1. The position of the Aluminium Industry on the proposed regulation to reduce CO 2 emissions from cars EPP-ED hearing 05-06-2008 Bernard Gilmont

2. Light-weighting impact on CO 2 emissions The energy required to move a vehicle is, except for aerodynamic resistance, directly proportional to its mass Source: Volkswagen AG

3. Reducing mass is necessary! Evolution of weight in the compact class

4. Weight-based regulation proposal Formula for permitted specific emissions of CO 2 = 130 + a × (M – M 0 ) Where… M = mass of vehicle in kg M 0 = 1289.0 (=average vehicle mass in 2006) a = 0.0457

5. CO 2 and cars: Weight-based regulation proposal CO 2 target (g/km) = 130 + 0.0457 × (M – 1289) Estimated future “natural” CO 2 reduction per kg saved Between 0.0714 & 0.0760, according to impact assessment Reducing vehicle weight by 100kg CO 2 emissions reduced by 7.14 to 7.60 g/km Permitted CO 2 target reduced by 4.57 g/km CO 2 (g/km) Mass (kg) CO 2 target

6. CO 2 and cars: Weight-based regulation proposal 60% of actual progress is annihilated! Very low motivation to make cars lighter Light-weighting is strongly penalized compared to other CO 2 reduction technologies!

7. Revision mechanism 130 + a × (M – M 0 ) Revision of M 0 based on observed mass increase during the period 2006 to 2009, extrapolated to 2012 E.g. if yearly mass increase is 1% from 2006 to 2009 M 0 = 1289 x (1.01) 6 = 1368 130 g/km CO 2 target is not secured Revision of M 0 is a “non-essential element” Mass increase during 2010-2012 could be higher than during 2006-2009 Mass increase after 2012 is ignored No revision of parameter “a” foreseen at all

8. No revision of parameter “a” = slope increase 130 + 0.0457 × (M – 1289), corresponds to a 60% slope under the hypothesis that average vehicle mass in 2012 = 2006, i.e. 0% mass increase Assuming 1.5% yearly mass increase, as observed in the past, 0.0457 corresponds to a slope of 64% ! Table from EC impact assessment 64% <= 0.0457

9. In the absence of any revision mechanism… Assuming vehicle mass increase continues at 1.5% per year... In 2012, the average car would weight 1409 kg, instead of 1289 kg would have an emission target of 135.5 g of CO 2 per km target missed by 5.5 g even if all manufacturers are in compliance In 2015, the average car would weight 1474 kg, instead of 1289 kg would have an emission target of 138.4 g of CO 2 per km target missed by 8.4 g even if all manufacturers are in compliance

10. Conclusion Light-weighting is a key CO 2 reduction measure and is strongly penalized by the draft regulation Weight should be excluded of the formula, as any other parameter having a direct impact on CO 2 emissions A new formula based on footprint is the best option for the environment and technological neutrality To reach the 130g target with a utility-based formula, revising both the average utility and the slope parameter “a” is necessary on a regular basis

11. Thank you www.aluminium.org