Comparison of options and conclusions

Comparison of options and conclusions

1. Simplification of legislation

In terms of efficiency, options 2 and 3 perform equally well, especially because both call for the current legal text to be replaced by technical equivalent or more appropriate UNECE regulations as far as possible, which should simplify the Regulation and in particular the associated technical implementing measures. For the new Regulation on approval and market surveillance of L-category vehicles, only the intention to use UNECE regulations can be indicated. The subsequent delegated acts containing technical details, to be developed after adoption of the Regulation, will clarify which specific text of the repealed implementing directives can be replaced with UNECE regulations.

Regarding efficiency, option 2 is better in terms of transposition and implementation costs and is expected to reduce the risk of delay in dealing with urgent matters or changes. As a result, the benefits of any new measures can be obtained more rapidly. Option 2 is therefore preferred.

2. Environmental measures

   1. New or revised environmental measures for the type-approval of new vehicles

      1. Revised lower emissions limits

The main criteria for comparing between the 5 different options over the short to medium term are implementation time and cost-effectiveness. Option 3 scores best for these aspects. However, over the long term, the disproportionately high HC, CO and PM emissions must be addressed, and this can only be achieved with option 5. Even option 5 will not be sufficient to bring emissions into line with the very low total vehicle mileage accumulated with L-category vehicles (2 – 3 % of total road vehicle mileage), but it is considered to be the most that can be done by the L-category vehicle industry to ensure clean vehicles over the long term. Therefore, the optimum solution will be a combination of a slightly modified option 3 (separate limits, which means no combined HC & NOx limits for all L-category vehicles) over the short to medium term (2013 – 2016 timeframe) and option 5 for the long term (2019–2020) depending on the results of an additional environmental effect study to be carried out by 2016. This strategy should provide industry with a longer lead-time and therefore help to mitigate the burden and the long-term effects of the current financial crisis on the industry. While option 3 is based on the self-regulation proposal put forward by the industry, the legal instrument used would be the new Regulation on approval and market surveillance of L-category vehicles, which will make these limits obligatory for type-approval.

Although PM will not be limited, the expectation is that the THC limit will automatically lead to a reduction in VOC, especially taking into account the particular composition and volatility of the particulates emitted by L-category vehicles in comparison to e.g. those emitted by diesel passenger cars.

2. Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicles

The advantages of using the stage-two WMTC only for L3e category vehicles over the short term and a revised WMTC other L-category vehicles over the medium to long term outweigh the disadvantages by far. Therefore, option 2 is the preferred solution for the long term. In order to provide industry with sufficient lead-time a transition towards the use of WMTC for all L-category vehicles is proposed as summarised in Annex XV, Ch. 1.2, Table 2. Certain L-category vehicles (L1B, L2e, L5e, L6e, and L7e) do not yet come under UNECE global technical regulation 2 (WMTC). The Commission will need to launch an initiative within UNECE to include these subcategories in the long term (2020).

3. Type-approval requirements for CO₂ measurement and fuel consumption determination and reporting

The ratings for effectiveness, efficiency and coherence are overall positive to highly positive for option 2. Consumers need to have additional information presented in a standardised form for them to be able to compare the fuel efficiency of different vehicles within the L-category and to be able to compare with alternative means of road transport. This will allow them to purchase the most fuel-efficient vehicle or to choose the optimum transport alternative in terms of fuel cost and will make them aware of the green house gas emissions per kilometre travelled. The motorcycle riders’ association, FEMA, for example welcomes the introduction of a compulsory labelling scheme, for which the data obtained through option 2 will be used as input. The preferred solution is therefore option 2. As L-category vehicles only contribute little to the overall CO₂ emissions of road transport as a whole, an explicit limit value was not deemed necessary. In fact, if the pollutant concerns of PTWs were addressed (currently their emissions are disproportionately high compared to all road transport based on mileage travelled), it would be advantageous if heavy, big passenger cars were to be substituted by light, flexible L-category vehicles. This may help to bring down the overall high fuel consumption of road vehicles and significantly reduce emissions of green house gas emissions like CO₂.

4. Evaporative emissions test and limit

As the high hydrocarbon emissions of L-category vehicles can only be influenced to a relatively small extent by type-approval measures addressing evaporative emissions, an effective low-cost measure that can be implemented quickly is preferable. The advantages of option 2 will become automatically available if more stringent emission thresholds will need to be fulfilled and the highest part of the financial burden to the manufacturers will already be amortised by the necessary hardware changes under this policy option to introduce revised tailpipe emission limits. Option 3 is estimated to be the only cost-effective way of reducing evaporative emissions from L-category vehicles and is therefore the preferred option.

5. Durability requirements

Option 1 was discarded as this makes the introduction of revised emission limits ineffective. Option 3 is regarded as very expensive and may inhibit manufacturers from introducing new products on the market. The introduction of durability requirements for L-category vehicles in option 2 already addresses the majority of the concerns identified at an acceptable cost to industry, so is therefore the preferred solution.

2. New measures to control vehicle emissions over vehicle life

   1. In-use conformity (IUC) testing and limits.

Owing to the many disadvantages, including impracticability and only moderate cost-effectiveness, IUC was discarded. However, this is one of the assumptions which will be re-examined in the environmental effect study referred to in chapter 6.2.1.1.

2. On-board diagnostic (OBD) systems and access to repair information

A distortion of competition arises in the internal EU market, as independent repairers are not able to retrieve standardised diagnostic on-board information from vehicles and are therefore not able to repair failures as effectively and efficiently as contract dealers and repairers. In the repair cycle (diagnosis and analysis of problem, repair of smallest identifiable component or ordering of replacement parts and replacement of smallest exchangeable unit) the availability of harmonised diagnostic information from the OBD system is essential for an independent dealer or even for a vehicle owner, to effectively and efficiently repair a vehicle. As option 3 is estimated to have a much better cost-effectiveness than option 2, this is the preferred option for the short term (2017). In addition, option 3 paves the way for a possible introduction of option 2 in the long term (2019), if proven cost effective in the environmental effect study referred to in chapter 6.2.1.1.

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