Policy Report - Confidential December 2013

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POLICY REPORT - CONFIDENTIAL DECEMBER 2013

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SMMT PUBLIC POLICY AND VEHICLE LEGISLATION DEPARTMENT

SMMT, 71 Great Peter Street, London. SW1P 2BN Telephone: +44 (0)20 7344 plus extension Fax: +44 (0)20 7344 9269

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CONTENTS

Automotive Council Page 4 Automotive Council Newsletter, October 2013 4 Automotive Council Newsletter, November 2013 8 Automotive Council Technology Group minutes, 2 October 2013 11

SMMT political issues Page 18 CARS2020 update 18 Skills update 19 Letter from Matthew Hancock MP, Skills Minister, 26 November 2013 24 Lobbying update 25 APMG breakfast meeting note, 30 October 2013 26 APMG breakfast invitation, 11 December 2013 28 Conservative Party conference meeting notes, 30 September 2013 29 Reshuffle briefing 31 Robert Goodwill speech to CV Forum 35

SMMT economic issues Page 38 SMMT Autumn statement update submission, 11 November 2013 38 Industrial strategy update 42 Europe update 44 Trade policy update 48

Environment Page 50 New car/van CO2 regulations update 50 HDV CO2 update 51 Noise update 52 Diesel fuel filter blocking update 57 Energy efficiency schemes update 62 Marketing best practice principles update 65

Low carbon vehicles Page 71 Low carbon vehicle update 71 Matthew Pencharz meeting note, 13 November 2013 74 SMMT position on proposed Central London ULEZ 75

Transport policy & safety Page 79 eCall update 79 Letter to Transport Secretary re: Motoring Services Modernisation, 15 October 2013 88 Letter to DfT re: proposal for an alternative process for obtaining NSSTA, 28 October 2013 90 Proposal for an alternative process for obtaining NSSTA 91

Digital Radio Page 95 Digital radio briefing, Septmeber/October 2013 95 Letter to Ed Vaizey MP, re: Digital Radio Switchover, 7 November 2013 97 Letter from Ed Vaizey MP, re: Digital Radio Switchover, 28 November 2013 98

Briefing papers Page 99

Consultation Index Page 100

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AUTOMOTIVE COUNCIL NEWSLETTER, OCTOBER 2013

October was See Inside Manufacturing month, with automotive manufacturers up and down the UK opening their doors in a bid to inspire the next generation of engineers. Successfully piloted by the automotive sector since 2011, the scheme’s success has taken UK industry by storm, with fully 10 sectors participating this year.

McLaren kicked off the month's events, giving the offices of the Department for Business, Innovation and Skills a Silverstone-style makeover for a showcase of its Manufacturing Challenge – where schoolchildren were tasked with building and then racing their own motor- less vehicles along a track. Overseeing proceedings were Business Secretary Vince Cable and Alan Foster, Operations Director at McLaren.

In the West Midlands, students were given backstage passes to the Jaguar XJ assembly lines at the firm’s Castle Bromwich plant, where they discovered the advanced manufacturing processes behind the firm’s flagship vehicle. The pupils also tried their hands at programming miniature robot arms, and took part in a special production challenge.

BMW, Ford, Michelin, Toyota and Vauxhall all offered See Inside Manufacturing experiences of their own, while Nissan took over the exhibition space at the SMMT offices to tell the production story of its all-new Note – from design, to clay modelling, to full manufacture.

Elsewhere, October saw further investment announcements across the UK automotive industry. Engine manufacturer Cosworth is to open a new £30 million ‘centre of excellence’, which will create 70 direct jobs and an estimated 200 in the supply chain. The University of Warwick, meanwhile, will be home to a new multi-million pound research centre working with staff from Jaguar Land Rover, Tata Motors European Technical Centre and others when its new National Automotive Innovation Campus opens in 2016 with support from the Higher Education Funding Council for England.

Racing start for the next generation of engineers

A joint government-industry initiative to encourage young people to consider a career in manufacturing moved into the fast lane when McLaren roared into Westminster.

The McLaren Manufacturing Challenge formed part of the See Inside Manufacturing campaign and aimed to encourage students to think about engineering in a practical, hands- on sense by designing a motor-less vehicle that, just as in Formula 1, had to comply with strict regulations. To read more click here.

Latest News

£75 million to build cars of the future

Automotive companies are being challenged to come up with engine technologies that will make our cars more energy efficient and ultimately change the way we drive, Business Secretary Vince Cable has announced.

The £75 million fund will enable businesses to make and test low carbon technologies that will keep the UK at the forefront of engine design and help safeguard up to 30,000 jobs in engine production. To find out more click here.

Deputy Prime Minister calls on industry to help UK accelerate demand

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Deputy Prime Minister Nick Clegg has called for innovative ideas from key players in the automotive industry to help the UK stay ahead of global competition and secure our position as global leader in ultra low emission vehicles.

The call comes following government’s announcement of a £500 million investment to drive a low carbon revolution. To find out more click here.

Enterprise zones drive forward UK industry with foreign investment

Enterprise zones are pushing the UK ahead of global competitors after attracting even more overseas investment, Communities Secretary Eric Pickles has said.

The latest investment, which comes from Swedish company Haldex, will be based at the MIRA Technology Park Enterprise Zone, creating jobs and growth for the local economy. To find out more click here.

Jaguar Land Rover leads the charge to address youth unemployment

As the latest UK unemployment figures highlight the on-going challenge facing young people in their search for fulfilling employment, Jaguar Land Rover, the country’s Responsible Business of the Year is launching a new youth training programme, ‘Inspiring Tomorrows Workforce’.

The initiative, designed to support young people aged 16-23 who are not in employment, education or training, is based on the traineeship model and will help participants develop the skill necessary to take on an apprenticeship or other sustainable employment within the automotive sector. To find out more click here.

Multi-million pound boost for Lotus

British car manufacturer Lotus has secured a £10 million government grant which will see the firm create more than 300 new jobs.

The Regional Growth Fund (RGF) has awarded the automotive firm £10.44 million, which will be used for research and development of products, along with staff training. In addition Lotus is expected to create 313 new full time jobs to support production over the coming years.

Vince Cable visited Lotus’ Norfolk headquarters earlier in the month, where he toured the engineering and factory facilities and formally announced the grant to Lotus management. To find out more click here.

Cosworth manufacturing excellence with new factory in Northampton

Performance engineering and manufacturing group Cosworth has announced plans to open a first-of-its-kind facility in Northampton, to manufacture components for some of the world’s most advanced engines.

Vince Cable attended the announcement at Cosworth’s headquarters in Northampton in support of the initiative to develop world class manufacturing capability within the UK for

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global export. To find out more click here.

Jaguar Land Rover launches its 2014 apprentice recruitment drive with a call for more female engineers

Jaguar Land Rover, the UK’s largest automotive apprenticeship provider has launched its 2014 apprenticeship recruitment campaign. The company is looking for up to 150 new recruits to join the 500 strong group currently undertaking the scheme across its five UK sites.

This year Jaguar Land Rover is calling on more young women to consider engineering careers and join a growing number of females choosing to work in the automotive sector. To find out more click here.

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AUTOMOTIVE COUNCIL TECHNOLOGY GROUP MINUTES, 2 OCTOBER 2013

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Agenda Item 1: Welcome and Introduction: Chair Jerry Hardcastle

The Chair welcomed all to the meeting and for the excellent attendance. Special thanks were given to Matt Barnes for his excellent work on the Industrial Strategy (IS). He welcomed the new attendees, Liam Lidstone (Energy Technologies Institute), Ian Collier (High Value Manufacturing Catapult), attending on behalf of Dick Elsy and Nick Grout (BIS) presenting an update on the Industrial Strategy. Apologies were received from Charles Morgan, Ashley Roberts, Bob Lonnon, Brian Gush, Mark Poulton, David Densley, Marco Warth and Theo Quick.

It was noted that Don Newton had stepped down from his role of workstream lead for Energy Storage & energy Management. The Group gave a vote of thanks to Don for the work he had led, especially the successful creation of the battery scale-up facility which is being developed at Warwick Manufacturing Group.

[ACTION 1: Chair to write a letter of thanks to Don Newton].

Agenda Item 2: Industrial Strategy

Nick Grout, supported by a presentation, provided the update and the following points were made:

 The IS sets out a shared vision for the UK automotive manufacturing industry.  Opportunities exist, but they will be challenging.  Key actions are in place to help address supply chain issues which include: BIS to build on and have a greater understanding of data on the capabilities the supply chain has; Access to finance, by building on the good work already going on between the sector and the BBA and looking to extend engagement across the wider finance sector; Automotive Investment Organisation (AIO) has been created and is looking to develop a strategy to repatriate the supply chain and target opportunities for the UK.  Skills – Looking to progress the Industrial Partnership (IP) bid for potentially £15m of funding to help with the piloting of new approaches to address the skills need in the auto sector.  The new Business Environment group will be chaired by Nigel Stein (GKN), with membership of the group yet to be confirmed.  The ‘Informal’ Auto Council meeting will be held on the 8th October, where they will look to gain agreement on the high level implementation plans.  Graham Hoare said that going forward, it was important for the workgroups to have strong connections, especially for skills and the supply chain. He added that it was important to have access to schools to spread the news of the auto sector.  The Chair said that they may have to look at the current structure of the ‘Informal’ Council to see how it can deal with comms and interlinks between the workgroups.

[ACTION 2: All members to consider and make nominations to join the new BE & S group].

Agenda Item 3: LCV 2013 Report

Robert Evans provided the update, supported by a presentation. The following points were discussed:

 The focus at the event was on the recently announced ULEV Strategy.

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 There was a 5% increase in the number of visitors compared to 2012 and was the largest LCV event to date.  Very pleased to have the continuing support of the Auto Council at the event.  Planning underway for LCV2014 with launch planned for November. Proposed dates are September 10th-11th. Would welcome the continued support of the Auto Council at next year’s event.  The Chair accepted the invitation and was keen for the Auto Council to support LCV2014. He added that LCV2013 had been very good, but there was always room for improvement.  Neville Jackson said there was a need to attract the large T1’s to these events. He added that these events were still passenger car centric and asked if heavy duty should be included at future events.  Richard Bruges said the events were getting better every year. He asked the question of whether the events were now too close to being a mainstream show.  John Miles said there was a high level of enthusiasm from IM group colleagues to be involved with LCV2014 and make the event even better.  David Hytch said an idea for future events was to have a forum for young people to get involved and how they can get an apprenticeship. He added that LEPs could also be involved at future events.  Robert Evans thanked members for their comments which he will feedback to the steering group meeting on the 4th October.

[ACTION 3a: Robert Evans to provide a breakdown of T1 attendance at LCV2013]. [ACTION 3b: Members to provide Cenex with their own feedback direct].

Agenda Item 4: Closure of Workstreams

The Chair provided a presentation which was first shown at LCV2013 and subsequently at the SMMT Forum. The roadmaps have also published on the Auto Council website. He encouraged members to use these roadmaps in any future presentations they make. He added that Jon Beasley is currently working on the creation of videos for the workgroups and once completed, will be uploaded to the Auto Council website.

Each of the workstream leaders provided a brief summary. The following points were discussed:

 Energy Storage & Energy Management – The Chair confirmed that this only included electro-chemical energy storage and that mechanical energy storage would be the subject of future activity.  Electric Machines & Power Electronics – The workstream leader said they had created three roadmaps for his workstream.  For Power Electronics the integration of invertors and motors would help with the space requirements in vehicles.  ICE – The workstream leader thanked his team for their support as well as Sam Larner for her assistance with the roadmap.  The main recommendations from the ICE group included improved collaboration with the academic research community, development of the APC and growth of the supply chain.  Lightweight Vehicle & Power Train – The workstream leader said the roadmap covered small, medium and large passenger vehicles.  The workstream leader added that the majority of the outputs would feed into the new workstreams.  Intelligent Mobility (IM) – The workstream leader said that this was a new and rapidly expanding area, with further work to be carried out in the new workstream.

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 Three key areas going forward: 1) Granularity; 2) Integration with other sectors and 3) Development of standards and guidelines.  The LUTZ program had received tremendous support from the Transport Systems Catapult (TSC) and there was now a commitment of funds from both BIS and the TSC, totalling £6m.  The Chair told members that the roadmaps were very much alive and would lead into the new workstreams. He added that the MIA motorsport roadmap had been adopted by the Auto Council and was available on the Council website as were all the others.  The Chair said that a Closure Report needed to be completed for the Energy Storage, Lightweight Vehicle and Electric Machines workstreams similar to those for ICE and IM.

[ACTION 4a: BIS Secretariat to create letter of thanks to be sent to all workstream members involved in the development of the roadmaps].

[ACTION 4b: Members were encouraged to offer support to the workstream leaders on the three outstanding Closure Reports].

Agenda Item: New Workstreams

The Chair provided an overview of the new workstreams:

 The new workstreams have been informed by the existing roadmaps.  There would be integration of activities with the APC, High Value Manufacturing Catapult and Transport Systems Catapult.  The Chair would like to announce the leaders of the new workstreams at the ‘Informal’ Council meeting on 8th October.  The Chair reminded all that if they wanted to be a plenary group attendee, then they or their organisation should support one or more of the new workstreams as a condition of membership.  The new workstream leaders would decide on the makeup of their teams and look to confirm the recruitment of their teams as soon as possible.  Industry recommended that the deliverables for work packages be defined and the impact they may have. It will also help to see where there are crossovers between the workstreams.  Proposal for the creation of a briefing document for all workstreams and the Chair accepted the action to write a direction paper.  APC – The Chair stated there were two stages. Implementation - from now until the end of March 2014, and from 1st April 2014 operation as a private company limited by guarantee.  Following establishment of the private company, the APC workstream will reconstitute itself to the Technology Advisor to the APC.  It was agreed by members that Richard Bruges should lead this workstream and the position be reviewed on the 1st April 2014.  Future Technology and R & D – Members agreed that Tony Harper should lead supported by Neville Jackson as deputy.  IM – Members agreed that John Miles should lead the workgroup. Recommended to work closely with Steve Yianni on how the workstream will work with the Transport Systems Catapult once it is up and running.  John Miles noted that autonomous vehicles will need to be included in the remit of the IM group in the future.

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 Manufacturing Technology – Members agreed that Dick Elsy should be appointed leader to the end of March 2014, when it should be reviewed.  There is a requirement to define the role of the HVMC as there maybe a possible conflict of interest. It was agreed that Dick Elsy would be asked to report how any potential conflict of interest would be handled.  The Chair noted that this workstream was light on nominations from OEMs and T1s. He asked industry to volunteer or nominate colleagues to join this workstream.  The Chair added that they should look at linking in to the Supply Chain Group.  Members requested an outline of what would be included in this workstream.  Energy Storage – No leader appointed at present. Leadership of the workstream has been offered to Miguel Fragoso, who is considering the offer.  The Chair said that fuel cells is likely to be included in the APC workstream.  H2Mobility group’s focus is on the infrastructure for hydrogen.  An open question was asked: Where does Energy Infrastructure go?  John Cooper said the storage of gaseous fuels provides an opportunity for the UK.  The Chair said that if members had a view on Energy Storage (ES), they should contact him with the details, copying in the BIS Secretariat.  The Chair asked all workstream leaders to consider ES and how it fits in with their respective workstreams.  The Chair added that there was a need to address the issue on ES and that it was a wide open topic.

[ACTION 5a: OEMs & T1s to volunteer / nominate colleagues to join the Manufacturing Technology workstream].

[ACTION 5b: Outline of subjects to be included in the Manufacturing Technology workstream to be circulated to all group members].

[ACTION 5c: BIS Secretariat to include Energy Storage on agenda for next Technology Group GOC / plenary meeting].

[ACTION 5d: Chair to create briefing document for all workstreams].

Agenda Item 6: Advanced Propulsion Centre (APC)

Richard Bruges provided an update on the APC, supported by a presentation. He stressed to members that this was a work in progress and was not for external publication. The following points were discussed:

 The APC has a steering group, project team and stakeholder group, where members can feed in their views.  The delivery focus is on two main areas: 1) Projects and 2) Organisation.  The APC has a draft vision: To position the UK as the global centre of low carbon power train development and production. Members were encouraged to feedback their views on this draft vision.  Aiming to launch pilot projects in April 2014.  A workshop had been held on 25th September, with the outputs from this included in the presentation. Members could provide feedback on these to Richard Bruges and Chris Burton.  The aerospace industry went through a similar process that the APC will need to go through, with the setting up of the Aerospace Technology Institute. Auto will learn from their experience.

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 Graham Hoare said the new company should be created as quickly and efficiently as possible in order to make decisions on future projects. He added that they were looking to compile the criteria for the location of the APC and present this at the ‘Informal’ Council on 8th October.  Dick Glover said that the statements made in the IS were very good, adding that they should keep using these to re-affirm the message.  The Chair said that following the Formal Council meeting on 13th November, they would look to disseminate an update on the APC to the wider public.

[ACTION 6: All members to provide feedback on draft APC vision to Richard Bruges and Chris Burton].

Agenda Item 7: Proposal for a Design Workstream

Nick Fell provided the proposal, supported by a presentation, where the following points were discussed:

 The purpose was to seek agreement that a Design workstream be added as a new workstream to the most appropriate Council working group.  Few OEM’s have design led from the UK.  Design studios can often be based where R & D facilities are located.  Members supported the proposal.  Tony Harper supported the proposal for a new workstream. He added that the UK had strength in design, but there was also the need to consider design materials. Attracting designers to the proposed new workstream is not seen as an easy task.  Chris Burton also supported the proposal, adding it had a strong link to Skills.  The Chair said that the proposal for the new workstream would be put to the Formal Council, with the aim of being up and running from 1st April 2014.

[ACTION 7: Nick Fell to submit formal proposal for the new Design workstream].

Agenda Item: Chair’s Conclusion / AOB / Next Meeting

The Chair thanked everybody for their support and their great ideas. The newly appointed workstream leaders should now look to select their teams membership, from the nominations for the new workstreams already submitted. Those members who have not yet submitted nominations for the new workstreams were encouraged to do so.

Next meeting for the Technology Group:

2nd December 2013 from 15:00 - 18:30 (Workshop to consider integration of workstream outputs) at BIS Conference Centre

Summary list of actions

Action Responsibility Deadline ACTION 1: Chair to write a letter of thanks Chair/BIS Completed to Don Newton. Secretariat ACTION 2: All members to consider and ALL 31/10/2013 make nominations to join the new BE & S group. ACTION 3a: Robert Evans to provide a Robert Evans 31/10/2013

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breakdown of T1 attendance at LCV2013. ACTION 3b: Members to provide Cenex ALL with their own feedback direct. ACTION 4a: BIS Secretariat to create letter BIS Secretariat Completed of thanks to be sent to all workstream members involved in the development of the roadmaps. ACTION 4b: Members were encouraged to ALL offer support to the workstream leaders on the three outstanding Closure Reports. ACTION 5a: OEMs & T1s to volunteer / OEMs & T1s 31/10/2013 nominate colleagues to join the Manufacturing Technology workstream. ACTION 5b: Outline of subjects to be Dick Elsy 31/10/2013 included in the Manufacturing Technology workstream to be circulated to all group members and report on how any potential conflicts of interest with HVMC would be handled. ACTION 5c: BIS Secretariat to include BIS Secretariat Completed Energy Storage on agenda for next Technology Group GOC / plenary meeting. ACTION 5d: Chair to create briefing Jerry 31/10/2013 document for all workstreams. Hardcastle ACTION 6: All members to provide All 18/10/2013 feedback on draft APC vision to Richard Bruges and Chris Burton. ACTION 7: Nick Fell to submit formal Nick Fell 30/11/2013 proposal for the new Design workstream.

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CARS 2020 UPDATE, NOVEMBER 2013

Working Group update Four CARS 2020 working groups have met throughout 2013, their presentations and papers are available online and can be accessed here: http://ec.europa.eu/enterprise/sectors/automotive/cars- 2020/index_en.htm

 Working Group on Economic Situation, Industrial Change and Social  Working Group on Internal market  Working Group on Clean Vehicles, Electromobility and Alternative  Working Group on Trade and International Harmonisation

The next Sherpa meeting is on Monday 9 December 2013. UK government will be presenting an overview of the Sector Strategy and also the Automotive Council.

European Parliament update The ITRE (industry) committee in the European Parliament undertook an own-initiative report on CARS 2020. Other key EP committees have given opinions including Trade, Internal Market, Transport and Employment.

