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Public consultation of the European Commission on the Green Paper on Energy Efficiency or Doing More With Less

Publication date: 29 March 2006

The Eurocouncil of the Fédération Internationale de l’Automobile (FIA) represents through its affiliated members, national motoring and touring organisations in Europe, more than 40 million citizens in the European Union. As passenger cars are one of the important users for energy in particular fossil fuels we would like to take this opportunity to bring our contribution to the debate from the perspective of the motorists.


Mobility is like many other sectors of our economies using energy through burning fossil fuels and emitting greenhouse gases and air pollutants. The transport sector has tremendously improved its capability and has reached in Europe a relatively high efficiency level. While CO2 emissions from road transport have increased by 9% during the 1990’s, the automobile manufacturers associations have committed to reducing CO2 emissions from new cars by 25% over this decade.


The FIA welcomes and supports the initiative of the European Commission to further encourage energy efficiency as a vital part of the European Union’s strategy to strengthen the competitiveness of its economy.


Achieving a sustainable mobility is one important aspect of this strategy and at the same time a major priority for the motoring and touring clubs. For instance, the automobile clubs help motorists increasing the energy efficiency of their cars by offering fuel efficient driving courses. Long-term analysis has shown that the promotion of such driver information and education schemes increases overall fuel efficiency of passenger cars by five to ten percent, a non-negligible contribution to improved efficiency.


Energy use by passenger cars has remained constant for the past ten years despite large increase in traffic. While improved energy efficiency with regard to passenger cars is vital the most cost-efficient strategy needs to be set-up. This is in the interest of all automotive stakeholders, the industry, the authorities and above all the mobile consumers.


Please find below the FIA’s answers to the Commission’s public consultation questionnaire in the hope that it is a useful contribution to the ongoing policy debate on this important topic and that it can help the Commission to determine its policy on improving energy efficiency.


The answer of the FIA regarding the options identified in the Green Paper


1. How could the Community and the Commission in particular, better stimulate European investment in energy efficiency technologies? How could funds spent supporting research in this area be better targeted? (Section 1.1)


In order to inform motorists better about the environmental impact of their cars, our German member club the ADAC has carried out research and developed the “Eco Test” which was commissioned by the FIA Foundation for the Automobile and Society. Using “Eco Test”, the emissions and fuel consumption of currently produced cars are measured, calculated and rated. The results are made available on the Internet.


The FIA would welcome to get the support by the European Commission in order to further develop and promote the “Eco Test”.


2. The emission trading mechanism is a key tool in developing a market-based response to meeting the goals of Kyoto and climate change. Could this policy be better harnessed to promote energy efficiency? If so, how? (Section 1.1)


The optimised CO2-reducing effects of emission trading mechanism can only be achieved in a downstream implementation, where the end users buy and use certificates. The enormous number of small emitters makes such a system impossible. An upstream implementation of emission trading, where the producers of fuel deal with certificates, does lead only to one more fuel tax. Thus emission trading mechanisms are not appropriate in road traffic.


3. In the context of the Lisbon strategy aiming to revitalise the European economy, what link should be made between economic competitiveness and a greater emphasis on energy efficiency? In this context, would it be useful to require each Member State to set annual energy efficiency plans, and subsequently to benchmark the plans at community level to ensure a continued spread of best practice? Could such an approach be used internationally? If so, how? (Section 1.1.3)


The FIA sees a strong link between energy efficiency and economic competitiveness. In the car market the development of the fuel prices is giving a competitive edge to manufacturers of fuel efficient vehicles and an image boost to manufacturers that propose innovative technologies in their product portfolio (e.g. Toyota Prius, Citroën C3 Stop & Start).


Further substantial increase in fuel efficiency ultimately depends on a new generation of ultra clean and highly efficient vehicles. On board diagnostics, improved aerodynamics, reduced rolling resistance of tyres and light-weight materials are some of the technological developments that will improve fuel economy. Voluntary agreements with the car industry to target CO2 reduction are a valuable stimulus to bringing new technologies to the market.


As a part of Europe’s road infrastructure regularly reaches the point of saturation developing a good road infrastructure is an indispensable condition for sustainable mobility, ensuring a smooth traffic flow while avoiding congestion and limiting air pollution. The road infrastructure (general design, traffic lights, circulation planning, variable message signs, traffic and incident detection systems, etc.) should allow an optimal traffic flow. For example badly adjusted traffic lights can have as negative an effect as congestion.


