Bellona response to EC consultation on the revision of Clean Vehicles Directive

Authors: Bellona Europa

Publisher: Bellona Europa

The European Commission has conducted a public consultation as part of the revision process of Directive 2009/33/EC on the promotion of clean and energy-efficient road vehicles (Clean Vehicles Directive). Bellona shares its views on the topic of public procurement and clear definitions of ‘clean vehicles’ in this response.

Meeting the EU’s target of reducing CO2 emissions from transport by 60% and eliminating the use of fossil fuels in cars by 2050 will necessitate a significant uptake in zero emission vehicles (ZEVs). Public authorities are a powerful purchaser on the market and as such are key actors in driving the transition to a zero-emission, electric transport system. World-wide 557,000 cities and communities spend roughly €4 trillion per year; the equivalent of 10% of global GDP’. Green public procurement (GPP) is therefore a key tool public authorities can use to build trust in and stimulate demand for low- and zero-emission vehicles.

The EU Clean Vehicles Directive (CVD), which sets criteria to orientate public procurement, has however been excessively complex and unclear, which in turn has resulted in its marginal transposition at the Member State level as well as a limited stimulus to public authorities for the procurement of ZEVs.

This calls for a comprehensive revision to address its weaknesses as well as to provide more clarity to public authorities. Firstly, the CVD has suffered from the absence of a definition for a ‘clean vehicle’ and an excessively complex monetisation methodology: these have made it possible to satisfy procurement requirements by the majority, if not all, vehicles on the market. What is more, the methodology has been disproportionately focused on fuel consumption and has thus favored the purchase of efficient diesel vehicles, at the expense of zero emission, electric vehicles.

In light of this, Bellona calls for the replacement of the monetisation methodology by a more simple system based on a clear definition of a ‘clean vehicle’ and the inclusion of a target specifying the minimum share of low- and zero-emission vehicles in public fleets. It is important that the revised CVD differentiates between ZEVs and low-emission vehicles while favouring ZEVs, such as pure battery electric vehicles. Giving priority to ZEVs  can be implemented by setting a specific procurement target for ZEVs or giving these vehicles a ‘multiplier’ (i.e. greater weight) to help public authorities to reach their targets.

The CVD’s level of ambition clearly needs to be raised to reflect the growing market for- and advances in battery and electric vehicle technology. Bellona sees pure battery electric vehicles as representing the most promising technology for cutting CO2 emissions, improving local air quality and addressing noise levels in cities. According to the IEA three-fourths of global car sales will need to be in EVs or plug-in hybrids by 2050 if the transportation sector is to do its part in keeping global average temperature rise below the 2 ̊C target of the Paris Agreement. In view of this, and in order to circumvent risks arising from reliance on tailpipe CO2 or pollutant emissions as shown by the Dieselgate scandal, Bellona is strongly supportive of defining clean  vehicles as those producing ‘zero tailpipe emissions’, i.e. electric vehicles. When it comes to heavy duty vehicles, where electrification is still constrained by battery and range, it may make more sense to consider a CO2 metric when specifying procurement targets, on the basis of the VECTO tool (which in turn is expected by the end of 2017).

That being said, we are continuously seeing tremendous improvements in battery technology, and in countries like Norway a number of cities are now moving beyond pilot projects to deploying fully operational urban duty e-trucks. Last year for example the country introduced its first electric food delivery truck, driving from the storage facilities on Oslo’s outskirts to nearby towns and Oslo city center. Despite its initial purchase price being the double of a conventional truck, it results in savings amounting to 0.5 million NOK (the equivalent of € 564,100.00) during its lifespan, while delivering significant CO2 and air pollutant cuts. What is more, the county of Sarpsborg in Norway last month introduced two fully electrified waste collection trucks, which will be in operation from September 2017. These electric waste collection trucks will result in the reduction of approximately 60 tons of CO2 emissions per year[1].

In light of the rapidly evolving EV and battery market it is crucial that the CVD is regularly reviewed and flexible enough to cope with continuous technological improvement in clean and zero emission mobility technologies.

Furthermore, the directive’s scope should be expanded to cover private companies contracted by public authorities to provide various transport services, such as waste management and delivery trucks as well as elderly transport services: this sector represents a substantial number of vehicles, but is currently omitted by the directive. What is more, the CVD could induce public authorities to choose the smallest, lightest and least powerful vehicle that meets their needs. Today the scope of the CDV is limited to M- and N-vehicles, whilst clean L-vehicles may sometimes represent a viable alternative. Bellona would thus support the inclusion of L-category vehicles in the CVD as well as the Clean Vehicles Portal.

Last but not least, fostering the wider uptake of ZEVs will require, in addition to GPP, a more comprehensive approach to fleet management to be adopted. EU Member States should establish national and regional capacity building centres to provide free advice and training to public authorities. This wider mobility management approach should also encourage public authorities to rethink their mobility needs, and ensure thorough assessment of whether the purchase (or lease) of a vehicle is necessary in the first place, and the consideration of car sharing, and employee incentive schemes


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