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`Velocity, Patent Owner - Exhibit 2009
`Volkswagen Group of America, Inc. v. Velocity Patent, LLC
`Case No. IPR2015-00276
`Page 1 of 43
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`3.
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`2.
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`EXECUTIVE SUMMARY ............................................................................................................................... 7
`CARS AND THE ENVIRONMENT .......................................................................................................... 9
`1.
`Climate change and the automotive industry .............................................................................. 9
`1.1
`Approaches to reducing emissions ............................................................................................. 9
`1.2
`ECO‐DRIVING .................................................................................................................................. 12
`Eco‐driving and its role in carbon emissions reduction .............................................................. 12
`2.1
`The eco‐driving landscape ....................................................................................................... 13
`2.2
`Eco‐driving as an approach to emissions reduction ................................................................... 13
`2.3
`Do we know how effective eco‐driving can be? .................................................................... 13
`2.3.1
`Strengths and weaknesses .................................................................................................. 14
`2.3.2
`2.3.3 What we need from eco‐driving .......................................................................................... 18
`Fiat and eco:Drive .................................................................................................................. 19
`2.4
`The eco:Drive data: understanding eco‐driving ......................................................................... 23
`2.5
`ECO:DRIVE FINDINGS ....................................................................................................................... 24
`The data ................................................................................................................................ 24
`3.1
`Summary of findings ............................................................................................................... 24
`3.2
`Significant savings .............................................................................................................. 24
`3.2.1
`Different driving styles ....................................................................................................... 25
`3.2.2
`Better drivers .................................................................................................................... 25
`3.2.3
`How efficiently people drive .................................................................................................... 26
`3.3
`Initial eco:Drive performance .............................................................................................. 26
`3.3.1
`Breakdown ........................................................................................................................ 26
`3.3.2
`The effects of eco‐driving ........................................................................................................ 27
`3.4
`Average improvements in driving efficiency ......................................................................... 27
`3.4.1
`Average improvement in eco:Index ................................................................................. 27
`3.4.1.1
`Average improvement in fuel consumption ..................................................................... 28
`3.4.1.2
`Breakdown of average improvement by eco:Index indicator ................................................. 29
`3.4.2
`The potential of eco‐driving ................................................................................................ 31
`3.4.3
`How people use their cars ....................................................................................................... 31
`3.5
`Characteristics of journeys .................................................................................................. 32
`3.5.1
`3.5.1.1 Frequency ......................................................................................................................... 32
`3.5.1.2 Speed ................................................................................................................................ 32
`3.5.1.3 Stop time ....................................................................................................................... 3332
`Impact on efficiency ........................................................................................................... 33
`3.5.2
`3.5.3.1 Fuel consumption and average speed .................................................................................. 33
`3.5.3.2 Fuel consumption and stopping time ................................................................................... 35
`3.5.3.3 Start&Stop ........................................................................................................... 35
`3.5.3.4 Effects of eco:Drive ............................................................................................................ 35
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`3.5.3.5 Changed trip characteristics ................................................................................................ 35
`3.5.3.6 Unchanged trip characteristics ............................................................................................ 35
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`4. DRAWING CONCLUSIONS ................................................................................................................ 38
`What do we understand about eco‐driving? ............................................................................. 37
`4.1
`Where do we go from here?.................................................................................................... 38
`4.2
`Fiat’s commitments ................................................................................................................ 39
`4.3
`REFERENCES .................................................................................................................................... 41
`5.
`APPENDIX: METHODOLOGY ..................................................................................................................... 42
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`TABLE OF FIGURES
`Figure 1: Trend in CO2 emissions reduction for new passenger cars in the European Union ............................. 10
`Figure 2: Debate around technological and behavioural change approaches to reducing emissions ................ 11
`Figure 3: Cost‐effectiveness of eco‐driving ......................................................................................................... 16
`Figure 4: Illustration of an eco:Index report ........................................................................................................ 19
`Figure 5: Screenshot of eco:Ville ......................................................................................................................... 20
`Figure 6: Sample eco:Driving tips ........................................................................................................................ 21
`Figure 7: eco:Drive Fleet ‘Dashboard’ ................................................................................................................. 22
`Figure 8: Summary of annual savings from eco‐driving ...................................................................................... 25
`Figure 9: Changes in driving behaviour ............................................................................................................... 26
`Figure 10: Improvement in eco:Index over 30 days ............................................................................................ 28
`Figure 11: Improvement in fuel consumption over 30 days ................................................................................ 28
`Figure 12: Average improvement by eco:Index indicator ................................................................................... 29
`Figure 13: Gear shift trend over 30 days ............................................................................................................. 30
`Figure 14: Acceleration trend over 30 days ......................................................................................................... 30
`Figure 15: Deceleration trend over 30 days ........................................................................................................ 30
`Figure 16: Speed level over 30 days .................................................................................................................... 31
`Figure 17: Daily and weekly journey frequency .................................................................................................. 32
`Figure 18: Fuel consumption and average speed ................................................................................................ 33
`Figure 19: Fuel consumption and stopping time ................................................................................................. 34
`Figure 20: Fuel consumption with Start & Stop ................................................................................................... 35
`Figure 21: Trip duration trend over 30 days ........................................................................................................ 36
`Figure 22: Average speed (including stop time) trend over 30 days ................................................................... 36
`Figure 23: Stop time (min) trend over 30 days .................................................................................................... 36
`Figure 24: What can we all do to encourage eco‐driving? .................................................................................. 39
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`Page 3 of 43
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` A
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` heritage of environmental responsibility
`Since Fiat was founded over a century ago, our mission has been to provide vehicles that enhance people’s
`quality of life, making driving fun and affordable, while making as little impact as possible on the world around.
