1 Low emission zones in Germany The bus and coach operator‘s perspective02 March 2011 A warm welcome at first from our side. Our presentation on low emission zones is dedicated to the perspective of the German bus and coach operators. The creation of the low emission zones (LEZ) has progressed in Germany quite a bit. Germany plays here a sad leading role - as you can see here…(next screen) Christiane Leonard bdo - Germany

2 "Rag rug" Germany  No uniform regulations in Germany!To start with: Let us have a look on the so called “Rag Rug” in Germany (=“Flickenteppich”). At present we have more than 40 - namely 43 – low emission zones (LEZ) in Germany! Further ones are already planned! Additionally, within the cities the rules are continually made stricter - as for example in Munich, Stuttgart, Frankfurt and Berlin. In those cities the red EURO 2-buses are not allowed access anymore – you would need EURO 3 or the yellow disc at least for getting access into the cities. The patchwork of procedures leads us to one of the main problems at the moment: the lack of national regulations in Germany! Each city decides on their low emission zone on their own. The differing standards in every German city are confusing the bus and coach operators.    No uniform regulations in Germany!  Every town decides on their own about setting up a low emission zone Quelle:

3 Legal Basis for LEZ Limits set by the EU in Directive 1999/30/EC on air quality limit values Average daily limit value of particulate matter (PM10): 50 µg/m3 allowing 35 excesses per year The EU Member States are obliged to take „necessary actions“ in order to meet the required limit values No specific measure are regulated by law (no obligation to set up “low emission zones") Implementation into German Law by the 35. BImSchV (Stickers) Basis for the introduction of the low emission zones is the implementation of the air quality EU-directive from the year 1999. Concerning the charge by particulate matter (PM10) a day average value of 50 µg/m3 (micrograms per cubic meters) is compulsory with only 35 excesses per year. The EU-directive only prescribes a reduction of the particulate load and „necessary measures“ of the member states. However, it leaves them freedom with the implementation. Hence, a low emission zone in cities is not mandatory! The legal basis in Germany is the 35. BImSchV (Federal Immission Control Act) that implements stickers for certain vehicles - followed by the so called „rag rug of Germany”.

4 What is standardized Germany-wide?Emissions-control window screen stickers to enter the LEZ (EURO 2, EURO 3, EURO 4) Stickers are mandatory for all vehicles driving in LEZ – also for foreign vehicles! How to obtain these stickers?  Further Information: There is only one thing that is uniform in Germany: The stickers/ discs for the entry into the LEZ (EURO 2, EURO 3, EURO 4). Those are – as you will certainly know - also necessary for foreign buses! All other rules differ from region to region. That means that the exemptions, time periods and conditions of the LEZ vary between the different cities and change very fast. In the end, a coach operators never knows which vehicles can still drive into a city and which not..

5 In 2011 more than 43 LEZ in GermanyImportant is therefore: to check the local regulations before each trip! The bdo offers his bus operators always some kind of assistance that you can see here – an overview in our data base about the rules! You can read from the table that the green stickers –which means EURO 4-standard for buses and coaches- will already be required in So far, only few German cities - Hannover, Bremen, Berlin and Leipzig (highlighted in red) – have excluded coaches temporarily from the restrictions of access. But this is just a single success. Buses and coaches need a practicable exception rule for the whole system, not only single exceptions.

6 Argument 1: State-of-the Art in GermanyMost German coach operators are driving with EURO 3-coaches (30 % of the fleet) Only 23 % of the German coaches meet EURO 4+ Long-term-planning along the economic life-cycle of buses! Most German coach operators are currently driving with yellow stickers –means EURO 3 coaches. Those are 30 percent of all buses/coaches. This is not at all surprising, given that until 2006, these coaches were manufactured and delivered as state-of-the-art technology and were purchased at a price of approximately € Only 23 percent of the buses/coaches have a green EURO 4, 5 or enhanced (EEV) standard. Therefore, almost 80 per cent of the German bus fleet are threatened by access bans „of the greens sticker “ in the next year. What bus operators need is long-term planning based on the life-cycles of buses (for example for the certain use of buses over a 10-years-period) !

