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Position Paper

EU Member States and Industry Experts on

"Incentives for Clean and Energy Efficient Vehicles" Brussels, 21st September 2010

European Commission - DG ENTR   

The UE Communication entitled “A European strategy on clean and energy-efficient vehicles” (COM 2010/186 of 28th April 2010) outlines a strategy aiming to favor both development and circulation of low-polluting and energy efficient vehicles (“green vehicles”). It also defines the creation of a neutral picture on how to choose those suitable technologies able to facilitate the production of “green vehicles”. Basically, this proposal is based on two major addresses to be simultaneously followed:

1. to promote green and energy efficient vehicles based on conventional internal propulsion engines and

2. to facilitate the application of innovative technologies as for very low carbon consumption vehicles. Propulsion systems to be considered are the following:

a. fuels for alternative combustion systems (different from standard oils or diesel

engines) including liquid bio-fuels and gaseous fuels (LPG, CNG, biogas), that allow to reduce the environmental impact of road transports, lowering emissions of CO2 and other pollutants;

b. hybrids and full-hybrid vehicles able to combine the use of traditional petrol and electricity;

c. electric vehicles; d. hydrogen-fuelled battery-based vehicles.

ANFIA thoroughly supports the approach adopted by the Commission. Moreover, ANFIA believes that better results in terms of global reduction of CO2 emissions and circulation of low-polluting vehicles will be obtained by separately considering the two addresses proposed by the Communication. It is therefore indispensable that Member States be left free to act with flexibility so to grant interventions environmentally-aimed not only in the middle-long term (as per the Communication in reference) but also very shortly, to meet the environmental emergencies in terms of air quality (emissions of PM, NOx…). Evidently, it will be fundamental to ensure a correct application of the regulation onto State aids, and this be done to avoid any alteration in competitiveness existing among Manufacturers. To demonstrate the importance of defining the flexibility to be used by Member States, it can be cited, as an example, the case of the “methane for the automotive sector” that is considered by the Commission itself at European level (within EU27 countries) not only as one of the very alternative fuels of the future but also assumed to own a huge importance in Italy, and even though in a lower way, in some EU Member States like Sweden, Spain and Germany: it is actually considered able to promptly reply to pollution-related problems and CO2 reduction.

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In addition, comparing the “historical” data dating back to 2008-2009 (and related to new car fuelled vehicles have been taken advantage from incentive measures adopted by the Italian Government), an additional lowering in the average CO2 emissions in the park of newly registered vehicles:

W Without methane vehicles contribution W With methane vehicles contribution Source: ANFIA

It is therefore evident that, as for Italy, the effort jointly made by industries and institutions has involved an important process leading to a growth of the methane market. The chart hereunder gives a clear example of the above.

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2003 2004 2005 2006 2007 2008 2009

Total Market IT Car Manufacturers Number of distribution

Source: ANFIA

In general, statistical figures show that customers purchase lower impact vehicles according to different factors such as financial incentives. The graphic below shows that, when the 2009 scrapping campaign was over, the market share of ecological vehicles significantly decreased with negative effects in terms of CO2 emissions.

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Monthly trend 2009/2010 – market share

Q1 201031%

Q2 201012%

Q1+Q2.201023%

43,6 44,540,2 39,1 37,3 36,5 34,7 34,7 33,2 34,6

30,2 30,6 30,7 29,6 30,640,1 39,5 39,1 38,7 40,0

46,6 43,644,7

42,941,7 42,5

41,9 40,3 40,3 39,039,3 38,4 39,4 38,4 38,4

48,2 48,6 48,7 50,0 48,9

9,8 11,9 15,0 18,0 21,0 21,0 23,4 25,0 26,6 26,430,5 31,0 29,9 32,0 31,0

11,7 11,9 12,2 11,3 11,1

0109 0209 0309 0409 0509 0609 0709 0809 0909 1009 1109 1209 0110 0210 0310 0410 0510 0610 0710 0810

alim.alternativa diesel benzinaEcoloogicalvehicles

Diesel Gasoline

Y 200922%Ecological vehicles

Source: ANFIA

With regard to the electric vehicles, the EC Communication, among others, quotes as follows: “The battery-based vehicles, studies made on the subject foresee market shares close to 1-2% as for sales of new vehicles in 2020; this share could however increase up to 11-30% in 2030. As for hybrid-rechargeable vehicles, forecasts are around 2% in 2020 and 5-20% in 2030.” It is evident that incentives in favor of the electric vehicles cannot represent a unique measure to find a solution to environmental emergencies mainly linked to the vehicle-in-use park obsolescence, at this stage of development. Among other things, we must underline that the drive given to push the use of new technologies like electrics is exclusively based on estimations on what this use could be spread out in the next years (and data greatly differ one from another, depending on the source). We can cautiously quote some examples taken from past activities, demonstrating that forecasts made in this specific sector have always been deeply disregarded.

Source: Challenges for new design strategies for electric vehicle - Ecole Polytechnique, France – Giugno 2008

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In addition the EC Communication underlines “Moreover, the “impact of green vehicles equipped with alternative technologies must be accurately assessed and carefully compared with the impact of conventional/standard vehicles, by means of the method of the lifecycle analysis, which takes into consideration the impact produced by the Well-To-Wheel emissions, there included those emissions deriving from production of electric energy as well the environmental impacts of production and scrapping of the vehicle.” ANFIA believes that it should be necessary to have always in mind the impact attained, in the optics of alignment with the so-called “Well-To-Wheel” (WTW) emissions. In the chart here below, it is quoted and described a comparison made by the German Institute for the Energy among the levels of different fuels, in accordance with the mentioned WTW requirements.

Also to anticipate possible schemes of incentives to purchase (with or without scrapping), that tend to proportionally favor those cars with lower and lower CO2 emission levels; it is therefore indispensable that CO2 emissions be not considered like Tank-To-Wheel but “Well-To-Wheel” (WTW).

Source: DENA: Deutsche Energie-Agentur – Giugno 2010

As for how and when to use incentive systems, the Commission underlines that incentive modalities – relating to the demand – are essential to favor the market in its phase of “acquisition” and that they should be introduced possibly in line with what follows: when necessary (at the right moment); targeted as far as possible; non-discriminatory; limited in terms of time of application and amounts to be fixed; aimed at favoring both consumers and distribution of best technologies; only related to both vehicles and infrastructures. ANFIA believes, as underlined also by the Commission, that it is important to give emphasis to the realization of infrastructures both for alternative fuelling and recharges. ANFIA believes that it is fundamental that support policies will be technology neutral and able to favor solutions to solve environmental problems linked to mobility, not only practically feasible in the future, but also in the short term. Otherwise, the risk is to waste great funds which could, on the contrary, be used for already existing, efficient and stronger solutions.