ACEA comments on the proposal for. Monitoring and Reporting of CO2 emissions and fuel consumption of new heavyduty

Transcription

1 ACEA comments on the proposal for Monitoring and Reporting of CO2 emissions and fuel consumption of new heavyduty vehicles July 2017

2 KEY MESSAGES a. The industry supports the Commission s objective to increase transparency on the market based on data generated by VECTO. b. The monitoring and reporting scheme is necessary for authorities to tackle the knowledge gap regarding CO2 emissions from trucks in Europe; it is also a reliable tool enabling vehicle operators to take well-informed purchasing decisions. KEY RECOMMENDATIONS a. To collect and submit data on, as well as align timing for, vehicles subject to CO2 certification, to ensure the use of consistent and certified data for monitoring for the different vehicle classes. b. To refrain from publishing confidential data and secondary data that do not provide information on complete vehicles performance in terms of fuel consumption and CO2 emissions. c. To collect and report data available at the stage where the CO2 customer file is issued by VECTO i.e. when the truck leaves the production line of the OEM. ACEA Document 24/07/2017 1

3 INTRODUCTION The European Automobile Manufacturers Association (ACEA) welcomes the Commission s proposal for a Regulation on the monitoring and reporting of CO2 emissions from and fuel consumption of new heavy-duty vehicles. This legislative proposal is part of the European Commission s strategy to further decarbonise transport in Europe. It complements the computer calculation tool VECTO, developed by the European Commission with the support of the industry, model CO2 emissions from a wide variety of complete truck and trailer configurations. By 2019, VECTO will enable manufacturers to gradually provide certified CO2 values to their customers for new trucks produced. The industry supports the Commission s objective to increase transparency on the market based on data generated by VECTO. The monitoring and reporting scheme is necessary for authorities to tackle the knowledge gap regarding CO2 emissions from trucks in Europe; it is also a reliable tool enabling vehicle operators to take well-informed purchasing decisions. Information on vehicles performance in terms of fuel consumption and CO2 emissions should therefore be made publicly available when relevant. ACEA Document 24/07/2017 2

4 However, we have comments about the wording on Art 2, Art 5 and Annex I. Article 2, Scope The proposal states that all vehicles of categories M3 and N3 fall within scope. However, the recently adopted Certification regulation will be implemented in phases and does only cover some N3 vehicles in the first phase (the groups 4, 5, 9 and 10 as defined in the Certification regulation, Art 24 Transitional provisions). Hence, we suggest that manufacturers should only be requested to collect and submit data on vehicles subject to CO2 certification. We ask the Commission for clarification of the scope and the intentions, both short term and long term. Scope for the monitoring and reporting A phased-in introduction is foreseen for the mandatory certification of CO2 emissions from heavyduty vehicles including the VECTO calculation: Vehicle classes 4, 5, 9, 10 are foreseen in the 1 st step by 2019, as these represent almost 80% of the CO2 emissions of heavy-duty vehicles in Europe; Vehicle classes 1, 2, 3 will be certified in a 2 nd step, and will be followed by vehicle classes 11, 12, 16; Finally, buses and coaches should be included in the CO2 certification procedure subsequent to trucks. As the monitoring and reporting scheme should be based on the certified CO2 values, the scope should be according to the phase-in introduction. Hence, we suggest that manufacturers should only be requested to collect and submit data on, as well as align timing for, vehicles subject to CO2 certification to ensure the use of consistent and certified data for monitoring for the different vehicle classes. Article 5, Monitoring and reporting by manufacturers We do support the procedure where we as manufacturers collect and report certain data based on production date. However, we are concerned over the definition of date of production. ACEA Document 24/07/2017 3

5 The proposal suggests that the date of production is defined as the date of signature of the certificate of conformity for EC Whole Vehicle Type Approval or the date of signature of the Individual Vehicle Approval certificate. This process for the Individual Vehicle Approval is one that we as the first vehicle manufactures have little control over. Trucks are often built in steps, were an incomplete cab-chassis is finalized by a 2 nd stage manufacturer, a bodybuilder Individual approval is done by dealers or distributors after the vehicle has been finalized by the bodybuilder, usually at time of registration of the vehicle. This date is not known to the first vehicle manufacturer. Furthermore, the lead time from the first vehicle manufacturer s production to registration of the vehicle can be significant, several months or even years. Hence, the proposed definition would result in inconsistency in the manufacturers data collection per calendar year. Instead, we suggest that: The production date for the CO2 monitoring of vehicles with the Individual Vehicle Approval should refer to the date when the vehicle leaves the first (base) manufacturer s production. The date of the CO2 customer file could be considered as the production date. Annex I, Data to be monitored and reported We agree that information on a vehicle s performance in terms of fuel consumption and CO2 emissions should be made publicly available. However, it is the performance of the complete vehicle that is of public interest. The certified input data from the manufacturers used to calculate the overall performance are confidential information, verified according to the procedure in the certification regulation, and should not be made public. The Commission propose to include certified and confidential input data on air drag losses of the cab-chassis in the data to be made publicly available Air drag data is one of many data points used for the CO2 emission simulation, and is not by itself of public interest It is not made public in any other regulation in the world, including the US. Air drag values are especially sensitive for competition and very costly to generate, making them public information will hurt the competitiveness of European vehicle manufacturers. ACEA Document 24/07/2017 4

