cocoo v ban on int.comb.engines

To vigorously defend the internal combustion engine (ICE) industry against bans, I would construct a multi-pronged legal, economic, and environmental defense based on the following core strategies. As the world’s best competition lawyer, I would target legal loopholes, economic impacts, technological rebuttals, and procedural fairness. Here’s the detailed approach:

1. Legal Defense: Challenging the Ban’s Foundation

A robust legal defense begins by questioning the legitimacy and legal basis of the ban under existing frameworks:

  • Jurisdictional Overreach: I would argue that the ban violates legal principles by overstepping governmental authority. For instance:
    • National or regional governments often rely on regulatory bodies. If the ban circumvents proper legislative approval or lacks robust public consultation, it can be nullified.
    • I would challenge whether environmental agencies have the constitutional authority to impose outright bans.
  • Infringement on Trade Rights: Banning ICE vehicles infringes upon free market principles and existing trade agreements (like WTO regulations) by discriminating against ICE manufacturers.
  • Procedural Fairness: If sufficient time has not been granted for industries to adapt, I would challenge the ban based on due process.
  • Lack of Technological Neutrality: Courts have historically favored technological neutrality, allowing consumers to decide what tech prevails. I would argue that the ban gives unfair advantage to electric vehicles (EVs) and discriminates against ICE advancements.

2. Economic Impact Defense: Jobs, Trade, and Industry Collapse

The ban’s repercussions on the economy would form a compelling argument:

  • Job Losses: ICE production supports millions of direct and indirect jobs globally, from manufacturing to supply chains. I would commission an economic study showing that:
    • A rapid ban risks widespread job displacement, worsening socioeconomic inequalities.
    • Regions reliant on ICE industries (e.g., rural or developing areas) would be hardest hit, exacerbating poverty.
  • Impact on SMEs and Suppliers: ICE supply chains involve thousands of small and medium enterprises (SMEs). Disruption could trigger mass bankruptcies.
  • Consumer Choice and Costs: I would highlight:
    • The higher upfront cost of EVs limits options for lower-income consumers.
    • Limited charging infrastructure in rural and developing regions makes ICE vehicles essential.
  • Global Trade: Nations heavily reliant on exporting ICE-related technologies would face severe trade deficits. I would show how the ban risks destabilizing trade agreements, causing retaliation from trading partners.

3. Technological Defense: Position ICE as a Sustainable Option

Rather than framing ICE as obsolete, I would spotlight ongoing advancements in ICE technology:

  • Cleaner Combustion Engines: Modern ICE vehicles incorporate low-emission and hybrid technologies:
    • Recent innovations in synthetic fuels, biofuels, and hydrogen combustion make ICE vehicles nearly carbon-neutral.
    • I would argue that banning ICE stifles innovation in these green technologies.
  • Battery Production Concerns: EV manufacturing relies on rare earth metals like cobalt and lithium, which cause:
    • Environmental damage (unsustainable mining practices).
    • Ethical issues, such as child labor in resource-rich countries.
  • Infrastructure Disparities: In regions without EV infrastructure (e.g., charging stations), ICE remains the only viable option. I would position ICE as complementary, not contradictory, to EVs.

4. Environmental Counterarguments: Lifecycle Emissions and Alternatives

I would debunk the myth that EVs are universally superior by presenting:

  • Lifecycle Analysis: The full lifecycle emissions of EVs (including battery production, resource extraction, and disposal) can be greater than advanced ICE vehicles.
  • Grid Dependency: EVs rely on power grids, which in many countries still use fossil fuels. I would argue:
    • Shifting to EVs does not inherently reduce emissions without a green grid.
  • Synthetic Fuels: I would propose investments in carbon-neutral synthetic fuels and green hydrogen as viable pathways for existing ICE infrastructure to align with environmental goals.

5. Competition and Innovation: Protecting Free Market Principles

Finally, I would defend ICE industries based on fair competition:

  • Antitrust and Monopolization: I would argue that the ban gives EV manufacturers an unfair market advantage, potentially violating competition laws.
  • Consumer Freedom: Letting markets decide promotes innovation and competition. Government bans can stifle advancements in cleaner ICE alternatives.
  • Technology Coexistence: The ICE and EV markets can coexist, particularly in heavy industries (e.g., trucks, ships, and aviation) where ICE remains essential.