On 5 November, the European Parliament´s Committee on Industry, Research and Energy adopted a report by MEP Franck Proust (EPP, France) on ‘CARS 2020: Action Plan for a competitive and sustainable automotive industry in Europe’.

The rapporteur amended the original text to include social dialogue as a basis for improving firms' competitiveness, continuous training for employees to adapt to changes or the implementation of reforms for competitiveness in the sector.

The report was adopted with 37 votes in favour, 5 against and 4 abstentions. The Plenary vote on this report is scheduled for December 2013.

The Committee’s report can be accessed here: http://www.europarl.europa.eu/meetdocs/2009_2014/documents/itre/pr/939/939496/939496en.pdf

The basic legislative document can be accessed here: http://www.europarl.europa.eu/oeil/popups/summary.do?id=1258223&t=e&l=en

The ITRE draft report can be accessed here: http://www.europarl.europa.eu/sides/getDoc.do?type=COMPARL&reference=PE- 513.268&format=PDF&language=EN&secondRef=01

The EU legislative file can be accessed here: http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?reference=2013/2062(INI)&l=en

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SKILLS UPDATE, NOVEMBER 2013

Apprenticeship trailblazers project The automotive sector is participating in the apprenticeship trailblazers project, a pilot which aims to implement the recommendations of the Richards Review of Apprenticeships supported by government in its ‘Future of Apprenticeships in England: Implementation Plan”.

The automotive trailblazer is chaired by Ian Eva, Jaguar Land Rover, with members of the core group meeting weekly. Participating organisations include all the major UK VMs, whether attending all meetings or kept in the loop via email updates, the supply chain (represented by EEF and Semta but with wider engagement planned), and SMMT and SMMT Industry Forum.

The occupation chosen for the automotive trailblazer is “Mechatronics Maintenance Technician”, as this was identified as both an area of critical skills shortages for the sector and was also chosen due to its similarities and linkages with maintenance technicians in other key advanced manufacturing sectors (for example aerospace are developing a trailblazer for a similar occupation).

The group has identified the key workstreams to be developed and sub-groups are developing these areas and reporting back to the full group for discussion and agreement. Core amongst these areas are developing the high-level assessment approach, in line with government’s requirements for an end test and grading, and the establishment of the core competencies for the occupation.

The deadline for the submission of the trailblazer is February 2014 with Ministerial sign off expected in March. The chair, Ian Eva, regularly speaks with the automotive trailblazer relationship manager, Olly Newton (BIS), and is in constant liaison with representatives from the other advanced manufacturing projects.

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The key government documents for the trailblazer scheme can be found online here: https://www.gov.uk/government/consultations/future-of-apprenticeships-in-england-richard-review- next-steps

Government launched trailblazers at an event at BMW’s MINI plant in Oxford. The BIS press release is below:

Department for Business, Innovation and Skills Improved Apprenticeships, which will bring greater focus on quality for the learner and ease of use for employers, will be unveiled by the Prime Minister at MINI Plant Oxford today.Under the reforms, employers will be put in the driving seat to create new Apprenticeship standards that will deliver the skills businesses and learners need to compete in the global race.

Groups of companies, including BMW Group UK, have come together to give industry the power to lead the design of these new Apprenticeships. More than 60 companies who took on more than 13,000 Apprenticeship starts in 2011/12 are involved in these groups, which are known as Trailblazers.

The reformed Apprenticeships will be:  employer-led and designed so they respond to the needs of industry, meaning each apprentice has the skills required by the sector  focused on quality so the apprentice has to demonstrate their ability through rigorous assessment at the end of their Apprenticeship  graded on completion – pass, merit, or distinction – to mark the level of achievement. Prime Minister David Cameron said:

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“If you want an apprenticeship, we’re going to make sure you do the best apprenticeship in the world. The reforms we’re announcing today will put employers in the driving seat and ensure that we deliver rigorous training that supports you and our economy for years to come.”

Eight Trailblazers will represent a broad spectrum of businesses from a range of different sectors; aerospace, automotive, digital industries, electro-technical, energy, financial services, food and drink, and life and industrial sciences. Their participation will mean that apprenticeships are firmly driven by those who deliver and use them.

Skills and Enterprise Minister Matthew Hancock said:

“We asked Doug Richard to review the Apprenticeship system and tell us what was needed to make the British system a world leader. Our reforms will do just that and I am pleased to welcome industry leaders as Trailblazers to make the new system a reality.

“Our aim is that the new Apprenticeships will focus squarely on rigorous training for learners and simplicity of use for employers. This will mean that our Apprenticeship system will respond to the needs of the modern economy.”

Being involved in the Trailblazers will give employers and professional bodies the opportunity to develop the new Apprenticeship standards for occupations in their sector. These will become the industry standard for any Apprenticeship in that occupation.

New apprentices can expect to take part in reformed Apprenticeships as early as the end of 2014.

Dr Frank Bachmann, managing director of MINI Plant Oxford said:

“As a major employer of apprentices, BMW Group is supporting this important skills initiative which is designed to develop the first apprenticeship standards across many industrial sectors including automotive. We’re delighted to host and help launch this new Government programme.”

Industrial Partnership/EOP At the end of July, it was confirmed that the sector had been successful in its draft bid to UKCES for an Industrial Partnership (IP) – an infrastructure to address the long-term skills challenges for a sector. The sector was invited to submit a full bid by mid-October. This bid has now been submitted with a decision expected in early 2014. To support this process representatives of the bid will present to UKCES on 13 December.

The IP was included in the automotive sector strategy document, with a focus to address/deliver the draft automotive skills roadmap. (see below)

A group, chaired by Jo Lopes, Jaguar LandRover, formed to develop a full bid. Key automotive companies, Semta, SMMT and SMMT Industry Forum were all involved. SMMT support included providing support in facilitating and administering the group before formal structures are established.

UKCES advised they would provide £30 million for aerospace and automotive to bid for – with advice to companies whose EOP participation bids were unsuccessful that this may be a route to access some funds. The automotivel bid focuses on establishing the IP infrastructure with the skills roadmap as the priority focus, and also a number of pilot participation bids to test out some solutions under the priority skills roadmap workstreams.

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Draft skills roadmap

For more information, contact Jennifer [email protected]

See Inside Manufacturing (SIM) See Inside Manufacturing (SIM) is a joint initiative between BIS and industry, designed to change outdated perceptions of manufacturing in the UK and build awareness of the careers opportunities available in the sector. Automotive has been involved in the scheme since its inception in 2011.

Key points to note on the 2013 scheme are:  Events under See Inside Manufacturing 2013 were held during the month of October  The initiative was expanded to include the following sectors: automotive, aerospace, food & drink, life sciences, nuclear, oil and gas, offshore wind, construction, chemicals and electronics  The BIS SIM website can be accessed here: http://discuss.bis.gov.uk/seeinsidemanufacturing/

Automotive organisations taking part hosted events such as factory tours, discussions with employees, and competitions, under the SIM banner. In total over 50 days of activities were hosted by the following automotive organisations: Allied Vehicles, BMW, Ford, GKN, JLR, Nissan, McLaren, Michelin, Millbrook, Toyota, Vauxhall.

For more information, contact: Josh Harris [email protected]

Perkins review of engineering skills The Department for Business, Innovation and Skills has published the Perkins Review of Engineering Skills. Professor Perkins is the Chief Scientific Advisor at BIS.

A key theme of the recommendations is further collaboration between industry and government to promote, raise awareness and facilitate the uptake of engineering careers. This is through recommendations as diverse as instigating campaigns to encourage young people (particularly women) into the engineering careers to reviews of funding for higher education. Key amongst these recommendations are:  The engineering community, including all the professional engineering institutions, should join in partnership with Tomorrow’s Engineers, to agree effective core messages about engineering and cooperate to disseminate these messages to young people.

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 Government should provide seed funding to develop nationwide roll-out of the Tomorrow’s Engineers employer engagement programme and help schools and colleges connect with employers.  The engineering community should work with government to develop and promote new Level 2 and 3 qualifications that will create high quality vocational routes for 16-19 year olds to enter engineering careers.  Government should review funding arrangements for engineering degree courses to ensure that it is financially sustainable for HE institutions to deliver high quality engineering programmes.

In response government is making available nearly £49 million in funding for engineering skills, this will be spent on the following initiatives:  up to £30 million in funding in the new year for employers to bid for to address engineering skills shortages in sectors with specific needs  an £18 million investment in a new elite training facility at the Manufacturing Technology Centre in Coventry. This is part of the High Value Manufacturing Catapult, which works with companies from start-ups to the likes of Rolls Royce in developing innovation and next generation technology  £250,000 of seed funding to enable Tomorrow’s Engineers to accelerate the nationwide rollout of its employer engagement programme aimed at encouraging children in school to consider engineering careers  £40,000 to support the Daphne Jackson Trust to develop a new fellowship to support people returning to professional engineering jobs after a career break  a portal on the National Careers Service website matching businesses that want to promote engineering careers in schools with organisations who can deliver educational outreach activity.

The press release for the report can be found online here, and the full report can be found attached and online here.

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LETTER FROM MATTHEW HANCOCK MP, SKILLS MINISTER, 26 NOVEMBER 2013

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LOBBYING UPDATE, NOVEMBER 2013

Status of legislation The Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Bill was presented and had its first reading in the House of Commons on 17 July 2013. The Bill was given House of Commons Third Reading consent on 9 October 2013 and started its progress in the House of Lords the same day.

The Bill has come under increased scrutiny in the House of Lords, and although already in Committee Stage, at the beginning of November government agreed to pause the legislative process for six weeks in response to charity groups’ concerns over the Bill.

For a detailed briefing of the Bill and its contents, please refer the following House of Commons Library paper: www.parliament.uk/briefing-papers/RP13-51.pdf

Timeline

Stage Date 1st reading: House of Commons 17 July, 2013 17.07.2013

2nd reading: House of Commons 3 September, 2013 03.09.2013

Money resolution: House of Commons 3 September, 2013 03.09.2013

Ways and Means resolution: House of Commons 3 September, 2013 03.09.2013

Programme motion: House of Commons 3 September, 2013 03.09.2013

Committee: 1st sitting: House of Commons 9 September, 2013 09.09.2013

Committee: 2nd sitting: House of Commons 10 September, 2013 10.09.2013

Committee: 3rd sitting: House of Commons 11 September, 2013 11.09.2013

Programme motion (No. 2): House of Commons 8 October, 2013 08.10.2013

Report: 1st sitting: House of Commons 8 October, 2013 08.10.2013

Report: 2nd sitting: House of Commons 9 October, 2013 09.10.2013

3rd reading: House of Commons 9 October, 2013 09.10.2013

1st reading: House of Lords 9 October, 2013 09.10.2013

2nd reading: House of Lords 22 October, 2013 22.10.2013

Committee: 1st sitting: House of Lords 5 November, 2013 05.11.2013

Committee: 2nd sitting: House of Lords 11 November, 2013 11.11.2013

Committee stage: House of Lords 16.12.2013

Committee stage: House of Lords 18.12.2013

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APMG BREAKFAST – “DRIVING SUCCESS?” CHURCHILL DINING ROOM, HOUSE OF COMMONS, LONDON, 30 OCTOBER 2013

Attendees Darren Lindsey, Michelin Tyre plc Adrian Bailey MP Ian Lucas MP Richard Burden MP Sejal Mahida, Private Secretary to Vince Cable Rt Hon Vince Cable MP, Business Secreatry Alison McGovern MP Stephen Crisp, Jaguar Land Rover Andrew Miller MP Jon Dennison, GKN plc Ian Parsons, BIS Ben Fletcher, Renault Jennifer Pheasey, SMMT Helen Foord, General Motors Mark Prisk MP Lucy Hadley, Office of Richard Burden MP Dr John Pugh MP Madeleine Hallward, Ford of Britain Jason Reakes, BMW Group UK Josh Harris, SMMT Robin Shaw, Robert Bosch Ltd Mike Hawes, Bentley Motors Rt Hon John Spellar MP Jonathan Hawkings, SMMT Nigel Stein, GKN plc Sally Hepton, Bentley Motors Simon Tippet, Renault Luke Herbert, Jaguar Land Rover Heather Wheeler MP Rupert Lewis, BIS

Meeting note

Richard Burden MP Richard Burden welcomed attendees and the Business Secretary to the meeting and noted the importance of the Automotive Sector Strategy ‘Driving Success’ and its implementation for the sector.

Vince Cable MP  Noted the strength of the automotive sector highlighting recent investment announcements.  The Automotive Council was praised as providing long-term thinking and collaboration between government and industry.  Government’s role was stated as to assist in areas where industry fails short or needs support with the areas of the supply chain, skills and innovation highlighted.  The AIO and attracting Tier 1s into the UK was referenced as a priority.  The single market and the EU’s ability to trade with other locations (eg. the TTIP agreement) was noted as critical for the automotive industry.

Mike Hawes  Industry agrees with the comments of the Business Secretary.  Strong voice in Europe and the ability to shape regulation is key. Industry will do what it can to illustrate how being in the EU is beneficial to the UK.  Competitiveness is the strand linking all elements of the industrial strategy together.  New car registrations still growing in the UK and September showed the first month of EU growth in a while, all positive signs for industry.  Cross party support and delivery of the strategy is now the focus.

Questions

Adrian Bailey MP asked how the issue of capacity in the supply chain can be addressed. Vince Cable noted the strengths of the UK as the flexibility of the labour market, the links with Europe and government’s support for the sector but noted that pulling these strengths through to the supply chain was a challenge. He noted that once supply chain companies have left it is hard to get them to come back and that the lack of sufficient skills is a particular challenge/concern. He noted government’s intended reform of the apprenticeship scheme as a way that government is addressing this issue.

Mark Prisk MP asked for further details on the APC and how government saw this progressing. Vince Cable noted that the direction of the APC will be left for industry to decide and also highlighted government’s funding of electric vehicles through the £500 million of OLEV funding.

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John Spellar MP noted that he was pleased that Vince Cable referenced the importance of the unions in the UK being an attractive location for investment as these have been key for growth in the sector. He further noted that upskilling is a key issue and that colleges need more flexibility. In addition he asked whether reinstating capital allowances for SMEs was a way forward for growth in the supply chain. Vince Cable noted the TRS scheme as a way to encourage retention in the advanced manufacturing sector. With regards the supply chain Mr Cable noted the progress being made through discussion with the banking sector on tooling finance and noted that in the last budget there were certain taxation measures on investment allowances which should help the supply chain.

John Pugh MP raised the issue of the importance of infrastructure in the development of alternative fuels markets providing the example of LPG and asked who is coordinating between industry and government on this issue. Vince Cable noted that BIS works closely with DfT on infrastructure issues and liaises with industry. With regards ULCV he highlighted the new Tesla EV that has a 300 mile range stating that soon EVs may have addressed the issue of range anxiety.

Alison McGovern MP asked how the school curriculum can assist in the development of skills for industries such as automotive. Vince Cable noted government’s work on traineeships as a stepping stone to apprenticeships.

Nigel Stein, GKN reiterated that despite the positive news coming out of the sector politicians need to ensure that they are not complacent and that there is awareness that growth is a long-term game which needs long-term thinking.

Richard Burden concluded by thanking the attendees and the Business Secretary and highlighted that the next APMG breakfast will be hosted on 11 December in Dining Room A.

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INVITATION TO 11 DECEMBER APMG BREAKFAST

ALL-PARTY PARLIAMENTARY MOTOR GROUP

“Gaining the leading edge” Priorities for Government’s 2015 – 2020 ultra-low emission vehicles funding package

Secretary of State for Transport, Rt Hon Patrick McLoughlin MP

8.30am, Wednesday 11 December 2013 Dining Room A, House of Commons

Dear Colleague,

I am writing to invite you to the All-Party Parliamentary Motor Group’s upcoming breakfast, at which we will be discussing the Government’s recently published call for evidence on the £500 million funding package for ultra-low emission vehicles from 2015 – 2020.

I am delighted to confirm that we will be joined by the Secretary of State for Transport, Rt Hon Patrick McLoughlin MP.

The breakfast will be a timely opportunity to share views on the Government’s future policy for a critical sector within the automotive industry, and discuss how to secure the UK as a leading location for the design, development, manufacture and sale of ultra-low emission vehicles.

The breakfast will take place on Wednesday 11 December, 8:30 - 10:00am, Dining Room A in the House of Commons. After the Secretary of State has addressed the group there will be will be a roundtable discussion.

I do hope you will be able to join us. Please RSVP to Jonathan Hawkings, [email protected] or 020 7344 9217, and please do not hesitate to get in touch if you have any questions.

Best wishes,

Richard Burden Chair, All-Party Parliamentary Motor Group House of Commons, London, SW1A 0AA 020 7219 2318

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CONSERVATIVE PARTY CONFERENCE MANCHESTER, SEPTEMBER 2013

SMMT lunch: “UK Automotive: Supporting growth through industrial strategy” Victoria Room, Midland Hotel, 30 September 2013

Attendees Andrew McCall, Ford of Europe Political attendees David McPhee, MB&G Insurance Stephen Hammond MP, Parliamentary Under Tim Morris, Tata Steel Secretary of State at the Department for Mark Ovenden, Ford Motor Company Transport Jason Reakes, BMW Group UK Rt Hon Sir Robert Atkins MEP Rahul Sareen, Jaguar Land Rover Lord Borwick Tanya Sinclair, Nissan Motor (GB) Ltd Victoria Borwick AM James Stephens, Nissan Motor (GB) Ltd Martin Callanan MEP Cllr Simon Fawthrop, Bromley SMMT Cllr Ian Galletley, North East Chairman of the Mike Hawes, Chief Executive, SMMT Conservative Party Konstanze Scharring, Director of Policy, Robert Goodwill MP SMMT Mary Macleod MP Jennifer Pheasey, Senior Policy Manager, Emma McClarkin MEP SMMT Anne McIntosh MP Jonathan Hawkings, Policy Manager, SMMT Anthea McIntyre MEP Robin Walker MP Gavin Williamson MP Philip Bradborn MEP Steve Bell, Vice President of the National Convention of the Conservative Party

Other Lady Atkins, wife of Rt Hon Sir Robert Atkins MEP Nicola Blackman wife of Bob Blackman MP Dan Large, adviser to Edward Timpson MP Martine Martin, assistant to Bob Blackman MP Frank Myers, husband of Anthea McIntyre MEP Paul O’Donnell, The Manufacturing Technologies Association Sue Robinson, RMI Alistair Little, Assistant to Philip Bradborn MEP Assistant to Philip Bradborn MEP Daniel Isichei, Chartered Institution of Highways & Transportation Sue Percy, Chartered Institution of Highways & Transportation

SMMT members Tim Abbott, President, SMMT & BMW Group UK Ian Allen, General Motors UK & Ireland Helen Foord, General Motors UK & Ireland Julian Francis, The London Taxi Company Madeleine Hallward, Ford Motor Company Sally Hepton, Bentley Motors Luke Herbert, Jaguar Land Rover Nicholas Howard, MB&G Insurance Darren Lindsey, Michelin Tyre Plc Eman Martin-Vignerte, Bosch

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Speech summaries: Mike Hawes (MH): Welcomed attendees and introduced himself as SMMT’s new CEO; MH’s opening remarks focused on:  Industrial strategy and the importance of implementation and support from across government  OLEV strategy and supporting the market for ultra-low carbon vehicles  The transformation of motoring services and industry keenness to engage and ensure a smooth transition  Europe – the importance of the UK having a strong voice and influential role

Stephen Hammond MP (SH): SH responded to MH’s comments and focused on:  Government support for industrial strategy and OLEV’s support for low-carbon vehicle market and development  Government support for the automotive sector and ambitions for growth  Strong relationship between DfT and industry and a recognition of breadth of relationships – i.e. with DfT’s agencies  Better regulation and his commitment to delivering on this agenda for business

Other meetings At the Conservative Party Conference SMMT also held meetings with:  Malcolm Harbour MEP – focus on industrial strategy and trade policy  Martin Callanan MEP – discussed EU engagement and CO2  Jacqui Foster MEP – briefed on industrial strategy and trade policy  Heather Wheeler MP – focus on APMG and industrial strategy  Ken Clarke – focus on EU-US T-TIP

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SMMT BRIEFING ON GOVERMENT AND OPPOSITION RESHUFFLE 10 OCTOBER 2013

Background On Monday 7 October 2013, the government and opposition both reshuffled their frontbench teams.

