A renewed sense of urgency about fighting the causes of climate change seems to have taken hold of European politics over the last few months, resulting in bold, ambitious statements from the European Commission. However, in spite of such rhetoric, in the first major test case for its commitment to seriously tackling CO2 emissions, the Commission bowed to an intensive lobbying campaign by vested interests and watered down its proposals for reducing CO2 emissions from cars. This does not bode well for the Commission’s ability to act in the public interest and take the difficult decisions needed to halt climate change. This article shows how the watering down and postponement of EU measures to curb passenger car CO2 emissions are the result of a long running lobby campaign by the car industry.
On 7 February 2007, the European Commission agreed on mandatory targets for CO2 emissions from cars. The Commission only proposed a binding target after it had become clear that the car industry was failing to meet targets agreed under a 10 year voluntary agreement on CO2 emissions. Initially, Environment Commissioner Dimas wanted a binding target of 120g/km by 2012, to be achieved through innovations in vehicle technology. But in the end the Commission opted for a much less ambitious target of 130g/km. The final legislative proposal is expected the latest in Spring 2008.
A decade of car industry lobbying
The European Union has long been conscious of the need to address the problem of rising CO2 emissions from road transport (which increased by 26% between 1990 and 2004). Since 1993 the Commission and the car industry have been discussing how to reduce passenger car CO2 emissions, but to date the carmakers have been able to delay and water down reduction targets. With the Commission now preparing to impose binding targets, car industry lobbying can only be expected to intensify in 2007. The 1998 voluntary agreement: failed promises In 1996 the EU agreed a Community Strategy to reduce carbon dioxide emissions from passenger cars. The aim was to reduce the average emissions from new cars sold in the EU to 120g/km CO2 (a 35% reduction) by 2010 at the latest.
As a result of ongoing talks between the European Commission and the car industry in the context of the "Auto-Oil I" programme (1993-1997), the two parties concluded a voluntary agreement, setting a mid-term target of 25% reduction on CO2 emissions from motorcars by 2008 (from 186g/km in 1995 to 140g/km in 2008). This way, the car industry succeeded in postponing the 1996 Community Strategy's target date for reaching 120g/km with two years, from 2010 to 2012.
The Commission’s annual progress report for 2004, published in August 2006, concluded that reductions in average car emissions over the period 1998-2004 were too slow to reach the 25% reduction target for 2008. Most of the reductions achieved were attributed to a shift in the market towards diesel cars (which have better fuel economy) rather than to technical improvements. Environment Commissioner Dimas and Industry Commissioner Verheugen concluded that the voluntary approach was not working and that mandatory targets were needed.
Commenting on the progress report, Verheugen’s spokesman said that the situation was “by no means satisfactory”: if the “carrot approach” was not working, the Commission would have to resort to a “stick approach”, which would include legislative measures to ensure that the necessary CO2 reductions are achieved.
The new proposals and the new lobbying campaign
On 30 October 2006, Commissioner Dimas declared he had lost faith in a voluntary agreement and called on his colleagues to support binding legislation on carmakers to reduce car CO2 emissions. Energy Commissioner Andris Piebalgs and, initially, President Barroso also stressed the need for binding measures.
Such statements from the Commission sounded alarm bells among the car lobby. A few days after the release of the Commission’s progress report, ACEA issued a press release declaring its explicit opposition to any legislation on CO2 emissions from cars. ACEA added that the voluntary agreement “runs until 2008 and its final results won’t be available before 2010”, implying that decision-makers should not consider additional measures until then.
The German car industry – lagging behind in reducing CO2 emissions of most of its models – immediately started a PR and lobbying campaign that included heavy doses of scaremongering. Most likely the car makers chose for such scare tactics because they knew that blocking EU legislative action to curb car CO2 emissions was going to be an uphill battle. Though the Commission has always focused on average reduction targets for all cars in the EU, articles started appearing in the German press suggesting the Commission wanted to propose a general CO2 emissions cap for all car classes, complaining about this ‘disastrous threat’ to the German automotive sector and the ‘unfair treatment’ by Brussels.
