Lifetime mileage (km) 
200,000 
250,000 
1,000,000 
800,000 

Results and interpretation 

The results of the case study – the total monetised operational costs of each vehicle, 
broken down into energy costs, costs of CO2, and costs of local air pollutant emissions - 
are shown in Figure 17-1. 

44  Petrol and diesel prices were based on EU average values over 2012, as reported in DG 
ENER’s weekly Oil Bulletin European Commission. (2015). "DG ENER: Weekly Oil Bulletin. 
."  from  http://ec.europa.eu/energy/en/statistics/weekly-oil-bulletin..  Diesel  prices  (in 
€/litre) were therefore converted into an energy price in €/MJ with reference to the energy 
content of Diesel. 

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Figure 17-1: Comparison of bus operational costs for different powertrain 
technologies using the monetisation methodology as specified in the Directive 

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Energy

Air pollutants

Tailpipe CO2

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€33k

€28k

€13k

€33k
€13k

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€85k

Energy costs 
predominate 
in the 
calculations

€210k

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€266k

€266k

Diesel’s energy efficiency 
gives it a strong advantage

Source:  Ricardo  Energy  &  Environment  calculations,  incorporating  emissions  data  from 
(VTT 2015) 

One of the notable results of this comparison was that the monetised operational costs of 
the relatively advanced EEV CNG bus were only marginally lower than that of the EURO I 
diesel  bus.  This  was  because  despite  the  huge  pollutant  emissions  benefits  of  gas  over 
EURO I diesel buses, energy costs as quantified using the monetisation methodology tend 
to account for the majority of operational costs and diesel vehicles have a strong advantage 
on energy costs because of the high combustion efficiency of diesel engines. Only diesel-
electric hybrid technology outperforms diesel in terms of energy costs.  

When comparing the EEVs powered by CNG versus EEV diesel buses, diesel has the lowest 
lifecycle cost, despite the monetised pollutant emissions of the diesel bus being twice as 
great as the emissions of the CNG bus. Again, this is due to low energy costs of diesel as 
measured by the monetisation methodology. 

Diesel’s  advantage  over  gas  is  strong  enough  that  even  a  biomethane  bus  -  which  is 
assumed  to  have  zero  CO2  emissions  and  therefore  zero  monetised  costs  of  CO2  –  is 
outperformed in terms of total costs. 

The EEV bioethanol bus performs relatively well, again because biofuels are assumed to 
have zero CO2 costs, and because the performance of bioethanol buses in terms of energy 
consumed is closer to diesel buses than gas buses.45 

In sum, this case study clearly illustrates the dominance of energy efficiency considerations 
in  the  calculations,  and  the  consequent  dominance  of  diesel  technology.  Rather  than 

45 In terms of volume of fuel consumed per kilometre, ethanol buses compare poorly with 
diesel buses, but this ultimately has no bearing on the results of the methodology, because 
it is assumed that all energy will cost the same amount per megajoule used, regardless of 
the fuel it comes from. 

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offsetting the higher initial (purchase) costs of some cleaner vehicles such as CNG-powered 
buses,  the  monetisation  methodology  makes  them  appear  less  competitive.  For  this 
reason, cities with air quality concerns may decline to use the monetisation methodology, 
and some have even challenged the validity of its workings. 

To underline this point, Figure 17-2 shows how buses using different powertrains compare 
in terms of total monetised costs, but also how they compare just in terms of monetised 
emissions.  The  diesel  and  hybrid  diesel  buses,  which  do  not  perform  particularly  well 
relative to alternative powertrains in terms of emissions, come near the top of the league 
table  for  total  monetised  operational  costs.  The  vehicle  with  the  lowest  monetised 
emissions, i.e. the biomethane bus, ranks below three other powertrains in terms of total 
monetised  operational  costs.  In  this  sense,  the  methodology  does  generally  promote 
procurement of powertrain technology associated with low emissions. 

Figure  17-2  Rankings  of  bus  powertrains  on  the  basis  of  monetised  emissions 
costs (left bar chart) and total monetised operational costs (right bar chart)  

Case study 2: Use of actual market prices of fuels 

Different sources of energy for road transport, such as diesel, petrol, gas, and electricity, 
have different market prices – the price of one megajoule of energy depends on the source 
chosen.  However,  as  explained  in  the  introduction  to  this  annex,  the  methodology 
prescribes use of a single monetary value for one megajoule of energy regardless of the 
type of energy being used.  

Case study two explains the effect this has on the results of monetisation, by illustrating 
what would happen if the procurer did not use this hypothetical price of energy, and instead 
took into account the different market prices of different fuels.  

This case study relies on largely the same set of calculations and parameters as the first 
case study. The only exception is to make use of the actual prices for each of the fuels 
considered. The energy prices set out in Table 17-5 have been used when calculating 
energy consumption costs with the following equation: 

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Energy consumption (MJ/km) × Price of energy (€/MJ) × Lifetime mileage of vehicle 
(km) 

Table 17-5 Costs of energy from different fuels used in case study 2 

Costs of energy from different fuels 

Fuel 
Diesel 
Petrol 
Natural Gas 
Biogas 
Biodiesel 
Bioethanol 
Electricity 

Cost per megajoule 
0.0214 €/MJ 
0.0226 €/MJ  
0.0092 €/MJ  
0.0125 €/MJ  
0.0362 €/MJ  
0.0392 €/MJ  
0.0333 €/MJ  

These prices were based on information from the following sources: 

Natural  gas  price  and  electricity  price:  based  on  average  2015  industrial  energy  prices 
excluding taxes from the DG ENER quarterly market reports (European Commission 2015, 
European  Commission  2015)  –  industrial  prices  are  used  as  recharging  facilities  for 
contracting authorities are likely to be at their premises, where they will pay industrial (not 
consumer)  rates  for  energy,  and  because  industrial  prices  are  likely  to  be  closer  the 
marginal opportunity cost of providing the energy; 

  Bioethanol and biodiesel price: approximated on the basis of an International 
Institute for Sustainable Development estimate of the cost spread between 
biofuels and mineral fuels (IISD, 2012); 

  Biogas price: based on the lowest UK Ofgem Renewable Heat Incentive feed-in 

tariff per kWh for biomethane injection (Ofgem, 2015). 

  Petrol  and  Diesel  price:  as  before,  based  on  EU  average  values  over  2015,  as 

reported in DG ENER’s weekly Oil Bulletin (European Commission 2015) 

  Results and interpretation 

The results are illustrated in Figure 17-3. 

Figure 17-3 Bus costs calculated with and without use of actual fuel prices 

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Energy
Air pollutants
Tailpipe CO2

Use of actual fuel 
prices would 
significantly alter 
comparisons across 
technologies

€22k

€33k

€28k

€200k

€24k
€23k

€145k

€33k
€13k

€13k

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€22k

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€33k
€13k

€266k

€266k

€167k

€208k

€210k

€500k

€450k

€400k

€350k

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(2) = calculated using actual market prices of fuel

Source: Ricardo Energy & Environment calculations 

This  adjustment  to  the  methodology  has  a  significant  effect  on  comparisons  across 
technologies. With market prices of the fuels taken into account, the operational costs of 
an  EEV  CNG  bus  are  lower  than  the  operational  costs  of  an  EEV  diesel,  mainly  due  to 
significantly lower energy costs. CNG is still made to look more costly than diesel hybrid 
technology on an operational costs basis, although the gap has been reduced significantly. 

The  biogas  price  data  used  for  this  case  study  (taken  from  the  UK  energy  regulator) 
suggested that biomethane is slightly more expensive than fossil natural gas, which makes 
the  biomethane  bus  slightly  less  attractive  than  the  fossil  natural  gas  bus.  The  effect  is 
offset somewhat by the assumption that biomethane has zero CO2 cost. 

According to the data chosen for this case study, the adjustment to the methodology would 
also have a radical (negative) effect on the competitiveness of bioethanol. Actual market 
prices of fuels vary over time and across markets (for example the price of bioethanol may 
depend greatly on feedstock), so this specific result should just be understood as just an 
illustration of the potential importance of variation in the cost of energy across different 
fuels. 

Most  importantly,  this  case  study  illustrates  that  the  dominance  of  diesel  might  be 
overturned  if  the  methodology  were  to  take  into  account  the  actual  price  of  fuels.  In 
particular, the operational cost benefits of gas in comparison to diesel would be made more 
apparent. 

It  is  also  important  to  note  that  energy  costs  remain  very  dominant  in  the  alternative 
methodology explored here, which is why the CO2 benefits of biomethane are insufficient 
to make it more attractive than fossil natural gas or hybrid diesel buses. 

Sensitivity to high and low fuel prices 

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Energy prices vary from country to country and are constantly in flux. The results of making 
comparisons on the basis of actual market prices would therefore vary over time, as fuel 
prices change. To illustrate this, we made comparisons between vehicles on the basis of 
actual fuel prices both in 2012 (when oil prices were relatively high) and during January-
May 2015 (when oil prices had fallen dramatically). Figure 17-4 illustrates the results: it is 
apparent  that  alternatively-fuelled  vehicles  would  have  fared  worse  in  the  comparison 
against conventionally-fuelled vehicles during the period of low oil prices. 

Figure 17-4: Bus total costs using 2012 and 2015 energy prices 

Energy

Air pollutant + CO2 emissions

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€22k

€22k

€300k

€61k

€61k

€270k

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€200k

€46k

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€195k

€145k

€0k

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€13k

€519k

€436k

€46k

€46k

€153k€167k

€191k€208k

Note: calculated using actual market prices of fuel

Case study 3: Passenger car comparisons including fully-electric vehicles 

This case study extends the analysis of the monetisation methodology to passenger cars, 
and also serves the purpose of illustrating some  of the issues  surrounding the apparent 
competitiveness of  electric vehicles when using monetisation. Fully-electric vehicles are, 
according to some stakeholders’ observations, on the cusp of becoming competitive with 
conventionally fuelled vehicles within the framework of the monetisation methodology. 

Comparisons  were  made  between  passenger  cars  using  different  fuels  and  powertrains. 
Specifically, the vehicles chosen were medium-sized family cars and include a petrol hybrid 
and  a  fully-electric  vehicle.  Emissions  factors  and  energy  consumption  figures  for  these 
vehicles were taken from publically available manufacturer data. 

In this example (see Figure 17-5), the monetised operational costs of the fully-electric car 
are considerably lower than the conventionally fuelled vehicles’ costs. It is assisted by the 
fact  that  no  emissions  are  attributed  to  it,  but  energy  efficiency  is  still  the  largest 
contributing factor in its competiveness within the framework of the methodology. 

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Figure 17-5 Comparison of passenger cars’ operational costs 

€7k

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€0.11k

€0.03k

€0.66k

€0.69k

€0.79k

€4.17k

€4.35k

€4.99k

€1.45k

€1.72k

Energy

Air pollutants

Tailpipe CO2

Electric vehicles 
benefit from no 
CO2 and low 
energy costs, 
according to 
methodology

Source: Ricardo Energy & Environment calculations 

As a next step in this case study, indicative purchase costs were added on to the monetised 
operational costs (see Figure 17-6). Purchase costs will obviously be included within the 
purchasing decision, alongside operational costs, and the most straightforward approach 
to procurement would probably be to just add the two together as has been done in this 
case study. The purchase costs used here are only for illustration, as they are based on 
(pre-tax)  recommended  retail  prices,  and  contracting  authorities  may  be  able  to  secure 
discounts on these prices. 

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Figure 17-6 Comparison of passenger cars’ operational costs and purchase costs 

Energy
Tailpipe CO2

Air pollutants
RRP (pre-tax)

€30k

€25k

€20k

€15k

€10k

€5k

€0k

Some electric 
cars’ monetised
operational 
costs plus 
purchase costs 
are close to 
those of some 
petrol and diesel 
cars

Source: Ricardo Energy & Environment calculations 

The  results  suggest  that  electric  vehicles  might  be  approaching  competitiveness  with 
conventionally fuelled vehicles using this approach to procurement. 

Also note that one of the key assumptions in this comparison is the total lifetime mileage 
of the vehicle – this case study uses the default value from the Directive, but contracting 
authorities  specifying  a  higher  (or  lower)  mileage  would  find  electricity  more  (or  less) 
competitive.  

Case study 4: Updating the emissions cost factors 

A number of stakeholders indicated that they believed the emissions factors in the Directive 
to be erroneously small, or outdated. This case study shows what the effect would be of 
updating the emissions cost factors to technical progress. 

The emissions cost factors in the Directive were specified in 2007 on the basis of evidence 
available at that time. Since then, new evidence and analysis has led to new estimates of 
the social costs of emissions, and some of these estimates are effectively endorsed in EU 
policy.  In  this  particular  case  study,  the  emissions  cost  factors  in  the  Directive  were 
replaced with newer estimates, taken from the 2014 update to the European Commission’s 
Handbook on the External Costs of Transport. Several buses are compared using each set 
of emissions cost factors. 

Table 117-6 Updated CO2 and pollutant emissions costs used in case study 4 

Case study 4: updated CO2 and pollutant emissions costs 

Pollutant 

Cost per unit mass – 
values specified in 
Directive 

Cost per unit mass – 
updated values used 
in case study 4 

NOX 
Non-methane hydrocarbons (NMHCs) 
Particulate matter 
CO2 

0.0044 €/g 
0.001 €/g 
0.087 €/g 
0.03 – 0.04 €/g 

0.011 €/g 
0.002 €/g 
0.041 €/g 
0.072 €/kg 

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Results and interpretation 

In  general,  the  factors  in  the  Handbook  are  substantially  higher  than  those  used  in  the 
Directive. Therefore the result of putting them to use (Figure 17-7) is that emissions costs 
become much more significant (roughly doubling) in absolute terms. But despite this large 
increase, energy costs still constitute the majority of total operational costs for all but the 
most polluting of vehicles (i.e. the EURO I). This example shows that if the methodology 
for calculating energy costs is not altered, an EEV CNG bus would still be outperformed by 
an EEV diesel bus using the new emission cost factors. 