Below is an overview of the government reshuffle and a summary of the responsibilities for key new Ministers for the automotive sector.

Government

Reshuffle changes in full

Job In Out

Secretary of State Lib Dem Alistair Lib Dem Michael Moore for Scotland Carmichael (leaves government)

Financial Secretary Conservative Sajid Conservative Greg Clark to the Treasury Javid (moves to Cabinet Office)

Economic Secretary Conservative Conservative Sajid Javid to the Treasury Nicky Morgan (promoted within department)

Home Office Lib Dem Norman Lib Dem Jeremy Browne Minister Baker (leaves government)

Work and Pensions Conservative Conservative Mark Hoban Minister Esther McVey (leaves government)

Junior Work and Conservative Mike Conservative Esther McVey Pensions Minister Penning (promoted within department)

Communities Conservative Kris Conservative Mark Prisk Minister Hopkins (leaves government)

Transport Minister Conservative Lib Dem Norman Baker Robert Goodwill (moves to Home Office)

Transport Minister Lib Dem Baroness Conservative Simon Burns Kramer (leaves government)

Foreign Office Conservative Conservative Alistair Burt Minister Hugh Robertson (leaves government)

Cabinet Office Conservative Greg Conservative Chloe Smith Minister Clark (leaves government)

Junior Justice Conservative Conservative Helen Grant Minister Shailesh Vara (moves to culture, media and sport)

Conservative Hugh Robertson (moves to Junior Sports Helen Grant Foreign Office) Minister

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Reshuffle changes in full

Job In Out

Deputy Chief Whip Conservative Greg Conservative John Randall Hands (leaves government)

Northern Ireland Conservative Conservative Mike Penning minister Andrew Robathan (promoted)

Lib Dem Chief Whip Don Foster Alistair Carmichael (promoted to cabinet)

Fisheries Minister Conservative Conservative Richard George Eustice Benyon (leaves government)

Junior Defence Conservative Conservative Andrew Minister Anna Soubry Robathan (moves to Northern Ireland office)

Junior Health Conservative Jane Conservative Anna Soubry Minister Ellison

Key new minsters

Baroness Kramer (Lib Dem) – Minister of State for Transport

The minister is responsible for:  future transport (including ULEV)  natural environment (including biofuels)  cities and urban renewal (including growth deals and Heseltine Review)  localism and devolution  local connectivity (including smart ticketing, buses, taxis, light rail and trams)  HS2 – Phase Two  rail – funding and futures (including RIS, SOFA, ORR, stations policy)  accessibility and equalities  SMEs  International

Robert Goodwill MP (Con) - Parliamentary Under Secretary of State for Transport

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The minister is responsible for:  strategic roads and Highways Agency  motoring agencies  road safety and standards  freight and logistics – including lorry road user charging  local roads  cycling  Europe  aviation  HS2 Phase One

Nicky Morgan MP (Con) – Economic Secretary to the Treasury

The minister is responsible for:  taxation of transport, North Sea oil, gas and shipping  climate change and energy issues  excise duties and gambling, including excise fraud and law enforcement  retail financial services, including consumer finance and financial advice and capability  banking support, including responsibility for the Asset Protection Scheme and other schemes and UK Financial Investments  personal savings and pensions policy, Equitable Life and the Government Actuary’s Department  The Royal Mint, Crown Estate and Departmental Minister for HM Treasury Group  tax credits and child poverty, and assisting the Chief Secretary on welfare reform and public service pensions  charities, the voluntary sector and gift aid

To note: Matthew Hancock MP has been promoted from Parliamentary Under Secretary of State for Skills and Enterprise to Minister of State for Skills and Enterprise, a jointly held role between BIS and DfE.

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Key new shadow Ministers

Mary Creagh MP – Shadow Secretary of State for Transport

Richard Burden MP – Shadow Transport Minister (same brief as Robert Goodwill MP)

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TRANSCRIPT OF SPEECH BY ROBERT GOODWILL MP, TRANSPORT MINISTER, AT CV FORUM 2013

Thank you for inviting me here today, I’m very pleased to have this early opportunity of meeting you. Freight transport is essential to the effective functioning of the country. It ensures that supermarket shelves remain stocked, medical supplies and post get to where they are needed when they are needed; factory floors are supplied with equipment, and UK businesses have access to overseas suppliers and can sell UK goods abroad.

The UK freight and logistics sector is therefore vital to economic growth and prosperity. It is worth around £75billion to the economy and employs over 2m people across 190,000 companies. It delivers the country’s core needs (food, oil, coal, hospital supplies); facilitates industrial and manufacturing sector (imports and exports) and ensures the service sector can thrive through supply of consumer goods. Efficient freight transport is vital for efficient business.Of course, you all know this, and the Government does too.

The Logistics Growth Review, back in November 2011, set out our position on the importance of the freight sector. This made clear that facilitating conditions for growth in the logistics sector is critical to the Government’s growth agenda. It included a wide package of measures to target real barriers to growth identified by businesses across the sector which we have been taking forward.

We have made significant investment in increasing rail freight capacity: over £400m between 2009-2014 and over £200m agreed for 2014-2019. To give just one example: the Felixstowe to Nuneaton (West Coast Main Line) capacity scheme (£52.8m) for Control Period 4 (to April 2014) is designed to deliver 16 additional freight paths per day in each direction, enabling rail to accommodate part of the growth arising from the expansion of the Port of Felixstowe.

The road network is vital to our economy. Since the late-1980s, more than 60 per cent of goods moved have been transported by road.

In the June Spending Round we announced transformational investment in our road network and reform to the status of the Highways Agency.

We have committed investment of over £24bn in this and the next Parliament. This should deliver 52 new national road projects and will triple annual investment on road enhancements from today’s levels to over £3bn by 2021.

Over 400 extra lane miles of Improved Motorways’ will be added, linking existing stretches to create a new ‘Smart Motorway’ corridor between the North West, Birmingham and London.

And we will invest more than £9bn in maintaining our national road network

The M62 J25-30 scheme near Leeds in South Yorkshire is now fully operational. A number of other schemes are already under construction, including the widening of the A23 between Handcross and Warninglid in West Sussex, and dualling the A11 Fiveways to Thetford in East Anglia, with completion expected in 2014/15;

The plans for the Highways Agency will see it turned into a publicly owned company with long term funding certainty, ending decades of underinvestment and uncertainty in our road network, making sure money goes where it is most needed and schemes are backed from design to completion.

Commercial vehicles are the basis of the sector. A trial of longer semi trailers is now well under way. Longer trailers enable freight companies to transport more goods, more efficiently, and should give significant economic and environmental benefits. We want to maximise their use during the trial to ensure we properly

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assess the benefits therefore we have recently changed the allocation procedure to better match supply and demand, so that the trailers can be used by the operators who are ready to use them.

Since we made the change, we have had requests for over 500 semi-trailers, from operators who are ready to place their orders with manufacturers within the next six months, in addition to the 550 that had already been authorised since the trial started last year.

Heavy goods vehicles are responsible for around 20% of green house gas emissions from domestic transport.

We have set up a joint Government and Industry Low Carbon HGV Technology Task Force with the aim of promoting the use of fuel efficient, low emission road freight technologies.

We have also launched a low carbon truck trial, which will support over 300 low carbon HGVs, (with around 130 already on the road and the remainder coming soon) and a number of gas refuelling stations that will be open to other operators. The trial aims to demonstrate the wider benefits of low carbon trucks, such as the potential for reduced running costs through fuel savings for operators, and will provide crucial evidence that will link with the government’s Ultra Low Emission Vehicle (ULEV) strategy which was been broadened to include heavier vehicles.

We are working on our new guidance on quiet out of hours deliveries, which will improve flexibility for freight operators and their customers and relieve peak hour congestion on busy high streets. We will be issuing this soon and disseminating it to all the sectors involved, including freight operators, retailers, local authorities and community groups.

We will continue to work with the freight industry to identify priorities where we can do more to help the sector develop and support the wider economy.

The HGV road user levy Act has now become law, and we are working to introduce the levy from April 2014.

The levy is being introduced to ensure a fairer arrangement for UK hauliers.

At the moment there are charges for lorries in almost every European country, yet foreign HGV drivers pay nothing to use UK roads. The HGV road user levy will correct that imbalance and ensure that foreign hauliers pay a contribution whenever they use UK roads and we will introduce other measures to be introduced at the same time to ensure that more than nine out of ten will pay no more than now.

We know that the freight sector is very competitive with many small firms and narrow profit margins.

In recognition of the impact that persistently high prices have on business costs the 1.89 pence per litre fuel duty increase planned for 1 September was cancelled.

Fuel duty has now been frozen for nearly three and a half years, the longest fuel duty freeze for over 20 years. As a result of government actions, average pump prices are 13ppl lower than if we had stuck to the previous government’s plans.

Cancelling the September increase will save a typical haulier £750 per year.

Budget 2013 announced that vehicle excise duty would be frozen for HGVs meaning that hauliers have been benefiting from frozen VED rates since 2001.

In 2013-14 the HGV rates would be around 45% higher if they had increased with RPI since 2001 and around 12% higher if they had increased with RPI since 2010.

In 2012, there were almost 300,000 people employed as large goods vehicle drivers in the UK. Driving is a

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skilled and safety-critical activity and we welcome the work being done by the industry to increase the recognition of it as a worthwhile job. We are committed to doing our part, for example working with industry to enable people with skills acquired in the military to make the most of their potential in civilian driving.

We continue to press for the right European-wide rules, the right level of discretion for the United Kingdom and the right interpretation of the European rules. So for example we have just laid a regulation to amend who is in-scope of driver CPC. This means that some drivers who drive infrequently as part of their job will not need to hold a CPC. This change represents a saving to the industry of nearly £24m per year.

We continue to negotiate to avoid excessive European requirements for roadworthiness testing. There are still some risks of disproportionate costs including related to caravans, but I am pleased that some of the potential impositions have been stopped.

I know that there are a number of issues that concern you. Our proposed option for a new commercial model for the VCA is to create a new company in a joint venture with a private sector partner. The Secretary of State will be a minority shareholder in the new company and will retain the position of UK Type Approval Authority. All of the services currently offered by VCA, including those considered by industry to be a “one stop shop”, will continue to be delivered by the new company. A prime objective for this project is to ensure VCA’s well-deserved international reputation for integrity and the delivery of high-quality services is maintained.

The new company will be established so that there will be a seamless transfer of responsibilities from VCA and although customers will obviously see some differences, the VCA’s capacity and quality of service on offer will not be impaired in any way

I understand the concerns of the industry regarding problems when booking an appointment for an individual approval inspection. The Vehicle and Operator Services Agency (VOSA) who are responsible for the inspections are working closely with the trade bodies, especially the SMMT, to identify and address concerns.

VOSA has implemented a number of measures including additional administrative and technical staff to boost capacity.At the moment VOSA staff operate from seventeen privately owned inspection facilities and plans to open three more VOSA sites are well advanced.

Despite introduction of the requirements in 2009, many manufacturers & builders have only recently had their first encounter with the type approval requirements and VOSA staff spend a lot of their time providing expertise and support. We recognise this is a difficult and demanding area.

Individual approval inspection remains very cost-effective route to registration for use on UK roads and VOSA staff will continue to provide assistance to help customers through the process.

We know that the freight and logistics industry is vital to the UK’s economy and I look forward to hearing more about the issues that matter to you.

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SMMT AUTUMN STATEMENT SUBMISSION, 11 NOVEMBER 2013

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INDUSTRIAL STRATEGY UPDATE, NOVEMBER 2013

Business Environment and Skills Working Group At the October informal Automotive Council meeting, the new Business Environment and Skills (BES) Working Group was approved and Nigel Stein, GKN, confirmed as chairman. The BES group has four key working groups with industry chairs. The four working groups are:

 Skills (Lead – Jo Lopes, JLR)  UK international competitiveness (Lead – tbc)  UK business environment (Lead – Gareth Jones, ebmPapst)  Europe (Lead – Andrew McCall, Ford)

The BES Group will meet four times and year and report to the full Automotive Council. It will have its first meeting on Monday 25th November. It will aim to improve the competitiveness of the UK business environment. The secretariat and strategic support will be provided by BIS, SMMT, GKN plus secondees. The membership is yet to be agreed.

Skills - Industrial Partnership bid In March 2013, an outline bid for an automotive Industrial Partnership (IP) was submitted to the UK Commission for Employment and Skills (UKCES) under the Employer Ownership of Skills pilot fund. Through an IP employers have a unique opportunity to create the mechanism to take end-to-end responsibility for addressing the skills needs in their sector.

The impact of the automotive IP will be:  Simple and transparent frameworks and processes for the entire sector which represent the consensus view of employers  Alignment of strategy and investment leverages more and better outcomes at sector level  Ensuring delivery at micro level fits within an overall hierarchy  Removes duplication of activity across the industry to provide real value to employers  Allows industry level consensus on prioritisation of needs to focus scarce resources  Cleans up accountability of all stakeholders  Ultimately ensure all activities aligned with delivery of the Automotive Consensus Skills Roadmap

At the end of July 2013, UKCES invited the automotive industry to develop a full IP bid, for submission in mid-October. UKCES advised that funding up to £30 million was ring-fenced for the automotive and aerospace sectors to bid to establish IPs. The IP, if successful, would have both government funding and also require industry to support through in-kind contributions and funding.

Following the UKCES invitation to submit a full-bid, the Automotive Council were invited (in August 2013) to nominate colleagues to be involved in an Automotive Skills Industrial Partnership Development Workshop. This group wrote and submitted on 18 October a full Automotive Industrial Partnership bid. The Automotive Council endorsed the draft and full bids. In the Sector Strategy it was confirmed that the IP - should a bid be successful - would be well-placed to deliver the draft consensus skills roadmap and the recommendations in the ‘skills’ chapter of the Strategy.

There are two parts to the full bid – infrastructure and participation pilots. The infrastructure element of the bid establishes the structure, processes and governance to deliver the consensus skills roadmap. The participation pilots element establishes test initiatives to deliver on some agreed areas from the consensus skills roadmap – basic skills/traineeships, apprenticeships and people in work. These areas were chosen as being both priority areas but also easily developed in the timeframe available.

Further to submission of the bid, industry will be invited to present to UKCES on the bid and expect to be advised on whether it has been successful in early 2014.

Advanced Propulsion Centre - £75 million for pilot projects On 7 November, government announced £75 million funding for pilot projects under the auspices of the Advanced Propulsion Centre (APC), which was announced in July. The APC will channel £1 billion investment from government and industry to fund the development of new technologies over the next 10 years. The competition to find the pilot projects for the APC will be run by the Technology Strategy Board. To apply for a share of the £75 million APC fund, bidders must form a group which includes at least one vehicle

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manufacturer, an SME and at least one supply chain company. The competition, which will support a range of powertrain technologies, will open on the 2nd December 2013, with projects expected to begin from April 2014.

Government has also announced funding of £1.5 million for the LUTZ project that will test driverless cars in a pedestrianised area for the first time. The ‘pods’ will be able to carry 2 people and will be run on designated pathways in Milton Keynes city centre. It is planned that in 2015, an initial batch of 20 pods will be driver- operated and will run on lanes separated from pedestrians. By mid 2017, 100 pods that are fully autonomous will be running on pathways alongside people and will use sensors to avoid obstacles. The early collaborators on the project are Arup, the Transport Systems Catapult, the Automotive Council, and Cambridge and Oxford Universities.

BIS-CBI Industrial Strategy conference SMMT attended the BIS-CBI Industrial Strategy conference on Wednesday 11 September 2013. Alongside this conference BIS published a written ministerial statement, and an economic analysis of key themes cutting across the sector strategies. These papers bring together insights from the analysis underpinning the sector strategies using the four themes of the conference – Exports, Innovation, Skills and Supply Chains. The key announcements focused on:

 Round 2 of the Employer Ownership Pilot - Government wants to give employers more direct control of how public funding for vocational skills is spent and are testing this through the Employer Ownership Pilot. Round 1 of the programme is funding 36 projects with £102m of Government funding matched by £108m of private investment. Under Round 2 of the project, 39 bids have progressed to the next phase and we will be announcing the first wave of these bids.

 Round 3 of the Advanced Manufacturing Supply Chain Initiative - the initiative was first established in December 2011 to help existing UK supply chains grow and achieve world class standards, while encouraging major new suppliers to come and manufacture here in Britain. The Autumn Statement 2012 provided an additional £120 million for two additional funding rounds of AMSCI – Rounds 3 and 4 – taking the total government contribution to this scheme to up to £245 million. Subject to due diligence five supply chain projects from the aerospace, chemicals, electronics and life sciences sectors will be receiving over £115 million of joint public and private sector investment and we expect their projects to create and safeguard over 1,500 jobs.

 £150 million investment in Green Construction projects - £60 million is being invested through the Technology Strategy Board to support the UK construction industry in designing and developing more energy efficient buildings. Government expects the projects to attract an additional £60 million of industry investment and £30 million extra funding from across Government. The construction industry contributes almost £90 billion to the UK economy and supports around 3 million jobs.

 The See Inside Manufacturing programme will be expanded from three to ten sectors, with seven new industries joining automotive, aerospace, and food & drink. The seven new sectors include construction, offshore wind and the life sciences. See Inside Manufacturing enables young people and teachers to get behind the scenes of the manufacturing industry and see first hand the opportunities available.

Alongside the conference, the CBI published a ‘year-on’ progress report on 11 September 2013.The main message of the report was the need to focus on timely implementation of the strategies and also focus on supply-chain development. Automotive and aerospace are prominent in the report. Ahead of Party Conference, EEF also published a review of progress on industrial strategy. EEF acknowledges progress has been made, and that the government has taken a number of positive steps to encourage investment in new equipment and research and development and to support exporters, however there is only limited progress in creating a more balanced growth.

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EUROPE UPDATE, NOVEMBER 2013

EU MEMBERSHIP – PROVIDING A VOICE FOR UK AUTOMOTIVE NOVEMBER 2013

The debate about a potential referendum on the UK's continued membership of the EU has seen significant contributions by the CBI and EEF in the autumn. Their reports and surveys aimed to provide the voice of business and manufacturing in this discussion and expressed strong support for the UK remaining a influential player in the EU, supporting a reform agenda that focuses on the real issues of relevance to businesses – competiveness, growth & jobs.

SMMT and Automotive Council SMMT has been asked by member companies to provide the automotive voice in this debate, based on an economic argument that reflects the interest of the automotive industry.

The Automotive Sector Strategy, published in July 2013, highlighted the integrated nature of the automotive industry in Europe and argued the importance of strong engagement and influence by UK government and industry on EU single market legislation, trade negotiations and wider industrial policy making:

“The automotive industry in the UK is fully integrated into the EU industry, with significant EU supply chains and substantial exports of finished vehicles and engines to EU markets. The Automotive Council believes that the UK’s active membership of the EU is an essential factor in the automotive industry’s current and future success.” (‘Driving success’ p.71)

The new Business Environment & Skills group of the Automotive Council under Nigel Stein, GKN, will build on this and establish over the next months the work it wants to undertake under the new 'Europe' work stream, to be led by Andrew McCall, Ford of Europe.

Following initial discussion at the Policy Co-ordination Committee and approval at the SMMT Executive meeting on 26th November, SMMT will develop and communicate the key economic evidence and industry views on the question of the value of EU membership and strong UK influence on EU policies by April 2014, providing the automotive voice as a key contribution to the public debate and further Automotive Council work.

Providing a voice for UK automotive - SMMT report & member survey SMMT has asked KPMG, led by John Leech, to develop a proposal for a robust report on the UK automotive industry and the EU that provides the economic case and evidence to demonstrate the value and need for the UK’s continued membership and strong engagement in the EU to deliver future economic growth and jobs in UK automotive.

The report will establish key economic analysis, facts and arguments for an SMMT campaign involving a member survey and SMMT messaging by April 2014.

The objective is to develop a robust report that provides the economic case and evidence to demonstrate the value and need for the UK’s continued membership and strong engagement in the EU to deliver future economic growth and jobs in UK automotive. It will build on the Automotive Sector Strategy and the CBI and EEF work and contribute to the work of the Automotive Council.

It is proposed the report project will be undertaken in two phases, initial desk research and then industry interviews and finalising report in March. The project will deliver a 25-30 page report and supporting slide pack, to be used at either at an SMMT stand alone event on Europe (April) or at the SMMT International Summit (June).