Legal Remedies and Next Steps

  1. File Injunctions: Immediately halt the ban’s enforcement pending further review.
  2. Class Action Lawsuits: Represent affected workers, industries, and suppliers in legal action against unfair economic harm.
  3. Economic and Environmental Impact Reports: Commission expert studies to demonstrate flaws in the ban.
  4. Lobbying: Engage policymakers to revise bans into phased transitions rather than outright prohibitions.
  5. Global Coordination: Align with countries opposing ICE bans to form a united front under trade agreements.

Closing Argument

The ICE industry is not the enemy of sustainability; it is evolving to meet climate goals. Governments must embrace technological neutrality, allowing a fair, competitive market that balances environmental goals with economic stability and innovation. The proposed ban is arbitrary, economically harmful, and legally flawed—thus unsustainable


COCOO:  Eco-friendly internal combustion engines IS A NEW INNOVATION to reduce harmful emissions. This includes both traditional gasoline and diesel engines, soft hybrids and those using only alternative fuel source >> there is no reason for a ban on internal combustion engines.   Besides, electric engines cause risks of electrocution in cases of natural disasters like floods, which are ever more frequent.

COCOO TO join forces with EPP.group, to COMPLAIN AND TO request a revision of the ban on internal combustion engines and a technology-neutral approach to encourage innovation. They also propose temporary relief measures to help carmakers avoid being penalised. The EPP Group wants to tackle the growing crisis in the European car industry by revising the planned ban on combustion engines set for 2035. “We need a revision of the ban on internal combustion engines. We must ensure that driving remains affordable for everyone, not just those who can afford expensive electric cars. We should be driven by economic realism and remain technologically neutral. If we do not, driving will become too expensive for many Europeans, and we will lose countless jobs in the automotive industry to competitors like China,” said Jens Gieseke MEP, the EPP Group’s lead negotiator on the rules to reduce CO2 emissions from new cars and vans.  protecting European jobs and maintaining competitiveness is at the heart of the solution. “The possible closure of plants, such as the Volkswagen factories in Germany and the Audi Brussels factory, is a real threat to thousands of jobs. The ban on internal combustion engines must be urgently revised to protect workers and defend their future job prospects during the green transition. The European Commission must follow up its ‘Green Deal’ with an ‘Industrial Deal’. The EU must defend itself and its interests


 

Modern internal combustion engines continue to evolve, with manufacturers introducing new technologies. One example is Mazda, which has developed a new six-cylinder gasoline unit and a large diesel engine in a soft hybrid system that meet stringent emission standards. Meanwhile, Porsche has offered a new six-cylinder boxer engine, which is expected to be introduced even before the company finally limits itself to electric drives only. Among the technologies using modern automotive fuels, the hydrogen engine seems especially interesting as a potential attractive alternative to both diesel and gasoline-powered cars. Manufacturers such as Toyota, China’s GAC, Yamaha and Renault are currently working on a combustion hydrogen engine.

Why can the development of modern internal combustion engines be beneficial?

EPP parts to protect the car’s batteries. 

The development of green internal combustion engines is beneficial because it allows for a gradual transition to more environmentally friendly solutions without having to change the entire infrastructure. Currently, the biggest challenge for electromobility is the limited battery capacity and high price of electric cars. Although battery technology is constantly evolving, electric vehicles can still travel fewer miles and have longer charging times compared to traditional internal combustion or hydrogen cars. Various types of electric cars, such as extended-range hybrids, are a possible answer, but a full transition to electromobility requires extensive infrastructure, such as a sufficiently dense network of charging points and specialized service workshops. In addition, disposal of used batteries is still an unsolved problem. Due to their complex structure and rare earth content, they not only cause resource depletion, but remain also difficult to recycle. All this is causing a search for other types of fuels that are easy to obtain, process and will not cause harmful emissions to the environment. Hydrogen cell electric cars are also a problematic issue. They are expensive to produce and have a low efficiency of only 30-35%. For this reason, modern internal combustion engines that could run on environmentally friendly fuels seem to be a good off-the-shelf solution.