6 Analysing this data requires very specific expertise, usually only available at the manufacturers themselves. Hence, only other manufacturers would be able to evaluate the values and retrieve sensitive R&D knowhow. This would not only reduce European manufacturers competitiveness, but also lead to less competition among those. The air drag value is determined under certain standardised conditions regarding assumption of generic bodywork and wind conditions. This data is not relevant for the actual vehicle in most cases which means making it public information would rather be misleading to the customer. Given that the type approval authorities will be responsible for ensuring that the data is accurate, there is no reason for making it public. If the legislators deem it important to disclose certain data, we would strongly suggest removing the Air drag value (CdxA) from Annex I, Part B Access to competitive input data ACEA supports that information on complete vehicles performance in terms of fuel consumption and CO2 emissions should be made publicly available. The CO2 performance of the complete vehicle information supports the objective of having more transparency and competition in the market regarding CO2 performance of trucks and to fill the knowledge gap regarding CO2 emissions from trucks in Europe. However, ACEA strongly rejects the unlimited publicity of certain data for several reasons: Making certain data publicly accessible will impact the global competitiveness of EU vehicle manufacturers when it comes to fuel-efficiency improvements. These data represent the technical know-how of Europe s truck manufacturers, which they have acquired through significant investments in R&D over the years. CdxA values, engine maps, and transmission loss maps are very valuable information for foreign competition. Other commercially sensitive information proposed to be disclosed, such as the names of suppliers or market shares of their components, would lead to market distortion. We are convinced that some suppliers will be disadvantaged if their sales numbers are to be revealed. Moreover, these data are certainly not relevant for the monitoring of CO2 emissions from heavy-duty vehicles, as they do not have any impact on the fuel efficiency performance of a vehicle. For instance, data on engine maps provides key information about the strategy of an OEM, which would be of advantage to non-eu manufacturers who try to compete with EU manufacturers. ACEA Document 24/07/2017 5

7 Access to this information should be restricted to parties with regulatory obligations. This data is certified in accordance with EU type approval procedures, and is normally only available to the technical services assigned to perform the necessary inspections and tests as well as to the Type Approval Authority granting the approval and providing the type approval certificate. It can be used to perform compliance checks already today. The certified input data from the manufacturers are used to calculate the overall performance of complete vehicles. Considering that European manufacturers design and develop complete vehicles, including engines, it makes more sense to provide the values for the overall performance of the vehicle instead of single component values. It is questionable whether the data sharing proposal as raised by some parties might conflict with today s antitrust rules e.g. market sensitive information on supplier used such as the name of the transmission supplier. In addition, some suppliers might be disadvantaged if their sales numbers are to be revealed, like currently proposed. Certain data are certainly not relevant for the monitoring and reporting scheme in general, and for public disclosure especially, as they do not have any impact on the fuel efficiency performance of a vehicle. Therefore, ACEA is not in favour of providing access to data that is related to know-how and that could undermine European competitiveness, such as: Air drag value (CdxA) VIN number ACEA Document 24/07/2017 6

8 A practical example with Air drag value (CdxA) Air drag data is one of many data points used for the CO2 emission calculation, and is not by itself of public interest. It is not made public in any other regulation in the world, including in the USA. Air drag values are especially sensitive for competition and very costly to generate; therefore, making them publicly available would seriously hurt the competitiveness of European vehicle manufacturers. Analysing this data requires very specific expertise, usually only available at the manufacturers themselves. Hence, only other manufacturers would be able to evaluate the values and retrieve sensitive R&D know-how. This would not only reduce European manufacturers competitiveness, but also lead to less competition among those. The air drag value is determined under certain standardised conditions regarding assumption of generic bodywork and wind conditions. This data is not relevant for the actual vehicle in most cases which means making it public information would rather be misleading to the customer. ACEA Document 24/07/2017 7

9 ABOUT ACEA ACEA represents the 15 Europe-based car, van, truck and bus manufacturers: BMW Group, DAF Trucks, Daimler, Fiat Chrysler Automobiles, Ford of Europe, Hyundai Motor Europe, Iveco, Jaguar Land Rover, Opel Group, PSA Group, Renault Group, Toyota Motor Europe, Volkswagen Group, Volvo Cars, and Volvo Group. More information can be found on ABOUT THE EU AUTOMOBILE INDUSTRY 12.6 million people or 5.7% of the EU employed population work in the sector. The 3.3 million jobs in automotive manufacturing represent almost 11% of EU manufacturing employment. Motor vehicles account for almost 396 billion in tax contributions in the EU15. The sector is also a key driver of knowledge and innovation, representing Europe's largest private contributor to R&D, with more than 50 billion invested annually. The automobile industry generates a trade surplus of about 90 billion for the EU. European Automobile Manufacturers' Association (ACEA) Avenue des Nerviens 85 B-1040 Brussels T F ACEA Document 24/07/2017 8