The KPMG proposal and SMMT plans were discussed at the Executive meeting on 26 November and the project was approved to commence.

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Next steps

 PCC meeting - 10 December – PCC to discuss Europe project following Executive approval

 KMPG Workshop – Date (tbc) - SMMT will organise a kick off workshop for KMPG with members to validate and allow discussion about KPGM’s initial themes and arguments for the report

 Member engagement – December-April 2014 - SMMT will inform members of Europe project and membership survey through relevant section & committee meetings and corporate communication channels

 Member survey – January/February 2014 - SMMT will conduct a membership survey on EU membership

 Report launch - April 2014

Lead contacts: Konstanze Scharring Robert Baker Director of Policy Chief Economist [email protected] [email protected] 020 7344 9223 020 7344 9224

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EUROPE UPDATE - CBI REPORT, EEF REPORT & KEY DATES NOVEMBER 2013

CBI report On 4 November, at their annual conference, the CBI published their report ‘Our Global Future: the business vision for a reformed EU’, setting out the need for the UK to stay in the EU but with reform urgently needed. The report followed an in-depth study and surveys, and includes research findings such as that membership of the EU is worth approximately 4-5% of UK Gross Domestic Product every year, or £62-78 billion.

The CBI highlights the following costs of membership:  Common rules are essential to the Single Market but the UK’s lack of unilateral control over some regulations is the biggest downside, especially on employment law where the Temporary Agency Workers Directive and Working Time Directive have caused deep frustration  The European Commission has a strong tendency to regulate, giving a sense of ‘mission creep’, particularly in areas around health and safety, and welfare legislation  There is an EU membership fee although net costs are less than often reported – equivalent to £116 per person every year – and it is dwarfed by the benefits of membership.

The CBI argues that the EU must be more outward looking, open and competitive to stay a key player in the international arena. It says:  The EU must be open and competitive, building a Single Market fit for the 21st century – that means a genuine Single Market for Services and the creation of a Digital Single Market to reduce barriers to e-commerce, allowing member states to remain responsible for policy where possible  The EU must be more outward looking, signing trade deals with large established markets such as the US, along with high growth emerging markets  The EU must work for all its member states, so that with an increasingly integrated core, legal safeguards are in place for non-Eurozone countries, as has been achieved in Banking Union negotiations  The EU must recognise and respect the boundaries set by member states and look to add ‘value’ not ‘functions’  The EU must improve and streamline how it operates by refocusing Commissioners to key growth portfolios like external trade and the Single Market, rather than 26 different Commission portfolios, each with a separate Commissioner and legislative agenda.  The EU must improve the process for assessing new regulations and reduce the cumulative regulatory burden, particularly on SMEs.

The CBI claim, business would like to see:  A moratorium on legislation where there is a case for decisions to be made at national level, such as employment law and ‘life-style’ regulation  The opt-out from the Working Time Directive made permanent.

The CBI report concludes there is no realistic alternative to EU membership that can combine all the benefits of the UK’s current relationship with none of the costs. Ultimately, all alternative models would leave the UK following market rules decided by others, rather than having a major role in setting the rules. The EU is increasingly having an impact on regulation not just on those who want to trade inside the EU, but at a global level. The report rules out the following options:

 Customs union – this model would leave the UK with limited EU market access, a ‘standards-taker’ and with zero influence over trade deals – which means where the EU signs a trade deal, the third party country would have access to our markets but not necessarily vice versa.  A customs union is no longer sufficient to give the access UK firms need in a complex global economy. Turkey currently operates with this model on the pathway to full membership, but their agreement does not cover services  A bespoke UK-EU trade deal – there would be great uncertainty around the likelihood of a deal on favourable terms to the UK, with the EU having a stronger negotiating hand and unlikely to ‘reward’ an exit. This arrangement would not free the UK from having to comply with EU regulation  Going it alone with the World Trade Organisation – this alternative would reduce market access by increased tariffs. There would be greater freedom for the UK to pursue its own trade deals, but it

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would be unlikely to get as favourable deals as the EU can and there would be a long period of dislocation while any new deals are negotiated  Norway and Switzerland options - while the CBI recognises the different arrangements that Norway and Switzerland have with the EU work for them in many respects, they would not work for the UK.

EEF report In September, EEF published their report ‘Manufacturing: Our future in Europe’. Their report was developed through in-depth research, interviews and surveys. In summary they found:  Manufacturers see advantages and disadvantages of being in Europe – key advantages are EU market access, investment, skills pool and ease to access multiple markets  The EU needs to work better for growth – for example the UK better accessing EU R&D funds  The UK must be better at being in Europe and influencing the debate  Government and EU institutions must take a long-term view on Europe with a long-term economic plan

EU - key dates  1 January 2014 - Greece takes over EU presidency  1 January 2014 – Bulgaria and Romania see EU ‘free movement’ restrictions lifted  Spring 2014 – New Commissioner candidates emerge  22 May 2014 – European Parliament and UK local elections  Summer 2014 – EP votes in new Commissioners, New Commissioners appointed and new Commission starts  1 July 2014 – New state aid rules enter into force (follows challenging process to agree and restrictions on category C area/large enterprises eligibility  1 July 2014 – Italy takes over EU presidency  18 September 2014 – Scottish Referendum (‘yes to independence’ vote could require Scotland to negotiate and EU relationship)  1 January 2015 – Latvia takes over EU presidency  2015 – New EU Multiannual Finance Framework begins (EU Budget)  2015 – UK general election  [BY 2017 – EU in/out referendum if Conservative government elected in 2015]

Jennifer Pheasey Senior Policy Manager [email protected] 020 7344 9221

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SMMT TRADE POLICY TRACKER NOVEMBER 2013

Latest status on trade dossiers Transatlantic Trade and Investment Partnership (TTIP) A second round of negotiations on the Transatlantic Trade and Investment Partnership (TTIP) between the US and EU were held at the beginning of November. This round was previously due to take place in October but was postponed due to the US government shutdown. During the latest round of negotiations, the European Commission met with key US government stakeholders to discuss issues concerning the automotive sector, including recognition of equivalence of regulatory systems. The Commission was joined by the Office of the US Trade Representative (USTR), officials from the Department of Commerce, the Department of Transportation and the National Highway Traffic Safety Administration (NHSTA). The European Commission and US officials discussed at very initial stages how recognition of equivalence and associated methodology could be used to overcome barriers. Negotiators also discussed harmonisation of General Technical Regulations (GTRs) and how to improve the international harmonisation process.

The Commission has indicated that the third round of negotiations scheduled for December will be key in terms of the Commission putting forward more substantial proposals on methodology. ACEA’s US counterpart, the Auto Alliance, will be appointing a consultant to look further at potential methodology for functional equivalence. Initial ideas are expected to be shared by ACEA with the Commission ahead of the third round.

On 14 November, SMMT met with Alex Lau, Senior Policy Adviser in the BIS Transatlantic and International Unit, who has been tasked to lead on issues related to automotive. SMMT provided an overview of the automotive industry position on TTIP and discussed specific issues related to low volume manufacturers, recognition of equivalence, engagement with US regulators and the industry’s export profile to the US.

SMMT participated in a roundtable in the House of Lords by EU Sub-Committee C on External Affairs on 24 October as part of their inquiry and the UK parliamentary scrutiny process of TTIP. SMMT will give formal oral evidence to the Committee as part of an automotive panel (including Jaguar Land Rover, McLaren Automotive and Ford Motor Company) on 12 December.

EU-Japan trade relations Formal negotiations for an EU-Japan FTA were launched on 25 March 2013. A third round of negotiations was held in Brussels between 21 and 25 October, which focussed on each side’s proposals for the text of the future FTA. The European Commission will hold an inter-session meeting with Japanese negotiators in December ahead of a fourth round of negotiations in early 2014. A key focus for discussions between negotiators is progress on the roadmap of NTBs outlined as a result of the scoping exercise before negotiations were opened. Member States have stressed the importance of focussing on the roadmap in the Council’s Trade Policy Committee.

On 17 October, SMMT met with the Commercial Counsellor of Japanese Embassy in London and JETRO, where an assessment of the implementation of the Government of Japan’s cabinet decision in relation to NTBs was presented.

UK government has commissioned an economic study into the effects of NTBs on UK companies to ascertain more detailed priorities. BIS has sent an information request to a range of vehicle manufacturers requesting feedback on how NTBs in Japan are affecting their exports. BIS will also continue to monitor progress on NTBs alongside the official review built into the mandate, which will be triggered a year after negotiations open.

EU-India FTA There has been limited progress in negotiations between the EU and India. There is little progress likely in the coming months due to Indian elections and the appointment of the new European Commission in 2014. Indications from the Commission, however, note that if an agreement on the services package in the FTA is forthcoming, this may provide pressure on closing a deal. Overall, there is little likelihood that the FTA would be concluded this year or next. The automotive industry’s position remains firm on tariff dismantling and regulatory convergence, particularly around the principle of “zero-for-zero” on import duties for vehicles and components. ACEA has assessed the current offer for automotive and concluded that it would lead to an unbalanced agreement with no leverage for further liberalisation on the Indian side.

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EU-South Korea FTA implementation There are ongoing issues regarding the application and implementation of the FTA. Key concerns at a European level have been voiced by ACEA and CLEPA to the Commission. The Commission has raised these issues directly with Korean authorities, however little progress has been made. ACEA has identified a list of NTBs that it considers the most significant obstacles, which include: acceptance of UN ECE regulations; evaporative emission standard and Euro 6 On-Board Diagnostics (OBD) for petrol cars; truck tractors; vehicle width; and duplicated certification of fuel economy.

Doha trade facilitation agreement A ministerial WTO meeting is due to be held in Bali, Indonesia from 3 to 6 December to find agreement on a trade facilitation package as a result of no progress in the Doha round of trade talks. It is estimated that a deal on trade facilitation and other measures could potentially amount to half of the value of a full Doha agreement. Lord Green, the UK government’s trade minister will act as Vice-Chair of the conference at which political momentum is hoped to persuade a number of countries to clarify implementation plans resulting from an agreement on trade facilitation. The CBI is also attending the conference as part of a UK government-business delegation, alongside the new Director of Trade and International in the Department for Business, Innovation and Skills, Chris Barton.

SMMT activity in Q3 & Q4 2013  SMMT met with Edward Barker, Head of BIS TTIP Unit, 23 July  SMMT participated in CLEPA conference call on TTIP, 25 July  SMMT participated in ACEA/AAPC/Alliance conference call on TTIP, 5 September  SMMT attended CBI member roundtable on TTIP, 10 September  SMMT and members met with BIS TTIP Unit officials, 12 September  SMMT met with Ken Clarke MP on TTIP, 1 October  SMMT met with Japanese London Embassy on EU-Japan FTA, 17 October  SMMT met with Special Adviser to Ken Clarke, Kathryn Laing on TTIP, 23 October  SMMT participated in House of Lords roundtable on TTIP, 24 October  SMMT attended British American Business conference on TTIP, 12 November  SMMT meet with Alex Lau, BIS TTIP Unit, 14 November  SMMT met with CBI, ESCA, CLEPA in Brussels, 19 November  SMMT attended ACEA Trade group in Brussels, 20 November  SMMT attended BIS TTIP Core Stakeholder Group meeting, 27 November  Ongoing contact with CBI Brussels office, CLEPA and ACEA on trade issues  Regular updates in SMMT Policy Report

Member engagement  Current requests for member feedback - South Korea FTA implementation issues - BIS Japan NTB analysis and request for information

Key next steps  SMMT to attend BIS core stakeholder group meetings on TTIP  SMMT to meet with BIS Trade Policy Unit in early 2014 to discuss progress on EU-Japan FTA  Further engagement on TTIP with members and BIS Trade Policy Unit  Continue monitoring EU/UK activities including ACEA/CLEPA engagement  Continue feedback to BIS on South Korea implementation

Contact Jonathan Hawkings Policy Manager [email protected] 020 7344 9217

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NEW CAR & VAN CO2 UPDATE

Cars An informal trialogue deal was struck on the review of new car CO2 2020 modalities on 2 November. The June trialogue text applies, with the additional points:  Phase-in for year 2020, with the 95g/km target applying to 95% of new cars (100% in 2021)  Super-credits averaged 2020-22, with a 7.5g/km cap over that period.

The deal was agreed by COREPER on Friday 29 November (member states' permanent representatives, for the Council).

SMMT has maintained regular dialogue with UK government officials and met recently with several key UK MEPs and UKRep (UK Permanent Representation to the EU). UK government is willing to be flexible to deliver agreement at first reading.

Comments from stakeholders:  Presidency "On 26 November a provisional [trialogue] agreement was reached on the possible elements of limited additional flexibility that could still be included in the text and ensure the fair and equitable treatment of all manufacturers without compromising the overall balance of the compromise package agreed in June.

The Commission by 2015 will submit a report to the European Parliament and to the Council which should include proposals for amending this Regulation with a view to establishing CO2 emission targets for new passenger cars beyond 2020, including the possible setting of a realistic and achievable target for 2025, based on a comprehensive impact assessment that will consider the continued competitiveness of the car industry and its dependent industries, while maintaining a clear emissions reduction trajectory" www.eu2013.lt/en/news/pressreleases/agreement-on-reduction-of-co2-from-cars-big-step-towards-resource- efficient-europe

 EP www.europarl.europa.eu/sides/getDoc.do?pubRef=-%2f%2fEP%2f%2fTEXT%2bIM- PRESS%2b20131126IPR26748%2b0%2bDOC%2bXML%2bV0%2f%2fEN&language=EN

 Council www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/en/envir/139786.pdf

 T&E www.transportenvironment.org/press/te-comment-final-cars-co2-trilogue-deal

 “CLEPA welcomes the Council agreement on 2020 CO2 limits for cars which offer a clear and stable legal environment for investment, and will help the automotive industry to keep its technological leadership. The retention of super credits and eco-innovation for low emission vehicles will boost the development of breakthrough technologies”. www.clepa.eu/index.php?type=1001&damId=6701&cuid=&file=fileadmin%2Ffiles%2FPRESS%2F2013_11_2 9_CLEPA_PR_CO2_limits_for_cars_agreement.pdf

Next steps  The EU Parliament may consider the deal at ENVI Committee in December and then vote in plenary session 13 January (which will also vote on the vans deal).  Council will finally approve the deal after the 13 January EP Plenary.

SMMT will maintain close contact with ACEA, SMMT members, UK government, and MEPs as appropriate.

Vans The June trialogue deal was approved on 5 November by the EP Environment Committee and, having already had approval from the Council; it now awaits a formal plenary vote in the EP. The text for the ENVI Committee is available at www.europarl.europa.eu/meetdocs/2009_2014/documents/envi/dv/envi20131104_co2_and_vans_/envi201 31104_co2_and_vans_en.pdf

Next steps  Post-2020: the Commission is expected to present a Communication on the post-2020 regime, but this has been held back to keep it separate from the 2020 modalities review, above. SMMT has begun to discuss with members the basic lines for engagement on post-2020 CO2. Members are asked for their views on what elements they would like to see/not see in the post-2020 regime.

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HDV CO2 UPDATE – UK METHANE GAS TRUCK STRATEGY, EU REGULATORY DEVELOPMENTS

Gas strategy from DfT/Industry Task Force on low emission trucks The TF study on barriers to uptake of low emission trucks (Dec 2012) recommended gas trucks (CNG/LNG/biomethane) as a key technology for reducing CO2 emissions from the freight sector, especially the long haul and regional delivery fleets that consume 70% of the fuel in the sector. Since the study was presented to the Freight Minister, the joint government-industry TF has developed a methane gas strategy to tackle the barriers, such as the lack of investment certainty for infrastructure providers and freight operators.

The draft strategy is nearing completion and is expected to be presented to the Minister Robert Goodwill on 9 January. The key actions are likely to include:  Clear strategy for the role of methane as a fuel for HGVs.  Remove financial and legislative barriers: review the range of fiscal incentives (fuel duty differentials, biomethane incentives, capital allowances); consider incentives to improve the business case for operators; recognition for the certified use of biomethane in carbon reporting (green gas certificates); revise the Construction and Use Regulations to add other types of gas; legislative amendments on weight classes for additional equipment (gas tanks); cross-departmental discussion on waste policy to remove barriers to biomethane supply.  Improve evidence base: improve data on numbers of gas vehicles; capture evidence from the Low Carbon Truck Trial; ancillary benefits of using gas in HGVs, eg noise, air quality; scenarios for vehicle uptake and biomethane supply to determine potential GHG savings, costs and benefits; gas production pathways to calculate well-to-wheel carbon savings for different forms of methane gas  Facilitate implementation and delivery: consider measures to address unwanted methane emissions; support infrastructure development; EU standards for refuelling infrastructure; gas fuel standards.

EU developments - VECTO As a first step towards an EU HDV CO2 strategy, a number of studies have been commissioned by DG CLIMATE ACTION, including a methodology for CO2 emission measurement for HDV, taking into account not only the engine but the whole system – engine, truck, driving resistance, aerodynamic - and measuring all relevant contributions of CO2 ("VECTO" - Vehicle Energy Consumption calculation Tool).

The latest information was presented at a JRC workshop at Ispra in May http://iet.jrc.ec.europa.eu/international-forum-co2-heavy-duty-vehicles-workshop . In particular, some of the Session 3 presentations will be of interest "CO2 from HDV monitoring methodology development" and "Proof of concept and validation testing in Europe". This illustrates a 3% error margin but more like 10% on urban duty cycles (not fit for purpose). Further work “Lot 3” will be to develop it into a certification tool.

We also discussed the reference body definition is important as this data is used unless the builder tests their own product.

Separately to the VECTO developments, the Commission will develop a regulation, probably focussing on CO2 measuring requirements as a first step. They are considering how to make a whole-vehicle regulation and split the responsibility between engine, tractor and trailer manufacturer.

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NOISE UPDATE – 27 NOVEMBER 2013

Council agreement – 15 November On Friday 15th November, the Council of Ministers endorsed a provisional agreement between the Lithuanian Presidency of the Council and the European Parliament representatives on the sound level of motor vehicles. The agreement should lead to formal adoption of the new regulation, on which the European Parliament is expected to vote early next year.

The regulation will be applicable two years after its entry into force.

In summary:  Limits: see annex in the attached document  Labelling/information: Under the agreement, manufacturers and distributors should display information on noise levels of vehicles at points of sale and in printed and electronic promotional material such as brochures, leaflets and catalogues. A similar label to the one currently used for information on CO2 emissions, fuel-consumption and tyre-noise should in future inform consumers about the sound emissions of a vehicle. Furthermore, public authorities will have to encourage the use of quieter vehicles through information campaigns in order to reduce road traffic noise.  Quiet vehicles/acoustic systems for electric vehicles: Quiet vehicles will be equipped in the coming years with Acoustic Vehicle Alerting Systems (AVAS).  Road surface quality: Research work will be carried out in order to assess the impact of the road surfaces in the levels of noise.

The Council’s press release can be seen attached – this includes the limit tables.

Please also see a statement by the Lithuanian presidency: http://www.eu2013.lt/en/news/pressreleases/lithuanian-eu-council-presidency-completednegotiations-on- regulation-stipulating-noise-limits-from-cars

 UK government position: As far as we are aware, we believe the UK government supports the above proposal, however this is to be confirmed and subject to EU scrutiny committee sign-off.

 Quiet road vehicles (QRTV): the council position is to make noise generators mandatory within 4 years for new vehicles and 6 years for existing types. There will be a switch to turn the device on/off, with a ‘key on’ default as ‘on’. No decibel limit has been proposed with an expected statement of ‘the sound will be similar to a vehicle in the same category’ up to a speed of approximately 20km/h. The next UNECE meeting is on the 10th December in Tokyo.

ENVI vote – 27 November On November 27, the European Parliament’s ENVI committee adopted the outcome of the negotiations with the Council on the Proposal for a Regulation of the European Parliament and of the Council on the sound level of motor vehicles with 45 in favour, 11 against and 1 abstention.

The consolidated text document can be found attached and here: http://www.europarl.europa.eu/meetdocs/2009_2014/documents/envi/dv/envi20131127_csl_soundlevel_vehi cles_/envi20131127_csl_soundlevel_vehicles_en.pdf

The legislative observatory link is: http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?reference=2011/0409(COD)&l=en

The next step is the European Parliament plenary vote in the New Year.