4. Fiscal policy is an important way to encourage changes in behaviour and the use of new products that use less energy. Should such measures play a greater role in European energy efficiency policy? If so, which sort of measures would be best suited to achieve this goal? How could they be implemented in a manner that does not result in an overall increase in the tax burden? How to really make the polluter pay? (Section 1.1.4)


The FIA would like to emphasise that the “user pays” principle should concern all modes of transport in order to avoid inefficient distortions.


Energy efficiency in the field of everyday car use depends also on behavioural aspects. While consumers should be given the free choice with regard to the car type they would to use legislators should create a policy framework promoting energy efficiency.


The Commission’s proposal for Directive to reform the car taxation, introducing a compulsory CO2 element in the calculation base without increasing the overall tax burden, is a strong encouragement for consumers to consider fuel efficiency as an important purchasing argument when buying a car.


The average weight of the car fleet is gradually increasing. The Green Paper should take into account that a downsizing the European car park would for the moment incoherent with the goal of halving the number of traffic related fatalities before 2010. While the crash behaviour of cars against a barrier has been improved tremendously the compatibility of car designs has worsened due to higher rigidity of car designs and the increasing differences in weight between cars (high comfort and safety equipment in large cars and trend towards sport utility vehicles). This puts lighter and smaller cars at a disadvantage. Therefore the FIA believes that European car type approval legislation needs urgently to be reinforced. This year the automobile clubs will again carry out compatibility tests to put the pressure on the decision makers and to set up the rules on car crash compatibility. The FIA has carried out a major investigation in 1996-1997, supported by the European Commission, which contains a lot of precious and still valid information. The European Commission should re-examine the findings and include car crash compatibility requirements into the European car type approval. Another consideration is that safety equipment tends to be standard on large cars whereas it is often unavailable on small cars. Car manufacturers should be encouraged to offer and consumers should be encouraged through information and education to require full safety equipment on small cars.


5. Would it be possible to develop state aid rules that are more favourable to the environment, in particular by encouraging eco-innovation and productivity improvements? What form could these rules take? (Section 1.1.5)


The proposal of new emission limit values for passenger cars should allow the member states to give financial incentives until the implementation date.


Direct injection technology has improved the fuel efficiency of conventional internal combustion engines. The progress that has been made in the field of diesel fuel technology is impressive. The remaining problem of small particles is on the verge of being solved with the spread of the particle filter. In order to roll-out this technology as quickly as possible the FIA supports financial incentives to promote their use.


Moreover alternative fuels and engine systems, including hybrid engines, battery-powered electric vehicles and fuel cell power sources need to be further developed. Special attention should be given to biofuels such as biodiesel. A specific refuelling and distribution infrastructure is needed. Moreover, with computer controlled matching of engine and transmission, using a high efficiency automatic gearbox, Intelligent and Integrated Powertrains can optimise overall efficiency.


6. Public authorities are often looked to for an example. Should legislation place specific obligations on public authorities, for example to apply in public buildings the measures that have been recommended at Community or national level. Could or should public authorities take account of energy efficiency in public procurement? Would this help build viable markets for certain products and new technologies? How could this be implemented in practice in a way that would promote the development of new technologies and provide incentives to industry to research new energy efficient products and processes? How could this be done in a manner that would save money for Public authorities? As regards vehicles, please see question 20. (Section 1.1.6)


Not applicable


7. Energy efficiency funds have in the past been used effectively. How can the experience be repeated and improved? Which measures can be adopted usefully at:

– International level

– EU level

– National level

– Regional and local level?

(Section 1.1.7. See also question 22)


Not applicable


8. Energy efficiency in buildings is an area where important savings can be made. Which practical measures could be taken at EU, national, regional or local level to ensure that the existing Community Buildings Directive is a success in practice? Should the Community go further than the existing Directive, for example extending it to smaller premises? If so, how could the appropriate balance be achieved between the need to generate energy efficiency gains and the objective of limiting new administrative burdens to the minimum possible? (Section 1.2.1)


Not applicable


9. Giving incentives to improve the energy efficiency of rented accommodation is a difficult task because the owner of the building does not normally pay the energy bill and thus has no economic interest in investing in energy efficiency improvements such as insulation or double glazing. How could this challenge be best addressed?