Figure  17-7  Buses’  costs  calculated  with  and  without  updating  emissions  costs 
factors 

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Energy

Air pollutants

Tailpipe CO2

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k
5
4
1
€

k
6
4
1
€

€53k

€22k

k
0
1
2
€

k
0
1
2
€

Emissions costs roughly 
double, but energy costs are 
still the biggest factor and still 
frequently decisive

€13k€30k

k
6
6
2
€

k
6
6
2
€

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k
0
0
2
€

k
0
0
2
€

€69k

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€13k €30k

k
6
6
2
€

k
6
6
2
€

€70k

€34k

€154k

€85k

k
9
0
2
€

k
9
0
2
€

(2) = Calculated using  new emissions costs factors based on 2014 
Handbook on External Costs of Transport

Source: Ricardo Energy & Environment calculations 

Case study 5: Refinement to the method for internalising air pollutant costs 

One  strand  of  criticism of the monetisation methodology states that it is not sufficiently 
sensitive to local conditions, and especially poor at supporting contracting authorities that 
may  be  particularly  concerned  about  local  air  pollution.  The  Directive  provides  a  single 
emissions cost factor for all particulate matter emissions, whereas recent thinking would 
attribute  a  much  higher  social  cost  to  particulate  matter  in  urban  areas  than  in  less-
populated areas. 

In  this  case  study,  the  single  emissions  factor  specified  in  the  Directive  has  been 
substituted,  firstly  with  a  factor  representing  the  damage  cost  of  particulate  matter  in 
urban  areas,  and  then  with  another  factor  representing  the  damage  cost  of  particulate 
matter in interurban areas (both are taken from the 2014 Handbook on External Costs of 
Transport). The cost factor for urban areas is roughly ten times larger than the factor for 
interurban areas.  

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Table 17-7 Urban and interurban particulate matter costs used in case study 5 

Case study 5: Use of urban and interurban particulate matter 
costs 

Pollutant 

Cost per unit mass 

Particulate matter (urban vehicles) 
Particulate matter (interurban vehicles) 

0.283 €/g 
0.029 €/g 

Figure 17-8 Bus costs calculated using urban and interurban particulate matter 
emissions cost factors 

€450k

€400k

€350k

€300k

€250k

€200k

€150k

% difference in 
urban vs. 
interurban total 
costs is small

Energy

Air pollutants

Tailpipe CO2

€33k
€41k

€33k
€24k

€33k
€14k

€33k
€12k

€266k

€266k

€34k

€154k

€34k

€65k

€100k

€200k

€200k

€209k

€209k

€50k

€0k

Source: Ricardo Energy & Environment calculations 

Comparing the results from use of each factor shows to what extent this creates significant 
differences. With the exception of the EURO I bus, the difference this makes to total costs 
is  rather  mild,  despite  the  huge  difference  in  the  emissions  cost  factor.  This  is  because 
particulate matter costs make up just one part of air pollutant costs, which are in turn a 
small proportion of total monetised operational costs. 

Therefore this elaboration to the methodology (i.e. allowing contracting authorities a choice 
of two particulate matter emissions factors) might not often yield different results in terms 
of comparisons between vehicles of different technologies. 

In  should  be  noted  that  the  Directive  currently  allows  some  degree  of  flexibility  in  the 
choice of emissions cost factors anyway, but this flexibility is not commensurate with the 
difference in emissions factors tested here: the Directive only allows for a doubling of any 
one cost factor, not a ten-fold increase.  

17.4.  Assessment – conclusions on relevance and effectiveness 

The  recitals  of  the  Directive  note  that  clean  vehicles  have  a  higher  initial  cost.  Several 
years  after  the  Directive  was  written,  this  is  still  the  case.  The  recitals  also  provide  the 
rationale  for  including  energy  and  environmental  impacts  of  vehicles  in  award  criteria, 

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which  is  that  doing  so  “does  not  impose  higher  total  costs,  but  rather  anticipates 
operational lifetime costs”. Clean and energy-efficient vehicles can have lower operational 
lifetime costs than non-clean and less-energy-efficient vehicles. This is why monetisation 
is on the face of it a relevant means of increasing the uptake of clean and energy-efficient 
vehicles. 

There are, however, two major respects in which the methodology can either be considered 
to be inconsistent with EU environmental policy or inappropriate to the requirements of the 
intended beneficiaries, discussed in turn below. 

Firstly, one of the objectives in setting out the methodology was to ensure “an appropriate 
degree  of  harmonisation”  in  the  way  costs  are  determined.  However,  the  degree  of 
harmonisation imposed by the monetisation methodology may not be consistent with the 
requirements  of  contracting  authorities.  In  particular,  their  requirement  for  enough 
flexibility to take the local situation into account (especially concerns over acute local air 
pollution), and their requirement for enough flexibility to “experiment” at a local level. 

Secondly,  the  objectives  associated  with  the  monetisation  methodology  included 
stimulating the market for clean and energy-efficient vehicles, with an implicit emphasis 
on  energy-efficiency.  This  emphasis  is  apparent  in  the  results  of  the  methodology  (as 
demonstrated by the case studies) and rationalised in recital 10, which states: “The High 
Level Group on competitiveness, energy and the environment, in its report of 27 February 
2007,  recommended  that  private  and  public  procurement  should  take  account  of  full 
lifetime costs with emphasis on energy efficiency. […]” 

However,  because  some  vehicles,  notably  diesel  vehicles,  are  associated  with  relatively 
high energy  efficiency  but also relatively high pollutant emissions, “emphasis on  energy 
efficiency” is in tension with the need to provide support to clean vehicles (especially low 
pollutant emissions vehicles) in procurement decisions and thereby stimulate their uptake. 

We have provided recommendations on how to mitigate the second issue in section 17.5. 
In  brief,  our  recommendation  is  not  to  arbitrarily  add  more  “weight”  to  air  pollutant 
emissions, but to address certain issues with the calculation of energy costs. Addressing 
the other challenge to the methodology’s relevance, i.e. the lack of flexibility, would require 
adding to its complexity and therefore detract from its effectiveness. 

In  terms  of  effectiveness,  the  case  studies  and  stakeholder  feedback  highlight  that  the 
effectiveness  of  the  methodology  in  achieving  its  chief  objective,  the  internalisation  of 
external costs, is limited, because of flaws in its design, especially its failure to incorporate 
differences in the costs of different fuels. 

Furthermore, as documented in the main text of this report, the methodology is very rarely 
used in practice, which obviously places a serious limit on its effectiveness. The widespread 
non-use of the methodology can be attributed to the fact that it is perceived to be difficult 
for most contracting authorities to follow, whereas the other options in the Directive are 
relatively simple to apply. Finally, those procurers who do understand the methodology are 
also unlikely to apply it, for another reason: they are likely to have good awareness of the 
external costs of transport and an existing desire to purchase vehicles with alternative fuels 
and  powertrains  –  vehicles  which  the  methodology  tends  not  to  favour,  at  least  when 
compared with diesel vehicles. 

We have provided recommendations on how to mitigate these problems with effectiveness 
in 17.5. 

17.5.  Possible solutions/improvements 

Some  of  the  criticisms  made  of  the  methodology  are  in  tension  with  each  other;  it  is 
considered to be both too complex to apply, and too simplistic to capture relevant details. 
Therefore  it  may  not  be  possible  to  solve  every  problem  with  the  methodology 

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simultaneously.  However,  if  the  methodology  is  to  be  retained,  a  few  relatively 
straightforward changes could greatly improve its effectiveness. Box 1 provides details of 
potential changes to the legislation that would improve it in that regard.  

Box 1: Potential changes to the methodology 

Potential change 1: Take into account the different market prices of different 
fuels 

The methodology currently directs contracting authorities to use a hypothetical price 
of energy all for non-petrol and non-diesel fuels, which is often grossly out of line with 
actual prices. It is not obvious that this hypothetical price of energy is a better tool 
for internalising costs than market prices, which reflect real conditions of supply and 
demand. The use of the hypothetical energy price actually obscures the operating cost 
savings  that  contracting  authorities  can  make  by  purchasing  alternatively-fuelled 
vehicles, and provides artificial and unnecessary support for diesel. Addressing this 
will  go  some  way  towards  preventing  results  which  many  stakeholders  regard  as 
contrary to the objectives of the Directive. 

Market  prices  of  diesel  and  petrol  are  relatively  easy  to  obtain,  but  the  prices  of 
alternative  fuels  often  require  investigation.  Contracting  authorities  should  not  be 
made  to  expend  time  and  energy  on  investigating  the  prices  of  alternative  fuels. 
Therefore  it  may  be  prudent  for  the  Commission  or  the  Member  States  to  supply 
contracting  authorities  with  a  bulletin  of  indicative  prices  of  different  fuels  (either 
averaged  across  the  EU,  or  specified  at  the  level  of  Member  States)  for  use  in  the 
monetisation calculations. 

Potential  change  2:  Update  the  emissions  cost  factors  in  light  of  technical 
progress 

There  is  a  clear  case  for  updating  the  emissions  cost  factors  in  the  monetisation 
methodology to take account of technical progress. Estimates of the societal costs of 
emissions  –  estimates  that  have  effectively  been  given  the  Commission’s 
endorsement in other policy areas – have changed substantially since the Directive 
was written. 

Doing  this  will  also  help  to  address  the  “predominance”  of  energy  efficiency  in  the 
monetisation  methodology,  because  today’s  estimates  of  the  costs  of  pollutant 
emissions are higher than the estimates used at the time the Directive was written. 

Potential change 3: Index emissions costs to inflation 

It  is  important  to  ensure  that  the  relative  importance  of  emissions  costs  is  not 
erroneously  undermined  over  time  by  increases  in  the  general  price  level  of  goods 
and  services,  i.e.  inflation.  This  could  be  tackled  by  rebasing  all  other  costs  to  the 
same price base as the emissions cost factors, or indexing the emissions cost factors 
to inflation. 

Potential  change  4:  Clear  up  remaining  areas  of  ambiguity  in  the 
methodology 

As noted above, the legislative text describing the monetisation methodology is felt 
to  be  insufficiently  clear  in  certain  areas,  including  the  treatment  of  CO2  emissions 
from vehicles powered by biofuels. 

EU policy on accounting for CO2 emissions of biofuels in road transport is set out in 
other legislation (namely the Fuel Quality Directive). Therefore, one option is for the 
Clean Vehicles Directive to make  reference to the  relevant accounting rules in that 
legislation. Another option would be to make a singular recommendation on how all 
biofuels  should  be  treated  for  the  purposes  of  the  monetisation  methodology.  This 

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would  result  in  some  loss  of  flexibility  for  contracting  authorities,  but  on  the  other 
hand it would enhance its clarity. 

Potential  change  5:  The  monetisation  methodology  should  not  be  the  only 
option 

The monetisation methodology has to be sufficiently simple for contracting authorities 
to  be  able  to  apply  it  without  significant  prior  knowledge  of  vehicle  emissions  and 
internalisation of costs. This places very significant constraints on the level of nuance 
that we can expect to include in the methodology. However, a minority of contracting 
authorities will have a very good knowledge of the energy and environmental impacts 
of vehicles, and attach  high priority to those impacts, and these authorities should 
not be prevented from applying a more exacting methodology for internalisation of 
costs. Therefore, if the methodology is to be retained, it should not be made into the 
sole option for taking energy and environmental impacts into account in procurement 
decisions. 

There are a number of other steps that could be taken, in addition to revising the text of 
the  legislation,  to  improve  the  effectiveness  of  the  monetisation  methodology.  These 
possible additional supporting measures (see Box 2), other than amending the Directive, 
would provide authorities using the methodology with more support.  

Box 2: Possible additional supporting measures 

Potential  supporting  measure  1:  Ensure  that  contracting  authorities  are 
equipped with a user-friendly tool for performing the calculations 

Many stakeholders suggested that the monetisation methodology was too complicated 
for  most  contracting  authorities  to  be  able  to  follow.  Contracting  authorities  might 
find it much easier to apply the methodology correctly and quickly if they made use 
of  a  tool  that  guides  them  through  each  stage  in  the  process.  The  Clean  Fleets 
Lifecycle  Costing  Tool  (Clean  Fleets  Project  2014)  is  an  existing  spreadsheet  tool 
capable  of  performing  the  monetisation  calculations,  but  its  effectiveness  might  be 
substantially  increased  if  it  were  converted  into  a  web-based  tool  and  then  widely 
publicised (potentially even referenced in the legislation itself).  

Potential supporting measure 2: Create a  harmonised community standard 
for quantifying the CO2 impacts of heavy duty vehicles 

If  the  monetisation  methodology  is  to  be  applied  to  heavy  duty  vehicles  in  a 
meaningful way, it is essential that objective, comparable information is available on 
the CO2 impacts and energy efficiency of these vehicles. 

Potential  supporting  measure  3:  Ensure  that  more  comprehensive  data  on 
vehicle emissions is made available in a one-stop-shop 

Contracting authorities should be able to find emissions data for different vehicles on 
a comprehensive and up-to-date portal. Centralising information in this way may not 
be an easy or cheap task, but if the monetisation methodology is to be retained, its 
effectiveness will be linked to the ease with which contracting authorities can find the 
appropriate information to input into it. 

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18.  ANNEX  10  –  ASSESSMENT  OF  THE  COMMISSION  INITIATIVES  AIMED  AT  THE 

PROMOTION OF THE DIRECTIVE 

The assessment presented in this Annex contributes to a number of evaluation questions, 
including: 

  Question  5:  To  what  extent  has  the  Directive  promoted  an  increased  awareness 
among  the  different  stakeholders  of  the  operational  lifetime  environmental  and 
energy impacts of vehicles? (see Section 6.4 of the main report). 

  Question  7:  Could  the  effects  have  been  achieved  in  a  more  efficient  way  (e.g. 

through other or additional (legislative) measures)? (see Section 6.7.1). 

  Question  9:  To  what  extent  have  the  Directive  and  the  associated  Commission 
initiatives (e.g. Clean Vehicle Portal, Clean Fleets Project) initiated and/or supported 
a recognised exchange of good practices between contracting authorities in different 
Member States? (see Section 6.10). 