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DIESEL FUEL FILTER BLOCKING

Summary  Between October 2012 and April 2013, there were a large number of diesel car and van failures as a result of a blocked diesel fuel filter, leaving customers with an under-performing vehicle or, in the worst cases, one that would not start.  AA and RAC data indicate 84 and 38 vehicle models respectively were affected, both old and new.  Combining the AA and RAC data shows there were ~6400 additional cases between October and April 2012/13 compared to 2011/12.  Several manufacturers have indicated an increase in dealer visits/warranty claims for this fault and in some instances repeat visits for the same fault. The cost in most cases has been covered by the manufacturer as goodwill.  There has been MP correspondence about the issue.  The vast majority of cases were reported in Edinburgh, Glasgow, Essex, Kent and Newcastle, perhaps indicating a localised fuel issue.  SMMT informed the British Standards Institution (BSI) committee responsible for fuel quality and BSI appointed SMMT to set up a BSI task force to investigate the issue. SMMT also wrote to BSI’s CEO to encourage a precautionary approach to protect consumers with a robust containment plan.  The issue has returned this winter and is monitored weekly as we move to winter grade fuel.

Background The SMMT first became aware of the issue following correspondence with the Down-stream Fuels Association (DFA) asking if any SMMT members had a fuel filter problem during winter 2012/13. SMMT member companies indicated there was an issue and the SMMT Fuels Working Group agreed to raise this formally with the BSI fuel standards group. BSI appointed SMMT to chair a task force to investigate the issue and the task force have agreed to implement an 8D problem solving approach. The group is well supported by experts from SMMT, UKPIA (UK Petroleum Industry Association), DFA and the fuel additives companies.

To date, the investigation has focused on defining the problem and collecting the information needed to establish the root cause. This work is still ongoing, but in parallel there is a need to put in place a containment plan to prevent the same issue occurring this winter. Early indications are that the fuel in the market meets the current fuel specification set out in the BS EN590 standard and that this is not traditional diesel waxing which can occur in cold temperatures. Preliminary results from the vehicle fuel tank samples contained 5-7% biodiesel, with the chemical analysis of the filter indicating a high level of saturated monoglycerides (SMG), pointing to a complex mix of tallow and waste material in the biodiesel.

The SMMT members via the Car Section Committee gave permission for the AA and RAC to provide daily breakdown data to the SMMT to track the issue. This is being fed to the fuels industry to trace the issue back to a terminal. The BSI standards have limited scope, but are being pursued along with providing data to ensure the oil and biofuel blenders resolve the issues as a commercial matter.

Next steps The task force are working on the following tasks in parallel: The next 3 months The next 12 months  Continue industry-wide data collection on the  Continue investigating to isolate the root source of the fuel prior to the breakdown cause  Request a more stringent UK winter diesel  Encourage CEN to develop an improved limit if the issue recurs in the market testing method to be included in the standard  Ensure the PR and political messages are in  Conduct SMMT market fuel survey to gather place and used as appropriate independent evidence of the fuel quality

Consideration for Executive Committee  Awareness of the warranty issues and the mitigation actions that can be put in place this winter.  Agree an outline approach to take with the BSI committee and wider if the issue reoccurs this winter.

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ENERGY EFFICIENCY SCHEMES UPDATE, NOVEMBER 2013

Summary  Increased political concern over rising energy costs and impact this could have on economic recovery – curbing consumer spending and impacting on competitiveness of businesses. Autumn statement (5 December) may see some measures announced to ease the burden.  Government still has legally binding emissions targets to achieve.  Expect wider industry to see little change in energy policy, and possibly of increased burden, if relief for consumers and electricity/energy-intensive sectors is provided.  Energy Savings Opportunity Scheme – ESOS is due in 2015. Non-SMEs will be required to undertake audit and identify costed abatement opportunities. Energy focus would also include transport (so beyond CCA/ETS/CRC reporting). Having ISO50001 or ISO140001 (plus energy audit) would be seen as compliant. Possibility that qualified internal staff could act as lead ESOS assessor.  EU Emissions Trading Scheme – EC plans to reduce number of allowances allocated are on-going. ACEA/SMMT met with EC in push for carbon leakage status in 2015-2020 (which would mean more free allocations), ahead of decision by late 2014.  Climate change agreements - around half SMMT members made use of the data correction window to re-submit baseline data (closed 30 September). Now awaiting Environment Agency to review and agree changes by the end of the year. Next year to see discussion on what data will publish on participants individual targets performance in first year reporting in 2015. Mineralogical and metallurgical sectors to be exempt from CCL in 2014 (so out CCAs and CRC). Question over whether any automotive activities could be exempted. Once these sectors excluded could mean review of CCAs per se. Review of targets expected in 2016.  Carbon Reduction Commitment – 2012/13 emissions reported in Annual Performance Report (which replaced performance league table). Registration for next phase of CRC, which starts in April 2014, closes at end of January. Loss of CCA exemption rule expected to bring more automotive companies and emissions into the scheme (increased cost).  Work stream on business environment to be set up following publication of the Automotive Strategy, expected to include business energy.  SMMT webinar on energy efficiency and promoting our CCA is provisionally scheduled for 10 December.

SMMT Autumn Statement letter – below is extract on business energy The impact of high energy costs and uncertainties over future energy supply on UK automotives international competitiveness is a long-standing concern of industry, affecting the supply-chain and highly mobile companies, which could be subject to carbon leakage. This is exacerbated by the complexity of the energy efficiency regimes in the UK, which are a significant issue for our sector – and SMMT reiterates its calls for simplification of regulations and reporting and, in particular, restoration of the general CCA exemption rule in the CRC. We also encourage government to make as much use as possible of existing reporting regimes in meeting forthcoming European and domestic measures on business energy use and abatement measures (e.g. within the Energy Savings Opportunity Scheme). Business energy costs impact on the global competitiveness of UK industry and present a competitiveness challenge to attracting investment, particularly as other European countries offer much greater incentives than the UK to companies which could be subject to carbon leakage.

Summary detail on specific energy efficiency schemes

ESOS (Energy Savings Opportunity Scheme) ESOS is the government’s proposed response to Article 8 of the EU Energy Efficiency Directive (2012/27/EU), which requires all Member States to introduce a regime of regular energy audits for ‘large enterprises’ (non-SMEs) to promote the uptake of cost-effective energy efficiency measures. ESOS will cover all energy streams, including transport, and be based at an organisational level (like CRC), rather than at a site level (like CCAs or EU ETS). The audits must be undertaken by 5 December 2015, and then at least every four years thereafter. ESOS will include need to list costed abatement opportunities (although companies will not be required to act upon them). DECC consultation on ESOS closed on 3 October (see https://www.gov.uk/government/consultations/energy-savings-opportunity-scheme.)

SMMT response to DECC submitted (TEC/2013/568), sought to make maximum use of existing reporting – eg CCA, EU ETS and CRC, coupled with de-minimis level (which would hopefully negate need to report

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transport emissions and only use CCA/ETS/CRC data to comply). SMMT supported DECC proposal that ISO50001 or ISO140001 (with an energy audit) would be seen as complying with ESOS. Government response to condoc is due in April.

EU ETS Backloading: The Council agreed to support a mandate on the backloading proposal as amended by the European Parliament. Consequently a trilogue is expected to start shortly. The auctioning regulations need to be amended to specify when the 900 million allowances will be removed from the market and then put back in. This amendment will be agreed through Comitology by Member States in the Climate Change Committee over the coming months

Structural reforms: The Commission indentified three front runners for the future structural changes of the Emission Trading Scheme. Those include:  A flexible supply mechanism - achieved by adding/releasing allowances into/from a reserve,  Permanent retirement of phase 3 allowances,  Early revision of the linear reduction factor.

Carbon leakage: ACEA and SMMT met with the Commission on 26 September to discuss the review of the carbon leakage list and sector’s carbon leakage exposure. The meeting was more positive than initially expected. ACEA presented calculations clearly showing the trade intensity ratio rising above the required 30% over recent years. The Commission promised to compare their data with the ACEA calculations. The Commission will be using either 2009-11 or 2010-12 as a baseline for the calculations. The draft work on the carbon leakage list should be completed in early 2014, a draft list in mid-2014 and a final list in the end of 2014. The list will be valid for 2015-2020.

Climate Change Agreements (CCA) The new Climate Change Agreements (CCA) came into effect on 1 April 2013. These are expected to provide participants with savings of over £10 million per annum in levy relief (up from £6mn under old scheme) in return for 15% improvement in energy efficiency by 2020. 37 automotive sites are now in the auto sector CCA, up from 27 under the old scheme (additional sites are all component producers). Members had till end of September to re-submit, without penalty, baseline data and around half of facilities used this data correction window. Environment Agency has till end of the year to review any proposed changes. The first milestone reporting of 2013 and 2014 emissions will take place in April 2015.

In Budget 2013 Chancellor announced metallurgical and mineralogical sectors would be exempt from CCL from April 2014. SMMT is reviewing where particular processes in our sector may be eligible, although unlikely. For those left in CCAs, there could be implications from the exemptions – in terms of Environment Agency running costs and a DECC review of the benefits/savings of CCAs.

Planned target review in 2016.

Carbon Reduction Commitment (CRC) Participants 2012-13 emissions performance was published on 14 November – see http://www.environment- agency.gov.uk/business/topics/pollution/146938.aspx.

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The CRC is being simplified, some measures already implemented (eg move to only reporting electricity and gas) with more to follow in phase 2 (April 2014). Many of the measures will have little real impact on the automotive sector, although removal of the CCA exemption rule (so all emissions not covered by CCA (and EU ETS) will be subject to the CRC, if they over the CRC threshold) expected to bring more automotive companies and emissions into the scope of CRC (which will mean increased costs for the sector). Registration for phase 2 is open till end of January 2014. Move to two auctions per annum starts in 2014 (auction in April and June/July), although details on price yet to be revealed (possibly in AS).

Definition of EU ETS installation in CRC published by Env.Agency, which suggests total site could potentially be exclude from the CRC scheme.

METS Energy efficiency topics are largely dealt with by the SMMT’s METS Group – Manufacturers Energy and Trading Schemes working group. The latest METS meeting on 27 November is at Midlands Wood Fuels (a biomass plant). The next meeting is scheduled for 28 January 2014, which will include presentation by British Compressed Air Society. SMMT also liaises with the CBI, MCCG (Manufacturers Climate Change Group) and UK ETG (Emissions Trading Group) and government departments directly to ensure members are kept up to date on energy efficiency regimes and policies and members’ views can be feed into the shaping of these measures.

Next steps  Ensure all CCA participants regularly reporting data  Encourage companies to register for CRC by end of January  SMMT business energy and promoting CCA webinar on 10 December  Develop business energy strategic overview – on-going  Work with ACEA on carbon leakage agenda – to support EU ETS – on-going

Contacts Matt Croucher - [email protected] - 0207 344 1640 Monika Bomba - [email protected] - 0207 344 1615

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MARKETING BEST PRACTICE PRINCIPLES UPDATE FOR PCC – NOVEMBER 2013

Background The Best Practice Principles for environmental claims in automotive marketing to consumers are a publication jointly endorsed by LowCVP, ISBA (Incorporated Society of British Advertisers) and SMMT.

The Principles are a reference point for consumers, the automotive industry and its marketers in the sphere of marketing communications for passenger cars and light commercial vehicles (up to 3.5 tonnes). The scope and basis for the principles is outlined clearly on the first page of the principles document.

The first version of the Principles was published in 2010, and an update project undertaken in 2011, with the second version of the Principles being published and relaunched in November 2011.

The 2011 update made changes to reflect the digital (online) remit changes of the Committee on Advertising Practice (CAP) Codes, to clarify comparative test data use, and update the legislative references and hyperlinks/web references.

2013 Principles Update The 2013 update project is a regular update, being led and co-ordinated by SMMT, on behalf of LowCVP and ISBA. The project plan and implementation was undertaken through full consultation with each of the partners and their members.

The following has influenced the updates – a need to:  Update the legislative references, hyperlinks, etc  Include appropriate terminology and references for plug-in hybrid vehicles  Reflect discussions in 2012 with the Advertising Standards Authority (ASA) regarding ‘zero emissions’ claims and subsequent CAP advice  Reflect recent ASA adjudications and advice on MPG claims  Reflect recent CAP advice on electric vehicles advertising.  Have an opportunity to remind audiences about the Principles and use of them

The most significant changes are the following:  3c) It should be clear whether environmental claims apply to the vehicle, to particular components or technologies, to the vehicle manufacturer or phases of the life-cycle e.g. ‘zero emission’ claims should refer to ‘whilst driving’ or similar.  4b) For plug-in hybrid vehicles, the equivalent drive cycle is the weighted combined cycle. It should be clear the weighted combined performance data relies upon both fuel and electricity e.g. MPG and miles/kWh (kilo Watt hours), and that the electricity is mains sourced.  4e) When using MPG figures to make efficiency claims, it should be ensured that they are sufficiently explained, for example by stating ‘MPG figures are official EU test figures for comparative purposes and real driving results may vary’ or similar.  4f) Electric-only-range figures should be sufficiently explained, for example by stating ‘Range figures are official EU test figures for comparative purposes and real driving results may vary’ or similar.

A ‘marked up’ version of the Principles (yet to be laid out by the designer) – showing the changes highlighted in red can be seen attached.

Launching the new Principles – 3 December The new Principles will be launched on Tuesday 3 December. The launch includes:  Press release, social media, etc  Webinar – 3 December, 2-3pm, register here: https://www2.gotomeeting.com/register/419704882  Communication of an updated version (PDF) to members

Contact: Jennifer Pheasey Senior Policy Manager [email protected], 020 7344 9221

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Best Practice Principles for environmental claims in automotive marketing to consumers

Jointly endorsed by LowCVP, SMMT and ISBA

BACKGROUND AND SCOPE

These Best Practice Principles (‘the Principles’) have been developed as a framework and a starting reference point for consumers, the automotive industry and its marketers in the sphere of marketing communications for passenger cars and light commercial vehicles (up to 3.5 tonnes). The Principles are not intended to supersede existing legislation, the mandatory Advertising Codes and government guidance which shall still be the key sources for ensuring that advertising and marketing are fully compliant in respect of environmental claims.

These Principles shall apply to all areas of marketing covered by the rules and guidance listed below. In addition, they will extend to in-showroom advertising, marketeers’ editorial content, press releases, corporate reports and marketing information on corporate websites (e.g. a vehicle manufacturer’s website) and other non-paid-for space under the advertiser’s control (eg social networking sites).

It is believed that these Principles will contribute to the Integrated Approach*1 by increasing consumer understanding of the environmental performance of vehicles. Consumers will benefit from the receipt of information which industry openly certifies as being based on genuine environmental benefits. The automotive industry, in adopting these Principles, will observe the spirit of them and support implementation in good faith.

The key sources governing the communication of environmental claims are in the legislation/codes/guidance listed below and further reference should be made to these for their detailed provisions:

 European whole vehicle type approval  CO2 and tailpipe emission standards  The End of Life Vehicles Directive  The CO2 Labelling Directive and specific to the UK, the colour coded CO2 labels for new and used cars, which are industry voluntary initiatives.  The Passenger Car (Fuel consumption and CO2 Emissions Information) Regulations 2001 (as amended) and related Vehicle Certification Agency Guidance Notes (VCA, see web link in Appendix) and other guides on labelling. Note the 2013 update to these Regulations, the main implication of which is to bring into scope cars that do not emit CO2, hydrocarbons or carbon monoxide;  International standards such as ISO 14021 on environmental labelling.  The Consumer Protection from Unfair Trading Regulations 2008;  The Business Protection from Misleading Marketing Regulations 2008  The UK Code of Non-Broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code) effective from 1 September 2010 (as updated)  The UK Code of Broadcast Advertising BCAP Code) effective from 1 September 2010 (as updated)  Defra Green Claims Code 1998 (updated 2000) and Green Claims Guidance 2011.  Advertising and Marketing Communication Practice Consolidated International Chamber of Commerce (ICC) Code – 2011

Additional information on the most relevant legislation of these is set out in the Appendix.

1 Integrated Approach is a sharing of responsibility between stakeholders, such as the automotive industry,

fuel supply industry, government - at local, national and European levels - and, of key importance,

consumers.

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ENDORSEMENT ORGANISATIONS LowCVP (Low Carbon Vehicle Partnership) has joined with the representatives of UK industry to establish these best practice principles. The LowCVP is an action and advisory group, established in 2003 to take a lead in accelerating the shift to low carbon vehicles and fuels in the UK and to help ensure that UK business can benefit from that shift. Visit the LowCVP homepage for more information: www.lowcvp.org.uk

SMMT (The Society of Motor Manufacturers and Traders Limited) is the leading trade association for the UK automotive industry; it represents companies ranging from vehicle manufacturers, component and material suppliers to power train providers and design engineers. Visit the SMMT homepage for more information: www.smmt.co.uk

ISBA (Incorporated Society of British Advertisers Limited) is the representative body for British Advertisers, covering all sectors of the economy and the public sector. Visit the IBSA homepage and cars pages for more information: www.isba.org.uk and www.isba.org.uk/issues/cars

THE BEST PRACTICE PRINCIPLES

1. General principles and definitions

a) Marketing communications should be legal, decent, honest and truthful.

b) The same good standards of commercial practices should apply throughout the marketing chain.

c) Consumers should be able to access information to make informed purchases with ease.

d) An environmental claim means information appearing in marketing communications which can be taken as saying something about its environmental aspects.*2

e) A marketing communication includes advertising as well as other techniques, such as promotions, sponsorships, and direct marketing, and should be interpreted broadly to mean any form of communication produced directly by or on behalf of marketeers intended primarily to promote products or to influence consumer behaviour.*3

2. Environmental principles

Environmental claims should:

a) Be specific.

b) Not mislead.

c) Be capable of substantiation.

d) Be transparent, unambiguous and clearly expressed.

e) Follow a common-sense approach.

3. Accessibility of information and plain language

a) Consumer information should be easily accessible. For instance, where vehicle manufacturers provide CO2 emissions or fuel consumption information on their websites, they should ensure it is available within the minimum practical number of clicks.

b) Plain language should be adopted and terms defined so consumers can understand technical data.

2 DEFRA Green Claims Code 3 Consolidated ICC Code of Advertising and Marketing Communication Practice

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c) It should be clear whether environmental claims apply to the vehicle, to particular components or technologies, to the vehicle manufacturer or phases of the life-cycle e.g. ‘zero emission’ claims should refer to ‘whilst driving’ or similar.

d) Where environmental claims infer benefits that conform to the law or to industry standards, this must be stated.

e) Environmental claims should not infer benefits that relate to aspects that would not normally be relevant to that vehicle/component/technology, or corporate practice.

f) Environmental claims should not imply that they are universally accepted if there is a significant division of informed or scientific opinion.

g) All environmental claims should be reassessed regularly and withdrawn if they are no longer capable of substantiation.

4. Comparisons and comparability information

a) Data quoted in comparisons should be clearly defined and adhere to commonly adopted current industry standards. The following are examples of commonly used measures, but are not an exhaustive list of the units used: carbon dioxide (CO2) is usually measured in grammes/km; fuel economy in litres/100 km or miles per gallon; and regulated emissions referenced to Euro standards*4, e.g. Euro 6.

b) If only one drive cycle is quoted for fuel economy or CO2 performance in advertising headlines, the combined cycle data should be used in preference to urban or extra-urban cycle data. For plug-in hybrid vehicles, the equivalent drive cycle is the weighted combined cycle. It should be clear the weighted combined performance data relies upon both fuel and electricity e.g. MPG and miles/kWh (kilo Watt hours), and that the electricity is mains sourced.*5

c) Comparisons must compare like with like and make it clear whether they relate to a model range, specific vehicle or attribute.

d) When referring to regulated emissions in comparisons, the Euro Standard for all vehicles compared should be stated. Test data for regulated emissions should not be used inappropriately.

e) When using MPG figures to make efficiency claims, it should be ensured that they are sufficiently explained, for example by stating ‘MPG figures are official EU test figures for comparative purposes and real driving results may vary’ or similar.6

f) Electric-only-range figures should be sufficiently explained, for example by stating ‘Range figures are official EU test figures for comparative purposes and real driving results may vary’ or similar.

5. Imagery and symbols

a) Use of “green” imagery The use of “green” imagery, such as featuring trees, vegetation or the colour green, should convey a level of environmental performance that is proportionate to the wording of the environmental claim and should be used with great care.

b) Use of “green” symbols and endorsements Third party endorsements, “green” logos and kite marks must be depicted clearly; must only be used with the consent of the relevant third party and in such manner that does not mislead.

