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The Consumer Voice in Europe
European Parliament Committee Environment,
Health and Food Safety Rue Wiertz 60
B- 1047 Brussels
10 December 2015
RE: Real Driving Emissions NOx Limits
Dear Member of the European Parliament,
On behalf of BEUC, The European Consumer Organisation, we are writing with regard to the Real Driving Emissions implementing measures agreed between the European Commission and Member States in October this year. For the sake of our health and importantly to restore trust amongst consumers after the outbreak of the emissions scandal, we call on you to reject the agreement and to make the case for a more ambitious approach.
On 28th October 2015, the Technical Committee on Motor Vehicles (TCMV) voted to allow Euro 6 diesel cars to emit over double the Euro 6 limit from 2017 to 2020 and for a 50% increase after 2020i. We find this astonishing because the agreement is clearly not in line with available scientific evidenceii.
The agreement also exceeds the implementing powers of both the Commission and Member States, as it represents a political decision to increase the agreed limits for diesel NOx emissions - EU limits that were adopted in 2007 through democratic due process, with the agreement of the European Parliament.
That 2007 agreement is very clear. It says that respect of emissions standards should be achieved under normal conditionsiii. RDE allows for making such measurements, and therefor only sound scientific advice should be considered in amending the limits, and not political interests or those of car makers.
With numerous debilitating lung diseases and more than 600,000 premature deaths linked annually in Europe to air pollution, and not to mention the exceptionally high healthcare costs added to already tight national budgetsiv, the Parliament must send a strong signal to the Commission and Member States by rejecting the agreement of the TCMV and for them to come back with a better deal before the summer of 2016v.
Motorists, let us not forget, are heavily impacted by the air pollution from road traffic as they stand to inhale large quantities of pollutants pumped out from vehicles whilst on the roadvi. Car buyers are also concerned about the environmental credentials of the vehicles they buy, in the UK for instance it was found in a recent survey that 90% of Volkswagen owners considered the environmental performance of the cars as an important factor when they made their purchasevii. Furthermore, the technologies needed to clean up our cars are available and are already being used by some car makersviii.
And of course, in light of the recent, ongoing and escalating emissions scandal, consumers are demanding a fitting European response and not a halfbaked measure that lets industry off the hook. If European consumers do not believe that European decision makers have their best interests at heart, they will never be reassured by the measures that are ultimately taken. We trust you will make the right decision and vote to clean up our cars in the manner that Europe so deserves.
Monique Goyens BEUC, Director General
i Member State representatives, not including the Netherlands, voted to allow Euro 6 diesel cars to
emit over double the Euro 6 limit from 2017 to 2020 (conformity factor (CF) of 2.1), and 50% after 2020 (CF of 1.5), in essence increasing the standard to 120 mg/km and which potentially .
The Commission’s own in house scientific service, the Joint Research Centre, has evaluated the
maximum measurement error of the testing equipment to be 30% (= CF of 1.3), with the Commission subsequently proposing CF of 1.2 in line with an average realistic margin of error. This was changed to CF 1.5 without a clear basis for doing so. The law previously agreed between the three institutions in 2007 has thus been circumvented and goes against the principle of the Commission not exceeding its own implementing powers during comitology procedures.
Under Article 5, of the EU Type Approval Regulation 715/2007 and which specifically concerns Euro 6
limits, it is stated that the “manufacturer shall equip vehicles so that the components likely to affect emissions are designed, constructed and assembled so as to enable the vehicle, in normal use, to comply with this Regulation and its implementing measures.”
The World Health Organisation reported earlier this year that 600,000 deaths per year are
attributable to air pollution in countries across Europe. The costs associated with all deaths and diseases associated with air pollution has been put at approximately 1,5 trillion Euros, which is nearly equivalent to one tenth of the gross domestic product (GDP) of the entire European Union in 2013.
The RDE conformity factor should be based on available scientific evidence, and be set as close to 1
as possible, representing only the genuine measurement uncertainty of testing equipment (Portable Emissions Measurement Systems).
There are numerous studies assessing the impacts of air pollution on motorists, other commuters
and other members of society. Some studies even indicate that motorists can stand to suffer the most under certain conditions (Karanasiou et al, 2014, King’s College, 2014).
vii BEUC’s UK member Which?, surveyed over 2,000 VW diesel owners in October this year and when
asked about the important factors in purchasing their car, 90% of people cited environmental impact.
The International Council on Clean Transportation – one of the organisations partly responsible for
the discovery of the VW defeat device – has highlighted several technologies that come at a reasonable price, and would allow diesel cars to meet Euro 6 NOx limits and which are available and already in use by some car makers.