7 Argument 2: Environment-friendlinessFor bus operators it is simply not clear that the most environmental-friendly means of transport is banished from the city centers by restrictive environmental policy. Buses have the lowest emissions of carbon dioxide as well as the smallest energy consumption. Additionally, a bus replaces 30 passenger cars and enables smooth traffic without traffic jams. Thus: The more persons use the bus, the better for the environment! coach = lowest carbon-dioxide = smallest energy consumption 7

8 Argument 3: Reduction of emissionsEURO 3 = -72% Particles The main argument for low emission zones -the reduction of particles- is insignificant for buses. Modern EURO3-buses have already reduced their particle-emissions by altogether 72 per cent (compared with 1993). Buses have reduced all the other emissions since 1990 to a minimum. Therefore a EURO 3-bus emits only 19 percent of carbon dioxide, 28 percent of hydrocarbons, 35 percent of nitrogen oxides and 28 percent of particles (=72% reduction) - compared to the year 1990. Against this background it is not clear that starting from the year 2011/2012 even clean Euro 3-coaches are to be forbidden in German city centers.. Modern EURO3-buses have already reduced particle emissions by 72 percent (compared with 1993). 8

9 Argument 4: Retrofitting is no solutionRetrofitting with particle filters costs approx.: € € (price for double filters for NOx) high investment with uncertainty Low acceptability in other countries Problems with guarantees & warranty claims possible Retrofitting with particle filters costs approximately to € and is therefore expensive. These high investment costs cannot be passed onto customers by increasing travel costs. Even with the expensive filter the vehicle stays the old EURO-standard as the filter only improves one emission value, not all! Even with a double filter you could only improve two emission values (NOx and particles). Additionally, Retrofitting always means uncertainty, because it is often not accepted in other European countries (e.g. Austria, Sweden, Poland). Moreover, it is not clarified what impact the installation of particle filters has upon existing guarantee and warranty claims of the operator. 9

10 Expenditures in German cities for Exemption PermitsArgument 5: Exemption permits Exemption permits in all cities mean payment of more than € 3,000! Procedures differ from city to city, with immense bureaucratic efforts and hardly feasible! Expensive patchwork of application procedures Expenditures in German cities for Exemption Permits City Minimum Maximum Augsburg 50 € 180 € Berlin 245 € 760 € Bremen 135 € 430 € Frankfurt: 20 € 100 € Heilbronn 15 € 106 € Herrenberg 53 € Ilsfeld 16 € 300 € Köln 75 € Leonberg 120 € Ludwigsburg 80 € Mannheim 30 € 40 € München 10 € 200 € Neu-Ulm Osnabrück Pforzheim Ruhr Area Stuttgart Ulm Total 1.027 € 3.113 € Bus and coach operators travelling to multiple cities are therefore forced to apply for many different exemption permits. However, this procedure differs from city to city, with immense bureaucratic efforts, cost-intensively and hardly feasible. If a tourist coach operator applies for exemption permits in all cities, the operator will currently pay more than € 3,000. This calculation does not include the administration costs incurred, which will cost an additional €600 per coach per annum. For bus operators this has created a confusing and really expensive patchwork of application procedures! 10

11 Argument 6: Impact on city tourismStudy on the economic factor of the coach tourism will be issued on 17 March 2011 Accomodation Culture travels Shopping Active adventure travels Furthermore it is has not been considered that the city access restrictions cause substantial damage to the entire city tourism. The market share of the coach tourism has been reaching 9 to 10 percent of the whole vacation trips for many years. Most tourist sites in Germany are however situated in low emission zones. These tourist places must remain reachable for coaches from Germany and foreign countries. Because for many persons (seniors) the coach is the means of transport without alternative. Driving bans for coaches will therefore lead to a decrease of city trips and thus to sinking turnovers of the local tourism economy. This development cannot be the interest of the cities. On the contrary, many European mega-cities such as Paris, Madrid, Barcelona, Marseille, Vienna, Riga, Warsaw and Brussels - offer free entry into their cities. The bdo will present a new fundamental study on the “economic factor of coach tourism” very soon so that the economic effects will become clearer. City trips Food Employment Leisure time Turnovers Transport Taxes 11

12 Requirements and actionsExemptions of traffic restrictions for EURO3-buses and coaches until 2015 Long-term-planning and -information Harmonized framework on LEZ Provision of single-window-registration for operators and vehicles Because ecological means of transport must be promoted and not hindered In order to promote busses and coaches the bdo asks for some actions: Vehicles must at least be allowed to run until the end of their economic life (about years). Therefore, in case of the EURO3-buses and coaches – which were the best environmental deal only five years ago- exemptions are needed until 2015! Besides, coach operators need information on traffic rules, restrictions and city taxes at least one year in advance and not within weeks! Business planning is impossible at the moment for coach operators – since they never know which vehicles can drive where in the next year. Therefore long-term-planning and predictable rules are a „must“! At the moment, the patchwork of rules makes it difficult for bus operators to respect all of these. A harmonised framework that all cities would apply is necessary! Various documents, exemptions and registrations in the cities increase bureaucracy for small bus operators. Therefore the provision of a single-window-registration in Europe would be a big relief for small companies. With the help of those actions we wish to promote the busses and coaches as ecological means of transport!

13 Thank you! Thank you very much for your interest and patience. If you have any questions don‘t hestitate to ask…