(Section 1.2.1)


Not applicable


10. How can the impact of legislation on the performance of energy-consuming products for household use be reinforced? What are the best ways to encourage the production and consumption of these products? Could, for instance, present rules on labelling be improved? How could the EU kick-start research into and the subsequent production of the next generation of energy efficient products? What other measures could be taken at

– International level

– EU level

– National level

– Regional and local level?

(Section 1.2.2)


The labelling of household appliances shows that the labelling with standard energy efficiency classes has proven to be a success. The market sales and product design have been moved to more energy efficient products by the labelling Directive. Due to a common label design, also the cost for manufacturers and retailers could have been kept low.


It is a challenge to develop a common energy efficiency labelling system for new passenger cars similar to the one for appliances. The FIA believes that in a Europe that is characterised by the growing mobility of its citizens, a multinational car industry and great ease in purchasing all kinds of cars in different Member States, an identical labelling system should be implemented in all Member States rather than the patchwork allowed by Directive 1999/94/EC. The European Commission contracted the German automobile club ADAC to evaluate the effectiveness of the labelling Directive. The proposals of the ADAC have been published by the European Commission in March 2005. The needed implementation of the given recommendations is still awaited. The full report can be downloaded from the Commission’s website


11. A major challenge is to ensure that the vehicle industry produces ever more energy efficient vehicles. How can this best be done? What measures should be taken to continue to improve energy efficiency in vehicles and at which level? To what extent should such measures be voluntary in nature and to what extent mandatory? (Section 1.2.3)


The “Eco Test” and a harmonised emission labelling for new vehicles combined with strong information and marketing activities would help the consumers to choose energy efficient vehicles and so give incentives to the car manufacturers to improve the energy efficiency of their products.


Also the tax system should be used positively to reward the purchase of low-emission cars, in terms of both CO2 and toxic pollutants, rather than just being operated as a penalty-driven regime. As voluntary regulation or legislation, the emphasis must be on replacing the car fleet as quickly as possible by less polluting and more fuel-efficient vehicles. The FIA therefore welcomes the initiative of the Commission to abandon registration taxes and include a CO2 element in the annual circulation tax.


The FIA supports the voluntary agreement between the EU and the ACEA to reach the target of 140 g CO2/km from new passenger cars and notes that further effort is needed as the current annual rate of emission reduction is insufficient.


While efficiency improvements through engine technology tend to be cost intensive smart driver support can help to save energy. On board diagnostics should inform drivers about the current performance of their vehicle and the consequences of driving habits and maintenance. The gear shift indicators currently developed in a cooperation of several European automobile clubs help the driver to shift gears at the right moment, optimise the engine performance and lead to a more efficient use of fuel.


With regard to navigation support real time traffic information can improve traffic flow and reduce congestion on Europe’s busiest routes. On board telematic systems, in particular navigation aids, adaptive cruise control, route guidance, congestion warning systems and parking information systems, will improve the efficiency of road transport.


12. Public information campaigns on energy efficiency have shown success in certain Member States. What more could and should be done in this area at:

– International level,

– EU level,

– National level, or

– Regional and local level?

(Section 1.2.4)


Fuel efficient driving can be promoted by specific driver information and training. Long-term analysis has shown that the promotion of such driver information and education schemes increases overall fuel efficiency of passenger cars by five to ten percent, a significant contribution to increasing energy efficiency. A major role is played by the automobile clubs which help motorists reducing their fuel consumption by offering fuel efficient driving courses. This offer should be supported by public information campaigns on energy efficiency stressing the benefits of such initiatives to the general public.


Fuel efficient driving should be a mandatory element of driver training throughout the European Union. Candidate drivers should learn right from the beginning of their driving life how to drive in energy efficient way.


Moreover an important step in improving driver education should be taken by implementing the second stage of driver training. Some Member States have already successfully implemented it. The European Commission should use the experience gained to implement it on the European level. Second stage driver education and training should besides road safety also include fuel efficiency aspects.


13. What can be done to improve the efficiency of electricity transmission and distribution? How to implement such initiatives in practice? What can be done to improve the efficiency of fuel use in electricity production? How to further promote distributed generation and co-generation? (Sections 2.1-2.3)


Not applicable


14. Encouraging electricity and gas providers to offer an energy service (i.e. agreeing to heat a house to an agreed temperature and to provide lighting services) rather than simply providing energy is a good way to promote energy efficiency. Under such arrangements the energy provider has an economic interest that the property is energy efficient and that necessary investments are made. Otherwise, electricity and gas companies have an economic interest that such investments are not made, because they sell more energy. How could such practices be promoted? Is a voluntary code or agreement necessary or adequate?


