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Updated Environmental Statement 2019EvoBus GmbHMannheim plant
2 UpdatEd EnvironMEntal StatEMEnt 2019
inhalt3 preface4 the EvoBus plant in Mannheim6 Energy and environmental program 12 Figures, data, facts26 validation
Imprint
Responsible environmental protection officer: randolf troche BUS/opt-UWS
Responsible editor:Stephan Schmitt BUS/opt-UWSEnvironmental protection departmentphone: +49 621 740-2127telefax: +49 711 17-790 [email protected]
Head of Production Daimler Buses:dr. Marcus nicolai
Layout and implementation:daimler aG, CBS/M
imprint allowed with exact source.
UpdatEd EnvironMEntal StatEMEnt 2019 3
preface
Dr. Marcus NicolaiHead of production daimler Buses
Randolf TrocheHead of environmental protectionMannheim plant
the Mannheim location stands for the development and production of city buses and thus makes a significant contribution to environmentally friendly urban mobility concepts. apart from the classic diesel-fueled Citaro, these also include gas-fueled buses, hybrid vehicles and, as of this year, our eCitaro as a fully battery-electric vehicle, which is thus free of local emissions. on the production side, we are currently implementing our production vision, based on which we will build city buses in Mannheim efficiently and in alignment with the basic idea of industry 4.0.
Since the start of 2019, environmental protection has been assigned to technical service at the Mannheim and neu-Ulm locations.
the environmental management system has a long tradition at the location though. Since 1997, annual external validation has been taking place – especially of the Environmental Statement in accordance with the European directive EMaS. in the EMaS register, EvoBus Mannheim can be found with the registration number dE-153-00022. the registration certificate is updated by the Chamber of industry and Commerce every three years. this took place most recently in 2018. this is done by submitting the Environmental Statement, including the topics of environmental policy and environmental impacts. the Environmental Statement is updated in the intervening years but only for updated topics. the certification of the international environmental management standard iSo 14001 has been integrated into the matrix certification of our production locations since 2015.
Mannheim, May 2019
4 UpdatEd EnvironMEntal StatEMEnt 2019
the EvoBus plant in Mannheim
UpdatEd EnvironMEntal StatEMEnt 2019 5
tradition meets modernityapart from city bus construction, bodies-in-white for touring coaches and inter-city buses are also manufactured at the EvoBus GmbH location in Mannheim. the portfolio of the Citaro city bus family covers a large product range of non-articulated and articulated buses that are fueled by diesel, gas and electricity. the first battery-electric buses were handed over to customers at the end of 2018.
the entire plant floor space comprises 305,656 m2, of which 130,100 m2 is sealed as development space and 128.603 m2 is sealed as a traffic area. on the location premises, 16,591 m2 is left in a semi-natural state. outside the location, no semi-natural spaces are managed by EvoBus. the display of the core indicator “land consumption in relation to biological diversity” is depicted on page 21; this is limited to sealed spaces from development and asphalting.
at the end of 2018, 3,436 employees were employed. this number includes interns, diploma students and trainees.
Compliance with legal provisions, official requirements and other mandatory requirements is a matter of course for our company. For this purpose, the required information and resources for reviewing and achieving the requirements are ensured.
Plan of the EvoBus plant in Mannheim in 2018
OALGFPlaanungVertiebWD VBE
VerwaltungBR
Montage EMRPKW - Tausch
Logistik EMRPKW - Tausch
WSLKW-
Leitstelle
WSLKW-
Wareneingang
EMR
Logi
stik
Lack
- Fin
ishAu
slief
erch
eck
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trieb
nahm
eGL
Z ko
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EG. F
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mon
tage
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eile
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KTL / OLA / KTZ
BemiWerkstatt
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Wzg -Lager ET - Fertigung
KlappenfertigungStadtbus
PrototypVorrichtung
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Logistik / SLT
Rohm
ontag
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Lager
Versuch
Musterbau
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ONC
6 UpdatEd EnvironMEntal StatEMEnt 2019
Energy and environmental program
UpdatEd EnvironMEntal StatEMEnt 2019 7
in our energy and environmental program for the Mannheim plant, the most important targets of the individual units are taken from their energy and environmental program and summarized. on this page, the location’s environmental program for 2019 is presented with the completion Status.
on the following pages, you can find the current energy and environmental program, including selected targets of our plant, with the respective responsibilities and the target completion date.