German car industry scaremongering
DaimlerChrysler’s Erich Klemm told the newspaper Bild am Sonntag at 29 January that if the tighter standards where approved several factories would have to be closed. “If this is decided like this, then we will have to close our factories in which C, E and S-class are produced”, Klemm claimed, referring to the large luxury cars produced by his firm. “Around 65,000 workers in the cities of Sindelfingen, Untertürkheim and Bremen would be hit”.
Numerous German mass media seem to have adopted the subtle but deeply problematic misinterpretation of Dimas’ proposals originating from Klemm and other car industry spokespeople. Der Spiegel, for instance, wrote that “Dimas argues for a legal maximum of 120 gram CO2 per car kilometer”. This misses the point that the proposed CO2 limit would not be an absolute maximum, but an average target for the car industry to achieve.
In December 2006, the European Car Manufacturers Association (ACEA) apologised for only having achieved less than half of its obligation to reduce car CO2 emissions. In a paper entitled Committed to reducing CO2, the trade association highlighted a key clause in the 1998 agreement that says that “external factors beyond ACEA’s control may influence the outcome”. It claimed that factors such as ‘bad’ regulation on recycling, “weak demand for energy efficiency” (ie. blaming the consumers) and poor car sales had been responsible for the failure to meet the targets. ACEA said the way forward was an ‘integrated approach’: recognising that “relying largely on technological solutions is no longer an option” and that the “combined efforts of many parties and demand-related measures are essential instead”.
So the car industry wanted everybody mobilised against car CO2 emissions except… itself. ACEA had already been promoting this approach within the influential CARS21 High Level Group (see Appendix 3) and succeeded in making it a central principle of the CARS21 Report. In mid-January 2007, the details of the Commission’s proposal were taking shape. At the same time it became clear that Dimas’ ambitions for an obligation to achieve 120g/km by car technology innovations up to 2012 were encountering resistance within the Commission, particularly from vice-president Gunter Verheugen (Enterprise and Industry). Verheugen, who had previously agreed on the need of binding measures (see above, note 8) now openly contested the possibility of such legislation in interviews with French media. The shift in Commissioner Verheugen’s stance may well be explained by political pressure and an intense PR campaign waged by the German car industry since October 2006. Verheugen’s objections forced President Barroso to postpone the publication of the Commission proposal, which had been scheduled for 23 January 2007, even when Mr. Barroso had on previous occasions publicly supported binding measures. When announcing the postponement, his spokeswoman said: “The president believes there is a need for legislation to meet the target set by the Commission”.
She was referring to an emissions level of 120 grams per kilometre of CO2 by 2012 for new cars, which has been repeatedly endorsed by EU leaders. This target (‘level of ambition’) remained, she added, but more time was needed to reach consensus on “how to achieve it, and precisely what the legislation should cover”.
Time would show that the delay was only beginning of bad news. On 26 January 2007, German companies BMW, Volkswagen and DaimlerChrysler, together with the European units of Ford and General Motors sent a letter to Commission President Barroso. In the letter they asked him to withdraw the proposed new emissions standard, alleging that the proposed measures were “technically unrealisable” and would constitute “a massive industrial political intervention at the expense of the entire European, and especially the German, automobile industry”. They did not hesitate to evoke the spectre of massive industrial desertification: “The direct consequence would be the migration of a large number of jobs from the automobile manufacturers and the supplier industry”.
This threat may have looked quite convincing as it came only two months after Volkswagen had announced restructuring plans that could result in the loss of up to 4,000 jobs in the Brussels region. Some media interpreted the German (and American) carmakers’ move as a split in the European car industry. German companies specialised in heavy and luxury vehicles were said to be drifting away from their Mediterranean competitors producing more energy-efficient cars.
There are indeed big differences in the performance of the various companies on car emissions reduction. According to the European Federation of Transport and Environment (T&E), in 2005, only Fiat had already reached the 2008 goal (139 g/km), while Citroen and Renault were on track to meet the 140 g/km commitment in time and Ford and Peugeot were almost on track. All other major brands were, and remain, well short of achieving 140 g/km in 2008 with Volkswagen, BMW and Audi among the worst performers.
