Author Archives: Annick Roetynck

About Annick Roetynck

Annick is the Manager of LEVA-EU, with decades of experience in two-wheeled and light electric mobility.

• LEVA-EU calls on Commission to speed up review LEV-legislation

  12/09/2022 12:51 Comments Off on LEVA-EU calls on Commission to speed up review LEV-legislation

  On 14 September 2022, the European Commission will hold a workshop on the technical requirements and road safety for so-called Personal Mobility Devices (PMD). The term PMD covers all electric cycles, including cargocycles and speed pedelecs, e-scooters, self-balancing vehicles, electric skateboards, etc. In a letter to the Commission, LEVA-EU has expressed serious concerns about the workshop and about LEV-legislation in general.

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  In the letter to the Commission, LEVA-EU explained that Regulation 168/2013 as well as the Machinery Directive are very severely hampering the market development of LEVs. The trade association is confronted with these legal bottlenecks on a daily basis, through questions and issues reported by its members. Furthermore, the inadequacy of the current technical framework for LEVs was confirmed by the TRL-study carried out for the Commission and presented in March 2021.

  In March 2021, TRL presented to the Commission, Member States and stakeholders, among which LEVA-EU, their “Study on market development and related road safety risks for L-category vehicles and new personal mobility devices“. In that study, TRL formulated a number of important findings and recommendations. Just to quote a few:

  • The current 250 W limit applied to EPACs is too low for the heavier pedal assisted cargo bikes that are now growing in popularity.
  • The L1e-A subcategory (electric cycles up to 25 km/h but more than 250W) has failed to attract manufacturers and consumers.
  • The business model of many PMD manufacturers is incompatible with the type-approval system.
  • On the question of traffic rules, there is support for the development of an EU harmonised approach.

  TRL concluded that technical regulation outside the Machinery Directive and Regulation 168/2013, tailored to the needs of the PMD industry was the best way forward . The system could include a variety of assessment methods, ranging from self-certification to independent testing. TRL concluded further: “In our view this new system for the regulation and approval of PMDs would provide the flexibility necessary to support innovation in this rapidly evolving sector, while maintaining technical standards and road safety.”

  In the letter to the Commission, LEVA-EU expressed its surprise and confusion about the content of the workshop. Even though the TRL study covered all so-called PMDs and also made recommendations for all of them, the workshop deals almost exclusively with e-scooters. Moreover, this workshop is not organised as a dialogue with the LEV-businesses on the many regulatory problems they are facing and how they might be solved. The workshop programme consists mainly of the presentation of national e-scooter legislation in 3 member states.

  LEVA-EU fails to understand why the programme is only focused on vehicles that are not covered by Regulation 168/2013, but by the Machinery Directive. The organisation also doesn’t understand what the purpose is of explaining national legislation that, in their opinion, is at least in breach of Article 6.1 of the Machinery Directive and possibly also of Directive 2015/1535.

  In a prompt reply, the Commission also stated surprise by LEVA-EU’s reaction to the workshop. The Commission explained that this workshop is focused on e-scooters “due to their recent substantial market size growth, increasing safety concerns and the diverging national measures regulating them across the EU.” However, the Commission reassured LEVA-EU that the workshop is only a first step and the discussions will not be limited to e-scooters: “The discussions will build on the findings of the TRL study on L-category vehicles and PMDs and are aimed as a preliminary step in the analysis of potential common rules on PMDs.” Furthermore, the Commission announced a dedicated impact assessment for 2023 that will include an extensive consultation of all actors of the PMD and L-category sectors.

  LEVA-EU will continue to urge the Commission to speed up the legislative review for the benefit of LEVs and to hear the voice of the LEV-sector. In the past few weeks, LEVA-EU has called on the whole LEV-sector to participate in the workshop to have their say on how EPACs, Electric Cargo Cycles, Speed Pedelecs, E-Scooters, Self-Balancing Vehicles, … need their own accurate legal framework without any futher delay. In the framework of the energy and cost of living crises, as well as the Green Deal, the Fit for 55 Package, the New Urban Mobility Framework, the European Climate Pact and many more EU policies, it can no longer be justified that LEVs are neglected for so long and to this extent. We need solutions NOW.

  Fur further details, please contact LEVA-EU Manager, Annick Roetynck, tel. +32 9 278 45 46, email annick@leva-eu.com.