Goals for 2018 Measure Assessment criterion Planned date
Completion status*
Process optimization
reduction of environ-mental impact
Contribution to daimler target 70 % of the supplier revenue (purchased parts) is covered by certificates for environmental management
Evaluation criterion of at least 70 % has been met
04/19 done, ongoing issue
reduction of hazardous material use and emissions
Conversion relocation of the raised floor Floor coating to neu-Ulm
implemented 06/18 done
Energy saving
reduction of energy consumption
implementation of the “Switching off machines outside working hours” project
the machines that may be switched off have been defined and labeled
06/18 postponed until decem-ber 2020
reduction of energy consumption
replacement of the Cdp dryer’s thermal afterburning
planning, notification/approval, and installation of the Cdp dryer’s new thermal afterburning. Energy conservation
02/18 done
reduction of energy consumption
renewal of the ultrafiltration in Cdp proof of energy conservation 06/18 done
Efficient processes
reduction of energy consumption and chemicals
the tube washing unit was replaced with a tube cleaning unit. the cleaning is done by means of a foam plug that is shot through the tube with compressed air
the tube washing unit is no longer in service
10/18 done
Using substitutes for hazardous materials
Conversion of the floor coating to black for the Citaro
Converted 01/18 done
Using substitutes for hazardous materials
Substitution of black (zinc-free) for Cdp paint Substitution started after authori-zation by the regierungspräsidium (regional administrative council)
06/18 done
reduction of noise development
Expansion of natural gas filling station reduction of compressor run times per vehicle
06/18 done
reduction of environmental impact
Changing the assembly process in order to reduce reworking due to damage
Changed assembly sequence for glazing and painted external parts
12/19 taken over in 2019
avoidance of packaging materials
incorporation of Mercedes-Benz turkey in production network with standard load carriers
Use of standard load carriers and gradual elimination of one-way wood and cardboard packaging
06/19 taken over in 2019
Energy and environmental goals for 2018
* Status: april 15, 2019
8 UpdatEd EnvironMEntal StatEMEnt 2019
Energy and environmental goals for 2019
Goals for 2019 Measure Assessment criterion Planned date
Primary res-ponsibility
Process optimization
reduction of Co₂ emissions
derivation from green production for the location: reduction of absolute Co₂ emissions in Europe
By 40 % by 2030 (base year 1992–94)
12/30 BUS / oM
reduction of environ-mental impact
Contribution to daimler target of having 70 % of supplier revenue (purchased parts) be covered by certificates for environmental management
annual pursuit of measures 04/19 tp / G52
reduction of environ-mental impact
reduction of wax application of the materials cur-rently used in B32 as a consequence of the use of black floor coating
Specification created in accordance with the floor coating changeover and implementation coordinated with the unit. reduction of the kg/vehicle is to be taken from the guideline values
07/19 CQW
Energy saving
reduction of energy consumption
derivation from green production for the location: reduction of global energy demand
By 2.5 % per vehicle per year by 2030 (base year 2013–14)
12/30 BUS / oM
reduction of energy consumption
reduction of the combustion chamber temperature of Cdp-tnv following documentation of compliance with limit values through measurement and public authority confirmation
reduction of the combustion chamber temperature from 745 °C to 725 °C
05/19 oMB
reduction of energy consumption
implementation of the “Switching off machines outside working hours” project
Machines that can be switched off are defined and marked
12/20 opt
reduction of energy consumption
Conversion of office lighting to lEd in Building 135, rooms 101–103, and Building 45, rooms 201–205
Calculated saving approx. 4,000 kWh/a
03/19 oMB
UpdatEd EnvironMEntal StatEMEnt 2019 9
Continuation energy and environmental goals for 2019
Goals for 2019 Measure Assessment criterion Planned date
Primary res-ponsibility
Efficient processes
increasing recycling rate
derivation from green production for the location: increasing the global recycling rate and objective: „Zero waste to landfill“
to 90 - 95 %; -2.5 % per vehicle per year by 2030 Waste for disposal (base year 2013–14)
12/30 BUS / oM
Conservation of resources
reduction of grab bar waste parts, waste optimiza-tion, and fewer mistakes when making cutouts by using a new laser system
assessment as to whether there are fewer complaints and duplicate productions
06/19 oMM
Conservation of resources
Use of smart repair in the finish area reduced use of solvents 12/19 oMM
reduction of paper use reduction of accompanying vehicle papers by using pda
Using pda yes/no 10/19 oMM
avoiding packaging incorporation of Mercedes-Benz turkey into the production networkrnwith standard load carriers
implementation of standard load carriers and gradual elimination of single-use wood and cardboard packaging
06/19 oSl
reduction of environ-mental impact
Changing the assembly process to reduce reworking due to damage
Changed assembly sequence for glazing and painted external parts
12/19 opl
reduction of masking scopes in the floor coating area on the front + rear
reduction of masking scopes in the work schedules documentation of eliminated masking scopes
04/19 oMB
10 UpdatEd EnvironMEntal StatEMEnt 2019
UpdatEd EnvironMEntal StatEMEnt 2019 11
12 UpdatEd EnvironMEntal StatEMEnt 2019
Figures, data, facts
UpdatEd EnvironMEntal StatEMEnt 2019 13
production
0
500
1000
1500
2000
2500
3000
3500
4000
2016 2017 2018Manufacturing units (MU) Body-in-white MU for sister plants PU (production unit) equivalents
Production figures
Mannheim is the main production location of the Mercedes-Benz Citaro city bus fleet for public transportation. in addition, all bodies-in-white of the Mercedes-Benz and Setra brands are produced here for assembly at sister plants in neu-Ulm and ligny-en-Barrois (France).