Approach taken 

An assessment was undertaken to identify whether selected complementary Commission 
initiatives had had measurable impacts with regards to the objectives of the Directive and 
whether this might be improved. This assessment had a particular focus on exploring the 
role of, and potential for, cross-border joint procurement in contributing to the objectives. 
In order to cover all of these potential elements, the assessment explored the extent to 
which the complementary initiatives have: 

  Had measurable impacts with respect to the main aims of the Directive, i.e. with 

respect to: 

o  Promoting  and  stimulating  the  market  for  clean  and  energy  efficient 

vehicles;  

o 

Increasing the market share of clean vehicles; 

o  Contributing  to  reducing  CO2  and  pollutant  emissions  from  the  transport 

sector (and improving energy efficiency); 

o 

Internalising operating costs in procurement decisions; 

o  Harmonising the determination of operating costs; and 

o 

Increasing the awareness amongst stakeholders of the operational lifetime 
environmental and energy impacts of vehicles. 

  Encouraged and/or facilitated (cross-border) joint procurement. 

 

Initiated  and/or  supported  an  exchange  of  good  practice  between  contracting 
authorities in the Member States. 

  Contributed to promoting the Directive. 

A  particular  focus  of  the  task  was  on  the  Clean  Vehicle  Portal  and  the  Clean  Fleets 
project (see Box 3), which had been developed to specifically complement the Directive. 
Additionally, up to three other initiatives were to be covered.  

Box 3 : Overview of the Clean Vehicle Portal and the Clean Fleets project 

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Clean Vehicle Portal (2011-ongoing)              

Objective: The Clean Vehicles Directive calls for the dissemination of information about the 
Directive and about relevant financial instruments available in Member States. The portal was 
developed to deliver these requirements. In addition, the Portal aimed to promote the exchange 
of knowledge and good practice and to provide further explanation on the implementation of 
the Directive’s requirements. There have been two projects related to the Portal: the first was 
to develop the  Portal and put it online;  the  second,  which is ongoing at the time of writing, 
aimed to enhance the Portal and to migrate it to the europa.eu website, so that it is effectively 
hosted by the European Commission. Both projects have been led by TUV Nord.  

The Portal’s primary target audience is the bodies targeted by the Clean Vehicles Directive (i.e. 
public contracting authorities, contracting entities as well as certain operators for the discharge 
of public service obligations). It also aimed to engage other key stakeholders, such as vehicle 
manufacturers  and  relevant  national  and  regional  support  bodies/regulators  by  providing 
tendering information and services. 

Geographically, the portals cover all of the countries that participated in the IEE programme, 
namely all the 28 EU Member States, Norway, Iceland, Liechtenstein, and the Former Yugoslav 
Republic  of  Macedonia.  The  Portal  contains  a  vehicle  database,  information  on  procurement 
rules/incentive schemes, and provides a calculator to help users to identify the most energy-
efficient  road  vehicles.  It  also  links  to  other  web  resources,  including  the  online  EU  Official 
Journal supplement TED (Tenders Electronic Daily). In addition, the Portal has an internet forum 
aims to facilitate joint procurement. 

In the second phase of the project, the aim was to relaunch the website and to transfer it to 
the Commission’s ‘europa’ website. However, the project has been delayed and at the time of 
writing the relaunch is scheduled for the second half of 2015. In the course of the second phase 
of the project, prior to the relaunch, no updates were made to the information on the Portal.  

Clean Fleets Project (2012-ongoing)             

Objective: The Clean Fleets Project aimed to provide direct support and build capacity for the 
implementation of higher standards of energy and environmental performance in road transport 
vehicles. The project was led by ICLEI and involved city authorities or public transport operators 
from  eight  EU  cities  (the  German  cities  of  Bremen  and  Freiburg,  London,  Rotterdam,  Sofia, 
Stockholm, Vitoria-Gasteiz in Spain and the Croatian capital, Zagreb), plus the Romanian public 
transport union (URTP), as well as a number of consultancies.  

The  project  supported  specific  procurement  actions,  including  market  consultation,  the 
development  of  specifications,  competitive  tendering  and  contract  management.  It  also 
included the development of a guide on how to procure clean and energy-efficient vehicles in 
practice, which was consistent with the Directive. The project was based on modular training, 
information  exchange  and  specific  advice  to  regulated  organisations.  The  project  aimed  to 
deliver:  

  An online exchange and help desk functions on the Clean Vehicle Portal; 

  Workshops  and  training  reaching  350  people  from  public  authorities,  fleet  operators 

and suppliers; 

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  A CVD toolkit and adaptable training modules; and for  

  20 public authorities and/or fleet operators commit themselves to develop a tender that 

goes further than the current legislation requires 

Sources:  Respective  project  websites  (www.cleanvehicle.eu  and  www.clean-fleets.eu)  and 
interviews undertaken with the project coordinators for this report. 

The identification of the other potential Commission initiatives that it might be appropriate 
to assess was undertaken using searches of the main EU project databases of relevance, 
i.e. the CORDIS website for FP7 projects (European Commission 2015), the Commission’s 
database  of  projects  supported  by  Intelligent  Energy  for  Europe  (European  Commission 
2015) and DG MOVE’s Transport Research and Innovation Portal (TRIP Consortium 2015). 
Searches were made for projects that focused on ‘clean vehicle procurement’, but also for 
projects that had a wider focus on ‘green’, ‘clean’ or ‘low carbon procurement’ and which 
also covered road transport vehicles.  

Those projects that were considered to be most appropriate for further consideration within 
this task were: 

  GPP 2020: The project was  supported by  IEE; it began in 2013 and was due to 
finish  in  2016.  It  was  led  by  ICLEI  and  involved  various  national  and  regional 
government departments. It aimed to mainstream low carbon procurement across 
Europe and covered a range of products, including road transport vehicles, through 
the  implementation  of  more  than  100  low  carbon  tenders.  Of  particular  interest, 
from the perspective of identifying the impacts of Commission initiatives, is that it 
estimated the amount of CO2 emissions and energy saved as a result of the project.   

  COMPRO (COMmon PROcurement of collective and public service transport clean 
vehicles): The project was supported by IEE; it began in 2007 and finished in 2009. 
It  was  led  by  ISIS  (Italy)  and  brought  together  four  local  authorities  (Nantes, 
Bremen, Gothenburg and Emilio-Romagna). The aim was to create an international 
buyers’  consortium  for  the  joint  procurement  of  clean  public  transport  services. 
Even though the project is relatively old, it did focus on joint procurement, which is 
covered  by  this  evaluation.  Furthermore,  early  engagement  with  stakeholders, 
including  those  involved  with  the  Portal  and  Clean  Fleets,  suggested  that  joint 
procurement, particularly of the cross-border kind, remains problematic. Hence, it 
was considered worthwhile to identify the project’s experience in this respect.  

  PROCURA (Green Fleet Procurement Models): The project was supported by IEE; 
it began in 2006 and finished in 2008. It was led by Ecofys and involved various 
technical  organisations,  as  well  as  a  manufacturer.  It  aimed  to  test  models  of 
“centralised  AFV  procurement”  and  claimed  to  have  led  to  the  purchase  of  135 
alternatively fuelled vehicles (AFVs). Again, the project is of interest as it focuses 
specifically on the creation of ‘buyer pools’ for clean vehicles46. 

There were two main sources of evidence for the assessment presented here. The first was 
a  review  of  the  documentation  associated  with  the  respective  projects,  including  their 
websites  and,  where  relevant,  reports  obtained  directly  from  the  respective  project 
coordinators  or  Commission  desk  officers.  The  second  was  direct  engagement  with  the 
respective  project  coordinators,  respective  Commission  desk  officers  and  other  relevant 

46   Information for these three projects was taken from the entries on the respective project pages of the IEE 
database (European Commission, 2015c) and from the GPP 2020 project website (www.gpp2020.eu). 

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project  partners,  as  appropriate47.  The  engagement  with  the  project  coordinators  and 
project partners was based on a brief questionnaire that was designed to explore the issues 
that were the focus of this task, as set out in Section 6.3.1. For the older projects, this was 
more challenging as those involved had often left the organisations that they represented 
at the time. Additionally, for Clean Fleets, engagement was undertaken with selected cities 
that  had  been  part  of  the  project  in  an  attempt  to  obtain  further  information  about  the 
project, as well as to seek these cities’ broader views on the Directive in order to contribute 
directly to answering some of the evaluation questions.  

In the following sections, our findings are presented in relation to the four different parts 
of the assessment, as listed at the beginning of this Annex.  

Have the initiatives had measurable impacts with respect to the main aims of the 
Directive?  

The analysis revealed that there has been little in the way of measurable impacts – of the 
type of interest to this evaluation – in the course of the five complementary initiatives that 
were assessed. However, this is largely as a result of the fact that most of the initiatives 
were not designed to specifically deliver such measurable impacts, with the exception being 
GPP 2020. As described in Box 3, the main focus of the Clean Vehicle Portal and the Clean 
Fleets  project  were  on  the  dissemination  of  information  and  on  capacity  building, 
respectively. While both projects had the intention of assessing some quantifiable impacts, 
this has not happened in practice. In the ongoing second phase of the Portal, the intention 
was  to  include  a  pop-up  survey  that  would  ask  users  questions  that  might  be  used  to 
identify  and  quantify  the  experience  with  the  Portal.  However,  the  project  has  been 
delayed, so this survey has not yet been put in place and it is not clear whether it will be 
in the time left in the project.  

One of the elements of the Clean Fleets project was to provide procurers with support in 
the  preparation  of  tenders;  the  intention  was  to  collect  data  on  the  impacts  of  these 
tenders. However, there have been few requests for support within the project and, where 
support  has  been  given,  it  has  subsequently  proved  to  be  difficult  to  obtain  useful 
numbers48. A couple of the cities that have been involved in the Clean Fleets project noted 
that  their  involvement  in  the  project  had  led  to  the  promotion  of  the  market  for  clean 
vehicles in their respective countries while one noted that involvement in the project had 
influenced a purchasing decision that will lead to reduced CO2 and pollutant emissions.    

As the main reason for the inclusion of both the PROCURA and COMPRO projects in this 
assessment was their focus on joint procurement, it is not surprising that neither delivered 
much  in  the  way  of  relevant  measurable  impacts.  However,  135  alternatively-fuelled 
vehicles were procured as a result of PROCURA, with more anticipated after the end of the 
project. This information was provided on the project’s entry on the IEE database, but it 
was not possible to obtain further information on what these vehicles were, let alone their 
impacts, from the project documentation (European Commission 2015).  

47   In this context, we would like to thank the following people for their support in providing information for this 
assessment: Kai Sporckmann (TUV Nord, project manager of the ongoing project relating to the Clean Vehicle 
Portal),  Simon Clement  (ICLEI,  project  manager  of  the Clean  Fleets project),  Olav  Luyckx  (EASME’s desk 
officer for both the Clean Vehicle Portal and the Clean Fleets project), Philipp Tepper (ICLEI, project manager 
of the GPP 2020 project), Angelika Tisch (IFZ, partner in the GPP 2020 project), Rob Winkel (Ecofys, lead on 
the Procura project) and Silvia Gaggi (ISIS, lead on the COMPRO project). 

48 Based on interviews with the respective project leads 

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As noted above, one of the reasons for including the GPP 2020 project in this assessment 
was because the project does quantify the CO2 emissions reductions and energy savings 
resulting from the low carbon tenders that are implemented in the course of the project 
for  road  transport  vehicles  and  other  low  carbon  products.  At  the  time  of  writing,  there 
have been five relevant tenders relating to the procurement (either the purchase or lease) 
of over 5,000 road transport vehicles, which will deliver savings of 22,930 tonnes of CO2e 
emissions and energy savings equivalent to 6,935 tonnes of oil over the lifetime of vehicles 
(or of the respective contracts where the vehicles were not purchased; see Table 18-1). 

Table 18-1: CO2e and energy savings as a result of tenders implemented for road 
transport vehicles within the GPP 2020 project (as of May 2015)  

Procurer 

Vehicles procured 

Type of contract 

Number 

CO2  saved 
(tCO2e)  

Energy  saved 
(toe) 

Consip SpA, Italy 

Joint  leasing  of  green 
vehicles 

4,075 

19,303 

5,616 

Ministry  of  Territory  and 
Sustainability, Catalonia 

Lease-purchase of low 
C cars 

37 

120 

HEP  Ltd  (Croatian  Energy 
Company), Croatia 

Electric vehicles 

20 

379 

31 

99 

Ministry  of  Home  Affairs, 
Catalonia 

Lease-buy  of 
cars 

low  C 

175 

1,597 

696 

Federal 
Agency, Austria 

Procurement 

Purchase  of 
diesel cars 

small 

810 

1,581 

493 

TOTAL: 

5,117 

22,980 

6,935 

Source: Respective tender case studies at www.gpp2020.eu/low-carbon-tenders 

Have  the 
procurement?  

initiatives  encouraged  and/or  facilitated  (cross-border) 

joint 

Joint procurement was in the scope of both the Clean Vehicle Portal and the Clean Fleets 
projects. The first project relating to the Clean Vehicle Portal, which resulted in the Portal 
being developed in the way in which it was present on the internet in the first half of 2015, 
included a forum that users could access to discuss and exchange information on potential 
joint procurement, but this was not well used. On the revised version of the Portal, which 
is due to go live in the second half of 2015, there will be a page where those interested in 
joint procurement can publish their needs, which can be seen by other authorities that can 
then contact each other about potential joint procurement. As part of the ongoing work, a 
database of joint procurement activities is being developed, while it is anticipated that joint 
procurement will be covered in the case studies that are also being developed.  

In the early stages of the Clean Fleets project, a ‘user needs assessment’ was undertaken 
in collaboration with the second phase of the Clean Vehicle Portal in order to inform the 
work of the project. While users expressed some support for work on joint procurement, 
there were many other areas in which there was more interest, including implementing the 
requirements  of  the  CVD  in  practice,  methods  used  by  European  public  authorities, 

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information on technologies and costs and using the life cycle cost calculation (TTR 2013)49. 
Consequently,  joint  procurement  was  not  a  focus  of  the  project.  In  the  course  of  the 
engagement  with  both  the  Portal  and  the  Clean  Fleets  project,  it  was  mentioned  that 
examples  of  joint  procurement  are  rare,  while  cross-border  joint  procurement  is  even 
rarer50.  It  is  worth  noting  that  there  are  two  case  study  examples  of  national  joint 
procurement – in Slovenia and Sweden – on the Clean Fleets project’s website51.  

