The Environmental Action Germany (DUH) welcomes this public consultation regarding the draft regulation on the RDE 4th package and WLTP 2nd act.
In general, DUH calls on the European Commission (EC) to cut red tape in the current test procedure and market surveillance provisions in order to increase transparency and comprehensibility and not make testing unnecessarily expensive. For example, the criteria for vehicle selection for in-service conformity (ISC) testing should be simplified for the purposes of reflecting real-world vehicle use. In addition, the current certification procedure foresees a number of tests that have no environmental benefit (e.g. smoke test or Type 5 test) and that need to be reviewed by the EC.
DUH supports complementing current ISC checks by manufacturers with market surveillance activities at the member state level through type-approval authorities and other parties such as accredited laboratories. However, DUH strongly deplores that there is absolutely no mention to independent third party testing in the final draft despite being decisive to ensure compliance, as Dieselgate has clearly shown. Instead, the EC only refers to “accredited laboratories and technical services” and does not safeguard the independence of the tests.
DUH welcomes the EC proposal to standardize and make on-board fuel and energy consumption measurement (OBFCM) devices compulsory. However, we call on the EC to establish provisions on data collection and data use and to ensure that third parties have access to the collected data. The data should not only be used to establish a monitoring framework for real-word fuel and energy consumption but also for compliance purposes, i.e. to address the gap between type-approval and real-world values. Collecting real-world fuel and energy consumption data is also relevant to monitor the charging behavior of plug-in hybrid vehicles (PHEV). The data collected should be used to adjust the utility factors of PHEV periodically. Moreover, DUH demands to set an accuracy requirement of ±4%, as initially suggested by the EC and recommended by the JRC, instead of the current ±5%.
The introduction of OBFCM devices replaces by no means the need for on-road CO2 emissions tests at type-approval. It is not possible to rely on the data collected by these devices to effectively root out test manipulations during type-approval as this data will only be available once the vehicles are already in use. DUH calls on the EC to stipulate the short-term introduction of on-road tests for CO2 emissions that build the basis of the future type-approval procedure and compliance with CO2 standards.
DUH supports the introduction of transparency provisions that allow independent re-testing and therefore we welcome the provision to make two transparency data lists available to the public, in electronic form and free of charge. Further, we support the obligation of Grating Type-Approval Authorities (GTAA) to publish compliance assessment results and remedial measures and welcome the annual publication of an ISC report. However, we demand that test results of individual vehicles within an ISC procedure are made public as soon as the tests are completed and not to unnecessarily delay their disclosure until the publication of the GTAA´s report or the closure of the ISC procedure.
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