`Throughout our history we have led the way in developing new technology that can make driving even more
`accessible and economical. By their very nature, our designs have always been environmentally aware ‐ our
`cars are made to fit into their environment and not to impose on it, providing solutions to people’s mobility
`needs in the most efficient way possible.
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`Today we are still recognised as the leading manufacturer of small, practical and efficient cars. And our
`heritage as an environmentally‐aware manufacturer of affordable and fuel‐efficient cars continues to shape
`our approach to innovation and design. We focus on creating ever‐more efficient vehicles, and are proud to
`have, in Europe1, the lowest average CO2 emissions of any vehicle manufacturer group. We are constantly
`exploring new ways to improve the efficiency of our vehicles, from our Start&Stop technology, available in our
`7 newest models and 31 versions; to our MultiAir engines that reduce fuel consumption and CO2 emissions by
`up to 10% while improving performance. The newest expression of MultiAir technology is the two cylinder
`TwinAir engine, a fun‐to‐drive engine with 85HP and only 92 g/km CO2 emissions on 500 with Dualogic
`gearbox.
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`We are also committed to expanding the use of alternative fuels. We are leader in the European market of
`CNG vehicles with our bi‐fuel Natural Power range covering every mobility need from city cars to professional
`vehicles.
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`Changing driver behaviour with eco:Drive
`But a car manufacturer’s responsibility towards the environment doesn’t stop at technological advances that
`reduce the CO2 emissions of its vehicles. This area has for a long time been the focus of the car industry in its
`response to the challenges of climate change, and rightly so – we have a responsibility to innovate to produce
`low emission cars if we are to remain relevant in the future. However, at Fiat we feel strongly that there are
`opportunities to further reduce the emissions associated with cars by looking beyond the model itself, and
`thinking about the role of the driver.
` We don’t believe that a manufacturer’s responsibility towards the environment ends when a customer drives
`the car away from the showroom – we must be concerned not just with what people drive but with how they
`drive it, too.
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`1 JATO Dynamics, Volume‐weighted average CO2 emissions 2009 (g/km)
`http://www.jato.com/PressReleases/Small%20Cars%20Driving%20Down%20European%20CO2%20Emissions.pdf
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`That’s why we developed eco:Drive. We knew that by making simple changes to the way you drive, you can
`significantly reduce your CO2 emissions. With eco:Drive, we wanted to show drivers exactly how they can drive
`more efficiently and what effect that has on their fuel consumption and CO2 emissions. eco:Drive is an
`interactive, personalised tool that makes use of Fiat’s in‐car Blue&Me infotainment system. Plugging a USB key
`into the Blue&Me port on the dashboard allows eco:Drive to record information about your driving style. You
`then just plug this USB into your computer to see how you performed, how you can improve, and track the
`fuel and CO2 savings you manage to make.
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`eco:Drive has provided us with a bank of data about how people drive their cars – over 9,000,000 journeys
`have been uploaded by 42,000 drivers. For the first time, we are able to see exactly how efficiently people
`drive and how they respond to learning about eco‐driving. In the past, knowledge about eco‐driving’s
`effectiveness has been based on individual experiences comparing one’s fuel consumption from one day to the
`next, having been explained the techniques. The eco:Drive data tells us about the effectiveness of eco‐driving
`for a large number of people, over an extended period of time, in a range of road and traffic conditions. This is
`the closest anyone has come to understanding the ‘real‐life’ impacts of eco‐driving.