No activities on joint procurement have been undertaken, or are planned, within the GPP 
2020 project. 

As noted above, as a result of the early findings relating to the Clean Vehicle Portal and to 
Clean  Fleets,  two  other  projects  were  identified  that  appeared  to  have  a  focus  on  joint 
procurement, at least according to the information on their respective project pages on the 
IEE project database (European Commission 2015). Here it was noted that PROCURA would 
developed  “buyer  pools”,  while  COMPRO  aimed  to  “create  an  international  buyers’ 
consortium” for the purpose of joint procurement. However, in the documentation that was 
available on the IEE project database relating to PROCURA, there was no mention of the 
formation of any ‘buyer pools’ within the project; it was confirmed by someone involved in 
the  project  that  it  did  nothing  with  respect  to  buyer  pools,  focusing  instead  on  sharing 
information  about  the  transition  to  using  alternatively-fuelled  vehicles  and  the 
development of tools to analyse fleets. 

COMPRO,  on  the  other  hand,  did  focus  on  joint  procurement  and  indeed  two  successful 
national examples were reported upon: the joint procurement of trams in the French cities 
of  Brest  and  Dijon  and  the  joint  procurement  of  trains  by  the  Italian  regions  of  Emilia 
Romagna  and  Veneto.  In  spite  of  the  project’s  stated  intention  (see  above),  no  cross-
border  joint  procurement  took  place  within  the  project;  instead  the  project  focused  on 
bringing cities together and identifying the barriers to joint procurement and the definition 
of the elements needed for cross-border joint procurement. Issues that currently prevent 
cross-border joint procurement that were identified in the project included: 
  The existence of different local regulatory and legal frameworks. 
  Local  culture  and  tradition,  which  makes  defining  a  common  product  to  procure 

difficult.  

  A lack of tradition in cross-border requirement, coupled with language barriers.  
  Unbalanced  commercialisation  of  products  in  different  countries  as  a  result  of  a 

fragmented market and different local requirements. 

  A lack of understanding about clean technologies in general (ISIS, 2009)  

In  its  final  ‘Common  position’,  the  project  partners  underlined  the  potential  for  joint 
procurement  and  that  the  project  could  identify  no  legal  barriers  to  cross-border  joint 
procurement.  They  called  for  more  financial  support  for  the  purchase  of  clean  vehicles, 
including the exploration of the EIB’s Elena (European Local ENergy Assistance) facility, as 

49 In order to identify the needs, a survey was undertaken of the needs of potential users 
of the support that might be provided by the project. The results are based on online 
survey, to which there were more than 80 respondents, and telephone interviews with 
50 representatives of relevant organisations. In order to identify on what users were 
interested in receiving support, a long-list of options – including joint procurement  – 
was provided. ‘Joint procurement’ was the 10th most popular choice out of the 13 listed.   

50 Based on interviews with the respective project leads 

51 www.clean-fleets.eu/case-studies/ 

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well as future support from the Commission for common procurement in order to overcome 
the barriers identified. 

Hence, the overall conclusion is that while there are theoretical advantages of cross-border 
procurement, not least in shared expertise and from economies of scale and the potential 
to  reduce  administrative  costs  in  the  longer-term,  these  are  not  yet  proven  in  practice, 
whereas the increased, short-term administrative costs associated with cross-border joint 
procurement, at least in the initial phase, are real.  
Have  the  initiatives  initiated  and/or  supported  an  exchange  of  good  practice 
between contracting authorities in the Member States?  

As  was  noted  above,  the  Clean  Fleets’  user  needs  assessment  identified  that  there  was 
interest in learning about methods used by other European public authorities. Hence, the 
exchange of good practice has been an important element of the Clean Fleets project. In 
the course of the telephone interviews undertaken for the user needs assessment, topics 
that  were  suggested  for  workshops,  training  and  events  included  “How  is  procurement 
organised  in  best  practice  organisations?”  and  “Best  practice  examples”.  The  report 
recommended  that  ‘inspirational’  and  ‘replicable’  case  studies  would  be  one  of  the  best 
ways  of  expressing  the  European  dimension  within  the  project.  As  a  result,  nine  case 
studies were developed in the course of the project and uploaded onto the project website, 
along with another 11 from the Commission’s Green Public Procurement website52. These 
case studies have been downloaded over 6300 times53. 

The main focus of the European-level and national workshops that have been held within 
the project has also been on the exchange of good practice. More than 870 people have 
attended  (or  watched  videos  of)  the  project’s  European  and  national  events,  while  the 
various presentations from these workshops have been downloaded more than 8500 times. 
The  general  level  of  satisfaction  with  the  workshops  has  been  high  (see  Figure  18-1). 
Furthermore,  a  project  report  on  clean  technologies  for  buses,  which  also  includes  case 
studies, has been downloaded over 3,600 times.  
Figure  18-1:  Feedback  from  attendees  of  Clean  Fleets’  national  and  European 
workshops  to  the  question  “What  was  your  overall  assessment  of  the 
Workshop?”  

a)  National workshops 

b) European workshops  

Source: Developed on the basis of data provided by ICLEI 

52 http://www.clean-fleets.eu/case-studies/ 

53 This and the other data mentioned in this section has been provided by ICLEI 

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The exchange of good practice is also an important element of the GPP 2020 project. For 
each  of  the  low  carbon  tenders  implemented  within  the  project,  an  associated  “tender 
model”  is  developed,  which  is  effectively  an  overview  of  the  experience  of  the  procurer 
with the tendering process. Additionally, information on good practice is exchanged in the 
course of the various events and training exercises undertaken within the project, including 
national and European meetings and webinars.  

The first phase of the Clean Vehicle Portal, on the other hand, was not set up to exchange 
good  practice,  although  some  good  practice  examples  are  being  developed  for  the  re-
launch of the Portal later in 2015. As a result of the focus of COMPRO and PROCURA, as 
noted  above,  neither  focused  on  the  exchange  of  good  practices,  even  though  one  of 
recommendations  of  the  latter’s  final  report  was  the  provision  of  information  on  best 
practice. 
Have the initiatives contributed to promoting the Directive?  

Supporting  the  CVD  was  one  of  the  aims  of  the  Portal,  while  raising  awareness  and 
supporting the implementation of the Directive are aims of the Clean Fleets project.  

The Portal was presented at a number of events in the course of the first project, which 
indirectly promoted the Directive, although there has been little in the way of promotional 
activity under the second project relating to the Portal. On the Portal itself, there is a link 
to  a  page  about  which  information  on  the  Directive  can  be  found.  This  link  has  been 
accessed  relatively  frequently  throughout  the  lifetime  of  the  Portal  (see  Figure  18-2);  if 
anything interest has increased in the last 6 months. 
Figure 18-2: Number of times the page on the Clean Vehicle Portal about the CVD 
has been accessed per year  

Source: Data provided by TUV Nord 

As part  of its initial user needs assessment, Clean Fleets asked respondents about their 
awareness  of  the  Directive;  only  50%  of  respondents  were  aware  of  the  CVD’s 
requirements  and  only  one  in  four  had  accessed  guidance  (mainly  a  webpage)  on  the 
Directive. However, it was noted that as the Directive has been transposed into national 
legislation,  a  greater  proportion  of  respondents  would  probably  have  been  aware  of  the 
Directive’s  requirements  in  this  way.  The  meetings  held  within  the  Clean  Fleets  project 
appear to have been largely beneficial in increasing attendees’ ability to apply the Directive 

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(see  Figure  18-3).  The  project’s  website  has  been  visited  by  more  than  26,000  unique 
visitors54. The Clean Fleets cities contacted directly for this assessment generally thought 
that the national workshops in particular had gone well, while the project website was also 
complemented.  
Figure  18-3:  Feedback  from  attendees  of  Clean  Fleets’  national  and  European 
workshops  to  the  question  “To  what  extent  has  the  workshop  helped  you  to 
better apply the CVD?” 

a)  National workshops 

b) European workshops  

Source: Data provided by ICLEI 

The existence of the Directive was considered useful for both the Clean Vehicle Portal and 
the Clean Fleets projects by those involved in the projects, as it gave  both a focus that 
would not otherwise have been there. The need to  apply the provisions of the Directive 
also  acted  as  a  motivation  for  procurers  to  become  involved  in  the  respective  projects. 
However, some of those that were spoken to felt that something similar to the Clean Fleets 
project in particular could have been successful without the Directive, as local authorities 
across Europe are dealing with common issues with respect to clean vehicles.    

While the Directive is not the focus of the GPP 2020 project, it is one of the issues that the 
project covers. It is worth noting that the Directive’s lifetime operational cost monetisation 
methodology was used in the first GPP 2020 road transport tender model listed in Table 
18-1. On the other hand, as both PROCURA and COMPRO had ended before the CVD came 
into force, neither focused on the promotion of the Directive, although both were aware of 
the proposal and its potential relevance, as it was mentioned in the final reports of both 
projects.    

54 Data provided by ICLEI 

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19.  ANNEX 11: EVALUATION OF THE EXTENT TO WHICH IT IS, AND WILL CONTINUE TO 
BE, IMPORTANT TO INCREASE THE ENERGY EFFICIENCY AND COMPETITIVENESS OF 
TRANSPORT AND TO REDUCE ITS CO2 AND POLLUTANT EMISSIONS 

In order to evaluate the extent to which there is, and will continue to be, a need to reduce 
transport’s  CO2  emissions,  it  is  first  worth  underlining  that  there  remains  a  need  to 
reduce  greenhouse  gas  emissions  (GHGs)  more  generally, including  CO2  which  is  by  far 
the most common GHG emitted by the transport sector. In its most recent assessment of 
the evidence, the Intergovernmental Panel on Climate Change (IPCC) concluded that there 
was a need for “substantial and sustained reductions of greenhouse gas emissions” as the 
evidence was more conclusive than ever that the global climate is warming as a result of 
increased concentrations of GHGs in the atmosphere that are the result of human activity 
(IPCC 2013). The EU has already committed itself to delivering significant reductions in its 
GHG emissions. The Commission’s 2011 Low Carbon Roadmap set the framework for the 
development  of  EU  policy  action  to  meet  an  80  to  95%  reduction  in  GHG  emissions  by 
2050 compared to 1990 levels. The Roadmap concluded that cost-effective reductions of 
GHG emissions of between 54% and 67% by 2050 compared to 1990 could be delivered 
by the transport sector (European Commission 2011, European Commission 2011). Hence, 
in order to meet long-term economy-wide CO2 reduction targets, there is a need to reduce 
transport’s CO2 emissions.   

In  order to  evaluate whether there is, and will continue to be, a  need to improve the 
energy  efficiency  of  transport,  it  is  necessary  to  identify  what  the  required  GHG 
reductions above imply for transport in terms of improvements in vehicle efficiency. The 
Commission’s 2011 Transport White Paper explored the implications of delivering such GHG 
emissions reductions, as it took as its starting point the need to reduce transport’s GHG 
emissions  by  60%,  i.e.  the  midpoint  in  the  range  identified  by  the  Roadmap  (European 
Commission 2011). The policy option that the Impact Assessment accompanying the White 
Paper identified as its preferred option included action to reduce the CO2 emissions of all 
transport vehicles. This assumed that the average CO2 emissions from new cars would be 
only 20 g/km by 2050, compared to the target of 95 g/km in 2020, while the equivalent 
figure  for  LCVs  would  be  55g/km  compared  to  the  2020  target  of  135  g/km.  For  heavy 
duty vehicles a 40% improvement in energy efficiency was assumed by 2050  (European 
Commission 2011). Other studies have also concluded that there is a need to deliver such 
reductions from vehicles in order to meet the CO2 reduction levels assumed by the White 
Paper. A report for the European Commission’s DG Climate Action concluded that reducing 
transport’s  CO2  emissions  by  60%  by  2050  compared  to  1990  levels  would  require 
reductions in lifecycle CO2 emissions of 80% for cars, buses and vans, and of between 60 
and 75% for heavy goods vehicles in parallel to action to improve vehicle efficiency in other 
modes  of  transport  (e.g.  rail,  air  and  water  transport),  improvements  in  operational 
efficiency and the decarbonisation of fuels and energy sources (Ricardo-AEA, TEPR et al. 
2012).  

For  vehicles  that  use  fossil  fuels,  reducing  the  CO2  emissions  of  road  transport  will 
necessarily  require  improving  the  fuel  efficiency,  and  therefore  the  energy  efficiency,  of 
vehicles, as the CO2 emitted is closely linked to the energy consumed. For vehicles that 
use electricity and hydrogen, this link is not as direct, as in-use CO2 emissions for these 
energy sources are zero (see Section 5.4). Hence, the energy efficiency of such vehicles 
could be relatively poor, but their in-use emissions would be unaffected. However, given 
the levels of investment that are required to decarbonise the electricity sector in particular 
(European Commission 2011), it would seem prudent to ensure that the energy consumed 
in transport as a result of its electrification is consumed as efficiently as possible. Hence, 
it can be concluded that there is a continuing need to imrpove the energy efficiency of the 
transport sector for all fuel types. 

