FEBRUARY 2013 Revision of the EU Thematic Strategy on Air Pollution UITP (Union Internationale des Transports Publics) is the international organisation of public transport, it is based in Brussels and covers all urban, suburban and regional public transport modes (bus, metro, light rail, regional rail and waterborne public transport). It gathers over 3.100 members worldwide, public transport operators, their authorities and suppliers. In the European Union, the UITP EU Committee (EUC) represents the views of the public transport undertakings of the 27 member countries. It is closely following and participating in the elaboration of the different European policies and initiatives that have an impact on urban, suburban and regional public passenger transport. Key facts for public transport in the EU 27: Passenger journeys: 60 billion/year, more or less equally shared between road modes (mainly bus) and rail modes (urban, suburban and regional rail) Economic value of public transport services: 130-150 billion/year or 1 1.2% of GDP Employment: direct employment 1.2 million and indirect employment 2-2.5 indirect jobs for each direct job on average
1. Executive Summary In view of the consultation on the EU Thematic Strategy on Air Pollution and Related Policies, European Union (EU) public transport undertakings represented by UITP would like to highlight the following: While action to reduce transport emissions alone cannot remove the causes of poor air quality in cities, it can play an important role in working towards the achievement of the EU limit values and delivering health benefits. Actions to reduce emissions from vehicles should be achieved through a combination of measures, notably from shifting to alternative sustainable modes and to cleaner fuels and improved vehicle technology. This should be complemented by better managing transport demand to increase the efficiency with which we use transport. The EU should support and enable actions at the local level and earmark more resources for the development of sustainable urban mobility based on high quality networks, low emissions fuels and the electrification of the transport sector, in particular through the Smart Cities and Communities Initiative. Public transport undertakings have already made considerable strides in addressing air pollutants from the sector. Placing additional disproportionate burdens on a sector that is already under substantial cuts to funding could result, in these tight budgetary times, lead to reduced public transport services. Pushing public transport ridership away to singleoccupancy cars will have adverse emissions implications. Local authorities/public transport undertakings are committed to support the achievement of limit values with the means at their disposal. However, in some cases these means are limited and for some measures public acceptance is rather low. Member States should remain responsible for paying respective fines and should not hand down fines to local authorities/public transport undertakings. The relationship between air pollution and climate change needs particular attention. The Commission should support policies that encourage a shift to sustainable modes of transport as this can greatly benefit wider sustainability objectives such as the reduction of carbon dioxide (CO 2 ), oil dependence, the competitiveness of Europe s economy while at the same time improving air quality. 2. Introduction Overall, EU air quality legislation has done much to help minimise health risks caused by air pollution. It has supported coordination of policies at the EU level and given guidance to national, regional and local policy makers. Public transport offers alternative modes of transport to the private motor car. By using less space and energy than comparable travel in private vehicles, public transport helps relieve traffic congestion, cut CO 2 and air pollution from road transport.
The use of public transport must therefore be encouraged if an effective and complete review of the EU Thematic Strategy on air pollution is to be developed. The review should also be careful of placing disproportionate burdens on a sector that is already facing substantial cuts to funding as this could result in these tight budgetary times affect frontline public transport services. Pushing public transport ridership to single-occupancy cars will have adverse air quality implications. 3. Controlling emissions at source Effective policies have been put in place over the years to control emissions from a number of sectors, notably the road transport sector through vehicle emissions standards. As a consequence, emissions of several pollutants have reduced substantially in the last two decades. In spite of these measures, there remains widespread non-compliance of the current air policy framework from Member States and air quality remains a real issue in some cities. While action to reduce transport emissions alone cannot remove the causes of poor air quality in cities, it can play an important role in working towards the achievement of the EU limit values and delivering health benefits. Buses and bus systems have already been the target for various EU environmental legislations (including air pollution) in the past. Both, bus manufacturers as well as public transport undertakings have made considerable efforts in cleaning up bus fleets and ensuring that travelling by bus today is green mobility. This fact should be taken into consideration if eventually further legislation on air pollutant values for buses is proposed. As a consequence of regulation 1999/96 local emissions from buses have been reduced considerably. Today public transport undertakings purchase very clean EURO V or EEV buses and regulation 595/2009 on the introduction of EURO VI for heavy duty vehicles will result in another reduction of emissions close to the detection limit. Especially the step from Euro V to Euro VI will require considerable investments for manufacturers as well as for public transport undertakings and bind huge resources on the side of bus manufacturers. At the same time the implementation of stricter Euro emission classes has resulted in increased fuel consumption in the past years. To try to compensate the efficiency penalties by Euro VI additional vehicle and drive train related measures are necessary. Against background also any eventual further legislation on limitation of pollutants from HDV engines (Euro VII?) should be seriously questioned. 4. Addressing compliance problems at source An important driver for present compliance problems is that some source legislation is not delivering as expected. To address this, the review will need to eliminate discrepancies between test cycle results and real-life driving conditions. Standards failings have been further exacerbated by Member States failure to control traffic volumes. As public transport uses limited road space more efficiently, it should be put forward as a key measure to help Member States control traffic volumes. For example, a journey from home to work by car consumes 90 times more urban space and community financed infrastructure than the same journey made by metro, and 20 times more space than if it had been made by bus or tram. Many UITP members have made additional significant efforts to decrease the average age of bus fleets and to introduce a variety of cleaner fuels and new technologies. It should be noted that many of the cleaner technologies come with a higher price tag than the improved clean diesel internal combustion engine.