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`Lower emissions, better drivers
`What have we learnt? We have seen that eco‐driving works – on average, eco:Drivers reduced their fuel
`consumption and emissions by 6%; the best 10% of drivers managed to improve by at least 16%. We have
`seen that the changes from eco‐driving are not, in most cases, temporary – it is possible to achieve real
`behaviour change that lasts over an extended period of time. We have seen that eco‐drivers are better drivers,
`learning to anticipate changes in traffic flow so that they stop and start less frequently and drive at a more
`consistent speed. We have also seen that there are big variations between the improvements experienced by
`different people and in different places, which shows that the effectiveness of eco‐driving is heavily dependent
`on traffic conditions, road systems and personal commitment.
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`Next steps for Fiat
`The findings from eco:Drive to date provide some important lessons for Fiat and for all those involved in the
`car world.
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`As a carmaker, we believe we have a responsibility to explain to drivers just how they can save on fuel and
`emissions by driving more efficiently, and make it as easy as possible for them to do so. Changing driving
`behaviour isn’t easy. We think eco:Drive’s interactive, personalised approach helped drivers by allowing them
`to see what they are achieving. But we think we can do more to remind drivers regularly of what to improve
`on, so that eco‐driving becomes true habit. That’s why we are developing a new version of eco:Drive for 2011,
`eco:Drive Live, which provides regular feedback on driving style, and tips for improvement, through portable
`devices (such as satnav or smartphones).
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`The success of eco‐driving in reducing emissions depends on carmakers working together with a range of
`stakeholders to unlock the potential of eco‐driving. For example, we all need to encourage and educate drivers
`to try to change their behaviour. We also need to make our roads more eco‐driving‐friendly. Legislators and
`town planners have a role to play here – the eco:Drive data shows just how important traffic fluidity is to CO2
`emissions, which increase sharply when average speeds are lower. This applies particularly to cities where
`traffic systems require regular stopping and starting.
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`The car industry faces huge challenges to reduce the emissions associated with driving – it’s essential for the
`future of the planet, and it’s essential if we are to remain competitive and relevant in the future. Big
`achievements have been made to date through technological innovations, but we think there is more that can
`be done, today, by engaging drivers in the journey to reduce emissions. With eco‐driving, we have an approach
`that can save up to 16% and more of emissions – today. We have an opportunity to re‐shape the
`environmental impact of mobility now, and we believe it is our collective responsibility to promote eco‐driving
`and to make it as easy as possible for people to become more efficient drivers.
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`Page 6 of 43
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`As an industry, car manufacturers are experiencing difficult times. With climate change providing one of the
`biggest challenges of our time, individuals and institutions everywhere are under pressure to reduce CO2
`emissions. The car industry is responding well. Through huge investment in a range of technological
`innovations, emissions from new cars are steadily declining.
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`However, reducing the emissions from driving isn’t just about making a more efficient vehicle; nor is it solely
`the responsibility of car manufacturers. To date, the industry has focused on technological solutions to
`environmental challenges, but CO2 emission reductions can also be achieved by thinking about driver
`behaviour ‐ not just by looking at the vehicles that people drive, but also at how they drive them. This is the
`focus of eco‐driving – techniques to reduce fuel consumption and emissions, which can be used by any driver
`in any car.
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` A
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` range of activity in recent years – activity from governments, companies, and NGOs – has raised awareness
`of eco‐driving. Such activities have also shown that eco‐driving can deliver significant reductions in fuel
`consumption and emissions; over 20% in some cases. However, understanding of the ‘real‐life’ effectiveness of
`eco‐driving is limited. Whilst eco‐driving can be powerful it faces challenges to its successful implementation,
`such as how to motivate people to start eco‐driving and stick to it, and how to change behaviour in the long‐
`run. Communications campaigns are not enough – drivers must be engaged on a personal level and shown
`how they can improve and then maintain these improvements.
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`Fiat’s eco:Drive was developed with this in mind, as a tool to involve drivers in a process of understanding,
`reviewing and improving their driving performance over time. This is the first ever qualitative measurement of
`driving efficiency; which we believe is the only way to really change behaviour. Quantitative measures, such as
`fuel consumption counters, don’t go far enough in helping drivers to understand their behaviour, understand
`what the numbers mean, and what they should do to improve.
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`With eco:Drive, drivers use a USB stick to record information from their car’s inboard computer whilst driving,
`which is then analysed on through the eco:Drive computer programme. Through this process, Fiat has
`acquired extensive data about how people drive which shows that eco‐driving, approached in this way, does
`indeed create real change – a 6% reduction in fuel consumption on average across all users and a reduction of
`at least 16% for the top 10% of improvers – and that this change does last over time. However, the data also
`suggests that various factors that can limit eco‐driving’s effectiveness, from road and traffic conditions, to the
`individual’s own commitment.