EEA (2014), which drew on the latest evidence concerning health and air quality from the 
World  Health  Organisation  (WHO),  underlines  that  there  is  a  still  a  need  to  reduce 
pollutant  emissions,  generally,  and  those  from  transport  in  particular.  The  report 

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highlighted that transport was the largest emittor of the oxides of nitrogen (NOX) and a 
significant  emitter  of  large  and  fine  particulate  matter  (PM10  and  PM2.5,  respectively).  It 
was  estimated  that  between  21%  and  30%  of  the  urban  population  of  the  EU-28  are 
exposed to concentrations of PM10 above EU air quality limit values, while the equivalent 
figures are 10% to 14% for PM2.5 and 8% to 13% for NOX. WHO has air quality guidelines 
(AQG)  for  the  same  pollutants  that  indicate  the  levels  at  which  it  believes  health  risks 
would be reduced to a minimum on the basis of the latest scientific evidence (WHO 2013). 
For some pollutants, these AQGs are tighter than the existing EU limit values. EEA (2014) 
demonstrates that over 91% of the EU’s urban population is exposed to levels of PM2.5 that 
exceed the respective WHO AQG, while the equivalent figure for PM10 is 64%55. The role of 
road transport in these exceedances is clear as the daily limit value for NOX was exceeded 
at 37% of ‘traffic’ monitoring sites56, while the equivalent figures for PM10 and PM2.5 were 
22% and 4%, respectively. Of the transport measures suggested that would contribute to 
reducing the adverse of transport on air quality, a shift to the use of cleaner vehicles was 
mentioned.   

The  need  to  increase  the  competitiveness  of  transport  was  a  theme  of  the  2011 
Transport White Paper, including the role of transport in enhancing the competitiveness of 
the  wider  economy  (European  Commission  2011).  The  need  to  strengthen  the 
competitiveness of the EU automotive sector is emphasised by the multi-stakeholder CARS 
2020 process (European Commission 2012). An earlier report from the CARS 2020 process 
also  highlighted  that  the  competitiveness  of  the  EU  automotive  industry  can  only  be 
assured if it delivers sustainable and advanced products (European Commission 2012). 

Hence,  it  can  be  concluded  that  there  remains  a  need  to  decrease  transport’s  CO2  and 
pollutant emissions, and to increase its energy efficiency and competitiveness.  

55 The proportion of the EU urban population exposed to NOX levels above the respective 

WHO AQG is the same as that for the respective EU emission limit value.  

56 ‘Traffic-related’ monitoring sites are one of four types of fixed air quality sampling points 
in  Europe,  the  others  being  urban/suburban  background,  rural  background  and 
industrial (EEA, 2014).  

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20.  ANNEX 12: GRAPHS FOR RELEVANCE 

The graphs in this Annex are to complement the discussion about what might be considered 
to be a clean vehicle under relevance (see Section 6.2.2 of the main report). The figures 
below focus on NOX emissions for air pollution, as this transport is the largest source of 
these emissions, as mentioned in Section 6.2.2. 

Figure  20-1:  Emissions  of  NOX,  CO2  and  the  energy  consumption  of  different 
variations of the same model of car 

Source: Own research (see Annex 18) from manufacturers’ website and reviews 

Figure 20-2: Emissions of NOX, CO2 and the energy consumption of different light 
commercial vehicles 

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Source: Own research (see Annex 18) from manufacturers’ website and reviews 

Figure  20-3:  Emissions  of  NOX,  CO2  and  the  energy  consumption  of  different 
versions of the same heavy goods vehicle 

Source: Cenex (2014); see Annex 18 

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Figure 20-4: Emissions of NOX, CO2 and the energy consumption of different types 
of bus 

Source: VTT (2013) 

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21.  ANNEX 13 – ASSESSMENT OF WHETHER REPORTING REQUIREMENTS ON MEMBER 

STATES WOULD BE EFFECTIVE AND PROPORTIONATE 

The assessment presented in this Annex contributes to one evaluation question, i.e.: 

  Question  7:  Could  the  effects  have  been  achieved  in  a  more  efficient  way  (e.g. 
through other or additional (legislative) measures)? (see Section 6.7.1 of the main 
report). 

Approach taken 

This assessment focuses on identifying the extent to which: 

  The current reporting obligations (on the Commission) are adequate; and  

  Whether the introduction of reporting requirements on Member States would be an 

effective and proportionate means of determining the impacts of the CVD.  

In order to assess the adequacy of the current reporting obligations, it was necessary 
to: 

 

Identify  the  extent  to  which  the  current  reporting  obligations  facilitated  the 
Commission in understanding the application and effects of the Directive;  

  Compare  reporting  requirements  in  similar  pieces  of  EU  legislation  in  order  to 
identify  the  extent  to  which  the  requirements  of  the  CVD  in  this  respect  differed 
from those considered important elsewhere; and  

 

Identify the views of Member States and stakeholders. 

The  latter  two  elements  were  also  used  to  inform  the  assessment  of  whether  the 
introduction of reporting requirements on Member States would be effective and 
proportionate in determining the impacts of the CVD. This part of the assessment was 
undertaken  in  a  manner  consistent  with  the  Commission’s  own  Impact  Assessment 
Guidelines  (European  Commission  2015).  In  other  words,  the  following  stages  were 
implemented: 

  A  long-list  of  potential  options  for  Member  State  reporting  was  identified  on  the 
basis  of  similar  reporting  requirements  in  similar  pieces  of  EU  legislation  and 
suggestions from the project Steering Group, Member States and stakeholders. 

  The options included on the long list were then assessed qualitatively according to 
a number of criteria, including their potential effectiveness, their proportionality and 
their political acceptability. The feedback from Member States in the course of the 
Member State representative meeting was taken into account for the last criterion. 

  A  short  list  of  options  was  then  identified  for  which  administrative  costs  were 
estimated, in order to try to provide quantitative evidence of the proportionality of 
the different proposed reporting requirements.  

In order to support this assessment, views on the adequacy of the existing monitoring and 
reporting arrangements and on the utility, or otherwise, of Member State monitoring and 
reporting requirements were asked of: 

  Member States; and 

  EU level stakeholders (as part of the EU stakeholder interviews, see Annex 2, and 

in the stakeholder workshop, see Annex 3). 

Adequacy of the current reporting obligations 

Currently, the CVD places no reporting requirements on Member States; it only requires 
the Commission to produce a monitoring report every two years on the CVD’s application 
and effects. The Commission’s report needs to cover the:  

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  Application of the Directive; 
  Complementary actions taken by Member States; 
  Effects of the Directive, especially Article 5(3) options and how these have affected 

the market for vehicles (including an evaluation of Article 6 methodology); 

  Nominal/relative  numbers  of  vehicles  purchased  corresponding  to  best  market 

alternative; and 

  Need for further action, and proposals, as appropriate. 

To  date,  the  Commission  has  produced  one  monitoring  report  on  the  application  of  the 
Directive (European Commission 2013), and has commissioned one report in support of its 
monitoring actions (Ricardo-AEA and TEPR, 2012). The former noted that the absence of 
reporting  obligations  on  Member  States  made  analysing  the  implementation  of  the 
Directive  difficult  and  suggested  that  it  might  be  appropriate  to  impose  reporting 
obligations on Member States in the future, which echoed the findings of the latter report. 
Hence,  the  first  attempt  at  identifying  the  impacts  of  the  Directive,  let  alone  its 
measureable  impacts,  proved  to  be  difficult.  As  part  of  this  evaluation,  we  have  also 
attempted to obtain information about the impacts of the Directive in order to quantify its 
impacts  (as  discussed  in  Section  4.1  of  the  main  report).  This  has  again  proved  to  be 
challenging  in  spite  of  the  number  of  responses  to  the  online  survey  that  have  been 
received.  

In order to identify whether there are alternative approaches to assessing the impact of 
EU legislation, a number of other Directives have been reviewed in order to identify from 
where the Commission obtains information to assess the implementation of these. (This 
review  was  also  relevant  to  the  next  part  of  this  assessment,  i.e.  the  development  of 
options  for  potential  reporting  requirements  on  Member  States.)  The  focus  was  on 
identifying  and  reviewing  legislation  that  was  similar  in  its  requirements  to  the  CVD, 
particularly that which required action from public authorities at the regional or local levels. 
In the legislation covered in this review, it was clear that the CVD is in a minority in that it 
does  not  require  action  from  Member  States  (see  Table  21-1).  Consequently,  it  can  be 
concluded that some form of monitoring and reporting action on Member States is generally 
considered to be important for the purpose of monitoring EU legislation that is applicable 
at the regional and local levels.   

Table  21-1:  Summary  of  monitoring  and  reporting  requirements  on  Member 
States in EU legislation that requires action at the local level  

Procurer 

Energy saved (toe) 

New general procurement legislation, 
Directives 2014/24 and 2014/25 

Member  States  are  required  to  monitor  the 
application  of  the  public  procurement  rules  and 
the  results  of  these  monitoring  activities  are  to 
be  made  available  to  the  Commission;  Member 
States have to submit monitoring reports to the 
Commission  every  three  years  from  2017  that 
has 
to 
issues 
implementation and enforcement 

include  any 

relating 

to 

Alternative Fuels Infrastructure Directive, 
Directive 2014/94 

Starting in 2019, Member States are required to 
submit  a  report  to  the  Commission  every  three 
years  on  the  implementation  of  their  national 
policy  framework,  the  adoption  of  which  is 
required  by  the  Directive;  these  have  to  cover 

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inter  alia  the  relevant  legal  measures,  policy 
measures  that  have  been  implemented  to 
support  the  national  policy  framework,  budgets 
(e.g.  to  support  infrastructure  deployment  and 
R&D), targets and objectives, and information on 
the supply and demand of the fuels concerned 

Energy  performance  of  buildings, 
Directive 2010/31 

Member  States  are  required  to  report  all  input 
data/assumptions  for  the  calculation  of  cost-
optimal  levels  of  minimum  energy  performance 
requirements  to  the  Commission  at  regular 
intervals  (of  no  longer  than  5  years);  Member 
States have to develop national plans to increase 
number  of  nearly  zero  energy  buildings  and 
inform the Commission of these; Member States 
have to draw up a list of existing and proposed 
measures  to  promote  the  objectives  of  the 
Directive,  and  communicate 
the 
Commission 

this 

to 

Environmental 
2002/49 

noise, 

Directive 

Air  quality 
2008/80 

framework,  Directive 

Member  States  are  required  to  inform  the 
Commission of any relevant limit values in force 
or  planned,  the  major  roads,  railways,  airports 
and  agglomerations  in  their  territories,  other 
criteria  for  drawing  up  action  plans  and  of  the 
information  from  strategic  noise  maps  and 
actions  plans  developed  as  a  result  of  the 
Directive 

Member  States  are  required  to  make  annual 
reports  available  to  the  public  for  all  of  the 
pollutants covered by the Directive, which should 
include  inter  alia  exceedances,  objectives,  alert 
thresholds  etc.;  Member  States  are  to  ensure 
that information on ambient air quality is made 
available  to  the  Commission  within  specified 
timescales 

Source: Own review on the respective pieces of legislation 

Of the 14 Member States that responded to the question about the adequacy of the current 
provisions on the Commission for the effective assessment of the impacts and operation of 
the Directive, five believed that there were adequate, five did not, while the other four had 
no clear opinion. Of those that thought the requirements were adequate, two (Germany 
and Italy) were going to put in place their own monitoring systems, while two others argued 
that requiring on Member States would increase the administrative significantly as a result 
of  the  need  to  collect  information  from  a  large  number  of  local  authorities.  Two  of  the 
Member States that considered the current situation to be inadequate were not in favour 
of  additional  reporting  requirements  on  Member  States  for  similar  reasons,  i.e.  the 
increased burden that this would entail.         

On  the  other  hand,  most  stakeholders  believed  that  the  current  reporting  requirements 
were  inadequate  and  that  reporting  requirements  on  Member  States  would  motivate 
Member  States  to  act  to  deliver  on  the  Directive.  It  was  also  noted  that  reporting 
requirements were important to be able to properly inform any revision of the Directive. 
However,  one  stakeholder  also  raised  the  same  issue  as  several  Member  States  that  it 

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would be difficult to monitor the impact in practice as a result of the number of authorities 
involved and their  reluctance to  report (see Annex 2). This issue was  also raised at the 
meeting with Member State representatives.   

Taken together, the discussion in this section suggests that: i) it is proving to be difficult 
to assess the impacts of the Directive, particularly to quantify these, on the basis of the 
approach taken in this evaluation; ii) generally similar EU Directives do require Member 
States to monitor and report on the implementation of (at least elements of) Directives to 
the Commission; and iii) some stakeholders, although not Member States, believe that it 
is important that there are monitoring and reporting requirements on Member States in EU 
legislation, not least as this can act also act as a motivation for taking action. Consequently, 
it  can  be  concluded  that  the  current  reporting requirements  on  the  Commission  are  not 
sufficient and are not consistent with similar legislation. The extent to which it is possible 
to identify monitoring and reporting requirements for Member States that will be effective 
and proportionate is assessed in the following section.  

Development  and  assessment  of  potential  reporting  requirements  on  Member 
States 

The first stage of this part of the assessment was to identify a long-list of possible options 
for  including  monitoring  and  reporting  requirements  on  Member  States  in  the  Directive, 
and to identify what role the Commission might have in each case. This was undertaken 
by  reviewing  reporting  requirements  in  similar  pieces  of  EU  legislation,  i.e.  those  that 
require action by local and regional public authorities (as noted above), and in legislation 
suggested by the various Commission DGs involved in the project’s Steering Group, as well 
as  by  asking  Member  States  and  EU  level  stakeholders  (see  Section  6.7.1)  for  their 
suggestions.  There  is  a  range  of  potential  requirements  that  might  be  put  in  place  to 
improve the monitoring of the Directive. The following discussion starts with the options 
that require less in the way of changes to the current situation, progressing to significantly 
more comprehensive options. First, it is important to note that the Commission’s Impact 
Assessment Guidelines for assessing different policy options recommends the inclusion of 
a ‘no change’ option in any assessment; hence, this is included on the long-list as the first 
option.  

There are a number of complementary Commission initiatives (see Annex  10) that have 
been put in place to support the implementation of the Directive. Some of these already 
monitor  procurement  opportunities  and  directly  engage  with  procurers.  Consequently,  a 
potential option is to utilise similar future initiatives, assuming that the Commission will 
continue to support such initiatives, to monitor the implementation of the Directive. 