However for many local authorities/public transport undertakings these newer technologies are still unaffordable, and strict air pollutant limits may result in lower service levels making individual car use the only option. While transport has become cleaner, increased volumes of private vehicles mean that it remains a major source of noise and local air pollution. Any framework should not send the wrong signals to policy and decision makers. It would be counterproductive if local authorities/operators would cut services in order to compensate increased costs for a reduced number of buses equipped with the newest technologies. In fact, financial support for the purchase of new cleaner public transport vehicles including new technologies as well as infrastructure is strongly advised. 5. Promoting a shift to cleaner forms of transport Actions to reduce emissions from vehicles should be achieved through a combination of measures, notably from shifting to alternative sustainable modes and to cleaner fuels rather than just an improvement in vehicle standards. This should also be complemented by better managing transport demand to increase in the efficiency with which we use transport. On average, for every kilometre travelled public transport is over three times more efficient than a private car. A standard diesel city bus remains the backbone of most public transport networks and already delivers low emissions trips per passenger kilometre when compared to a private car. Electrically powered public transport, such as trams and metros, has zero point of use emissions. In this context, UITP strongly advises that public transport vehicles are exempted from driving bans in low emission/environmental zones. An integrated and reliable public transport system is crucial to encouraging people out of their cars. A higher share of travel by collective transport will allow for increasing the density and frequency of service, thereby generating a virtuous circle for public transport modes. Access restrictions, demand management and land-use planning can also lower traffic volumes. Facilitating walking and cycling should become an integral part of urban mobility and infrastructure design to address air quality. Actions such as these should be encouraged and supported as part of the review. Road pricing and the removal of distortions in taxation can also assist in encouraging the use of public transport and the gradual introduction of alternative cleaner propulsion in the sector. Any road charging scheme should aim to establish a level playing field with other modes, in particular rail bound. The aim is to enable a balanced and fair pricing scheme for mobility as part of supporting general transport policy objectives. 6. Developing cleaner vehicles for urban transport Alongside a shift to sustainable transport, the gradual phasing out of conventionally fuelled vehicles from the urban environment will be a major contribution to a significant reduction of oil dependence, greenhouse gas emissions and local air and noise pollution in the future. At the same time, it will have to be complemented by the development of appropriate fuelling/charging infrastructure for all new vehicles. The Smart Cities and Communities Initiative is well placed to speed up the development of innovative solutions needed. Examples of lighthouse projects that could deliver a step change in addressing air pollution amongst others include energy and fuelling infrastructure and the operation of alternative carriers for public transport; and using electric public transport
vehicles that are able to exchange surplus energy through regenerative breaking into the energy system. 7. Responsibility for action While Member States have signed up to limit values, responsibility for action often lies at the local level. Local authorities/public transport undertakings are committed to support the achievement of limit values with the means at their disposal. However, in some cases these means are limited and for some measures public acceptance is rather low. For instance, some public transport/local authorities often find it difficult to implement access restrictions, such as low emissions zones or congestion charges, due to opposition by the public and businesses. In addition, they cannot change source policies, influence long range pollution or weather conditions. As such, Member States should remain responsible for paying respective fines and should not hand down fines to local authorities/public transport undertakings. 8. Synergies with air pollution and other policies Coherence and synergy of EU air pollution policies with other legislation should be addressed in the revised Thematic Strategy. The relationship between air pollution and climate change needs particular attention. The implementation of Euro VI itself will not reduce fuel consumption/co 2 emissions. Climate policies that encourage a shift to sustainable modes of transport can greatly benefit other sustainability objectives such as the reduction of oil dependence, the competitiveness of Europe s economy as well as health benefits, especially improved air quality. This makes it a compelling case for the EU to step up its efforts in this area to ensure greater policy coordination.