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`To get the most out of eco‐driving, and achieve the emissions reductions that it promises, a multi‐actor
`approach is essential. This includes developing efficient cars, helping people to understand how to drive them
`to get the most out of their efficiency, and making it easier for them to do so – by manufacturers providing in‐
`car ways to see and understand driving efficiency, and by governments both promoting eco‐driving and
`factoring it into decisions about road and traffic planning.
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`This report uses insights from interviews with a range of stakeholders involved in eco‐driving activity in Europe
`and, more generally, in the transport and environment sectors, along with an analysis of data gathered by
`eco:Drive, to further understanding of eco‐driving – including its effectiveness, the challenges it faces, and how
`it can play a more powerful role in reducing emission from driving.
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`Page 8 of 43
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`1.1
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`Climate change and the automotive industry
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`Climate change is one of the biggest challenges of our time. Governments, the private sector, non‐
`governmental sector and individuals around the world are engaged in finding ways to reduce CO2 emissions
`and limit the damage caused to people and the planet due to changes in global climate patterns.
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`According to European Commission figures, passenger cars contribute approximately 12% of manmade CO2
`emissions in Europe. As climate change has risen up the agenda, manufacturers have come under increasing
`pressure from consumers, NGOs and governments to do more to reduce the environmental impacts of their
`products
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`In 1998 the first voluntary targets were set by the European Commission, with manufacturers agreeing to work
`towards average emissions of 140g/km by 2008 and 120 g/km for all new passenger cars by 2012. As a result
`of this agreement, CO2 emissions levels for new cars sold in 2008 were 18% lower than for 19952. In December
`2008 European Commission introduced mandatory emission standards, setting an overall target of reducing
`the average CO2 emissions from new passenger cars to 120 g/km by 2015 (130 g/km by means of improvement
`in vehicle motor technology and a reduction of 10 g/km by additional measures) and to 95g/km by 2020
`(although these targets vary for different manufacturers, according to the average weight of their car fleets).
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`1.2
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`Approaches to reducing emissions
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`Car manufacturers’ responses to these pressures have largely been in the form of a technological approach.
`Thanks to ongoing research and innovation, vehicle emissions are gradually and steadily being reduced –
`although more rapidly in some segments and by some manufacturers than others. The range of technological
`approaches is broad – from improving existing technology through greater engine efficiency and structural
`efficiency (e.g. reducing body weight), to developing new powertrains based on hybrid and electric technology,
`to building cars to use alternative fuels such as CNG.
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`2 European Commission communications, COM(2009)713
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`Figure 1: Trend in CO2 emissions reduction for new passenger cars in the European Union
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`Sources: European Commission communications, COM(2009); 2009 Jato Dynamics forecast
`*Provisional data
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`This approach is complemented by efforts to look at the entire vehicle life cycle to find ways to reduce
`environmental impacts. For example, this includes reducing emissions from production processes and meeting
`environment management standards, as well as paying attention to the level of recyclability and recoverability
`of vehicles.
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`But reducing the emissions associated with driving is not just about the vehicles themselves – there’s also the
`question of how people make choices about driving and the impact this has on emissions. This can include
`purchasing decisions – encouraging people to buy more environmentally‐friendly models – the frequency with
`which people drive, as well as the way in which they drive. We can consider this behavioural change approach
`category to sit alongside the technological approach that dominates the environmental transport landscape.
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`To date, far more attention has been paid to technological responses to climate change in the car industry,
`with manufacturers investing large amounts in more efficient technologies and new, lower‐emission engines.
`The level of attention paid to the two approaches in online discussion also demonstrates the imbalance, as
`shown below, with discussion of low emission technologies far outweighing consideration of behavioural
`change approaches – namely, eco‐driving.
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`Figure 2: Debate around technological and behavioural change approaches to reducing emissions
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`To clarify the distinction, and the way in which these two approaches rely on each other, we can draw parallels
`with the broad climate change movement, beyond the car sector. For example, the technological innovations
`in low energy light bulbs, combined with behavioural changes around electricity use in the home and switching
`lights off. To reduce CO2 emissions, we need a combination of technological advancement, alongside changes
`in people’s behaviour – the greatest successes are yielded when both work together.
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`Page 11 of 43
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`2.1 Eco‐driving and its role in carbon emissions reduction
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`Eco‐driving can be seen as one example of a behavioural change approach to reducing emissions. It is the
`practice of reducing emissions by adopting a more efficient manner of driving, irrespective of the vehicle being
`driven. It usually centres on driving style principles, including slow and steady acceleration, early gear changes,
`maintaining a moderate and consistent speed as much as possible, and slow and steady deceleration.