• Stromer and LEVA-EU launch Speed Pedelec White Paper

  11:57 Comments Off on Stromer and LEVA-EU launch Speed Pedelec White Paper

  76% of all car trips and 50% of kilometers driven by cars can be replaced by micro-mobility[1], according to research carried out by DLR at the request of LEVA-EU. “As much as 37% of the trips could be done by speed-pedelecs (e-bikes up to 45 km/h),” Tomi Viiala, Co-CEO of myStromer, explains.

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  This example – and many more – should convince governments of the huge potential of light electric mobility and encourage them to improve focus on it and use it more frequently. “That’s why, together with LEVA-EU, we’ve invested in a Speed Pedelec White Paper to use as a basis for discussion with local authorities, as well as with European authorities,” says Tomi Viiala. The White Paper provides extensive information about the use of S-pedelecs with numerous concrete cases and figures.

  Examples of countries leading the way in sustainable solutions for commuter traffic are Belgium and Switzerland. Speed-pedelecs, are well integrated in both countries as an example of modern, sustainable traffic. Many commuters are already experiencing the benefits: with an S-pedelec, you can be sure of punctual departure and arrival times, along with a healthy(er) way of moving. Even more than that, S-pedelecs are also cost-saving, energy-efficient and, last but not least, more environmentally friendly than driving a car. The rules for using S-pedelecs in Belgium and Switzerland are therefore clear and offer riders a good alternative to cars. The White Paper is also intended to raise awareness of this issue among traffic planners and to convince fleet managers to offer pedelecs and S-pedelecs to their employees.

  Together with LEVA-EU, myStromer, the market leader in the S-pedelec segment, wants to convince and motivate other European countries to review and clarify their traffic regulations for S-pedelecs. This implies changes in policy and regulations. And there is still work to be done.

  Annick Roetynck, LEVA-EU Manager, adds: “LEVA-EU has commissioned research from DLR into the potential for LEVs to significantly reduce GHG emissions from the transport sector and thus to contribute to climate protection. The research shows that 37% of all car trips could theoretically be replaced with speed pedelecs and 19% of all car kilometres could be substituted by speed pedelec kilometres. Each trip for which an LEV replaces a car would avoid on average 88% of the GHG emissions from the substituted cars. These numbers clearly show that electrification of cars alone is not the solution. We also need to considerably reduce the weight of the vehicles we use for our transportation. The speed pedelec is therefore a very valuable, sustainable solution. Legal bottlenecks are very seriously hampering the technological and market development of speed pedelecs. The White Paper should convince the European, national and local authorities to prioritise those issues.”

  To receive a free copy of the Speed Pedelec White Paper, please fill in the form below. We will send you a copy in return.

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  [1] Micromobility includes all electric vehicles subject to Regulation 168/2013 as well as all vehicles excluded from this Regulation. That variety of vehicles ranges from e-scooters to electric mini-cars.

• Sweden bans e-scooters from pavements

  01/09/2022 12:41 Comments Off on Sweden bans e-scooters from pavements

  The Swedish government has decided on a driving ban on footpaths for electric scooters. The ban applies as of today, September 1. Also today a parking ban for electric scooters on foothpaths and cycle paths comes into force.

  With the change, the same rules that apply to traditional bicycles and electric bicycles now also apply to electric scooters and other self-balancing vehicles without pedals. Riders who don’t comply with the ban may be fined.

  “Now we get our streets in order as well. Speeding electric scooters on footpaths has been a big problem in many cities. Now that’s over. Together with the parking ban, this proposal will improve accessibility and safety for everyone who walks on our footpaths,” says Swedish infrastructure minister Tomas Eneroth.

• 2nd edition WOE to include International Cargo Bike Festival

  26/08/2022 16:16 Comments Off on 2nd edition WOE to include International Cargo Bike Festival

  On October 27, 2022, the doors will open of the 2nd edition of World of eMobility (WOE). The event that takes place in EXPO Haarlemmermeer, on the outskirts of Amsterdam, will include the International Cargo Bike Festival (ICBF).
  