An alternative option might be for the Commission to monitor the implementation of the 
Directive with the explicit support of the newly formed Sustainable Transport Forum Expert 
Group (which we understand will effectively replace the Committee that is set  up under 
the CVD, which would otherwise have been an option). Such an approach is similar to the 
requirements of Directive 2010/31 (energy performance of buildings), which requires the 
Commission to evaluate that Directive with the assistance of a Committee set up by the 
Directive.  However,  it  should  be  noted  that  there  are  other  reporting  requirements  on 
Member  States  as  a  result  of  this  Directive  (see  Table  21-1).  In  the  course  of  the 
engagement undertaken for this project, a Member State suggested that the Clean Vehicles 
Directive could be monitored by the Commission with the support of Member State experts 
(see Annex 2). 

Many Directives have some type of reporting requirement on both Member States and the 
Commission, including those Directives that aim to reduce the environmental impacts of 
inter alia road transport. Examples of such Directives are the environmental noise Directive 
(2002/49) and the air quality framework Directive (2008/80), both of which are similar to 

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the CVD in that they effectively set a European policy framework, but have to be largely 
implemented at the regional and local level. As noted in Table 21-1, both of these Directives 
have a number of reporting requirements on Member States. Additionally, both also require 
the Commission to review and  report  on, at least aspects of, the implementation of the 
respective pieces of legislation.  

There are also reporting requirements on both Member States (see  Table 21-1) and the 
Commission in the recently adopted alternative fuels infrastructure  Directive (2014/94), 
which is complementary to the CVD, as it focuses on infrastructure for alternative fuels. 
The  Commission  has  to  provide  an  assessment  of  the  national  policy  frameworks  and, 
every  three  years,  has  to  submit  a  report  on  the  application  of  the  Directive,  including 
actions taken by Member States, the  effects of the Directive  on the development of the 
market with respect to infrastructure and fuels. Many of these elements are comparable to 
issues on which the Commission has to report under the CVD (see Section 6.7.1). It is also 
worth noting that Annex I to the alternative fuels infrastructure Directive, which sets out 
the  requirements  for  Member  State  reporting,  explicitly  notes  that  the  “use  of  public 
procurement  in  support  of  alternative  fuels”  is  one  of  the  measures  on  which  Member 
States should report, although this does not make an explicit reference to the CVD.   

Similarly,  the  new  public  procurement  Directives  (2014/24  and  2014/25)  both  explicitly 
put monitoring and reporting requirements on Member States (see Table 21-1). A similar 
approach was proposed by a stakeholder as part of the engagement undertaken within this 
project (see Annex 2).  

A couple of stakeholders also suggested that there was a need for a more comprehensive 
approach to reporting on clean transport; this would require Member States to report on a 
wide range of relevant initiatives, not just the CVD.  

On the basis of the above discussion, the following long-list of options was identified and 
presented to the Member States in the Expert Group meeting (that took place as part of 
this project):  

1.  Maintain the current approach, in which the Commission has to produce a monitoring 

report every two years on the application and effects of the CVD.  

2.  Commission  uses  a  related  initiative,  e.g.  the  Clean  Vehicle  Portal  or  a  suitable 
alternative,  to  monitor  the  implementation  and  impact  of  the  CVD,  and  produces 
monitoring reports on the basis of this information. 

3.  Commission  monitors  the  application  and  effects  of  the  CVD  with  the  support  of  the 
Expert  Group,  which  should  agree  a  common  reporting  methodology  and  guidelines, 
and produces monitoring reports on the basis of the information provided by the Expert 
Group. 

4.  Member  States  are  required  to  monitor  the  application  and  effects  of  the  CVD  (as  a 
result  of  provisions  added  to  the  Directive)  and  to  make  results  available  to  the 
Commission  every  three  years  on  the  basis  of  which  the  Commission  produces  its 
monitoring reports.  

5.  Member States are required to monitor the application and effects of the CVD and to 
make the results available to the Commission in their reports as part of the report to 
be submitted under the new public procurement Directives on the basis of which the 
Commission produces a separate monitoring report for the CVD.  

6.  Member States are required to report generally on clean transport measures, including 
the CVD, on the basis of which the Commission prepares a monitoring report on the 
CVD.  

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These options have been assessed for their potential effectiveness and proportionality (as 
required by the terms of reference), as well as for their potential to make monitoring and 
reporting under the CVD consistent, comparable and complete and political acceptability 
(see  Table  21-2)57.  For  the  sake  of  clarity,  it  is  noted  that  the  Commission’s  own  IA 
guidelines  state  that  the  principle  of  proportionality  means  that  action  at  the  European 
level “should not go beyond what is necessary to achieve satisfactorily the objectives that 
have  been  set”  (European  Commission  2015).  In  the  context  of  this  assessment,  we 
assume  that  the  “objectives”  are  that  the  Commission  has  a  good  understanding  of  the 
implementation and impacts of the Directive. 

Option 1, retaining the existing approach, has the advantage that it requires no change to 
the existing monitoring and reporting arrangements, but, as described above, it has so far 
proved  difficult  to  obtain  sufficient  information  to  be  able  to  fully  identify  the 
implementation and effects of the CVD. The effectiveness of the approach depends on the 
contributions of a large number of actors over a short timescale. While attempts have been 
made to ensure that the information received is consistent and comparable, it cannot be 
considered to be complete. This also brings into question the proportionality of the current 
approach,  which  does  not  enable  the  Commission  to  obtain  a  full  understanding  of  the 
impacts of the Directive. However, this option should be retained as it is the one currently 
in  place.  Option  2  has  the  slight  advantage  over  Option  1  in  that  monitoring  can  be 
undertaken over a longer period of time, but many of the issues with Option 1 are likely to 
remain,  although  it  might  be  possible  to  improve  the  consistency  of  the  information 
obtained over the longer periods involved. Additionally, a commitment on a complementary 
initiative  to  contribute  to  the  monitoring  of  the  Directive  would  mean  that  resources 
allocated to other support tasks would be less than would otherwise have been the case. 
There would also be issues of budgets and responsibilities in this respect, as future support 
initiatives would probably be funded under Horizon 2020, whereas monitoring of legislation 
is the responsibility of the DGs concerned. Hence, it is not considered that this approach 
brings much in the way of added value, given the changes needed, and potential issues 
associated, with setting this option up.  

Option  3  has  the  advantage  that  the  relevant  monitoring  and  reporting  requirements, 
including  their  frequency  and  format,  can  be  agreed,  and  therefore  amended  as 
appropriate,  by  the  Commission  and  the  Member  States  in  the  Expert  Group,  which  we 
assume  would  be  the  newly  formed  Sustainable  Transport  Forum  Expert  Group.  Hence, 
together  the  members  of  the  relevant  Group  could  ensure  that  the  requirements  were 
effective, proportionate, consistent and comparable, as the Group together considered they 
needed to be, which should ensure the political acceptability of such an approach. However, 
the issue here is whether such an approach would deliver reporting requirements to the 
level needed for the Commission to understand the impacts of the Directive, which might 
need more information that would be provided under such a consensual approach. Option 
4  provides  consistency  with  the  general  public  procurement  legislation,  which  has  only 
recently been adopted,  so might be considered to be the  result of  current thinking with 
respect to monitoring and reporting on public procurement in the EU. It is likely to be more 
effective and lead to more complete results, as it would be a legal requirement, but it is 
likely to face challenges of political acceptability.   

Option 5 is slightly different from Option 4 in that monitoring and reporting for the CVD 
would be integrated into the monitoring and reporting requirements of the general public 
procurement legislation (rather than the reporting requirements being integrated into the 
CVD). While this option has the attraction that one fewer report would need to be submitted 
by each Member States, there is a risk that the reporting on the CVD is diluted to a level 

57   These  are  the  most  relevant  criteria  used  in  the  assessment  of  reporting  obligations,  e.g.  see  Regulation 
525/2013 on greenhouse  gas monitoring  Euopean Union  (2013). Regulation  525/2013/EU on  Greenhouse 
Gas Emissions Monitoring and Reporting, Official Journal of the European Union .  

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that  does  not  enable  its  effective,  consistent  and  comparable  monitoring  and  reporting. 
However,  it  should  be  noted  that  there  is  a  justification  for  this  approach  as  the  public 
procurement legislation refers to the CVD in an Annex, as the only sector-specific piece of 
public  procurement  legislation  in  place  at  the  EU  level.  This  approach  might  be 
implemented,  although  on  a  voluntary  basis,  if  the  Commission  included  the  CVD  in  its 
reporting format that it will propose for Member States. This approach might be potentially 
less  effective  and  lead  to  less  complete  results  than  option  4,  but  might  be  considered 
more proportionate and so politically acceptable.  

There  are  various  risks  with  Option  6.  It  would  require  a  new  monitoring  and  reporting 
system  to  be  set  up,  and  entail  a  potentially  significant  increase  in  the  reporting 
requirements on Member States if such an approach is to be meaningful for all of the issues 
covered. Hence, it is likely to face challenges from the perspective of political acceptability 
and proportionally, while not necessarily delivering sufficient information on the CVD,  as 
reporting on this Directive risks being overshadowed in the wider reporting mechanism.    

Table 21-2: Assessment of long list of options against the selected criteria  

Results of assessment with respect to the potential: 

Option 

Effectiveness  Proportionality 

Consistency, 
comparability 
and 
completeness 

Political 
acceptability 

1.  Maintain  the  current 
approach 

2.  Commission  uses  a 
related initiative 

3.  Commission  monitors 
the 
and 
application 
effects  of  the  CVD  with 
the  support  of  an  Expert 
Group 

 

 

 

4.  Member  States  are 
required  to  monitor  the 
application and effects of 
the CVD 

 

 

 

 

 

 

 

 

 

 

 

 

 

5.  Member  States  are 
required  to  monitor  the 
application and effects of 
the  CVD  as  part  of  the 
reporting under the public 
procurement legislation 

 

 

 

 

6.  Member  States  are 
report 
required 
generally 
clean 
transport measures 

to 
on 

- 

 

- 

 

Source: Assessment undertaken for this report 
Key: Assessment ranges from “” (option contributes well to this criterion) through “-” 
(option no effect on this criterion) to “” (option is very negative with respect to this criterion) 

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As noted above, relevant questions were asked of both Member States and stakeholders 
as part of the engagement within this project, while the above short-list was presented to 
Member States in the Expert Group meeting. The main comments in this respect were: 

  Several  stakeholders  suggested  that  the  inclusion  of  reporting  requirements  on 
Member States in the Directive would focus Member States on the Directive and act 
as a stronger motivation for action. Other stakeholders argued that it was important 
to  have  some  type  of  mandatory  reporting  otherwise  it  was  impossible  to  know 
what the impact of the Directive had been and whether changes were necessary. It 
was also suggested that the alternative fuels infrastructure Directive might be used 
to support reporting under the CVD (see Annex 2). 

  Some  Member  States  noted  that  they  already  publish  the  data  that  they  have 
and/or are planning to evaluate the Directive. It was noted that it is likely that the 
challenges  of  undertaking  an  evaluation  at  the  national  level  would  be  similar  to 
those  faced  by  a  European  level  evaluation,  such  as  this  one.  Hence,  it  was 
suggested  that  there  would  be  little  in  the  way  of  added  value  from  putting 
additional reporting requirements on Member States (see Annex 3).   

  A Member State suggested that the monitoring might be best focused on analysing 
market data, rather than on trying to identify the impacts of the Directive on a large 
number  of  small,  dispersed  actors.  It  was  also  suggested  that,  rather  than  new 
monitoring requirements, it might be better to cover clean vehicles as a separate 
part of similar reporting requirements. 

While some Member States do identify and publish information on the implementation of 
the Directive, and some may evaluate it, it is not likely that all Member States will do so. 
Hence, an alternative reporting requirement might be to require Member States to monitor 
the implementation of the Directive, at fixed periods, but without being too prescriptive, 
and to report to the Commission the findings of this process.   

As a result of the assessment above, and a discussion with the Commission, it was agreed 
that the following options are retained on the short-list for further consideration: 

A.  Maintain  the  current  approach,  in  which  the  Commission  has  to  produce  a 
monitoring  report  every  two  years  on  the  application  and  effects  of  the  CVD.  No 
additional monitoring or reporting requirements are put on Member States (Option 
1  above).  While  this  was  not  rated  well in  the  above  assessment,  it  needs  to  be 
retained as it is the current approach  against which all other  short-listed  options 
can be measured.  

B.  Commission  monitors  the  application  and  effects  of  the  CVD  with  the  support  of 
Member  States,  e.g.  in  the  newly  formed  Sustainable  Transport  Forum  Expert 
Group. Member States would be asked to monitor the application and effects of the 
CVD in a manner that they consider to be appropriate (i.e. as agreed in the Group) 
and to make the results available to the Commission at least every five years. On 
the basis of these reports, the Commission will produce its monitoring reports. This 
is based on Option 3 above, but loosened to be less prescriptive as to what, and 
how frequently, Member States report.  

C.  Reporting under the CVD is brought into line with, and made consistent with, that 
required under the general public procurement legislation. As part of the reporting 
under  this  legislation,  the  Commission  would  provide  a  reporting  template  for 
Member  States  that  would  cover  the  application  and  effects  of  the  CVD.  This 
template  would  be  voluntary,  but  the  Directive  does  require  Member  States  to 
report to the Commission every three years (starting from 2017) on the basis of 
which  the  Commission  produces  its  monitoring  reports.  This  option  is  effectively 
Option 4 above. 

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D.  Reporting under the CVD is brought into line with, and made consistent with, that 
required under the alternative fuels infrastructure Directive. As part of the reporting 
under  this  legislation,  Member  States  are  required  to  report  to  the  Commission 
every three years (starting from 2019) on the implementation of their respective 
national  policy  frameworks  on  the  basis  of  which  the  Commission  produces  its 
monitoring reports. The CVD could be included in this reporting by supplementing 
the guidelines that are to be adopted by the Commission concerning Member State 
reporting for this Directive by an Annex that sets out guidance for reporting for the 
purpose of the CVD. This option is based on Option 4, above, but focuses on the 
alternative fuels infrastructure Directive instead. 