Despite these differences, the thirteen large European and US carmakers with production plants across the EU represented through ACEA demonstrated their unity by publishing a new position paper with a message similar to that of the German carmakers’ letter that was sent the same day. Both put forward the same principle: “Reducing further CO2 emissions through vehicle technology only is the most expensive and least cost-effective option for society. (…) More can be done for the environment, at lower costs”. They were clearly opposed to binding targets.
Unsurprisingly, German carmakers, and the European-based units of American companies, being the heaviest polluters, were at the forefront of this lobbying effort. They were supported by their pan-European trade association with the assent of their French and Italian competitors. Ford, whose CO2 performance is among the best of its peers, also signed the letter, demonstrating an unfortunate united front defending the lowest common denominator towards EU decision-makers.
Pressure did not only come from the German car industry directly, but was also applied indirectly, for example through the German Chancellor, Angela Merkel. In a speech at the “Europe Day” event organised by the German industry federation (BDI), Merkel stated that “the German government will work with all its strength and energy for there to be a reduction by sector”. “We will prevent there being a general reduction” she said. With this statement, Mrs Merkel was de facto picking up the misleading PR campaign of the German car industry.
After this warning from the current head of the European Council, Barroso directly intervened to settle the internal argument in the Commission. Contrary to the statements made by his spokeswoman on 23 January, the ‘level of ambition’ was decisively watered down. While the car industry letter resulted in a Commission u-turn, a letter sent by the Green 10 – a group of ten environmental NGOs – on the same day as industry’s letter, was effectively ignored.
A dubious compromise
The result was a compromise, presented by the Commission on February 7th, suggesting a binding target of 130g/km for average CO2emissions through vehicle technology improvements for 2012 and a further 10g/km reduction through complementary measures “such as tyres and air conditioning systems, and a gradual reduction in the carbon content of road fuels, notably through greater use of biofuels”. Verheugen and the car industry cut the initially proposed reduction by 25% while also winning time. Appeals by Commissioner Dimas to confirm that the Commisison would make a final proposal before the end of the year 2007 were rebuffed and the decision was postponed until the second half of 2008.
When the Commission presented its proposal on 7 February 2007, the car industry again responded swiftly and in unity. A few hours after the Commission’s press conference, ACEA published another position paper, saying that the “proposed CO2 emission targets were arbitrary and too severe”. The first ACEA statements were made by Chairman Sergio Marchionne, who is also the CEO of Fiat. The Commission proposal leaves some crucial issues open, such as how to tailor the targets to different car types and companies, how to fully measure compliance and who will bear the responsibility of the actual drafting of the legislation (DG Enterprise or DG Environment). It is uncertain if specific sanctions for companies failing to comply are envisaged. The outcome of these points will determine the very essence of the new legislation.
Regardless, the car lobby insists it does not even accept the main elements of the compromise proposal and that it will try to reverse them. This is nothing less than the declaration of a full-scale lobbying offensive for the year 2007.
The lobbying battle ahead
Over the next 18 months, the car industry will continue its lobby campaign while the dossier passes through the EU institutions. The victory at the expense of the struggle against climate change in the first round was, to a large extent, based on the stranglehold in which DaimlerChrysler, BMW, Volkswagen and other car giants seem to hold leading German politicians. But the car industry has a far wider toolbox which it can use to shape the next stages of decision-making to its advantage. This includes:
* massive over-representation and advantage in spending power of car industry lobbyists in Brussels compared to those defending environment and health concerns;
* strong and well-organised allies in the European Parliament, including MEP-industry groupings such as the Forum for the Automobile and Society;
* a systematic pattern of privileged access to the European Commission, including Commission expert committees and High-level Groups.
The car industry’s lobby contingent in Brussels
Due to the absence of transparency rules around EU lobbying, exact figures about the number of car industry lobbyists in Brussels or the amounts invested in influencing EU decision-making are not available. CEO research shows that at least seventy professional lobbyists work in Brussels for individual car producing companies or for their trade associations (see appendix 2).