Organisations should be encouraged to provide appropriate information and training to their members of staff about efficient use of energy, for instance by sending them to fuel efficient driving courses. Such initiatives show a positive return on investment.


15. In a number of Member States, white (energy efficiency) certificates have been or are being introduced. Should these be introduced at Community level? Is this necessary given the carbon trading mechanism? If they should be introduced, how could this be done with the least possible bureaucracy? How could they be linked with carbon trading mechanism? (Section 2.4)


Please see answer to question 2.


16. Encouraging industry to take advantage of new technologies and equipment that generate cost-effective energy efficiencies represents one of the major challenges in this area. In addition to the carbon trading mechanism, what more could and should be done? How effective have been the steps taken so far through voluntary commitments, non-binding measures adopted by industry, or information campaigns? (Section 3)


The FIA believes that voluntary agreements often represent a cost-effective way to reach certain objectives. However there is an issue as to whether the agreement between the EU and the ACEA to reach the target of 140 g CO2/km from new passenger cars by 2008 is working effectively as planned.


The role of the consumer should not be forgotten as it is the consumer who takes the purchase decision and so can favour fuel efficient vehicles. Public information campaigns on energy efficiency should therefore get more attention. Clear information on fuel economy is needed to influence the motorist’s purchase decisions (publication of “Eco Test” results, fuel economy tests and point-of-sale labelling, please see also answer to question 10).


17. A new balance between modes of transport – a major theme of the strategy set out in the White Paper that the Commission adopted in 2001 on a European transport policy for 2010 – is still a top priority. What more could be done to increase the market share of rail, maritime and inland waterway transport? (Section 4.2)


Because of the very dominant role of the car in the European transportation system even large increases in the use of public transport will only have small effects on road traffic and hence on energy use. The Green Paper should more thoroughly mention the many cases in which, public transport, especially in rural areas or rail transport, is not an economical or environmental benefit to society.


In urban areas a competitive public transport offer and the car are both necessary for lively cities. A good integration of different modes of transport is an important aspect. Intermodal infrastructure like Park & Ride and information systems must be extended.


Despite the considerable support allocated to rail, the targeted modal shift has not come anywhere close. The White Paper outlined a series of measures targeted at shifting the balance between modes and halting the decline of rail. The measures included making rail systems inter-operable, integrating the modes and further improving the urban transport offer.


Inter-operability is a prerequisite for international transport services. Despite the ever-increasing demand for international transport services and the European Commission call to create ”favourable technical conditions and modernise services”, we assert that rail transport services still continue to be managed within a national framework. There is sufficient evidence showing that sticking to the “inter-modality approach” has not brought the EU any closer to having a solid, reality-tested, long-term transport policy that would successfully tackle the most important challenges facing the EU road transport sector, i.e. efficiency, safety, congestion, pollution and a sustainable financing for infrastructure. There is an overall lack of investment in efficient urban public transport systems providing a competitive alternative to car transport. For some types of journey and activity the car has become even more essential because public transport has been neglected as a result of short-sighted planning decisions. Integrating modes of transport and Intelligent Transport Systems must be a priority.


Land-use planning must be a central element of any energy efficiency strategy. Policies for urban renewal can halt the drift to out-of-town developments and increased car dependence.


18. In order to improve energy efficiency it is necessary to complete certain infrastructure projects from the trans-European transport network. How should the investments needed for infrastructure projects be developed, using what sources of financing? (Section 4.2)


Road transport contributes to social integration by reducing the geographical handicap of peripheral countries and regions and bringing EU citizens closer together. 90% of passengers and 80% of inland freight transport in the EU is carried on roads. The proper functioning of the EU’s transport system is essential to its competitiveness and the quality of life of its citizens. It enables the production process to run smoothly and is an indispensable condition for economic growth.


The enlargement has led to a high increase of road freight traffic in Europe. For instance foreign road freight transport has doubled in Germany since the East border opening in 1991. As Europe embarks on transport infrastructure development projects road infrastructure needs, in particular in Central and Eastern Europe, urgently to be upgraded and extended in order to match the requirements of a growing traffic and avoid a rising congestion problem.