  After a successful launch in November 2021, the WOE team is busy preparing for the event and to welcome diverse brands from different industries. In addition to the offer of electric cars, vans, charging station providers, motorcycles, scooters, light electric vehicles, and other providers of eMobility products, a large part of the total offer and lecture program will be about the eBikes and (e)Cargo Bikes.
  Light electric vehicles are the perfect replacement for heavier vehicles. They encouter fewer obstacles to get somewhere. Locations in the city center are much easier to reach. The use of an e(cargo)cycle is healthier, cheaper, quieter, and cleaner.

  ICBF conference
  To be able to answer the many questions and to be able to discuss possible solutions regarding the use of eBikes, Cargo Bikes and Light Electric Vehicles, Jos Sluijsmans, World of eMobility ambassador and founder of the ICBF, is organizing the annual ICBF Conference on Thursday 27 October in the framework of WOE. Throughout the day, various international speakers will give lectures in the Auditorium on a variety of topics. Each lecture or seminar can be attended by about 300 people. Among the confirmed speakers are: Lucas Harms (Dutch Cycling Embassy), Sam Starr (Coop Carbone), Darnel Harris (Our Greenway), Franklin Jones (B-line PDX), Karin van den Berg (LastMile eMobility) Philippe Lovens (Urbike), Ze Lobo (Transport Ativo), Natalia Tomiyama (Nüwiel) and Aigars Lauzis (Be-Triton). Giacomo Rossi and Robert Camm of Frost&Sullivan will each give 2 lectures on Thursday and Friday. Their company produces LEV market analyses and reports. The Climate Group, a non-profit organisation that works with businesses and government leaders around the world to tackle climate change, will also give seminars.

  Confirmed LEV-participants at WOE sofar are :
  | ALLIGT | ALUTECH | ANANDA | BABBOE | BAFANG | BESV | BEONE | BETA | BE-TRITON | BIMAS | BOHLT | BOUGH BIKES | | CARGOROO| CARGO CYCLING | CARLA CARGO | CITKAR | COH & CO | CUBE | DUTCH CYCLING EMBASSY | | DUTCH WORLD BIKES | EASY NOZ | EQ VOLT | FATDADDY | FERNHAY | FIETSREPARATIE.NU | FLEVOBIKE | FLYER | GEFKEN CASES | GLEAM BIKES | GO CAB | HIVE BOX |
  | IMOTO | KETTLER-ALU-RAD | KNAAP | LIL’BUDDY | LOVENS | MATE | MAVENOID | MYVELO | MECHANE | MUON | ONE WHEEL | NIJLAND CYCLING | NUWIEL | PASHLEY CYCLES | RAAF BIKES | | REDLER TECHNOLOGIES | ROBERT BIKES | ROOKS BICYCLES | RUFF CYCLES | STREET STUFF | STROMER | SWOBBEE | TEN07 CYCLES | | THE RUFFIAN | URBAN DRIVESTYLE | WOBS | ZOEM BIKE | 4 WIELER |

  
  

• First NieuwsFiets.nu B2B Festival in February 2023

  15:39 Comments Off on First NieuwsFiets.nu B2B Festival in February 2023

  On Sunday 12 and Monday 13 February 2023, NieuwsFiets Media & Events is organising the NieuwsFiets.nu B2B FESTIVAL for the first time in the Brabanthallen in Den Bosch (NL). The event takes place just before the start of the 2023 (e)cycling season and also offers an opportunity to look ahead to 2024. In other words, perfect timing for networking between suppliers and retailers in the Netherlands and Belgium.

  “To govern is to look ahead,” is a well-known Dutch saying. This certainly applies now, since anyone who waits will be at risk of falling behind. That is why a networking opportunity between suppliers and retailers in spring is incredibly relevant. Acting upon signals from the market, Nieuwsfiets has taken the initiative to organise the NieuwsFiets.nu B2B FESTIVAL, with the aim of combining business and pleasure in an accessible way and in a relaxed festival atmosphere.

  For two days, the (e)bicycle business will come together in Den Bosch (NL) to discover interesting novelties, new services, great brands and the educational NieuwsFiets.nu B2B PRACTICE DAY. This event offers an exciting programme of instructive workshops and interesting presentations for the (e)bike business.

  Suppliers will be given every opportunity to present themselves to the Dutch and Belgian retailers, who in turn will be given a particularly warm welcome. Trade visitors will be treated to free entrance, free parking as well as free food and drinks. On Sunday, the event will conclude with a Double Happy Hour, an informal drink with bites and musical entertainment.