Almost 20 staff represents the European Car Manufacturers Association (ACEA) while around 50 work for individual companies, mainly European or European branches of American ones, but also Japanese. In comparison, the European Federation for Transport and Environment (T&E), one of the few environmental NGOs deeply involved in the debate about reduction targets for car CO2 emissions, employs only 8 Brussels staff. The seventy-plus Brussels-based lobbyists employed by car firms and their lobby groups are only the tip of the iceberg. The number is a conservative estimate, not including lobbyists employed by highly related sectors such as distribution, supply and dealing. National level car lobby groups employ numerous lobbyists who will assist in targeting the European Commission, the European Parliament and national governments. Moreover, the spending power of the auto industry means it can easily hire in auxiliary troops from the many consultancies and public affairs firms based in the Brussels EU quarter.
Assessing how many of these hired-gun lobbyists will assist the car industry in the months to come is virtually impossible, given the absence of a proper lobbyists register. As such we can only guess at the budgets involved. In contrast to capitals like Washington D.C. and Ottawa, lobby transparency obligations are still absent in Brussels. Browsing a sample of lobby consultancy websites shows that the car industry is an important client group, but the consultancy firms are unwilling to voluntarily disclose any details of who they work for, what tactics they use, what specific pieces of legislation they lobby on, and critically who pays them and how much. While much of the details remain unknown, it is beyond any doubt that the car industry lobby will be massively over-represented in the looming Brussels lobbying battle. See appendix 2 for some basic facts about the car industry lobby in Brussels.
Friends in High Places: the Forum for Automobile & Society
The European Parliament’s first reaction to the Commission’s strategy was not in line with the car industry’s position. In a resolution on climate change approved on 14 February 2007, MEPs call on the Commission to impose a binding target of 120g/km by 2012 for new passenger cars marketed in the EU. But discussion in the parliament has just begun. MEP Jorgo Chatzimarkakis, a prominent member of MEP-industry grouping the Forum for the Automobile and Society, stated: “we will not completely dismantle this proposal but we will shape it in such a way that it will protect both the climate and the car industry”.
Most certainly, the thirty-three carmakers’ lobbyists accredited to the EP will assist in this process.
Appendix 1: The Forum for Automobile & Society
On 6 February 2007, just in advance of presenting the Commission’s new strategy to reduce carbon dioxide (CO2) emissions from new cars and vans sold in the European Union, Commissioners Dimas and Verheugen participated in the event “Enhancing the Competitiveness of the Motor Industry – Is an integrated approach really possible?” organised by the Forum for the Automobile and Society. According to its website, “the Forum for the Automobile and Society is an autonomous, not-for-profit organisation, supported by stakeholders in the automotive community with the aim of bringing together decision-makers, the automotive industry and motoring organisations to exchange information and views with all those interested in automotive issues and their impact on society.” It brings together forty MEPs and twenty-four corporate members. The organisation is financed by its corporate members; MEPs don’t have to pay membership fees.
The positions put forward during events organised by the Forum for the Automobile and Society tend to be almost identical to those of ACEA. The Forum – that shares its secretariat with the European Bureau of the Fédération Internationale de l’Automobile (FIA) – will most probably become the spearhead of the car industry lobby campaign in the European Parliament, when the Parliament debates the new Commission strategy on car CO2 emissions.
