Consultation of the Regulatory Scrutiny Board (RSB)

2 10 ANNEX 1:PROCEDURAL INFORMATION

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in relation to the impacts on employment, is further elaborated in Section 6.2.1.1.8.

Stakeholders’ views have not sufficiently informed the analysis

The views of stakeholders have been presented in more details in Annex II and throughout the report, as relevant, to explain how they have been used to inform the analysis. In particular, Sections 3 and 5 better explain how stakeholders’ views concerning the objectives and the options have fed into the analysis.

The Board also mentioned the following improvements needed, which were addressed in the revised impact assessment report as indicated below.

RSB opinion: “what to improve” Response The initiative revises Regulation

2019/631 that only came into force in 2020. The report should explain upfront why another revision of the CO2

standards is necessary after such a short period of implementation. It should clarify what new problems have arisen since the adoption. The report should make clear to what extent the very positive market developments in the uptake and availability of electric vehicles have been reflected in the baseline projections.

The reasons for revising the existing regulation have been further elaborated in Sections 2 and 3, to better frame the initiative in the context of the European Green Deal, and the need to contribute to the new climate objectives, set out in the European Climate Law. Section 2.3 on how the problems will evolve has been also been further elaborated.

The report should better explain the coherence with the linked ’Fit for 55’

initiatives. In particular, the report should clarify the added value of the current initiative in view of a possible extension of the Emission Trading System to road transport. It should explain why the latter would not be sufficient to reach the climate target for passenger cars and light commercial vehicles, and assess the risk of over-regulating road transport emissions.

The coherence with other linked ‘Fit for 55%’

initiatives has been further analysed in new Section 6.5. This includes explanations and analysis on the synergies and complementarities with the possible extension of emission trading to road transport, as well as the interlinkages with the strenghtening of the EU ETS, the Effort Sharing Regulation, the Renewable Energy and Energy Efficiecny Directives, the Alternative Fuel Infrastructure Directive.

The report should better explain how feasible the high-level reduction target is given the substantial investment needs for the EU automotive sector and the need for timely availability of a full EU wide charging network. It should be transparent on related assumptions, uncertainties and risks. The report should better explain the differences between the

An analysis of the feasibility of the different options for the target levels has been further elaborated in Section 6.2.1.1.4.

A full comparison of the options for the CO2

emission standard levels in terms of effectiveness, efficiency, coherence, added value and proportionality has been further developed in Section 7. Table 18 has also been updated

4 three target levels options in terms of

overall cost-efficiency and discuss the resulting trade-offs.

accordingly to better reflect the trade-offs.

Annex 4 has been updated to include all the relevant assumptions on the analytical methods.

Additional information is presented in the publication related to the EU Reference Scenario 2020.

The report should establish a clearer intervention logic throughout the report, especially for the objectives relating to consumer behaviour, and innovation and technological leadership. In particular, the report should strengthen the analysis of the impacts on innovation and competitiveness.

The intervention logic has been revised to better clarify the objectives, and their link with the problems and drivers, as also highlighted in an updated Figure 2.

Section 6.2.1.1.5 has been added to strenghten the assessment of the impacts on innovation and competitiveness.

The baseline should show the likely evolution of the automotive sector under the current legislation, including emissions, availability of zero-emissions vehicles, employment, competitiveness, etc. It should be used consistently as point of comparison when assessing the policy options. Apart from a clear analysis of who will be directly affected and how, the report should also consider any indirect impacts that may be significant. The report should systematically take into account the views of consulted stakeholder groups in discussing impacts.

Section 2.3 further elaborates on the evolution of the problems without further action. It also points to the presentation of the impacts in the baseline scenario, as presented throughout Section 6.

A full description of the Reference Scenario 2020, common baseline among all the initiaitves of the ‘Fit for 55% package’ is provided in a dedicated publication.

Views of stakeholders on the impacts have been added in Annex 2.

The methodological section (in the annex), including methods, key assumptions, and baseline, should be harmonised as much as possible across all ‘Fit for 55’ initiatives. Key methodological elements and assumptions should be included concisely in the main report under the baseline section and the introduction to the options. The report should refer explicitly to uncertainties linked to the modelling.

Where relevant, the methodological presentation should be adapted to this specific initiative.

Annex 4 has been updated to include all the relevant assumptions on the analytical methods.

Additional information is also presented in the publication related to the EU Reference Scenario 2020.

Annex 3 should present a complete summary of costs and benefits with all key information, including quantified estimates. The Board notes the estimated costs and benefits of the preferred

Annex 3 has been updated with the summary of costs and benefits.

5 option(s) in this initiative, as summarised

in the attached quantification tables.