Monitoring and reporting of CO2 emissions and fuel consumption of new heavy-duty vehicles

26-09-2017

The IA clearly defines the problems and the objectives of the proposed initiative, and relies on comprehensive and up to date sources of information. Overall, the objectives appear to be relevant, measurable, and achievable; however, some discrepancy seems to exist between the definition of the operational objective and the indicators suggested for monitoring and evaluating the impacts of the proposed initiative. In addition, two of the suggested indicators could have been better qualified, in order to make them operational. The IA lacks any precise quantification of the impacts of monitoring and reporting over time on HDV CO2 emissions in the EU, although this weakness is acknowledged and attributed to the lack of reliable methodology. The analysis of the impact on the competitiveness of SMEs appears to be, in general, insufficiently developed or explained. The Commission consulted a broad range of stakeholders, whose views are described and analysed extensively; however, at least two issues considered relevant by the large majority of stakeholders, were not taken up and dealt with in the IA. The IA appears to have addressed most of the RSB recommendations; however, the aspect regarding data sensitivity and the potential market-disruptive risks relating to the monitoring and data collecting system seems still to be insufficiently illustrated and the arguments used lack any supporting evidence. Finally, the IA seems to make a reasonable case for the preferred option, which is reflected in the legislative proposal; however it is unclear why vehicles of categories O3 and O4 (i.e. trailers), included in the scope of Article 2, are not covered by the IA.

The IA clearly defines the problems and the objectives of the proposed initiative, and relies on comprehensive and up to date sources of information. Overall, the objectives appear to be relevant, measurable, and achievable; however, some discrepancy seems to exist between the definition of the operational objective and the indicators suggested for monitoring and evaluating the impacts of the proposed initiative. In addition, two of the suggested indicators could have been better qualified, in order to make them operational. The IA lacks any precise quantification of the impacts of monitoring and reporting over time on HDV CO2 emissions in the EU, although this weakness is acknowledged and attributed to the lack of reliable methodology. The analysis of the impact on the competitiveness of SMEs appears to be, in general, insufficiently developed or explained. The Commission consulted a broad range of stakeholders, whose views are described and analysed extensively; however, at least two issues considered relevant by the large majority of stakeholders, were not taken up and dealt with in the IA. The IA appears to have addressed most of the RSB recommendations; however, the aspect regarding data sensitivity and the potential market-disruptive risks relating to the monitoring and data collecting system seems still to be insufficiently illustrated and the arguments used lack any supporting evidence. Finally, the IA seems to make a reasonable case for the preferred option, which is reflected in the legislative proposal; however it is unclear why vehicles of categories O3 and O4 (i.e. trailers), included in the scope of Article 2, are not covered by the IA.