Appendix 2: The carmakers’ lobbying battalions
Due to currently insufficient lobbying disclosure rules in the European Union, there is no accurate data available regarding those lobbyists working for the car industry in the Brussels EU quarter. The second column of the table below reflects data from the register of the European Parliament. For the first column we used the European Public Affairs Directory published by a commercial firm to find out which companies and associations have EU affairs offices. We then called most of the offices and asked them how many staff they employ. On the basis of the information provided, we estimate the number of car industry lobbyists in Brussels to be well over 70 (65 working in the various offices, plus 7 others with accreditation to the EP). Besides the car producers there are also companies dealing with other stages of the cars’ economic cycle, like distribution, supply and dealerships. Their European trade associations (CLEPA, CECRA and ECG) employ in total around 30 staff. These people together with the lobbyists of the individual distribution, supply and dealership companies may also be willing to assist the car industry on curbing the EU CO2 reduction measures. Car Industry Lobbyists in Brussels Company / Association Staff in EU affairs offices Lobbyists in the European Parliament Forum for the Automobile and Society / F.I.A (joint secretariat) ? 4 ACEA 19 3 German Association of the Automotive Industry (VDA) - 1 Volkswagen 4 3 BMW 3 2 DaimlerChrysler 4 2 Man - 1 Rolls-Royce <= 3 - General Motors 5 3 Ford 3 1 Volvo (buses etc.) 5 3 Scania - 1 Fiat 3 3 Renault 7 1 JAMA 6 1 Toyota ? 4 Subaru <= 2 - Honda 1 ? - Total <= 65 33 Lobbying consultancies working for the car industry In the absence of an effective lobbying disclosure system and the reluctance of lobbying firms to disclose details of individual clients it is impossible to know the exact number of commercial lobbyconsultants working for the car industry today. Nevertheless, some simple internet research shows that many public affairs firms do lobby work for carmakers or the ‘automotive sector’. CLAN public affairs, Cabinet Stewart, Burson Marsteller, ARPI and Athenora are some of the consultancies that on their websites state that they work for car industries. Weber Shandwick works for DaimlerChrysler, Renault, Volkswagen and probably also Ford. Appendix 3 : Official advisory groups The CARS21 High Level Group (DG Industry) EU policy making for the automotive sector has never left the industry out in the cold. On the initiative of Commissioner Verheugen, the High Level Group ‘CARS21’ was created in April 2005, with a mandate to suggest “a competitive regulatory framework for car industry”. Its membership was strongly imbalanced, in favour of the auto-industry: the Commission and the member states provided eight officials, while there were seven representatives from industry, two from trade unions, one from an environmental organisation and none for consumers. The CARS21 High Level Group (HLG) published its conclusions in December 2005. The main outcome on CO2 emissions was that an ‘integrated approach’ should be followed that would involve “all relevant stakeholders (i.e. vehicle manufacturers, oil/fuel suppliers, customers, drivers, public authorities, etc.)”. The conclusions of this ‘official’ HLG, heavily influenced by industry input, have rather predictably become a key part of car industry lobbying. The only environmental organisation involved in CARS21 (the European Federation for Transport and Environment) when consulted on the final report, explained point by point its disapproval and repeated its critique of the way the ‘integrated approach’ was perceived: “An integrated approach does not mean downgrading ambition levels for action in any one area. Rather it means seeking synergies instead of antagonisms and ensuring policy actions are complementary. The integrated approach should not, therefore, be used as a reason to lessen regulatory efforts in any one area, for example (…) revising the target for reducing average new car CO2 emissions via technical innovation.”