TYPES OF GREEN INTERNAL COMBUSTION ENGINES – WHAT MODERN LOW-EMISSION FUELS ARE USED?

Modern low-emission fuels, such as biofuels and synthetic blends, allow significant reductions in harmful emissions. Hydrogen and ammonia engines offer almost zero emissions, so they could enter clean transportation zones, for example. Other solutions rely on advanced technologies to increase efficiency and reduce emissions, making them increasingly competitive with electric vehicles.

Hydrogen engines

Internal combustion engines using modern hydrogen fuels do not emit CO2, which is beneficial in terms of climate change. The products of combustion, in this case, are water vapor and small amounts of nitrogen oxides (NOx), which are admittedly harmful to the environment, but the use of appropriate filters offsets this problem. Low energy efficiency remains an issue, however. Hydrogen has a much lower energy density than fossil fuels (about 2-3 kWh/l compared to 11 kWh/l for diesel). This means that an internal combustion engine must burn much more hydrogen than fossil fuels, leading to low range or the need for larger fuel tanks. In a reciprocating engine, only about 30% of the fuel energy is used for propulsion. The rest is converted to heat and is removed from the system in that form. Manufacturers are working on more efficient use of hydrogen and modern hydrogen fuels. For example, in 2021, the Chinese brand GAC Motor has developed an engine that is expected to be more than 44% efficient, and has announced the development of a corresponding infrastructure.

Ammonia engines

The ammonia engine is an innovative solution that has the potential to revolutionize the automotive industry in the future. During combustion, ammonia (NH₃) does not emit carbon dioxide, but nevertheless leaves a subtle carbon footprint due to its low nitrogen oxide emissions. Instead, it is readily available and can be produced in large quantities. Unlike hydrogen, it can be stored in liquid form, making logistics much easier. Toyota and Guangzhou Automobile Group (GAC) have jointly developed a prototype ammonia engine that uses specially designed components. Precision injectors control the amount of ammonia delivered to the combustion chamber, while advanced systems reduce nitrogen oxide (NOx) emissions. It is worth mentioning, however, that ammonia itself is a toxic substance, which raises great doubts among potential users. Therefore, the use of this type of engine is at this point considered rather in the context of industrial solutions – for example, to power trucks, which today are a serious source of emissions.

Biofuels and synthetic blends

Another solution to reduce the carbon footprint of traditional internal combustion vehicles are biofuels produced from renewable resources such as plants, organic waste or algae. This makes them a greener alternative to gasoline and diesel. They are divided into biocomponents (components of liquid motor fuels) and biogas (such as biomethane). Biofuels are already successfully used in internal combustion engines, and their production and combustion have a lower environmental impact than fossil fuels. Another category is synthetic fuels, i.e. hydrocarbons or their mixtures obtained from biomass or other renewable sources. Among these are GTL (Gas to Liquid), BTL (Biomass to Liquid), SynGas, produced by forest biomass gasification processes, or SynDiesel. These are chemically produced fuels and also generate lower emissions than traditional fossil fuels.

THE FUTURE OF INTERNAL COMBUSTION ENGINES

Trunk toolbox made of EPP.

Internal combustion engines have gone through a fascinating evolutionary path, from simple designs to advanced technologies. Their impact on the development of civilization is undeniable. Despite the growing popularity of electric vehicles, some forecasts indicate that cars with gasoline or diesel engines will still be a popular choice for the next 10 years. Bosch, for example, predicts that two out of three registered cars in 2030 will run on gasoline or diesel. The ever-increasing downsizing, ever more accurate particulate filters, new materials and attempts to optimize existing series so that they can meet the strict EU requirements show that there is still plenty of room for innovation in this field – both within the engine design and the body of combustion cars. One of these is ultralight plastics, such as foamed polypropylene (EPP), for example. They make it possible to produce much lighter body parts compared to traditional hard plastic components. By lowering the vehicle’s own weight, combustion can be reduced and targets required by stringent Euro standards can be achieved more easily. Many companies, including BMW, for example, have not yet set a date for phasing out the production of combustion units. This is further evidence that the technology may still have much to offer.

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