The financial contribution of the car users through taxation and road charges is sufficient to allow the provision of an appropriate road infrastructure. This income needs therefore to be earmarked for construction and maintenance of the road infrastructure.


19. Among the measures that could be adopted in the transport sector, which have the greatest potential? Should priority be given to technological innovations (tyres, engines…), particularly through standards defined jointly with the industry, or to regulatory measures such as a limit on fuel consumption of cars? (Section 4.3-4.5)


The FIA supports the integrated approach of the European Commission. Technological innovations, infrastructure improvement and behavioural changes contribute together to higher energy efficiency.


20. Should public authorities (state, administrations, regional and local authorities) be obliged in their public procurement to buy a percentage of energy efficient vehicles for their fleets? If so, how could this be organised in a manner that is technology neutral (i.e. it does not result in distorting the market towards one particular technology). (Section 4.3)


The FIA in principle favours market based instruments. However the European Commission’s proposal for Directive to support the creation of a market for “clean” vehicles by requiring public bodies to purchase low emission vehicles can be an appropriate instrument to trigger innovation as it gives an incentive to the market to further develop new technologies and to make them more affordable for the consumer. Public authorities often operate local fleets with isolated filling stations. They can use optimal fuel and engine technologies to reduce energy use and pollution emissions.


Enhanced environmentally friendly vehicles have been defined in the European Performance Standard (EEV) in Directive 2005/55/EC from 20.10.2005. This category of vehicles covers for example clean diesel, hybrid technology, electric vehicles, hydrogen and fuel cell.


21. Infrastructure charging, notably paying to use roads, has started to be introduced in Europe. A first proposal was made in 2003 to strengthen the charging of professional road transport. Local congestion charges have now been introduced in some cities. What should be the next steps in infrastructure charging? How far should “external costs” such as pollution, congestion and accidents be directly charged to those causing them in this manner? (Section 4.4)


European motorists accept the user-pays principle. In some European countries the road infrastructure was created in a tax based system. In this historic context the individual situation must be taken in consideration.


In fact the motorists pay much more than the infrastructure costs they cause. It is fair and justified to raise revenues from users in order to cover the costs of a publicly supplied transport infrastructure. Today, motorists in the European Union pay taxes and charges in high volume: over 100 million car users pay around 300 billion euro a year in taxes alone, i.e. some 15% of member state governments’ total revenues, representing about three times more than the cost they cause.


There is no scientifically or empirical evidence that road pricing will lead to a decrease in road use. On the contrary economical theory and experiences show that taxes over time are more or less incorporated / neutralised in the economy and users everyday life.


The description of the London Congestion Charging in the Green Paper is rather tendentious. The overall traffic level of London has not decreased, but the charging zone has to some extend moved traffic from inside the zone to the outside. That should be mentioned in future references.


22. In certain Member Sates, local or regional energy efficiency project financing schemes, managed by energy efficiency companies, have proven very successful. Should this be extended. If so, how? (Section 5.1)


Not applicable


23. Should energy efficiency issues be more integrated in the Union’s relationships with third countries, especially its neighbours? If so, how? How can energy efficiency become a key part of the integration of regional markets? Is it necessary to encourage the international financial institutions to pay more attention to demand management issues in their technical and financial assistance to third countries? If so, what could be the most effective mechanisms or investments? (Section 6)


The European Union should share best practices on urban planning issues, in particular urban transport management, an area in which European cities dispose of a substantial know-how. Integrated approaches to urban management can optimise the use of energy while improving the quality of life and the city’s economic performance, which in turn can attract new residents and businesses. These approaches could be disseminated to third countries, in analogy to the EU internal strategy followed by the Commission’s proposal COM(2005) 718.


24. How could advances in energy efficiency technology and processes in Europe be put to effective use in developing countries? (Section 6.3)


An obvious method to help developing countries to increase the energy efficiency is to share know-how on technology and processes. This is part of Europe’s worldwide competitiveness.


The “Eco Test” and a harmonised emission labelling for new vehicles are good practices that should be shared with developing countries helping also the consumers in these countries to choose energy efficient vehicles. Information and education about fuel efficient driving is another good practice that should be shared.


25. Should the Union negotiate tariff or non tariff advantages within the WTO for energy efficient products and encourage other members of WTO to do the same? (Section 6)


Not applicable


The FIA remains at your disposal for any further discussion should you so wish.


FIA European Bureau

March 2006


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