. It also highlighted the unbalanced composition of the group: “We believe that the composition of the group was not well-suited for this purpose. Representatives of environmental and safety NGOs were lacking in the group, which therefore was unbalanced in this respect, but also lacked specific expertise”. Stakeholder working group on the integrated approach to reduce CO2 emissions from light-duty vehicles (part of the European Climate Change Programme II, ECCP II – DG Environment) Another group that assisted the Commission’s reflections long before the announcement of the new measures was the working group on “technological and other measures to reduce CO2-emissions from passenger cars” under DG Environment. Interest representation within this working group also was unbalanced, with eight trade associations, three NGOs (all environmental) and with the industry-friendly FIA (Fédération Internationale de l’Automobile) representing consumers! It published its final options’ analysis in October 2006, just at the time when the internal ‘conflict’ in the Commission was starting. Criticising the interim report of the working group (published in July 2006), the European Federation of Transport and Environment said: “The fact that this draft report appears one year after a similar study [ed. IEEP 2004] done by almost exactly the same consortium with an exactly similar methodology, and still ends up with three times higher costs, raises with us serious doubts over the credibility of the outcomes. The large extent to which adjustments are based on ‘expert judgement’ only reinforces that impression.” High costs estimations remained in the final report. Notes 1. “C’est à nous, tous ensemble, que reviennent désormais le devoir moral et la responsabilité historique de mettre en place sans plus attendre des parades énergiques, à la hauteur des conséquences prévisibles du réchauffement de la planète”. [We – all together – have now the moral duty and the historic responsibility to put in place without waiting energetic answers that stand in the height of the foreseen consequences of the planet’s warming]. Speech at the Paris conference for a global ecological governance, "Citoyens de la Terre", Commission President José Manuel Durão Barroso, Paris, 2 février 2007. 2. In the final proposal, the original target of 120g/km by 2012 was watered down by allowing 10g/km reduction to be achieved through non-technical measures, like tyres and air conditioning systems, and a gradual reduction in the carbon content of road fuels, notably through greater use of biofuels. 3. Commission plans a legislative framework to ensure the EU meets its target for cutting CO2 emissions from cars, European Commission press release, IP/07/155, 7/2/2007. 4. A Community strategy to reduce CO2 emissions from passenger cars and improve fuel economy, European Commission, COM(95) 689 final, 20/12/1995; A COMMUNITY STRATEGY TO REDUCE CO2 EMISSIONS AND IMPROVE FUEL ECONOMY - COUNCIL CONCLUSIONS, Conclusions of the Environment Council meeting of 25 June 1996. 5. The Two Faces of EU Transport Policies, Corporate Europe Observer, June 1999. 6. Commission Recommendation on the reduction of CO2 emissions from passenger cars, (1999/125/EC), 5 February 1999. 7. CO2 emissions from new cars down by more than 12% since 1995, European Commission press release, IP/06/1134, 29/08/2006 8. Commission to get tough with carmakers on CO2 cuts, Euractiv, 29 August 2006. 9. Dimas pushes for EU car CO2 emissions law, ENDS Europe DAILY 2195 (30/10/2006). 10. Piebalgs urges EU car emission cap, EUpolitix, 25/01/2007; “Environment commissioner Stavros Dimas and commission president Jose Manuel Barroso are in dispute with German industry commissioner Günter Verheugen, who is leading the opposition to strict binding obligations [...] Mr Barroso’s spokesman told the industry on Monday to “embrace and anticipate change, not resist it.” Germany cranks up the pressure in car CO2 row, ENDS Europe DAILY 2251 (30/01/2007). 11. European Car Industry opposes recent statements of Environment Commissioner Stavros Dimas regarding CO2 Commitment, ACEA press release, Brussels, 5 November 2006. 12. How clean is your brand?, European Federation for Transport and Environment, October 2006. 13. “Dimas plädiert dazu für eine gesetzliche Obergrenze von 120 Gramm CO2 je gefahrenem Kilometer.” Source: Autolobby schießt sich auf Brüssel ein, Der Spiegel, 28 Januar 2007. 14. Committed to reducing CO2, ACEA website, accessed 15 March 2007. 15. A Competitive Automotive Regulatory System for the 21st century, CARS 21 final report, January 2006. 16. Commission row over car CO2 boils over, ENDS Europe DAILY 2244 (19/01/2007). 17. Barroso postpones car CO2 report amid infighting, ENDS Europe DAILY 2246 (23/01/2007). 18. German carmakers’ letter to the European Commission, 26 January 2007. 19. This restructuring had nothing to do with environmental measures and came at a time where Volkswagen's profits continued to rise. 20. For example: Emissions target splits EU car industry, John Reed (London) and Andrew Bounds (Brussels), Financial Times, 7 February 2007. 