`The concept has risen considerably in popularity in recent years, as the impetus to look for ways to reduce
`emissions from personal transport has increased. Eco‐driving courses, events and studies have produced
`evidence of the potential for eco‐driving to reduce people’s fuel consumption and emissions by anything from
`5 to more than 20%. In general, it is widely estimated and accepted that reductions of 5 to 10% should be
`achievable by the ordinary driver using eco‐driving techniques. These are considerable reductions.
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`Given that this is a low‐cost change to implement, many in the transport and policy worlds feel strongly that
`eco‐driving has an important role to play in efforts to reduce transport emissions. The EU’s preferred route is
`an ‘integrated approach,’ involving manufacturers’ technological advances, as well as the role of the fuel
`sector, policy makers and drivers. Eco‐driving sits very comfortably in such a broad vision. Jack Short,
`Secretary‐General of the International Transport Forum (ITF) suggests, “it’s one of the things that is relatively
`cheap and can be done relatively easily, so it should be part of the package. There’s no silver bullet, and
`anything that brings 5‐10% reductions should be grasped.”
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`2.2 The eco‐driving landscape
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`Eco‐driving has become more visible in a wide variety of ways in recent years, from government‐led
`campaigns, to competitive events to demonstrate the potential of efficient driving, to eco‐driving courses to
`improve people’s driving style, and even the inclusion of eco‐driving techniques into learner driver syllabuses.
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`2.3 Eco‐driving as an approach to emissions reduction
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`Eco‐driving undoubtedly has considerable strengths as an approach to emissions reduction – as the activities
`already outlined demonstrate, it can provide considerable savings in emissions in a low cost way, and is
`increasingly recognised by governments and other institutions as an important component of an ‘integrated
`approach’ to reducing emissions from driving.
`But eco‐driving has its challenges, too. As a ‘behavioural approach’ it raises the question of how effectively the
`different ways of communicating or teaching eco‐driving can be said to truly change behaviour, to what
`extent, and for how long. Moreover, our understanding of its effectiveness
`– when applied in ‘real‐life’ circumstances, away from test centres and eco‐driving courses – is limited. There
`are several factors that may limit its effectiveness in reality, including the difficulty of changing driving
`behaviour in the long run, and the role of road conditions such as traffic, other drivers, and signals. There are
`also practical obstacles to its widespread implementation and effectiveness, including securing funding and
`legislative support, and creating the right mechanisms to encourage people to adopt eco‐driving techniques.
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`This section considers existing knowledge and questions over the effectiveness of eco‐driving, before outlining
`some of its broader strengths and weaknesses as an approach to reducing emission from driving.
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`2.3.1 Do we know how effective eco‐driving can be?
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`There is a good range of existing information about how eco‐driving can reduce fuel consumption and
`emissions. We know from many people’s experiences of have data on the short‐term effectiveness of learning
`eco‐driving techniques on the spot – e.g. through one‐day eco‐driving courses and events on dedicated tracks
`– that eco‐driving can be very effective in the short term, in these favourable conditions (e.g. a test track)
`removed from real‐life driving. We also have data on how eco‐driving can produce short‐term benefits even on
`real roads – such as the FIA EcoTour – when drivers are fully focused on trying to do so. Some drivers achieved
`results below the manufacturer‐stated mpg on their vehicles over this seven‐day event – the purpose of which
`was to drive as efficiently as possible throughout. However, Olivier Lenz concedes that "of course you can’t
`achieve those results in a real, everyday situation – you will never be 100% focused on it in this way.”
`Estimated data on ‘real‐life’ savings is also available – such as the Dutch Government‐sponsored 2006 study by
`Dutch research institute TNO which measures the effect of driving techniques on tailpipe emissions. To
`evaluate the impacts of eco‐driving, TNO created two reference cycles (urban and non‐urban) representative
`of moderate driving in average Dutch traffic conditions – much closer to realistic driving conditions than the
`standard legislation European testing cycle. The study found that applying eco‐driving tips correctly under
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`these average traffic conditions led to a significant decrease of the CO2 emissions and fuel consumption – on
`average 7% with petrol engines, and 8‐10% with diesel.
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`All of these experiences leave no doubt that eco‐driving reduces fuel consumption and emissions, and can do
`so by a substantial amount. However, what is lacking is an understanding of its effects on a wide range of
`people during their day to day driving. Eco‐driving training courses are based on an individual concentrating
`intensely on eco‐driving on a single day. We have no way of knowing if the techniques drivers can learn on a
`one‐day course will be maintained in their driving style after the event. It demonstrates