4 See Appendix for definition of Euro Standard. 5 See Appendix for legal requirements to quote all three test cycles (combined or weighted combined, urban, and extra-urban) in promotional literature. 6 See Appendix for more information on CAP advice on fuel efficiency/MPG figures and on energy claims for electric/plug-in hybrid vehicles

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Appendix

The Advertising Codes The UK Advertising Codes of practice are not voluntary. The British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code) and the Broadcast Codes (BCAP Code) consisting of the Radio Advertising Standards Code and the Television Advertising Standards Code are independently adjudicated on by the Advertising Standards Authority. Advertisements, which breach the Codes, must be removed and are prohibited from further use. ASA may refer matters to the Office of Fair Trading (non-broadcast) or Ofcom (broadcast). The Codes cover traditional advertising on TV and radio, posters, print, direct marketing, promotions and paid-for advertising online. On 1 March 2011, the ASA’s online remit was extended to cover marketing communications on organisations’ own websites and in other non-paid-for space under their control. The CAP Code now applies in full to marketing messages online, including the rules relating to misleading advertising. Matters of taste and decency are also included in the BCAP and CAP Codes. Automotive advertisers are strongly advised to read the BCAP and CAP Codes in full, not just those parts that refer to specific car advertising or environmental issues. The Codes and a fuller explanation of the regulation of advertising in the UK can be found at: http://www.cap.org.uk/The- Codes.aspx. The register of CAP and BCAP Code updates can be accessed here: http://www.cap.org.uk/Advertising-Codes/Relevant-legislation-and-register-of-Code-changes.aspx Additionally, there are broader obligations within the Consumer Protection from Unfair Trading Regulations 2008 (CPRs), which implements the Unfair Commercial Practices Directive.

Fuel efficiency and MPG figures: In June 2013, following an ASA adjudication, CAP issued advice relating to the use of MPG figures, this can be accessed here: http://www.cap.org.uk/Advice- Training-on-the-rules/Advice-Online-Database/Motoring-Fuel-efficiency-and-MPG-figures.aspx

Electric vehicles: In October 2013, CAP issued advice on energy efficiency claims for electric and plug-in hybrid vehicles; this can be accessed here: http://www.cap.org.uk/Advice-Training-on-the-rules/Advice-Online-Database/Motoring-Electric- Vehicles.aspx

Vehicle Certification Agency (VCA): fuel consumption and CO2 information requirements The EU requires information on CO2 to be provided by motor manufacturers and retailers in point- of-sale material, brochures and print advertising. In the UK the VCA has responsibility for interpretation and enforcement of the CO2 Labelling Directive. Car dealers are required to have a CO2 label showing the fuel consumption and CO2 emissions of each different new model on display, either on or near the vehicle. Dealers are also required to display a poster in paper or as an electronic display, in a prominent position, showing the fuel consumption and CO2 emissions for all new passenger car models displayed, or offered for sale through that particular showroom. In addition to the above, the Directive also requires manufacturers to include fuel consumption and CO2 emissions data in all brochures and printed advertisements, provided that the literature relates to a specific model of car. See the VCA Guidance at: www.vca.gov.uk/fcb/enforcement- on-adver.asp

A colour-coded environmental label for all new cars was introduced in UK car showrooms from 2005, The colour-coded banding system for the label takes into consideration the 13 Vehicle Excise Duty (VED) bandings, from ‘A to M’. The label can be found here: www.dft.gov.uk/vca/fcb/point- of-sale-pos-so.asp From November 2009, the industry introduced a similar label on cars up to two years old on a voluntary basis, which is now delivered by HPI and Experian.

Non sector-specific environmental and green claims guidance The UK Government drew up the Green Claims Code in 1998 (revised 2000) supported by the Confederation of British Industry, British Retail Consortium, local government Trading Standards and the British Standards Institute. In 2011 Defra produced updated Green Claims guidance (http://www.defra.gov.uk/publications/2011/06/03/pb13453-green-claims-guidance/)) that builds on the earlier Green Claims Code, which agreed a set of easy-to-follow principles about how to make a good environmental claim. The Guidance is designed to help businesses apply these

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principles in practice, by providing further information and examples. Anyone using the guidance should not need to refer to the code. Defra’s guidance sits alongside the advertising codes and draws heavily on the International Organisation for Standardisation’s ISO14021 ‘Environmental labelling’.

The Chartered Institute of Public Relations has also produced Best Practice Guidelines for Environmental Sustainability Communications (Sept 2007), see www.cipr.co.uk/environmentalcomms

Euro standard European emission standards (Euro standards) set limits for exhaust emissions from new vehicles sold in EU member states. Emissions regulated include: nitrogen oxides (NOx), total hydrocarbon (THC), non-methane hydrocarbons (NMHC), carbon monoxide (CO) and particulate matter (PM). Compliance is based on a standardised test-cycle. New cars and vans must already comply with Euro 5.For more information visit: http://ec.europa.eu/enterprise/sectors/automotive/environment/euro5/index_en.htm Euro 6 becomes mandatory for the first vehicle types from September 2014.

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LOW CARBON VEHICLE UPDATE, NOVEMBER 2013

Government call for evidence on £500 million funding for ultra-low emission vehicles

Background Following the launch of government’s ultra-low emission vehicle (ULEV) strategy ‘Driving the Future Today’ on 4 September 2013, a call for evidence was launched on 7 November which looks to inform government priorities on the £500 million of funding allocated for ULEV uptake and development from 2015 to 2020.

Deputy Prime Minister Nick Clegg announced that alongside the call for evidence, Elon Musk, Co- Founder and CEO of Tesla Motors would be advising the government in a personal capacity on what further could be done to support the uptake of ULEVs in the UK. OLEV has noted that these views will be considered alongside the submissions of others as part of the call for evidence. The call for evidence will close on 10 January 2014.

The call for evidence is split into two sections, the first looking at core elements of government’s current support package and the second on other initiatives that could expand the ULEV market in the UK. The call for evidence also asks what measures beyond the scope of £500 million would be required to make the UK a clear global leader on ULEVs.

Outline of call for evidence questions

1. Core elements of the current support package

 Consumer grants for cars and vans o Questions focused on the future of the Plug-In Car and Van Grants including whether the current emission threshold of 75g/km CO2 is appropriate o Consideration of scale of grant support needed for the purchase of hydrogen fuel cell electric vehicles o Consideration of an exit strategy for government consumer incentives o Consideration of support for the second hand ULEV market

 Infrastructure o Consideration on where focus should be placed in terms of future charging infrastructure support as well as exit strategies from government support o Consideration of emerging infrastructure technologies and any required incentivisation o Consideration of funding for a national network of hydrogen refuelling stations o Consideration of funding for national network of gas refuelling points for commercial vehicles

 R&D o Questions related to how government should channel funding for R&D, through the Technology Strategy Board or otherwise o What support in addition to the Advanced Propulsion Centre would make it more attractive to invest in the UK o Questions around the sufficiency and approach of collaborative R&D support in the UK and the need for further trials or demonstration of ULEV technology

2. Other initiatives government could support to expand the ULEV market in the UK

 Consideration of new government support for ULEV taxis, private hire vehicles and car clubs  Exploration of funding for public sector procurement of ULEVs  Consideration of additional support for ULEV supply chain  Consideration of an approach for targeting funding to regional or city schemes  Exploration of targeting funding to other vehicle segments such as low carbon HGV technologies, L-category vehicles (quadricylces) and low emission buses

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 Consideration of additional support to strengthen the energy grid and promote energy management  Consideration of support for communications to communicate benefits of ULEVs

SMMT engagement

 SMMT held a conference call with members on 13 November to discuss initial views on the call for evidence, a steer on the policy direction and SMMT’s response drafting process.

 OLEV is hosting a workshop on 22 November designed to outline the call for evidence and answer initial questions from stakeholders.

 SMMT will host a workshop on the afternoon of 5 December for members to outline SMMT’s first draft response and discuss issues in more detail. Further details of the workshop are due to be circulated shortly.

 SMMT will incorporate comments to inform a second draft response during December and submit a final response to OLEV by 10 January 2014.

Ultra-Low Emission Vehicle Collaborative Communications Consortium (UCCC) The UCCC is in phase two of a project that will deliver a national communications campaign running through 2014 to encourage the consideration and uptake up ultra-low emission vehicles. The project is a collaboration between OLEV, SMMT and vehicle manufacturers.

In September, government approved co-funding of a communications campaign with five vehicle manufacturers confirming their participation and financial contribution.

Phase two of the project is progressing following the submission of signed contracts by all participating vehicle manufacturers. This phase will see the finalisation of marketing materials, website content and PR plans for approval by the Consortium. The project will deliver a website for the campaign during the middle of January 2014 with a media launch scheduled for the end of January.

London Ultra-Low Emission Zone  SMMT hosted a workshop on 19 September for members to provide views to Transport for London (TfL) on feasibility work being carried out to inform policy options on an Ultra Low Emission Zone in central London by 2020.

 SMMT met Matthew Pencharz, Environment and Political Adviser to the Mayor of London on 13 November to discuss the Ultra Low Emission Zone proposals and the likely policy direction of the Mayor. Mr Pencharz stressed the importance of a broad-base of consensus for ULEZ policy, noting that it was the intention to find an appropriate “sweet spot” between reduction in NOx emissions and the costs of ULEZ measures on industry, users and businesses. It was also noted that the Mayor intended to announce in January a date from which it would be required that all new licensed London taxis be “zero-emission capable”.

 SMMT attended a workshop hosted by Michèle Dix, Managing Director, Planning, at TfL on 14 November where TfL presented an update on its feasibility work and initial conclusions. It was noted by TfL that a good starting point for the basis of criteria across vehicle types was Euro 6. The assessment carried out by TfL indicated that a Euro 6 basis achieved the greatest emissions reductions (NOx) at the most acceptable cost to industry, users and businesses. TfL would look to refine this work ahead of submission to the Mayor in December.

 SMMT is due to finalise an initial position paper incorporating member views and priority principles at the end of November to submit to TfL and the Greater London Authority.

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 The Mayor of London is due to make a final decision on policy options to take forward to consultation in December 2013. It is expected that a public consultation on a range of measures will be launched at the beginning of 2014, with a view to consult again on specific measures in 2015. This timeline is subject to Mayoral approval.

Update on registration figures for ultra-low emission vehicles

Plug-In Car Grant Latest figures on uptake of the Plug-In Car Grant demonstrate that as of 30 September 2013, 5,702 claims have been made since the scheme opened in January 2011. (https://www.gov.uk/government/publications/plug-in-car-grant)

SMMT new car registration figures for electric and alternatively-fuelled vehicles in October 2013 are shown below:

Monthly Electric and Alternatively-Fuelled Vehicle registration figures: http://www.smmt.co.uk/category/news-registration-evs-afvs/

Plug-In Van Grant Latest figures on uptake of the Plug-In Van Grant demonstrate that as of 30 September 2013, 364 claims have been made since the scheme opened since the scheme opened in February 2012. (https://www.gov.uk/government/publications/plug-in-van-grant).

Jonathan Hawkings Policy Manager [email protected] 020 7344 9217

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MEETING WITH MATTHEW PENCHARZ, CITY HALL, LONDON, 13 NOVEMBER 2013

Attendees Matthew Pencharz (MP), Environmental and Political Adviser to the Mayor of London Elliot Treharne (ET), Air Quality Manager, Greater London Authority Konstanze Scharring, Director of Policy, SMMT Jonathan Hawkings, Policy Manager, SMMT Rob Walker, Senior Technical Manager – Environment, SMMT

Meeting note

Taxis  MP noted that in the new year, the Mayor has an intention to set a date from which new licensed London taxis would be zero emission capable. It was suggested the date could be a year or two ahead of the expected implementation of an ultra-low emission zone in 2020.  MP noted that the GLA and TfL would look to make representations to OLEV to secure funding for ultra-low emission taxi incentivisation.

Hybrid buses  ET noted that the interim London strategy on buses was hybridisation, where the GLA would like to look at the premium cost of hybrid technology, identifying pinch points in the supply chain.  ET noted that the GLA would look to host an event in March/April 2014 on this subject with manufacturers and leasing companies.  MP noted the trials of single-deck electric buses in London.

Central London Ultra-Low Emission Zone (ULEZ)  MP noted that he would be having an initial discussion with the Mayor later in the day (13 November) on the ULEZ feasibility work. A final decision on measures to take forward to consultation would be made in December 2013.  MP stressed the importance of a broad-base of consensus for ULEZ policy, noting that it was the intention to find an appropriate “sweet spot” between costs and reduction in NOx emissions. TfL feasibility work was referenced and a TfL workshop (14 November) where more detail would be discussed.  SMMT highlighted that the ULEZ should be part of a strategic approach to reducing emissions in London.  SMMT stressed the importance of the regulatory direction of travel in relation to ULEZ policy, as well as the ULEZ promoting London as a lead city for adoption of ultra-low emission vehicles. SMMT also noted the importance of the ULEZ being clear how to enable consumers through a supportive approach.  MP asserted that no manufacturer would have difficult meeting ULEZ requirements and that the level of ambition would be a “mix and match” from the medium, high and very-high scenarios presented in papers previously.

OLEV Call for Evidence  ET noted that he would share GLA’s priorities in relation to OLEV’s call for evidence with SMMT in due course.  MP noted it would be useful for SMMT and GLA to share synergies on elements of both organisations’ responses to the call for evidence.

Actions:  SMMT to follow up on request for information on new car/ultra-low emission vehicle registrations in London  GLA to share priorities for OLEV call for evidence with SMMT

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SMMT POSITION ON PROPOSED CENTRAL LONDON ULTRA LOW EMISSION ZONE

28 NOVEMBER 2013

Summary This paper outlines SMMT’s position on the proposals for an Ultra Low Emission Zone (ULEZ) in central London, announced in February 2013 by Mayor Boris Johnson. SMMT welcomes the early engagement with Transport for London (TfL) and the Greater London Authority (GLA) as feasibility work is undertaken on the Mayor’s proposals. This paper underlines principles from the UK automotive industry ahead of the anticipated publication of a consultation following a Mayoral decision in December 2013.

In summary, SMMT calls on the Mayor’s office and TfL to ensure that the ULEZ:

 Stems from a strategic approach to reducing emissions in London and is consistent with the wider regulatory direction of travel on air quality and CO2  Is part of a coordinated approach on air quality between local, national and European authorities  Helps promote London as a leading city in Europe for the uptake of ultra-low emission vehicles, resulting in economic benefits for the rest of the UK  Takes into account the impact on businesses and vehicle and road users  Is clear, transparent, easy to understand and affordable  Reflects recognised regulated emission standards and is technology neutral

SMMT position

Recognition of air quality challenges in London SMMT recognises the significant challenges that the Mayor and TfL face in efforts to reduce air pollutants and improve air quality for Londoners. A number of sources impact air quality in London and there is a shared responsibility between different actors, industrial sectors and transport modes to take action in reducing environmental impacts on air quality.

 There should be a coordinated approach between London, national and European-level action on air quality to ensure that the automotive sector has certainty in policy direction with measures supporting the global nature of the industry.

 TfL should take into account non-road transport sector emissions in its analysis and modelling of an ULEZ. While it is recognised that the highest amount of roadside activity and public exposure to air pollutants occurs in central London. Figures for 2010 show that, in Greater London, 66% of NOx emissions and 44% of PM10 emissions were from non-road transport sources. A wider action plan is required to tackle air quality issues outside the zone and from other sectors such as industrial emissions, domestic gas, aviation and construction.

 TfL analysis suggests that some of the biggest sources of NOx emissions in central London are buses and taxis. An incentivised and accelerated fleet renewal of buses and taxis, which are operated or licensed by TfL, would reduce NOx emissions cost effectively in the central London Zone. SMMT supports an approach that identifies achievable and measurable criteria for different vehicle types (i.e. cars, vans, buses, heavy commercial vehicles).

A strategic approach to reducing emissions in London The Mayor and TfL should ensure that policies to reduce emissions in London stem from a strategic approach and identify clear objectives. There have been concerted efforts by both the automotive industry and public authorities at a London, national and European level in reducing emissions from road transport, both in terms of CO2 reduction as well as air pollutants (NOx, PM10 and PM2.5).

 ULEZ proposals should be justified, objective and consistent with the wider regulatory approach on air quality and CO2 emission reduction targets.

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 Where local air quality has been identified as a primary concern, ULEZ vehicle criteria should be appropriate and proportionate. Establishing vehicle criteria that directly reflect widely recognised regulatory standards, such as EuroVI/6, is crucial.

 TfL should ensure that ULEZ proposals are coordinated with UK government’s funding for national ultra-low emission vehicle (ULEV) policy from 2015 to 2020. The Office for Low Emission Vehicle’s Call for Evidence looks at key issues which will affect the national framework of support for ULEVs up until 2020, including consumer incentives as well as policy to support UK-based R&D and manufacturing.

 Proposals for an ULEZ should be consistent and coordinated with other local transport policies. Where policy measures have been put in place previously to encourage the uptake of ultra-low emission vehicles (i.e. Congestion Charge discounts), new measures should also provide a basis for incentivisation while not inhibiting efforts to reduce emissions from the wider vehicle parc. TfL and the GLA should ensure that policy around an ULEZ reflects future plans for the Congestion Charge Zone.

 Policy around night-time deliveries and other traffic reducing measures should be taken into account when looking at measures for an ULEZ. TfL and the London boroughs should put in place more permanent arrangements to allow night-time deliveries following the successful trials during the London 2012 Olympics. TfL’s report7 on the transport legacy from the Olympics demonstrated that greater use of night-time deliveries should be possible with the development of noise-reducing technologies and positive results in reducing fuel consumption.

 Driver and road user behaviour should be considered when looking at reducing emissions in London. Reducing unnecessary journeys and encouraging more efficient driving will have a large impact and should be factored into ULEZ policy development.

 With a proposed timescale of an ULEZ from 2020, it is important to recognise that although there will be an increase in the number of ULEVs on the road, the vast majority of vehicles will remain conventionally fuelled in 2020. The Department for Transport projects that ULEV car sales as a proportion of all new car sales in the UK in 2020 will be between three and seven percent8. ULEZ policy should incorporate this trajectory in its planning and feasibility stage.

Vehicle technology, Euro standards and emissions Debate around the road transport sector’s contribution to air quality in London has focussed on the regulated emissions limits under the Euro standard regime, as well as the identification of diesel emissions as a source of pollutants in London’s vehicle fleet. There has been an increase in the penetration of diesel cars on UK roads in line with a focus on increasing fuel efficiency and reducing carbon emissions. This trend has recently stabilised with 2013 year-to-date new car registrations demonstrating that the UK market share of diesel and petrol cars is identical at 49.3%9. Average UK new car CO2 emissions stood at 133.1g/km in 2012, down 3.6% on 2011 and down 26.5% since 2000. Euro standard success in central London is evident; the London Atmospheric Emission Inventory shows a 45% reduction in NOx emissions by 202010.

 The automotive industry in the UK and across Europe has invested billions of pounds in technology to reduce both carbon emissions and other pollutants. The industry has followed regulation through Euro standards which have progressively tightened emission limits over time.

7 TfL report: London 2012 Transport Legacy One Year On, http://www.tfl.gov.uk/assets/downloads/london-2012-transport- legacy-one-year-on-report.pdf 8 ULEV strategy, ‘Driving the Future Today’, page 99, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/239317/ultra-low-emission-vehicle-strategy.pdf 9 SMMT New Car Registrations, October 2013, http://www.smmt.co.uk/2013/11/new-car-registrations-grow-20-months-smmt- ups-forecast/ 10 London Atmospheric Emissions Inventory, 2010, Table A1 http://data.london.gov.uk/datastore/package/london-atmospheric- emissions-inventory-2010

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 The impact of the regulated emission limits in real world conditions has led to a change in approach with more robust Euro standard development underway. For cars and vans, the emissions test limit values under the Euro standard regime have seen and will continue to see significant reductions to Euro 5 and Euro 6. At each of the Euro standard changes additional tests have been introduced to provide wider robustness to the emission measurement process over wider operating conditions. The future of Euro standards is likely to focus on increasing stringency of the test procedure, its robustness and incorporating real world testing elements. It should also be noted that Euro 6 diesel NOx limits are almost equivalent to petrol vehicles.