It is worth noting that the only real difference between Options C and D is that the CVD 
reporting is integrated into a different Directive. Hence, the assessment of these options 
is – at this point in time – the same as that for Option 4 in Table 21-2. In practice, it may 
turn out that one of these options is more politically feasible than the other; hence, both 
are included here. The difference between Option B and Option C/D is that the former is 
less prescriptive as to the format of reporting and requires less frequent reporting.  

Comparison of the administrative costs of the short-listed options 

In order to apply the SCM, the actions required by different actors need to be listed and 
the  potential  time  commitments  and  associated  costs  for  each  action/actor  need  to  be 
estimated on the basis of input from a number of Member States. As we were unable to 
obtain  any  support  from  a  Member  State  to  estimate  these  costs,  in  this  section  we 
compare these qualitatively.   

The actions required by different actors for options A, B and C are set out in Table 21-3). 
Only three options are considered, as a result of the similarities between options C and D, 
as noted above. On the basis of these actions, the differences in relative costs per actor 
compared to Option A of Options B and C are set out in Table 21-4. This analysis suggests 
that Options B and C would both incur more administrative costs for Member States than 
the  current  approach,  largely  as  a  result  of  the  need  for  Member  States  to  take  on  the 
responsibility for engaging with local authorities and collating and reporting these results 
to  the  Commission.  The  costs  under  Option  C  would  be  higher  than  under  Option  B,  as 
more frequent and prescriptive reporting would be required. The costs on local authorities 
are  also  higher  under  Option  C  than  Option  B,  as  more  frequent  engagement  would  be 
required. For both Options B and C, it is assumed that any engagement required between 
the Commission and Member States would be undertaken and meetings that would have 
taken place for other purposes, so there are no additional meetings for either. Hence, the 
Commission  benefits  administratively  from  both  options,  as  neither  need  the  costs 
associated  with  the  consultancy  contract  in  Option  A  to  be  incurred;  this  saving  also 
outweighs the need to develop a reporting template under Option C.  

Table 21-3: Actions required under each of the short-listed options 

Member  States 
(MS) 

Local 
authorities 
(LAs) 

Others 

-  Engage  with 
consultants 

-  Engage  with 
consultants 

for 

Costs 

- 
consultancy 
contract 

Option 

Commission 

A. 
current approach 

Maintain 

- Commission and 
manage 
consultancy 
contract 

- 
Prepare 
monitoring  report 
on  the  basis  of 
consultancy 
report 

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Commission 
B. 
impacts 
monitors 
with support of MS 
in an Expert Group 

- 
Prepare 
monitoring  report 
on  basis  of  MS 
reports 

C. Reporting under 
CVD 
in 
line/integrated 
with 
procurement 
Directives 

public 

Develops 

- 
reporting 
template for MS 

Prepare 
- 
monitoring  report 
on  basis  of  MS 
reports 

Potential 

- 
monitoring 
systems set up 

Potential 

- 
monitoring 
systems set up 

-  Engage  with 
national 
authorities 
(likely that more 
LAs 
involved 
than in Option 1) 
least  every 
at 
five years 

-  Engage  with 
national 
authorities 
(likely that more 
LAs 
involved 
than in Option 1) 
at 
least  every 
three years 

Engagement 
- 
local 
with 
authorities  and 
other 
national 
stakeholders 

- 
Prepares 
evaluation report 
the 
for 
Commission 
at 
least  every  5 
years  

Engagement 
- 
with 
local 
authorities  and 
national 
other 
stakeholders  at 
least every three 
years 

Prepares 
- 
evaluation report 
the 
for 
Commission 
at 
least every three 
years  

Source: Assessment undertaken for this report 

Table  21-4:  Qualitative  assessment  of  relative  costs  by  actor  (compared  to 
maintaining the current approach) 

Option 

Commission 

Member  States 
(MS) 

Local 
authorities 
(LAs) 

Others 

Commission 
B. 
monitors 
impacts 
with support of MS 
in an Expert Group 

C. Reporting under 
CVD 
in 
line/integrated 
with 
procurement 
Directives 

public 

 

 

 

 

As  no  additional 
to 
meetings 
convene (as there 
is  no  consultancy 
report 
to 
manage) 

As a more active 
role  required  of 
Member States 

As there will be a 
need  for  more 
involvement 
in 
order to respond 
to 
Member 
States’  
questions  about 
the Directive 

As there will be a 
need to set up a 
monitoring 
system,  at  least 
to  contact  local 
authorities  and 
bring 
together 
any  information 
received  

 

 

 

 

As  no  additional 
meetings 
to 
convene (as there 
is  no  consultancy 
to 
report 
manage), 
but 
there  would  be  a 
template 
to 
prepare 

As a more active 
role  required  of 
Member  States, 
and  on  a  more 
basis 
frequent 
compared 
to 
Option B 

As there will be a 
need  for  more 
involvement 
in 
order to respond 
to 
Member 
States’  
questions  about 
the 
Directive, 
and  on  a  more 
frequent 
basis 
than for Option B 

As there will be a 
need to set up a 
monitoring 
system,  at  least 
to  contact  local 
authorities  and 
bring 
together 
any  information 
received 

Source: Assessment undertaken for this report 

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Key: Assessment ranges from “” (option reduces the costs significantly for this actor 
compared to maintaining the current approach) through “-” (option has no effect for this 
actor compared to maintaining the current approach) to “” (option increases the costs 
significantly for this actor compared to maintaining the current approach) 

Combining  the  results  of  the  two  levels  of  assessment  (i.e.  Table  21-2  and  Table  21-4) 
suggests  that  the  preferred  option  depends  on  the  balance  of  the  benefits  of  the  more 
prescriptive  approach  set  out  in  Option  C  (or  Option  D,  whichever  proves  to  be  more 
politically acceptable) that is likely to deliver more complete results and Option B, which is 
less prescriptive and so potentially less complete. However, it is important to recall that 
reporting under both of these options would still effectively be voluntary. Given that on the 
basis  of  the  assessment  undertaken  within  this  evaluation,  it  was  not  possible  to 
conclusively decide between Option B and Option C, the best approach might be for the 
Commission to adopt a prescriptive approach  as proposed in Option C. However, as the 
use of the prescriptive template would be voluntary, it would be left up to Member States 
to  decide  whether  there  is  sufficient  benefit  in  using  this  template  on  the  basis  of  the 
implications for administrative costs in their respective national systems.  

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ANNEX 14: OVERVIEW OF RELEVANT POLICIES AND INSTRUMENTS (SUPPORTING 

COHERENCE Q10)  

Overarching strategies 

There are a number of overarching strategies which set out the general framework under 
which Directive 2009/33 contributes to, and these include high level environmental targets 
covering a range of sectors.   

The  Europe  2020  Strategy  (European  Commission  2010)  sets  out  a  series  of  targets 
including  those  aimed  at  reducing  CO2  and  improving  energy  efficiency.  These  targets 
include a 20% reduction in EU GHG emissions from 1990 levels by 2020; 40% by 2030 
(domestic); and 80% by 2050. It is within this framework that emissions from transport 
must also be addressed to meet these targets.  Hence, all targets aimed at reducing CO2 
and energy efficiency implicitly include vehicles. In addition, part of the justification for the 
policy was to ensure energy security of supply, a target of 20% of energy from renewables 
and a 20% increase in energy efficiency.  The targets also encompass smart and inclusive 
growth, with relevant actions to promote innovation, competitiveness and growth in Europe 
(e.g. 3% of the EU’s GDP to be invested in R&D). There are also targets for employment 
(75% of 20-64 year olds to be employed). 

2030  Framework  for  Climate  and  Energy  Policies  (European  Council  2014):  EU 
leaders agreed on a binding target to reduce EU domestic greenhouse gas emissions by at 
least 40% below the 1990 level by 2030. Reducing GHG emissions and the risks related to 
fossil  fuel  dependency  in  the  transport  sector  are  highlighted  as  being  important.  The 
Framework calls for further examination of instruments and measures for a comprehensive 
and  technology  neutral  approach  for  the  promotion  of  emissions  reduction  and  energy 
efficiency  in  transport,  for  electric  transportation  and  for  renewable  energy  sources  in 
transport  also  after  2020.  Such  measures  should  contribute  towards  achieving the  40% 
reduction in GHG emissions target.  

Transport  White  Paper  (European  Commission  2011):  contains  a  high-level  goal  to 
reduce GHG emissions from the transport sector by 60% by 2050 (against 1990 levels).  
There are also 10 further goals for a competitive and resource efficient transport system.  
Whilst the objectives of the CVD complement most of these goals, the way in which the 
objectives of the CVD are to be achieved (inputs to the intervention) are in contradiction 
to some of these goals, in particular, to “halve the use of ‘conventionally-fuelled’ cars in 
urban  transport  by  2030  […]”  (goal  1).  Whilst  the  aim  of  the  CVD  is  to  increase  the 
proportion of clean vehicles by stimulating their public procurement, the case study of the 
monetisation methodology (see Annex 9) reveals that the use of the methodology tends 
to favour diesel vehicles, rather than other alternatively fuelled-vehicles (AFVs).  

The CARS 21 Final Report (European Commission  2012, European Commission 2014) 
(part of the CARS 2020 process) sets out a strategic vision for the automotive sector for 
2020 and specific recommendations on a number of policy areas that are of importance to 
the  automotive  sector.  Key  aspects  of  relevance  include  ‘new  vehicles  purchased  by  EU 
customers, which are clean in terms of regulated pollutants, more fuel-efficient, quiet, safe 
and connected’; ‘a portfolio of propulsion technologies, dominated by advanced combustion 
engine technology, although increasingly electrified’; and ‘the deployment of vehicles with 
alternative powertrain concepts (such as electric and fuel cell vehicles)’.  The objectives of 
CVD are coherent with these key aspects of the strategic vision. In terms of reducing CO2 
from vehicles, the key messages highlight the need to reduce CO2 from HDVs, with a first 
step  ensuring  there  is  an  appropriate  method  for  evaluating  their  CO2  emissions  (whole 
vehicle  rather  than  engine).  In  terms  of  reducing  pollutant  emissions,  key  messages 
mention the need for a new test cycle and test procedure for measuring fuel consumption 
and emissions that is more representative of real-world driving. It is suggested that this 
should be complemented by measures controlling in-use vehicle emissions with the aim of 
delivering a timely reduction of real-world pollutant emissions and therefore contributing 

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to  improved  air  quality.    Again,  these  aims  to  reduce  CO2  emissions  from  vehicles,  but 
recognising the need to address lack of appropriate HDV data, are coherent with the CVD.  

The  Strategy  for  reducing  Heavy-Duty  Vehicles’  fuel  consumption  and  CO2 
emissions (European Commission 2014) sets out a clear, coherent policy framework for 
stakeholders,  indicating  likely  regulatory  developments,  thereby  facilitating  decision-
making and investment planning. The main objective of the Strategy is to curb HDV CO2 
emissions in a cost-efficient and proportionate way for stakeholders and society. Key short-
term actions include a series of initiatives foreseen in the Transport White Paper reinforcing 
existing EU policies that directly or indirectly contribute to curbing HDV fuel consumption 
and CO2 emissions; and an action to address the identified knowledge gap by measuring 
HDV  fuel  consumption  and  CO2  emissions,  as  well  as  certifying  and  reporting  newly 
registered  vehicles’  CO2  emissions  –  with  plans  for  the  Commission  to  make  legislative 
proposals  to  this  end  in  2015.  Whilst  CVD  aims  to  promote  clean  and  energy-efficient 
vehicles,  it  is  hindered,  in  part,  by  the  lack  of  data  for  HDVs.  Therefore  forthcoming 
legislation  in  this  area,  including  addressing  this  data  gap,  will  be  of  assistance  when 
applying the CVD in the future.  

The Sustainable Development Strategy (Council of the EU 2006): sets out a number of 
high level objectives that are coherent with the Clean Vehicles Directive, including aiming 
to ensure high level of protection and improvement of the quality of the environment; to 
prevent/reduce environmental pollution whilst promoting sustainable consumption; and to 
increase global market share in the field of environmental technologies and eco-innovations 
(thus  promoting  competitiveness),  while  respecting  the  limits  of  the  planet’s  natural 
resources. 

The Thematic Strategy on Air Pollution (European Commission 2005) was launched by 
the Commission in 2005 in order to make progress towards a long-term EU objective: “to 
achieve levels  of air quality that do not result  in  unacceptable impacts on, and risks to, 
human health and the environment”. The strategy set out intensions to simplify air quality 
legislation  (see  Air  Quality  Directive  2008/50/EC  below).  With  regards  to  transport  in 
particular,  the  Strategy  aimed  to  encourage  a  shift  towards  less  polluting  modes  of 
transport, alternative fuels, reduced congestion and the internalisation of externalities into 
transport costs. The aims of the CVD are coherent with the intensions of the strategy, in 
terms  of  aiming  to  reduce  air  pollutant  emissions,  and  encouraging  a  shift  towards  less 
polluting modes of transports/use of alternative fuels.  

The 7th Environmental Action Programme (EAP) (European Commission 2013) sets 
out three priority objectives which include to protect, conserve and enhance the Union’s 
natural  capital;  to  turn  the  Union  into  a  resource-efficient,  green  and  competitive  low-
carbon  economy;  and  to  safeguard  the  Union’s  citizens  from  environment-related 
pressures and risks to health and well-being.  

Clean  Air  Programme  for  Europe  (European  Commission  2013)  aims  to  propose 
legislation  to  reduce  harmful  emissions  in  the  longer  term  which  contribute  to  poor  air 
quality and damage the natural environment. It also aims to promote measures that also 
mitigate atmospheric warming and climate change. The measures set out in the strategy 
build  upon  those  originally  set  out  in  the  Thematic  Strategy  on  Air  Pollution  (European 
Commission 2005). As Member States have struggled to comply with air quality standards, 
the strategy also aims to tackle the reasons for the wide-spread non-compliance. Where 
Options 1 and 2a of the CVD are applied and tailored to local needs, the CVD will enable 
local authorities to address air quality concerns. However, as mentioned earlier, there may 
be issues with using the monetisation methodology (Option 2b) if air quality is a particular 
objective that an authority is aiming to address (if diesel vehicles are selected).  