21. How clean is your brand?, European Federation for Transport and Environment, October 2006. 22. Citroen, Audi and Volvo belong to other companies. 23. Car industry wants fact-based policy on CO2 reductions, ACEA press release, Brussels, 26 January 2007. 24. Rede von Bundeskanzlerin Angela Merkel anlässlich des Europatages der Deutschen Wirtschaft, Berlin, 30. Januar 2007. 25. Reducing CO2 emissions from light duty vehicles, letter by the Green 10 to EU Commission President Barroso and Commissioners Barrot, Verheugen, Dimas and Piebalgs, Brussels, 23 january 2007. 26. Commission plans a legislative framework to ensure the EU meets its target for cutting CO2 emissions from cars, European Commission press release, IP/07/155, 7/2/2007. 27. “Mr Dimas has called for the commission to make a firm commitment to legislate before the end of this year in next week’s paper following what is widely seen as failure by the car industry to respect an existing voluntary agreement on cutting emissions”. Source: Commission row over car CO2 boils over, ENDS Europe DAILY 2244, 19/01/07. 28. “A legislative framework to reduce CO2 emissions from new cars and vans will be proposed by the Commission by the end of this year or at the latest by mid 2008.” Source: Commission plans a legislative framework to ensure the EU meets its target for cutting CO2 emissions from cars, European Commission press release, IP/07/155, 7/2/2007. 29. Proposed CO2 emission targets are arbitrary and too severe, ACEA press release, Brussels, 7 February 2007. 30. Curbing emissions, Financial Times, 12 February 12 2007. 31. Climate change: tougher targets needed, say MEPs, European Parliament website, accessed 15 March 2007. 32. Jorgo Chatzimarkakis interview in his Audi, Chatzi News, 30 January 2007, YouTube website, accessed 15 March 2007. 33. Enhancing the Competitiveness of the Motor Industry – Is an integrated approach really possible?, Report of a conference organised by the Forum for the Automobile and Society in the Representation ogf the free State of Bavaria on 6 February 2007, Gaby Rosen, 19 February 2007. 34. About the Forum, website of the Forum for the Automobile and Society, accessed 15 March 2007. 35. See for example the letter from the European Public Affairs Consultancies Association (EPACA) to Corporate Europe Observatory, 16 March 2005, . 36. “The automotive sector”. Source: CLAN Public Affairs – Practice Areas, website CLAN Public Affairs, accessed 15 March 2007. 37. “Automotive industry”. Source: Cabinet Stewart – Sectors, website Cabinet Stewart, accessed 15 March 2007. 38. “Automotive industry”. Source: Burson-Marsteller Brussels – What we do, website Burson-Marsteller Brussels, accessed 15 March 2007. 39. “The automotive and transportation industries and suppliers of parts, components or systems to the automotive industry”. Source: Arpi International S.A. – Typical clients and services, website Arpi International S.A., accessed 15 March 2007. 40. PSA and Volvo, Source: Athenora Consulting Refernces, website Athenora Counsulting, accessed 15 March 2007. 41. DaimlerChrysler, Renault and Volkswagen. Source: Car Makers and fuel suppliers unite to promote synthetic fuels in Europe, Alliance for Synthetic Fuels in Europe (AFSE) press release, Brussels, 7th March 2006. Most probably also Ford. Source: Inside the German Presidency, Weber-Shandwick, Brussels, December 2006. 42. A Competitive Automotive Regulatory System for the 21st century, CARS 21 final report, January 2006. 43. Response of the European Federation for Transport and Environment (T&E) to the consultation of the European Commission of the CARS 21 final report, T&E, Brussels, 28 April 2006. 44. Membership of the ECCP working group on the integrated approach to reduce CO2 from light duty vehicles. 45. Review and analysis of the reduction potential and costs of technological and other measures to reduce CO2-emissions from passenger cars, Final Report, TNO Science and Industry, Institute for European Environmental Policy (IEEP) and the Laboratory of Applied Thermodynamics of the Aristotle University of Technology, 31 October 2006. 46. T&E comments to the interim TNO report on options to reduce CO2 from light duty vehicles, presented 30 June 2006 in Brussels, T&E, Brussels, 21 July 2007. 47. Review and analysis of the reduction potential and costs of technological and other measures to reduce CO2-emissions from passenger cars, Final Report, TNO Science and Industry, Institute for European Environmental Policy (IEEP) and the Laboratory of
Applied Thermodynamics of the Aristotle University of Technology, 31 October 2006.