  Nieuwsfiets has deliberately chosen for a 2-day format, as Tuesday proves to be a quiet day for many events anyway. The event doors are open on Sunday from 12:00 to 19:30 and on Monday from 10:00 to 17:00.

  For this event, Nieuwsfiets offers a full-service stand concept. This means that your stand will be completely assembled, furnished, lit and disassembled. You can choose from three different sizes of full-service stands, 12, 18 or 30m², at a very affordable price. The stands are provided with a personalized full-colour back wall, which gives the stand a beautiful appearance with the look & feel of your own brand or company. The design of your background image will be printed on a sturdy and beautiful canvas, which you can use for other events or in your showroom.

  All further details in English on participating as an exhibitor are here: https://bit.ly/3cozbEY.
  Further details in Dutch are here: https://nieuwsfiets.nu/b2b-festival/exposanten-info/

• Commission Workshop on LEV-Legislation: registration to close on 8 September

  11:16 Comments Off on Commission Workshop on LEV-Legislation: registration to close on 8 September

  On 14 September 2022, the European Commission will hold a workshop on the technical requirements on road safety for so-called Personal Mobility Devices (PMD). The term PMD covers all electric cycles, including cargocycles and speed pedelecs, e-scooters, self-balancing vehicles, electric skateboards, etc. LEVA-EU calls on the whole LEV-sector to participate in the workshop and have a say about current and future LEV-legislation.

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  This workshop is a one-off opportunity to make it clear to the European Commission that the current legislation is not adapted to light electric vehicles (LEVs) and therefore hinders their market development and uptake. LEVA-EU therefore warmly appeals to all companies, manufacturers, importers, distributors, as well as user groups involved, to seize this opportunity to testify that PMDs are currently severely hampered by a lack of proper legislation and to demand harmonised and accurate European legislation for these vehicles. The workshop will take place both physically in Brussels and online. Registration closes on 8 September, 12:00 CEST: https://bit.ly/3APEupl.

  In March 2021, TRL presented to the Commission, Member States and stakeholders, among which LEVA-EU, their “Study on market development and related road safety risks for L-category vehicles and new personal mobility devices“. In that study, TRL formulated a number of important findings and recommendations. Just to quote a few:
  

  • The current 250 W limit applied to EPACs is too low for the heavier pedal assisted cargo bikes that are now growing in popularity.
  • The L1e-A subcategory (electric cycles up to 25 km/h but more than 250W) has failed to attract manufacturers and consumers.
  • The business model of many PMD manufacturers is incompatible with the type-approval system.
  • On the question of traffic rules, there is support for the development of an EU harmonised approach.

  TRL concluded that technical regulation outside the Machinery Directive and Regulation 168/2013, tailored to the needs of the PMD industry was the best way forward . The system could include a variety of assessment methods, ranging from self-certification to independent testing. TRL concluded further: “In our view this new system for the regulation and approval of PMDs would provide the flexibility necessary to support innovation in this rapidly evolving sector, while maintaining technical standards and road safety.”

  Following this study, LEVA-EU submitted to the Commission a very extensive Position Paper on how EU rules and regulations for Personal Mobility Devices (PMDs) could be easily formulated into a simple but accurate legal framework, specifically for PMDs. The Commission responded: “We will carefully review and provide a detailed reply to your position paper.” That detailed reply never came. When we contacted the Commission to enquire after their response, we were told that at that time car emission issues had priority. On that occasion it was announced that there would be a workshop in the second half of 2022.

  LEVA-EU is, to say the least, very surprised by the content of that workshop. The TRL study explicitly covered All PMDs and also clearly stated that the legislation for ALL PMDs needs to be revised. The September workshop, however, seems to focus one-sidedly on e-scooters. There is no mention in the programme of any planning for a review of the legislation. The Netherlands, France and Germany are each allowed to explain their national rules for e-scooters which, in our opinion, are in direct conflict with European legislation. And before the Commission enters into discussion with the participants, only one e-scooter manufacturer is allowed to comment on technical aspects and regulatory compliance. You read it correctly: ONE.

  In the framework of the energy crisis as well as the Green Deal, the Fit for 55 Package, the New Urban Mobility Framework, the European Climate Pact and many more EU policies, it can no longer be justified that LEVs are neglected to this extent. We need solutions NOW.