European Energy Security Strategy (European Commission 2014) includes short term 
measures to help Member States cope with supply risks (e.g. increasing stocks, developing 
emergency infrastructure, reducing short-term energy demand and switching to alternative 
fuels).  Medium  to  long-term  challenges  are  also  covered,  including  increasing  energy 

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efficiency  and  reaching  the  proposed  2030  energy  and  climate  goals,  as  well  as  other 
measures to improve infrastructure and the internal market.  The strategy states that the 
EU’s dependency on oil needs to be reduced, in particular in the transport sector. Therefore 
in order to reduce EU energy dependence, substantial changes to the energy system in the 
medium to long term, including calls for shifting to alternative fuels and improving energy 
efficiency in transport, are required. The CVD is coherent with the objects of the strategy, 
including working towards reducing the EU’s dependence on oil.  

Whilst the CVD appears to be largely complementary to the objectives of the overarching 
strategies, it is the unintended outcomes of applying the provisions of the CVD (i.e. the 
monetisation methodology), that are contradictory in some instances, particularly where 
overarching strategies are aiming to be technology neutral, or specifically encouraging the 
uptake and use of alternatively fuelled vehicles.  

 CO2 legislation 

There are a number of important supply- and demand-side measures that affect CO2 from 
road transport vehicles in the EU.  

Supply-side CO2 measures 

In terms of CO2 the main EU supply-side legislation is in the form of the Light Duty Vehicle 
(LDV) CO2 Regulations for passenger cars and vans:  

  Passenger car CO2 Regulation (443/2009) (European Commission 2009): sets 
a fleet-wide average target of 130 gCO2/km for new passenger cars to be met by 
2015, and a target for 2021 of 95 gCO2/km.  

  LCV CO2 Regulation (510/2011) (European Commission 2011): sets a fleet-wide 
average target for new light commercial vehicles of 175 gCO2/km by 2017 and 147 
gCO2/km for 2020.  

General  objectives  for  the  Regulations  include  providing  a  high  level  of  environmental 
protection, improving energy security and fostering the competitiveness of the European 
automotive  industry  and  encourage  innovation  in  fuel  efficiency  technologies.  The  CVD 
works alongside these Regulations as one of two main EU-level demand-side measures. As 
supply-side measures, the Regulations aim to reduce the average CO2 emissions from new 
passenger cars and vans, whereas the CVD aims to stimulate the public procurement of 
cleaner and more energy efficient vehicles.  

Demand-side CO2 measures 

As mentioned, the CVD is one of two main demand-side measures, which aim to reduce 
CO2  emissions  through  influencing  the  demand  for  certain  vehicle  types  (it  also  aims  to 
address air pollutant emissions). The second main demand-side measure is the Car  CO2 
Labelling Directive.  

Directive relating to the availability of consumer information on fuel economy and 
CO2  emissions  in  respect  of  the  marketing  of  new  passenger  cars  (“Car  CO2 
Labelling Directive” - 1999/94/EC) (European Commission 1999): requires fuel economy 
and CO2 performance information to be publicly provided for all new cars on sale (European 
Commission,  1999).  The  objectives  are  therefore  to  raise  consumer  awareness  on  fuel 
economy and CO2 emissions of new passenger cars offered for sale or lease in the Union 
in order to: enable more informed purchase decisions; influence consumer choice in favour 
of cars which use less fuel and thereby emit less CO2; and to encourage manufacturers to 
take steps to reduce the fuel consumption of the cars they manufacture.  

Both the CVD and the Car CO2 Labelling Directive encourage the demand for, and uptake 
of clean and energy-efficient vehicles.  The CVD uses public procurement as a mechanism 
to stimulate the uptake of low carbon vehicles, helping to develop an early market for such 
vehicles and to bring down costs, whereas the Car CO2 Labelling Directive does this through 

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aiming to improve consumers’ knowledge, enabling them to differentiate between vehicles 
and demand better fuel efficiency. The CVD therefore complements rather than replicates 
this legislation.  

In  addition  to  the  Car  CO2  Labelling  Directive,  the  majority  of  Member  States  use  fiscal 
instruments  at  the  national  level  to  reduce  CO2  from  road  transport  vehicles,  such  as 
vehicle taxation, which aim to have an effect on vehicle demand. Twenty EU Member States 
currently apply some form of  CO2 tax to the registration and/or ownership of passenger 
cars  (ACEA  2015).  Again,  the  CVD  can  be  viewed  as  complementary  to  these  national 
measures, and can work in parallel in order to stimulate the purchase of clean and energy 
efficient vehicles.  

Infrastructure, fuel, and energy carrier policies 

There are a number of policies relating to infrastructure, fuel and energy carriers which are 
of  relevance  when  considering  clean  and  energy  efficient  road  transport  vehicles.  These 
include the following: 

Directive  on  the  deployment  of  alternative  fuels  infrastructure  (2014/94/EU) 
(European  Commission  2014):  sets  out  a  common  framework  of  measures  for  the 
deployment of alternative fuels infrastructure with the objective of minimising dependence 
on oil and to reduce the environmental impact of transport. The Directive sets out minimum 
requirements  for  alternative  fuel  infrastructure  (including  recharging  points  for  electric 
vehicles, refuelling points for natural gas and hydrogen), as well as setting out common 
technical  standards  for  equipment  needed  and  user  information.  This Directive  supports 
the  CVD  through  ensuring  that  the  relevant  alternative  fuel  infrastructure  is  in  place  to 
support  an  increase  in  the  share  of  alternatively-fuelled  road  transport  vehicles,  further 
promoting their uptake and use. 

The Renewable Energy Directive (RED) (2009/28/EC) (European Commission 2009) 
established  a  common  framework  for  the  production  and  promotion  of  energy  from 
renewable sources (European Commission, 2009). The goal related to a share of energy 
from  renewable  sources  in  the  transport  sector  was  increased  to  at  least  10%  of  final 
energy  consumption  by  2020  under  the  RED.    The  Fuel  Quality  Directive  (FQD) 
(2009/30/EC)  (European  Commission  2009)  established  minimum  specifications  for 
petrol  and  diesel  fuels  for  use  in  road  and  non-road  mobile  applications  for  health  and 
environmental reasons.  This includes targets for reducing the GHG intensity of transport 
fuels by 2020, as well as facilitating lower air pollutant emissions. Article 7a of the FQD 
requires fuel suppliers to reduce the greenhouse gas intensity of energy supplied for road 
transport (Low Carbon Fuel Standard). 

The Renewable Energy Directive and Fuel Quality Directive complement other supply-side 
legislation in promoting the reduction of CO2 emissions from transport (at various stages 
in the life cycle) and diversification of transport fuels (thus supporting energy  security), 
and all can be considered coherent with the CVD.  

End-of-Life vehicle policies 

There  are  two  main  end-of-life  policies.  The  End-of-Life  Vehicle  (ELV)  Directive 
(2000/53/EC)  (European  Commission  2000)  aims  to  primarily  prevention  or  reduce 
waste from vehicles.  This Directive requires that an average of at least 80% of the mass 
of an ELV is to be reused or recycled and another 5% or more of its mass is energetically 
recovered  in  each  EU  Member  State.  In  2015  the  rates  will  increase  to  85%  and  10%, 
respectively.  

Directive  2006/66/CE  (European  Commission  2006)  on  batteries  requires  a  recycling 
rate of 50% for electric vehicle Lithium-Ion batteries. It also requires the recycling of 65% 
by average weight of lead-acid batteries and accumulators, including the recycling of the 
lead  content  to  the  highest  degree  that  is  technically  feasible  while  avoiding  excessive 
costs. The Directive does not specifically address nickel-metal hydride batteries that are 
sometimes used in hybrid cars.  

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The CVD is focussed on the ‘in use’ phase of a vehicle’s life cycle, whereas the ELV Directive 
and Directive 2006/66 are  focussed on the ‘disposal’ phase. However, potential conflicts 
may be identified with regards to the technology choices available (and promoted via the 
application of the CVD) to reduce CO2 emissions and the impacts on recycling and recovery. 
Encouraging  the  uptake  and  use  of  more  energy  efficient  vehicles  may  have  negative 
implications for recycling and recovery at the end-of-life stage – in particular, making it 
more  challenging.  The  treatment  of  batteries  (used  in  hybrid  and  electric  vehicles)  may 
pose  challenges  for  reaching  high  levels  of  recycling  in  the  future.  However,  significant 
progress has been made in recent years, with a particular focus on recovering the valuable 
rare earth elements and a number of developments in Japan, France, Belgium, Germany, 
the USA and Norway (Optimat 2013).  For example, an industrial-scale battery recycling 
operation  (for  Li-ion  and  NiMH  batteries)  has  opened  in  Germany  (Umicore  website, 
accessed January 201558). 

Air quality and noise legislation  

Regulation 715/2007/EC on type approval (“Euro standards”) (European Commission 
2007) sets out the Euro 5 and 6 Emission standards for light passenger and commercial 
vehicles59 whereas Regulation 595/2009 (European Commission 2009) sets out Euro VI 
for heavy duty vehicles60. Further supply-side measures, the Regulations require vehicle 
manufacturers to achieve the limit values (in mg/km) that have been set out for emissions 
of a range of pollutants, including carbon monoxide (CO), total hydrocarbons (THC), non-
methane hydrocarbons  (NMHC), oxides of nitrogen (NOX), particulate matter (PM) (light 
duty and heavy duty vehicles), methane (MH4) and Ammonia (NH3) (heavy duty vehicles 
only). Over time, the achievement of increasingly stringent emission standards will support 
the  availability,  promotion  and  penetration  of  clean  and  energy  efficient  vehicles  in  the 
European fleet, thus supporting the objectives of the CVD. 

The  Air  Quality  Directive  on  Ambient  Air  Quality  (AQD)  (2008/50/EC)  (European 
Commission 2008) regulates concentrations of a range of air pollutants, including sulphur 
dioxide (SO2), nitrogen dioxide (NO2), particulate matter (PM10, PM2.5), carbon monoxide 
(CO), ozone (O3), benzene and lead. Local and regional Member State administrations are 
required to develop and implement air quality management (AQM) plans in areas where 
exceedances  occur  in  the  air  quality limit  and target  values  as  set  out  by  the  Directive. 
Whilst the CVD requires that the operational energy and environmental impacts to be taken 
into  account  should include  emissions  of  NOX,  NMHC  and  particulate  matter  (along  with 
61),  the  application  of  the  monetisation 
energy  consumption  and  emissions  of  CO2
methodology  can  result  in  diesel  vehicles  being  prioritised  (see  Annex  9)  –  which  could 
have negative implications for authorities experiencing areas of poor air quality and striving 
to meet the air quality limit and target values as set out under the AQD (even new Euro 6 
diesel vehicles emit higher levels of NOX compared with new petrol vehicles).  

The  main  aim  of  the  Environmental  Noise  Directive  (END)  (2002/49/EC)  (European 
Commission 2002) is to “define a common approach intended to avoid, prevent or reduce 
on  a  prioritised  basis  the  harmful  effects,  including  annoyance,  due  to  exposure  to 
environmental  noise”.  The  Directive  aims  to  provide  a  basis  for  developing  Community 
measures to reduce noise emitted by major sources, and specifically identified from road 
vehicles (in addition to other sources of noise). The CVD complements the END by enabling 
procurers to consider other environmental impacts, which may include noise.  

58 http://www.batteryrecycling.umicore.com/supply/HEV_EV/  

59 Euro 5 came into force in September 2009. Euro 6 standards apply from 1st September 2014 for approval and 

1st January 2015 for the registration and sale of new types of cars. 

60 Euro VI came into force in January 2013 for heavy duty vehicle.  

61 Article 5(2) 

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ABBREVIATIONS 

ACEA 
AEGPL 
AFVs 
AQG 
BEUC 
CEMR (CCRE) 
CLEPA 
CNG 
CO2 
COMPRO 

CONCAWE 

CVD 
DfT 
EBA 
EBB 
EBTP 
ECF 
EEV 
EHA 
EIB 
EMTA 
ERTRAC 
EU  
EU-28 
FCH-JU 
FIA 
GDP 
GHG 
GPP 
IA 
ICLEI 
IPCC 
IRU 
JAMA 
KAMA 
kg 
km 
LDV 
LPG 
MJ 
MS 
NGVA 
NOX 
NMHCs 
POLIS 

PROCURA 
PSOs 
REFIT 

European Automobile Manufacturers' Association 
Association of the European LPG Industry 
Alternatively Fuelled Vehicles 
Air Quality Guidelines 
European Consumer Organisation 
The European Network for Rural Development (city network) 
European Association of Automotive Suppliers 
Compressed Natural Gas 
Carbon Dioxide 
Common Procurement of collective and public service transport 
vehicles 
European Oil Company Organisation for Environment, Health and 
Safety 
Clean Vehicles Directive 
Department for |Transport (UK)  
Euro Biogas Association 
European Biodiesel Board 
European Biofuels Technology Platform 
European Climate Foundation 
Enhanced environmentally friendly vehicle 
European Hydrogen Association 
European Investment Bank 
European Metropolitan Transport Authorities 
European Road Transport Research Advisory Council 
European Union 
28 Member States of the European Union 
Fuel Cells and Hydrogen Joint Undertaking 
International Automobile Federation 
Gross Domestic Product 
Greenhouse Gas 
Green Public Procurement 
Impact Assessment 
Local Governments for Sustainability (city network) 
Intergovernmental Panel for Climate Change 
International Road Transport Union 
Japan Automobile Manufacturers' Association 
Korea Automobile Manufacturers' Association 
Kilogram 
Kilometre 
Light Duty Vehicles 
Liquefied petroleum gas 
Megajoule 
Member State 
Natural & Bio Gas Vehicle Association 
Nitrogen oxides NO and NO2 
Non-Methane Hydrocarbons 
Network of European Cities and Regions for innovative transport 
solutions 
Green Fleet Procurement Models 
Public Service Obligations 
REgulatory FITness and performance programme 

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transport vehicles 

SCM 
TED 
WHO  

Standard Cost Model 
Tenders Electronic Daily 
World Health Organisation  

228