The reduction in limit values under the Euro standard regime will see:  96% reduction in diesel PM from Euro 1 (1992) to Euro 6 (2014)  84% reduction in diesel NOx from Euro 3 (2000) to Euro 6 (2014)  60% reduction in petrol NOx from Euro 3 (2000) to Euro 6 (2014)

 The type approval test for Euro standards is designed to be pass/fail, therefore using individual test data for other purposes is inappropriate and not a robust basis for use in ULEZ criteria setting. In relation to this, UK government’s Vehicle Certification Agency (VCA) says that such data “should not be used to directly compare different models of vehicle”11.

 TfL should ensure that its proposals are technology neutral and use the basis of the existing Euro standard regime. Consideration of ‘zero emission’ options should be clearly defined and linked to strategic objectives on air quality or CO2 as outlined previously alongside socioeconomic impact.

Opportunity for London to lead on ULEVs and new technology London has been a leading city in Europe on ultra-low emission vehicles, with a focus on electric vehicle infrastructure, public procurement in the Greater London Authority’s fleet and incentivisation of vehicle up-take through discounts to the London Congestion Charge. London is also a stand-out city internationally for hybrid buses and trialling new technology, from hydrogen vehicles to introducing biofuels into the bus fleet.

 In looking to create an ULEZ in London, it is important to recognise the economic growth opportunities for the UK in the design, development, manufacture and sale of low and ultra- low carbon vehicles. SMMT believes that the approach through incentivisation and supporting a variety of technologies is the most appropriate way to enable London to become a lead market for ultra-low emission vehicles.

 A concerted and parallel focus should be placed on supporting the infrastructure needed to achieve ULEZ policy ambitions. There is also scope for national funding to be linked to ULEV deployment and take up in London. The aspiration to have electric or ‘zero emission-capable’ taxis in London by 2020 should be underpinned by a strategic network of multi-standard charging solutions that will enable the technology to proliferate and be accepted by both drivers and users.

Measuring and monitoring the impact and operation of an ULEZ TfL should follow principles of better regulation, including ensuring that the ULEZ proposals are simple and do not create additional administrative burdens, undertaking impact assessments and cost/benefit analysis. Criteria and operational elements of the ULEZ should be clear, transparent and easy to understand for consumers, users and businesses.

 Within this assessment, TfL should consider the social and economic impacts of the proposals. Identifying areas where the most significant challenges lie will help ensure that policy is directed effectively. Implementation of the zone should be monitored on a regular basis.

11 VCA, Cars and Air Pollution, http://www.dft.gov.uk/vca/fcb/cars-and-air-pollution.asp

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 Acceptance from stakeholders is crucial and TfL should undertake comprehensive consultation with industry and announce plans sufficiently in advance. This is particularly important for fleet renewal and must take into account vehicle production and development cycles.

 Affordability should be a key area of consideration in order not to inhibit business prospects or vehicle users. There are a range of low emission vehicles to suit individual needs, however TfL should also ensure that the ULEZ requirements do not place an unduly heavy burden on social groups that are most reliant on their vehicles.

Contact: Jonathan Hawkings Policy Manager [email protected] 020 7344 9217 / 07557 433604

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ECALL UPDATE, DECEMBER 2013

Background: Earlier this year the European Commission published two legislative proposals in relation to eCall.  Proposal for a regulation on type-approval requirements for the deployment of mandatory eCall in the EU: concerning type-approval requirements for the deployment of the eCall in- vehicle system and amending Directive 2007/46/EC  Proposal for a decision of the European Parliament and of the Council on the deployment of interoperable EU-wide eCall

Subject to legislative procedures, these proposals seek to have eCall systems installed in new types of passenger cars and light vans from 1 October 2015, allied with a fully functional eCall service in place throughout the EU (as well as in Iceland, Norway and Switzerland).

The European Council/Parliament co-decision process for adoption of the Regulation is now ongoing with the first reading forecast to be completed in Q1/2014. In parallel the Commission (DG-ENTR) have commenced drafting of the delegated act for type approval technical requirements. They intend to present their initial proposal to the TCMV on 26 November. Industry stakeholders will then be invited to participate in development of the act.

The proposal of most interest for industry is the regulation on type-approval requirements for the deployment of mandatory eCall in the EU.

SMMT actions In consultation with members, SMMT developed a position paper on the current raft of legislation in the European Parliament mandating the introduction of eCall in all new types of passenger cars and light vans by 2015 (legislative proposals 2013/0165(COD) and 2013/0166(COD)).

Below is the timetable for the legislative process of eCall. SMMT submitted proposed amendments to UK MEPs on the IMCO committee (Malcolm Harbour MEP and Catherine Stihler MEP) ahead of the deadline for amendments on 14 November. These amendments can be found on the following page.

Type-approval requirements for the deployment of the eCall in-vehicle system

Stage Key actors Action required Timeline

Exchange of views

Consideration of draft IMCO Committee 4/5 November report members

Deadline for IMCO Committee Send amendments to UK MEPs on IMCO 14 November amendments members committee (sent on 12 November) DONE Consideration of Rapporteur and 16/17 December amendments shadows

Consideration of Rapporteur and 22 January compromise shadows amendments

Adoption of draft report / 23 January vote in IMCO

Plenary session and All MEPs February 11 vote (tbc)

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SMMT AMENDMENTS TO THE TO EU COMMISSION PROPOSAL CONCERNING TYPE APPROVAL REQUIREMENTS FOR THE DEPLOYMENT OF THE ECALL IN-VEHICLE SYSTEM AND AMENDING DIRECTIVE 2007/46/EC

1. Recital (5):

Existing text Amendment The Union eCall system is expected to The Union eCall system is expected to reduce reduce the number of fatalities in the Union the number of fatalities in the Union as well as as well as the severity of injuries caused by the severity of injuries caused by road road accidents. The mandatory introduction accidents. The mandatory introduction of the of the eCall system would make the service eCall system and the mandatory upgrade of available to all citizens and thus contribute to telecommunications operators for reduce human suffering and healthcare and conveying eCalls and PSAPs for receiving other costs eCalls would make the service available to all citizens and thus contribute to reduce human suffering and healthcare and other costs Justification: Mandatory installation of a compatible mobile network operator and PSAP infrastructure covering the complete EU territory is a pre-requisite for mandating vehicle systems

2. Recital (6):

Existing text Amendment The provision of accurate and reliable Delete positioning information is an essential element of the effective operation of the eCall in-vehicle system. Therefore, it is appropriate to require its compatibility with the services provided by satellite navigation programmes, including the systems established under the Galileo and EGNOS programmes set out in Regulation (EC) No 683/2008 of the European Parliament and of the Council of 9 July 2008 on the further implementation of the European satellite navigation programmes (EGNOS and Galileo). Justification: According to the European GNSS Agency, Galileo will start Early Services from October 2014. At the present, it is impossible to determine when Galileo adopted production chipsets for automotive series production will be available.

For testing and evaluation of vehicle eCall systems currently under development industry needs:  Galileo adopted chipsets to be available for large scale testing within 2013 and for mass production / type approval before October 2015.  Galileo positioning services available within 2013.

It is not feasible to complete development of a positioning receiver without full availability of the positioning satellites. Until this time, it should not be part of a vehicle requirement.

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If industry is forced to provide Galileo compatibility before Galileo is operational and before compatibility has been fully evaluated on our eCall systems, there is a risk that eCall systems will have to be modified after being introduced on the market. Such a risk is not acceptable for the automotive industry.

Once Galileo is operational and evaluated, compatibility can be required for new vehicle types only and considering appropriate lead times.

3. Recital (8):

Existing text Amendment The mandatory equipping of vehicles with Delete the eCall in-vehicle system should be without prejudice to the right of all stakeholders such as car manufacturers and independent operators to offer additional emergency and/or added value services, in parallel with or building on the 112-based eCall in-vehicle system. However, these additional services should be designed not to increase driver distraction.

Justification: This regulation should govern emergency call systems only. Other functionalities, concepts and future applications should be dealt with separately outside this regulation. Furthermore, the references are not defined and could not be assessed in a vehicle type approval process.

4. Recital (9):

Existing text Amendment In order to ensure open choice for Delete customers and fair competition, as well as encourage innovation and boost the competitiveness of the Union’s information technology industry on the global market, the eCall in-vehicle system should be accessible free of charge and without discrimination to all independent operators and based on an interoperable and open-access platform for possible future in-vehicle applications or services.

Justification: This Regulation should govern emergency call systems only. Other functionalities, concepts and future applications should be dealt with separately. In addition, the term “interoperable and open-access platform” would require to be defined in detail, particularly specifying the respective systems, interactions and operations. The term is not defined and would allow an extremely wide interpretation which would create massive uncertainties for all stakeholders.

Also, the term “possible future in-vehicle applications or services” require a detailed definition

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by reference to appropriate and agreed standards. In order to use future applications or services the design of the equipment has to be specified to an appropriate level of hardware and software capability to an appropriate and agreed standard, and fully developed and validated during vehicle design and production. Absence of standards for this capability prevents the system designer from creating a design with the ability to implement applications and services that were not defined during the design process. It is not commercially feasible to provide a system with the flexibility to have such applications and services retrospectively applied without causing excessive and potentially unnecessary complexity and cost in the system during its design.

5. Recital (13):

Existing text Amendment According to the recommendations made by According to the recommendations made by the Article 29 Data Protection Working Party the Article 29 Data Protection Working Party and contained in the 'Working document on and contained in the 'Working document on data protection and privacy implications in data protection and privacy implications in eCall initiative', adopted on 26 September eCall initiative', adopted on 26 September 2006, any processing of personal data 2006, any processing of personal data through the eCall in-vehicle system should through the eCall in-vehicle system should comply with the personal data protection comply with the personal data protection rules rules provided for in Directive 95/46/EC of provided for in Directive 95/46/EC of the the European Parliament European Parliament and of the Council of 24 and of the Council of 24 October 1995 on October 1995 on the protection of individuals the protection of individuals with regard to with regard to the processing of personal data the processing of personal data and on the and on the free movement of such data and in free movement of such data and in Directive Directive 2002/58/EC of the European 2002/58/EC of the European Parliament and Parliament and of the Council of 12 July 2002 of the Council of 12 July 2002 concerning concerning the processing of personal data the processing of personal data and the and the protection of privacy in the electronic protection of privacy in the electronic communications sector (Directive on privacy communications sector (Directive on privacy and electronic communications), in particular and electronic communications), in particular to guarantee that vehicles equipped with eCall to guarantee that vehicles equipped with in-vehicle systems, in their normal operational eCall in-vehicle systems, in their normal status related to 112 eCall, are not traceable operational status related to 112 eCall, are and are not subject to any constant tracking not traceable and are not subject to any and that the minimum set of data sent by the constant tracking and that the minimum set in-vehicle eCall system includes the minimum of data sent by the in-vehicle eCall system information required for the handling of includes the minimum information required emergency calls. for the appropriate handling of emergency calls. Justification: The word “appropriate” is not precise enough to define a system specification. As the empowerment to adopt a delegated act does not foresee a clarification, it would therefore be preferable to make a reference to the EN standard 15722 in Article 5.7. to ensure a clear description of the minimum set of data.

6. Recital (16):

Existing text Amendment

Vehicle manufacturers should be allowed The car industry should be allowed at least sufficient time to adapt to the technical 36 months from the publication in the requirements of this Regulation. Official Journal of this Regulation and its

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delegated acts to adapt to the technical requirements.

Justification: In order to quality assure integration of the eCall system into the vehicle, a suitable lead time is required, in line with the CARS21 agreement. The regulation should take account of industry needs regarding the lead time, i.e. 36 months for eCall.

7. Article 3. Definitions, par 1 & 2:

Existing text Amendment ‘e-Call in-vehicle system’ means a system ‘e-Call in-vehicle system’ means a system activated either automatically via in-vehicle comprising of in-vehicle equipment sensors or manually, which carries, by triggered either automatically via in vehicle means of mobile wireless communications sensors or manually, which emits signals by networks, a standardised minimum set of means of mobile wireless communications data and establishes a 112-based audio networks, to enable the transmission of a channel between the occupants of the standardised minimum set of data and the vehicle and a public safety answering point; establishment of a 112-based or a private eCall based audio channel between the occupants of the vehicle and a public safety answering point;

‘in-vehicle system’ means the in-vehicle ‘in-vehicle equipment’ means equipment equipment together with the means to within the vehicle that provides or has trigger, manage and effect the eCall access to in-vehicle data required for the transmission via a public mobile wireless Minimum Set of Data, and providing a link communications network providing a link between the vehicle and a means of enacting between the vehicle and a means of the eCall service via a public mobile wireless enacting the eCall service via a public mobile communications network. wireless communications network. Justification: The draft definition is not suitable for a vehicle type approval requirement because at the timing of vehicle certification, a manufacturer would not be able to ensure the operation of the Mobile wireless communication infrastructure nor the operation of the PSAP. Therefore the vehicle requirement should be restricted to verifying the emission of a signal and/or data and not to the actual establishment of a connection. It should be permitted to run private eCall services not only in addition to a public eCall but as an alternative (see Article 5). The definitions should therefore also reflect this. Note that more detailed requirements are covered elsewhere in the document anyway and therefore do not need to be included in these definitions. Further wording changes are also suggested to avoid repetition, and improve consistency between the definitions in referenced CEN standards.

8. Article 5. Specific obligations of manufacturers, par 2: Existing text Amendment

Manufacturers shall demonstrate that all Manufacturers shall demonstrate that all their their new types of vehicles are constructed new types of vehicles are constructed to to ensure that in the event of a severe ensure that in the event of a severe accident accident which occurs in the territory of the which occurs in the territory of the Union, an Union, an eCall to the single European eCall to the single European emergency emergency number 112 is triggered number 112 or a private eCall number is

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automatically. triggered automatically by the vehicle. Manufacturers shall demonstrate that new Manufacturers shall demonstrate that new vehicles are constructed as to ensure that an types of vehicles are constructed as to eCall to the single European emergency ensure that an eCall to the single European number 112 can also be triggered manually. emergency number 112 or a private eCall number can also be triggered manually.

Justification: It should be permitted to run private eCall services not only in addition to a public eCall but as an alternative, provided all performance standards are met and one or both of the pan-EU or private eCall service is available in Member States. For private eCall services that are on the market already, backward compatibility shall be ensured in accordance with the ITS directive. This Regulation is intended for new vehicle types only as also indicated in Article 5, par 1. and par. 2. 1st indent.

9. Article 5. Specific obligations of manufacturers, par 3:

Existing text Amendment

Manufacturers shall ensure that the receivers Manufacturers shall ensure that the receivers in the in-vehicle systems are compatible with in the in-vehicle systems are compatible with the positioning services provided by satellite the positioning services provided by satellite navigation systems including the Galileo navigation systems e.g. GPS and the and EGNOS system. Galileo/EGNOS system.

Justification: According to the European GNSS Agency, Galileo will start Early Services from October 2014. At the present, it is impossible to determine when Galileo adopted production chipsets for automotive series production will be available.

For testing and evaluation of vehicle eCall systems currently under development industry needs: - Galileo adopted chipsets to be available for large scale testing within 2013 and for mass production by October 2015. - Galileo positioning services available within 2013.

It is not feasible to complete development of a positioning receiver without full availability of the positioning satellites. Until this time, it should not be part of a vehicle requirement.

Once Galileo is operational and evaluated, compatibility can be required for new vehicle types only and considering appropriate lead times.

In addition we see no added benefit in terms of road safety or fatality reduction when using Galileo compared to other satellite based positioning systems and in this respect the regulation should be drafted in a technology neutral way by only stating performance requirements .

10. Article 5. Specific obligations of manufacturers, par 6:

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Existing text Amendment The eCall in-vehicle system shall be Delete accessible to all independent operators

free of charge and without discrimination at least for repair and maintenance purposes.

Justification: It is understood this requirement only concerns access to the eCall system for the purpose of repair and maintenance of the eCall system. In that respect this requirement is covered already by the provisions in REGULATION (EC) No 715/2007 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 20 June 2007, on type approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information, Article 3.14 and Articles 6 and 7.

(EC) No 715/2007 is already an integral part the vehicle type approval requirements.

(EC) No 715/2007 is not limited to emission related systems but covers access to all repair and maintenance related information.

In order to avoid confusion on this topic this reference in the eCall regulation should be deleted.

11. Article 5. Specific obligations of manufacturers, par 7: Existing text Amendment The Commission shall be empowered to The Commission shall be empowered to adopt delegated acts in accordance with adopt delegated acts in accordance with Article 9 establishing the detailed technical Article 9 establishing the detailed technical requirements and tests for the type approval requirements and tests for the type approval of eCall in-vehicle systems and amending of eCall in-vehicle systems and amending Directive 2007/46/EC Directive 2007/46/EC accordingly. accordingly. The technical requirements and tests referred The technical requirements and tests referred to in the first subparagraph shall be based on to in the first subparagraph shall be adopted the requirements set out in paragraphs 3, 4 after consultation of relevant stakeholders and 6 and on the following standards, where and based on the requirements set out in applicable: paragraphs 3, 4 and 6 and on the following (a) EN 16072 ‘Intelligent transport system- standards, where applicable: ESafety-PanEuropean eCall-Operating (a) CEN EN 16072:2011 ‘Intelligent transport requirements’; system-ESafety-PanEuropean eCall- (b) EN 16062 ‘Intelligent transport systems- Operating requirements’; ESafety-ECall high level application (b) CEN EN 16062: 2011 ‘Intelligent transport requirements (HLAP)’; systems-ESafety-ECall high level application (c) EN 16454 ‘Intelligent transport systems - requirements (HLAP)’; eSafety - eCall end to end (c) CEN EN 16454: Version ‘Intelligent conformance testing’, as regards the eCall in- transport systems - eSafety - eCall end to vehicle system conformance to end conformance testing’, as regards the the pan-European eCall; eCall in-vehicle system conformance to the (d) any additional European standards or pan-European eCall; UNECE Regulations relating to eCall (d) CEN EN 15722:2011 ‘Intelligent systems. transport systems - eSafety - eCall minimum set of data (MSD)’

(e) CEN EN 16102:2011 ‘Intelligent transportation systems – eCall Operating requirements for third party support’

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Justification: Due to the number of involved parties and the complexity of this file, it is important to conduct consultations with relevant stakeholders. In combination with deletion of item (d) in par. 7, an additional reference to the EN standard for MSD should be made. This reference to “any” additional standards or regulations creates uncertainty about the specifications according to which we have to develop and test our eCall systems. If the standard, including a specific version reference, is not known at the moment of adoption of this legislative act it should not be required. This is especially important when referring to any UNECE Regulation covering eCall under the 1958 Agreement For any new standards subsequently added, industry should be given sufficient time to review and comment on such standards before they are adopted or referenced in the eCall regulations. In order to support the use of “third party support” as described in Article 5 par. 2, the delegated acts should also be prepared for CEN EN 16102. It is noted that EN16454 is not yet approved (exists only as TS16454:2013)

12. Article 6. Rules on privacy and data protection, par 1: Existing text Amendment In accordance with Directive 95/46/EC and Manufacturers shall declare, that the eCall Directive 2002/58/EC, manufacturers shall in-vehicle system does not actively provide ensure that vehicles equipped with eCall permanent tracking information unless in-vehicle system are not traceable and are the owner has given her/his explicit not subject to any constant tracking in consent for it. their normal operational status related to

the eCall. Delete Privacy enhancing technologies shall be embedded in the in-vehicle eCall system in order to provide eCall users with the desired level of privacy protection, as well as the necessary safeguards to prevent surveillance and misuse.

Justification: 95/46/EC and Directive 2002/58/EC do not specify requirements for vehicle manufacturers but address service providers and Member States. Therefore, this should be included in related regulations

Further, it is burdensome and time consuming to demonstrate, during a type approval test, that there are no traceability or constant tracking systems. Therefore, this should be covered by a manufacturer’s declaration in the type approval documentation package. Proceeding to make an eCall specification cannot occur unless privacy enhancing technologies, the desired level of privacy protection and necessary safeguards to prevent surveillance are well defined because these are an integral part of the eCall system’s development. In this respect this requirement should be deleted and thus left up to the Manufacturer’s responsibility.

13. Article 6. Rules on privacy and data protection, par 2:

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Existing text Amendment The minimum set of data sent by the eCall Delete in-vehicle system shall include only the

minimum information required for the appropriate handling of emergency calls.