  LEVA-EU therefore calls upon all LEV-stakeholders to attend the Commission’s Workshop of 14 September 2022, either live in Brussels or online. Do not miss this unique opportunity to have your say on how your EPAC, Electric Cargo Cycle, Speed Pedelec, E-Scooter, Self-Balancing Vehicle Business needs its own accurate legal framework without any futher delay. Register before 8 September, 12 CET, here: https://ec.europa.eu/eusurvey/runner/63d8a542-d4b1-17e4-4159-fad262171bff

  Fur further details, please contact LEVA-EU Manager, Annick Roetynck, tel. +32 9 278 45 46, email annick@leva-eu.com.

• EU Standardization News

  22/08/2022 13:54 Comments Off on EU Standardization News

  HAS assessment contract re-established
   The European Commission has signed a new contract with Ernst & Young for the HAS (Harmonised Standards) assessment process. Ernst & Young was the previous contractor until the beginning of 2022. This means that the HAS consultants system will be restored shortly and Technical Committees will therefore be able to request assessments of harmonised standards. CEN and CENELEC have stated they will request HAS assessments in the following order:

  • Documents received for Formal Vote;
  • Documents received for Enquiry and or which Enquiry has started;
  • On ad-hoc basis: all other documents (e.g first working drafts, documents not assessed previously and before publication).

  Webinar on how to draft machinery harmonised standards
   On 6 October, from 14.00 till 16.30, CEN and CENELEC will organise a webinar with practical information on how to prepare harmonised standards under the Machinery Directive. The workshop will provide advice on how to write the informative annex (Annex Z) with information on the relation between the essential requirements of the Machinery Directive and the clauses of the standard providing presumption of conformity with those requirements (once the reference of the standard reference is published in the Official Journal).
  Registration is mandatory and is available here: https://cencenelec.zoom.us/webinar/register/WN_C22eFvsoRmC99VhY_xmUNA

• Thor AVAS conducts comprehensive electric vehicle traffic safety study on ‘acoustic visibility’

  29/07/2022 16:01 Comments Off on Thor AVAS conducts comprehensive electric vehicle traffic safety study on ‘acoustic visibility’

  The problems of acoustic ecology in the human environment are studied by many researchers around the world, especially the contributions to city noise made by cars. In recent years, more and more electric vehicles that are much quieter have appeared on city streets. Cars and motorcycles are traditionally powered by the rather noisy operation of an internal combustion engine. Electric transport, on the other hand, runs on electric motors powered by noiseless energy sources (batteries, fuel cells, capacitors, etc.). As a result, the electric car creates noise only due to the contact of the tires with the asphalt and due to the turbulent air currents on the car body. All this makes the movement of electric vehicles less noisy and, at low speeds, almost silent. Therefore, electric vehicles are classified by UN Regulation No. 138 as silent vehicles. With the undoubted benefit of this circumstance for the acoustic ecology of the city, there is also a quiet threat to humans – a pedestrian may simply not hear the approach of an electric car. It is for this reason that the legislation of many countries of the world obliges electric vehicles to be equipped with special sound devices – AVAS systems that increase the acoustic visibility of electric vehicles.

  Contribute to the latest Thor AVAS survey on pedestrian safety, here.

  

  In recent years, a wide variety of micromobile vehicles have also begun to appear on the roads in large volumes. And, more importantly, on the sidewalks of cities – scooters, gyro scooters, unicycles, segways and everything that, despite its harmless appearance, can sneak up unnoticed (at a speed of up to 30 km/h) to an unsuspecting pedestrian. While the issue of ensuring the safe movement of microtransport vehicles causes great discussion, no country in the world has resolved this in law.

  Thor AVAS, together with the Research Institute of Building Physics, is conducting a large scientific study of the safety of electric transport. Their work studies how different vehicles are acoustically visible (heard) to a pedestrian and how it is possible to increase their visibility without causing ecological damage to the acoustic environment.

  

  In-laboratory work takes place in a unique acoustic measuring complex – a large acoustic anechoic chamber. This is a room in which there is absolutely no echo due to the walls and ceiling being covered in a layer of a special sound-absorbing structure more than 1 meter thick.

  The room used by Thor AVAS is the largest anechoic chamber in Europe and one of the largest chambers in the world – the floor area exceeds 120 square meters. It is also very quiet in this chamber – so quiet that it is a unique auditory experience, with the background noise level in the chamber only reaching 18 dBA.