Justification: It would be preferable to the make a reference to the EN 15722 in Article 5.7. to ensure a clear description of the minimum set of data. The wording “minimum information required for appropriate handling” is not precise enough to define a system specification. In addition, the empowerment to adopt a delegated act does not foresee a clarification of paragraph 2, so further clarification of “appropriate” cannot be expected.

14. Article 12, Entry into force

Existing text Amendment This Regulation shall enter into force on the This Regulation shall enter into force on the twentieth day following that of its publication twentieth day following that of its publication in in the Official Journal of the European Union. the Official Journal of the European Union.

It shall apply from 1 October 2015. It shall apply 36 months after publication in the Official Journal of the last of this Regulation’s delegated acts and once all Member States have the necessary telecommunications and PSAP infrastructure operational.

Justification: In order to decide the final eCall specification the car industry needs to know all the requirements imposed by the delegated acts and have sufficient lead time to develop and evaluate the system. According to the CARS21 agreement, regulation should take account of the car industry needs regarding lead time, i.e. 36 months for eCall. It is imperative that the necessary infrastructure is in place before mandatory fitment is required in vehicles. A staggered approach, whereby Member States introduce the final infrastructure at different dates is a non-feasible scenario for the automotive industry.

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LETTER TO SECRETARY OF STATE FOR TRANSPORT, PATRICK MCLOUGHLIN MP, RE: MODERNISATION OF MOTORING SERVICES

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PROPOSAL FOR AN ALTERNATIVE PROCESS FOR OBTAINING NATIONAL SMALL SERIES TYPE APPROVAL, LETTER TO DFT, 28 OCTOBER

28 October 2013

Ian Yarnold Department for Transport Great Minster House 33 Horseferry Road London SW1P 4DR

Dear Ian,

Proposal for an alternative process for obtaining national small series type approval

I am writing today with regards to a proposal developed by our members for an alternative process for obtaining national small series type approval (detail enclosed in document ‘Proposal for an alternative process for obtaining national small series approval’).

This proposal has been developed through the SMMT Type Approval Working Group in order to address the prohibitive cost and time burden that bodybuilders are currently faced with for obtaining approvals. In addition the proposals will have the effect of reducing the work load on VOSA, at a time when resources are at a premium.

We look forward to receiving the Department’s thoughts on the proposal and working with you to deliver a cost effective solution within the constraints of Directive 2007/46/EC.

Yours sincerely

Allan McKenzie Deputy Head and Senior Manager Vehicle Legislation Public Policy and Vehicle Legislation Department The Society of Motor Manufacturers and Traders Limited

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PROPOSAL FOR AN ALTERNATIVE PROCESS FOR OBTAINING NATIONAL SMALL SERIES APPROVAL

Background

With the introduction of GB NTA in 1982, it has been possible to register vehicles of Category N with the approvals of the first stage manufacturer. The UK is one EU Member State in which inspection before registration has not been considered necessary by the Government body responsible, primarily because the main safety and environmental measures considered essential have been effectively managed by the items legislated under GB NTA. With the advent of EC WVTA even more technical items on safety and environmental areas are also covered by the first stage manufacturer.

It is understood that the Department for Transport took the decision that GB NTA did not need to be extended to the bodybuilding industry as a gearing up to the implementation of EC WVTA, because it may have the potential to be restrictive to the UK bodybuilding industry which principally comprises SMEs.

The introduction of EC WVTA has come at a time when the bodybuilding industry is still recovering from the deepest and longest recession period the industry has had to contend with since WWII, if not in its history.

As a consequence, since the introduction of 2007/46/EC to cover N1 category vehicles, it has become apparent that the majority of bodybuilders in the UK are finding it difficult and cost prohibitive to apply for Type Approval. Many are finding the numbers of Types they are building on can result in high costs in obtaining approval for each type, obtaining Conformity of Production (COP) and maintain the approval once obtained. Information received from the European Bodybuilder association, CLCCR, has shown that it costs up to £5000 to obtain one type. With over 20 different types of vehicle spread across the mainstream base vehicle manufacturers, this means costs in excess of £100,000 are not un-common just to obtain the approvals. Add to this the cost of obtaining COP, and there is another £2000 to easily add to the cost. Further to this, it is likely that another member of staff will be required to maintain the approvals, with associated costs, this could easily add up to £60,000 per annum for salaries and employment costs. There is then significant workload for subsequent stage approval holders from the numerous extensions that the first stage manufacturers need to implement to keep their approvals up to date with manufacturing and legislation changes. The VCA fees for carrying out updates to approvals purely from these first stage extensions is an area that cannot be quantified at this time as it is unknown how many times the base vehicle manufacturer updates their approvals. However, this is likely to be a major additional cost.

With the forthcoming introduction of N2/3 categories there are significantly more types that a bodybuilder may have to obtain approval for. With the different axle configurations and rigid / artic variations, this could mean a 5 fold increase in the number of types compared to N1 types and subsequent 5 fold increase in cost. This is before we get into NSSTA for vehicles exceeding 4 meter heights and all wheel drive vehicles.

As a result of the high costs of obtaining approval, many bodybuilders are looking at the IVA scheme. One of its benefits is that it allows the bodybuilder to be able to quote the exact cost of approval whereas obtaining NTA and the spreading of the costs would depend on the number of vehicles produced of a type and the number of different types that need to be approved in case customers want another or a new base vehicle type.

Since the introduction of the IVA scheme for N1 vehicles and also for category O types, it has become apparent that VOSA cannot meet the demand. Waiting times of up to 16 weeks are being quoted from application to inspection. This has a severe affect on the Bodybuilders cash flow, the dealers not being able to supply vehicles on time and customer issues for the manufacturer.

With the introduction of Type Approval for N2/3 vehicles from October next year, due to the likely numbers of a type being produced, the signs are that many bodybuilders will look to use the IVA route as Type Approval will not be cost beneficial in its current state. From SMMT figures, 70 respondents to a recent survey indicated that over 3000 vehicles of Category N2/3 are likely to go through the IVA

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scheme per annum. Multiply this by an estimated 700 UK bodybuilders currently producing vehicles and there is a potential for over 30,000 N2/3 IVA tests per annum. This equates to about two thirds of all truck registrations in the UK at present. However, to compound the situation, this does not include N1 types or trailers and therefore, VOSA’s ability to handle the numbers of projected tests would be severely tested.

Therefore, to try and make the process of obtaining approval simpler and so reduce the work load on VOSA, we would like to put forward the following proposal for consideration as a possible alternative to the current process.

Proposal

The French Authorities currently operate a system based around the accreditation and certification of the bodybuilders’ COP. The proposed process would only be applicable to vehicles where the base vehicle has not been modified. Based on this system of working, the proposal is as follows:

1. Instead of applying for vehicle types as now, the bodybuilder would apply for a COP clearance for each of the areas subject to type approval that they affect or complete and so require approval for.

2. For example, in relation to lighting installation, the Bodybuilder would create COP Control plans showing the installation on all types of vehicle they wish to have approval for together with lists of the components to be fitted and details of the approval, if applicable, for those components.

3. VCA would ‘worst case’ check an installation before issuing COP for the installation. This installation would then be given a unique number and cover all the types of vehicle they wish to build on.

4. The above would be carried out for each area of approval requirement that the bodybuilder is involved with. For example, side guards, rear under-run, spray suppression etc.

5. At present, in support of an IVA application, the base vehicle manufacturer has to supply a ‘Statement of Compliance’. This lists all the relevant approvals that the vehicle concerned meets and the approval numbers for each. Below is an example document:

Vehicle VIN No: Manufacturer: Date of Manufacture: TA No:

TA Item No Description TA Number 1 Noise e11*xxxxxxxxx 2 Emissions – Light duty e11*715/2007*xxxx 3A Fuel tanks E11 34R 01 00000 3B Rear Underrun 4A Rear registration plate space 5A Steering effort E11 79R 01 00000 Etc. Etc. Etc.

Under this proposal, the base vehicle manufacturer would supply the statement of compliance for the vehicle with the base vehicle COC. The bodybuilder would then create their own statement of compliance filling in the areas that they have approval to fit. For the above, they would enter their COP reference number in the missing rear underrun box if they fit it, modify it or add to it. The particulars at the top of the base vehicle manufacturer supplied document would remain the same. The new document would be issued with a sequential number to ensure compliance with production numbers in relation to a type.

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It would be recommended that this document would be standardized so that as an industry it could be completed electronically.

6. Once all the missing areas are completed, this could involve subsequent stage manufacturers, the completed document is sent to the VCA for authentication. VCA would check to ensure that the COP authorisation is still valid and that the document is correct. This would be authenticated electronically to reduce lead times and sent to the bodybuilder for passing on to the dealer. VCA could charge a fee for each document verified.

7. The dealer would then register the vehicle using the base vehicle information including the type approval numbers and vehicle make as listed at the top of the document.

By using an electronic standardized form the additional data from the subsequent stages could also be used to automatically generate AFRL registration information, avoiding typographical and admin errors and forwarded to VOSA for plating purposes, thereby reducing lead-times and potential for errors in manual handling of data to the benefit of the operating, building industries and also Dept for Transport Agency costs.

The proposed process

1. Bodybuilder applies to the VCA for a COP authorisation for the fitment of the particular items they wish to have authorisation to fit. This would be by use of a particular application form to be determined and include all relevant system and component approval information and Control plans.

2. VCA check all the paperwork and arrange for a worst case vehicle inspection.

3. Vehicle is inspected and if all is found to be in conformity with the application, VCA issue a unique COP number for each of the processes.

4. Bodybuilder builds the vehicle according to the agreed process(s) and creates new Statement entering relevant COP numbers in the missing areas.

5. Bodybuilder Statement of Compliance is sent to VCA together with base vehicle COC and statement of compliance, any additional statements from previous stages of manufacture for authentication. This may be by electronic format.

6. Completed document returned to bodybuilder once authenticated.

7. All documents sent with vehicle to Dealer and/or base vehicle manufacturer to allow registration.

8. VCA carry out 6 month COP audits of the Bodybuilders approved processes to ensure compliance.

Perceived advantages

1. Low cost alternative to obtaining approval to current NSSTA requirements for simple builds.

2. All types of vehicle can be included in a COP authorisation. No need to approve individual types of vehicle and so removing possible costs of in excess of £100,000.

3. Strict controls ensure process is followed and so reducing possible instances of fraudulent issue of COC’s.

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4. Simplification of paperwork and process reduces the need for additional resources and possible extra costs.

5. Reduced work load for VOSA as less vehicles are likely to use IVA route.

6. Improved customer relations due to reduced time scales in releasing vehicle following build.

7. Improved cash flow for business

8. The wider application of an attractive COP orientated process would be highly beneficial to adding and retaining a high professionalism to a wider number of businesses within the UK bodybuilding industry. This could also be seen as a good stepping stone as COP compliance is a necessary requirement needed for EC WVTA if a bodybuilder finds that they want to expand their business to sell and export their products to a wider EU market.

Possible disadvantages

1. Possible increased work load for VCA staff processing documents.

2. Issue of controlling ‘Types’ would need to be controlled in a different manner to now and may involve additional resources at VCA.

Conclusions

The proposed change to the NSSTA process would result in vastly reduced costs to Bodybuilders by reducing the need to obtain and maintain approval for all the various ‘Types’ that would need to be approved. This would also reduce the work load of the Bodybuilder and improve cash flow.

Control of the build to ensure completion of an incomplete vehicle will be maintained and in some cases improved with increased surveillance.

In the current process, there is potential for a weakening in competitiveness amongst chassis manufacturers. It is possible that the larger volume chassis manufacturers may attract bodybuilders’ prioritisation towards specific vehicle that they wish to obtain approval on. This situation is already becoming apparent for N1 category types and it is likely the trend will repeat itself for N2 & N3. This proposed process will make the approval process fairer for all parties concerned and help reduce the possibility of above.

Applications for IVA will be reduced enabling VOSA to concentrate on key areas and plan work more efficiently.

Reduced costs for Bodybuilders and simplify the process of obtaining approval.

The high degree of accuracy of registration process utilising AFRL within the first stage manufacturers dealer network has a more significant potential of being be maintained without creating an increased need for workload handling manual registration documentation input both within truck dealerships and also DVLA.

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DIGITAL RADIO BRIEFING, SEPTEMBER/OCTOBER 2013

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LETTER TO ED VAIZEY MP, RE: DIGITAL RADIO SWITCHOVER, 7 NOVEMBER 2013

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LETTER FROM ED VAIZEY MP, RE: DIGITAL RADIO SWITCHOVER, 28 NOVEMBER 2013

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BRIEFING PAPERS

Briefing paper no:

2013 1 – Programme of the Irish EU Presidency 2 – Educating tomorrow’s engineers - Science & Technology Committee report 3 – Government response to the Heseltine Review 4 – Queen’s Speech 5 – Spending Round 6 – Investing in Britain’s Future 7 – Programme of the Lithuanian EU Presidency 8 – ULEV Strategy 9 – Reshuffle

SMMT briefing papers are available at www.smmt.co.uk or contact Josh Harris on 020 7344 1614 or at [email protected]

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SMMT CONSULTATION INDEX

Response Date Consultation Who is SMMT Contact Response to whom? Response Received Date Title/Subject Area Consulting? given? Respond: 07 June 2013 British Investment Bank Labour Party No Received: 27 March 2013

Respond: 11 June 2013 Fees for HGV and PSV VOSA Josh Harris Online at: Yes Received: 30 April 2013 testing, operator (Policy) https://survey.vovici.com/se.ashx?s=116604 licensing, other VOSA CB0EF3DF74 services and some DVA Email: [email protected] Services John MacLellan, VOSA Berkeley House Croydon Street, Bristol, BS5 0DA Tel: 0117 954 2531

Respond: 07 June 2013 Vocational Education, Labour Party Submissions online Yes Received: 26 March 2013 apprenticeships and the role of job guarantees in tackling youth unemployment

Respond: 21 June 2013 Consultation On The BIS Amanda Owen [email protected] Yes Received: 17 April 2013 WEEE Recast Directive (Environment) 2012/19/EU And Changes To The UK WEEE System

Respond: 28 June 2013 Driver CPC: Changes to Driving Josh Harris Send your views to Yes Received: 10 June 2013 the scope of exemptions Standards (Policy) [email protected] Agency

Respond: 09 July 2013 Proposal to change the DFT Allan McKenzie Complete the Consultation Questions Reply Sent to

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Response Date Consultation Who is SMMT Contact Response to whom? Response Received Date Title/Subject Area Consulting? given? Received: 11 June 2013 allocations process in (Technical) Form in section 4 and send by email to members as the longer semi-trailer [email protected] TEC/2013/36. trial or post to: Members to LST Trial Consultation Responses Freight, reply direct to Operator Licensing and Roadworthiness, DFT Division Department for Transport Zone 3/25, Great Minster House, 33 Horseferry Road, LONDON, SWIP 4DR

Respond: 19 July 2013 Corrective Amendments DEFRA Amanda Owen [email protected] No Received: 22 June 2013 to the Environmental (Environment) Permitting Regulations 2010

Respond: 06 August 2013 Review of UK and EU BIS Jonathan Send your evidence to Received: 12 July 2012 balance of Hawkings [email protected] by 6 Yes competences: call for (Policy) August 2013. You can also submit your evidence on trade and evidence online at investment https://www.surveymonkey.com/s/tradeinvest ment

Respond: 06 August 2013 EU balance of DFT Jonathan Respond online or write to us/email Yes Received: 14 May 2013 competences review: Hawkings [email protected] transport call for (Policy) evidence Balance of Competences, Department for Transport, Zone 2/29, Great Minster House, 33 Horseferry Road, London, SW1P 4DR

Respond: 20 August 2013 Review of the Fourth CCC Use the question proforma when responding Received: 17 July 2013 Carbon Budget and e-mail responses to: [email protected]

Committee on Climate Change – Call for Evidence, 7 Holbein Place, London, SW1W

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Response Date Consultation Who is SMMT Contact Response to whom? Response Received Date Title/Subject Area Consulting? given? 8NR

Respond: 23 August 2013 Government's lobbying Jonathan No Received: 18 July 2013 bill Hawkings (Policy)

Respond: 09 September 2013 Draft waste DEFRA Amanda Owen E-mail to: No Received: 15 July 2013 management plans (Environment) [email protected]

Respond: 10 September 2013 Waste Targets EC Amanda Owen E-mail to: No Received: 04 June 2013 Consultation (Environment) ENV-TARGET-REVIEW- [email protected]

Respond: 11 September 2013 Future of vehicle DVLA Josh Harris Respond online or Yes Received: 17 July 2013 registration and (Policy) Download the response form and return it licensing services in using the details provided below. Northern Ireland Email: [email protected] Post: Corporate Affairs Directorate, D16, DVLA, Swansea, SA6 7JL

Respond: 13 September 2013 Local Air Quality DEFRA Amanda Owen Online at: No Received: 12 July 2013 Management Review (Environment) https://consult.defra.gov.uk/communications/ https-consult-defra-gov-uk-laqm_review

Respond: 23 September 2013 Waste Prevention DEFRA Amanda Owen Online at: No Received: 06 August 2013 Programme (Environment) https://consult.defra.gov.uk/waste/waste_pre vention

Respond: 27 September 2013 Proposed amendment to DfT Ian Bacon Online response Received: 29 August 2013 the Motor Fuel (Environment) Composition and T506-13 EXTENDING Content Regulations THE REQUIREMENT TO PROVIDE A SUPER UNLEADED PROTECTION....pdf 1999

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Response Date Consultation Who is SMMT Contact Response to whom? Response Received Date Title/Subject Area Consulting? given?

SMMT response-form.doc

Respond: 01 October 2013 Apprenticeships funding BIS Josh Harris Download the response form No Received: 24 July 2013 reform in England (Policy) Email: [email protected]

Apprenticeship Funding Consultation BIS/DfE Joint Apprenticeships Unit BIS, Orchard 1, 2nd Floor, 1 Victoria Street, London, SW1H 0ET

Respond: 03 October 2013 Energy Saving DECC Matt Croucher Complete a response form and either Responded via Received: 10 July 2013 Opportunity Scheme (Economics) METS, MEWG Email to:[email protected] and EPC. Write to: ESOS Consultation, Energy Draft response Efficiency Deployment Office, Area 2A, out as Department of Energy and Climate Change, TEC/2013/536 3 Whitehall Place, London SW1A 2AW

Respond: 11 October 2013 Consultation on a new EC EC. Online form: Received: 25 July 2013 European approach to http://ec.europa.eu/yourvoice/ipm/forms/disp business failure and atch?form=InsolvencyTwo insolvency Respond: 22 October 2013 Review of Annex I and II EC Amanda Owen E-mail to: [email protected] No Received: 30 July 2013 of Groundwater (Environment) Directive Respond: 29 October 2013 Draft noise action plans DEFRA Ian Bacon Respond online: Received: 23 July 2013 (Environment) https://consult.defra.gov.uk/communications/ https-consult-defra-gov-uk- environmentalnoise/

Respond: 7 November 2013 Secondary legislation DfT Josh Harris Email to: No

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Response Date Consultation Who is SMMT Contact Response to whom? Response Received Date Title/Subject Area Consulting? given? Received: 26 September 2013 relating to the HGV (Policy) [email protected] Road User Levy Act Write to: HGV Road User Levy Secondary 2013 Legislation Consultation, Department for Transport, Great Minster House, 33 Horseferry Road,London,SW1P 4DR

Respond: 07 December 2013 Review of DVLA DVLA Josh Harris Online survey Received: 14 November 2013 services (Policy) Customer survey: https://www.snapsurveys.com/wh/s.asp?k=1 38424830018 Stakeholder survey: https://www.snapsurveys.com/wh/s.asp?k=1 38424786223

Respond: 18 December 2013 Consultation on DEFRA Amanda Owen Email: [email protected] Received: 22 October 2013 proposed fees and (Environment) Fees and Charges Consultation Atmosphere Charges 2014/2015 and Local Environment Programme, Defra, Zone 2C Nobel House, 17 Smith Square, London, SW1P 3JR Respond: 20 December 2013 Consultation on Environment Amanda Owen Online at: Received: 27 September 2013 proposed fees and Agency (Environment) https://consult.environment- Charges 2014/2015 agency.gov.uk/portal/ho/finance/charges2014 /charges2014 Respond: 24 December 2013 Proposed Changes to Environment Amanda Owen Online at: https://consult.environment- Received: 06 November 2013 the H1 Assessment Agency (Environment) agency.gov.uk/portal/ho/ep/h1_1/environmental Framework

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