  During testing, many loudspeakers are placed in a circle around the cell. Together they make up the radiating part of the laboratory setup. Six speakers imitate the noise of the environment, reproducing, for example, the sounds of a city courtyard or a city park, in 5.1 stereo, comparable to a movie theater. Another three-way speaker system simulates the noise of an approaching electric vehicle’s tires.

  

  The approach of a car is simulated at a speed range between 10 and 50 km/h. Imitation occurs by increasing tire volume according to auditory laws. When the distance between the car and the pedestrian decreases, the sound pressure level increases by 6 dB.

  Finally, consider the last loudspeaker is the AVAS system, the principle which is the subject of the study. By playing different sounds through the AVAS system, traffic safety conditions can be significantly improved.

  The essence of the experiment is to determine how long it takes a pedestrian to hear a car approaching them. Participants of the experiment are given registration panels and the experiment begins. At first, participants in the experiment hear only the sounds of the environment, the park or the yard, because the simulated car is still “far away”. At the moment when participants hear the approaching car, they press the registration button on their remotes. By this pressing, it can be determine how long it took for the pedestrian to register the approaching car, i.e. how much time the pedestrian has to react to the approach and decide on further actions. For example, an electric car without an AVAS system is heard when impact time is between 3-5 seconds, depending on the vehicle’s speed. In such a short time, the pedestrian will not have time to react to the approach of the vehicle and a collision may occur.

  When driving an electric vehicle with the AVAS system turned on, it is possible to significantly increase the time for acoustic detection of an approaching car by a pedestrian. The most effective method is to turn the system up to high volume. Very loud and unpleasant sounds can be played through the AVAS system (or alternatively, turn on loud music) and the residents of the next few blocks will know in advance about the approach of the car, which, of course, will have nothing to do with traffic safety. The correct sound of AVAS should ensure the safe movement of an electric vehicle and sound at such a volume that it will not exceed the established rules and sanitary standards for a residential area. However, sounds of the same loudness can have varying visibility. By changing the timbre of the sound, its frequency range, and introducing volume modulations and discrete components at certain frequencies, it is possible to significantly increase a vehicle’s visibility without increasing the volume.

  The Thor AVAS study aims to find the best ways to control the visibility of an electric vehicle using the AVAS system. The goal is to create such sounds for the AVAS system which, on the one hand, will not be unpleasant, excessively loud, and attract unnecessary attention, and, on the other hand, provide optimal and speed-independent visibility.

  Anechoic chamber tests of THOR AVAS – YouTube

• EU Commission confirmation on Series Hybrid published

  25/07/2022 14:48 Comments Off on EU Commission confirmation on Series Hybrid published

  The European Commission’s statement on the EPAC-status of electric cycles equipped with a Series Hybrid (SH) system has now been officially published in the minutes of the12th Meeting of the Forum for the Exchange of Information on Enforcement

  The wording of the Commission’s statement is as follows:

  “The exemption under Article 2.2(h) of Regulation (EU) 168/2013 applies to pedal cycles with pedal assistance, equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, for which the motor cuts off when the cyclist stops pedalling and otherwise progressively reduces and finally cuts off before it reaches 25 km/h. The auxiliary function of the motor is to be interpreted that the vehicle should not be propelled only by the motor. In addition, the motor should provide assistance only as long as the cyclist pedals continuously.

  The type-approval legislation is technology neutral. Therefore, the fact whether the vehicle has a chain or not, is irrelevant for determining if the vehicle concerned falls under the exemption in Article 2.2(h) of Regulation (EU) 168/2013.”

  Consequently, any electric cycle equipped with a SH system of which the motor cuts off at 25 km/h and with a maximum continuous rated power of 250W is excluded from Regulation 168/2013 under Article 2.2(h) and must be granted the same legal status as any other Electrically Pedal Assisted Cycle (EPAC). Electric cycles equipped with a SH system must comply with the Machinery, EMC and RoHS Directives.

  The minutes of the meeting including the Commission statement are here: https://www.dropbox.com/s/hbbbf1e0f3gpz6b/Minutes%20for%20ExpReg%20-%20Clean%20updated%20version.pdf?dl=0

  The history of this case is here: https://leva-eu.com/eu-commission-finally-confirms-series-hybrid-cycles-are-epacs-excluded-from-l-category/