in 2018, 2,107 fully-equipped buses were assembled at the Mannheim location, which corresponds to 2,766 manufacturing units [MUs]. the plant also prepared the bodies-in-white for 7,952 MUs. the number of manufacturing units is higher because an articulated bus consists of two manufacturing units.
the calculation of production unit [pU] equivalents takes into account the amount of work done in all plants participating in the production network. Since the introduction of this key figure in 2012, the value has leveled out at between 2,000 and 3,000 pU equivalents.
14 UpdatEd EnvironMEntal StatEMEnt 2019
Emissions
0
10
20
30
40
50
60
70
80
90
100
2014 2015 2016 2017 2018VOCs in g/m₂ of surface to be painted per vehicle Proportion due to Mannheim plant Proportion due to Neu-Ulm plant
VOC figures
Solventthe emissions of solvents overwhelmingly occur as a result of surface coatings. the solvent emissions in Mannheim have decreased consid- erably since 2011, when the vehicle topcoat painting process was transferred to the plant in neu-Ulm. the use of solvents, measured in voC per square meter, is significantly lower than the legally prescribed limit value of 150 g per square meter and is thus at a good level.
in 2018, the calculation of the voC value was revised; it was updated on the basis of the sampling of old paints, the efficiency measurement and the vehicle surfaces.
Noisein 2018, there was a production-related noise complaint by a local resident. Measures were promptly implemented in response to this; compliance with these measures is ensured.
Greenhouse gasesthe greenhouse gases that are emitted by the technical systems at our Mannheim plant are mainly due to the use of natural gas as one of the primary energy sources. in 2018, 2,081 metric tons of greenhouse gases were emitted; this corresponds to a 14.0% increase compared to the previous year.
With the exception of one occasion where the carbon monoxide limit value was exceeded, there were no further anomalies in the Cdp-tnv unit in 2018. When the carbon monoxide limit value was exceeded, we responded with immediate measures so that compliance with the limit value could be guaranteed again.
the precise figures for greenhouse gas emissions from our plant can be found in the list of core indicators on page 23.
UpdatEd EnvironMEntal StatEMEnt 2019 15
Energy
0
5
10
15
20
25
30
35
2014 2015 2016 2017 2018Consumption [GWh] Consumption per PU equivalent [MWh]
0
2
4
6
8
10
12
2014 2015 2016 2017 2018Consumption [GWh] Consuption per PU equivalent [MWh]
Electricity consumption Natural gas consumption
the following diagrams depict the energy consumption, broken down by the main energy sources. the consumption of heating oil is not represented here, because it is a negligible energy source, accounting for less than 0.5% of the total energy consumption. the heating oil consumption is taken into account when calculating the total energy consumption. the absolute energy consumption of the last three years at the Mannheim location is shown on page 21.
Electricity the diagram below shows the plant‘s electricity consumption from 2014 to 2018. For 2018, this amounts to 29.3 GWh and is thus higher than the previous year by approx. 7.7 %. this increase can be traced back to increased production figures. Consumption per manufacturing unit equivalent has decreased by 1.5 % to 10.1 MWh.
Natural gasthe natural gas consumption for 2018 amounts to 10.7 GWh and is thus 8.3 % higher than in 2017. However, per manufacturing unit equivalent, it was reduced by 0.3 % to 3.7 MWh.
16 UpdatEd EnvironMEntal StatEMEnt 2019
0
5
10
15
20
25
30
2014 2015 2016 2017 2018Consumption [GWh] Consumption per degree day [MWh]
0
20
40
60
80
100
120
140
2014 2015 2016 2017 2018Volume [10³ m₃] Volume per PU equivalent [m₃]
District heating consumption Total water consumption
District heating the heat consumption is displayed for the third energy source. this is additionally related to the degree days at the location. the relation to the degree days is necessary because the heating requirement depends heavily on the weather conditions, and this is the only way to enable a meaningful comparison with the previous years.
Compared to the previous year, consumption, both in absolute and relative terns per degree day, increased by around 0.5 % and is approxi-mately at the level of 2014 with 27.7 GWh or 10.1 MWh per degree day. this can be traced back to the increased production program and the resulting increased hall usage time.
UpdatEd EnvironMEntal StatEMEnt 2019 17
Water
0
20
40
60
80
100
120
2014 2015 2016 2017 2018Volume [10³ m₃] Volume per PU equivalent [m₃]
0
5
10
15
20
25
30
2014 2015 2016 2017 2018Volume [10³ m₃] Volume per PU equivalent [m₃]
Well water consumption Water from public utilities
in order to document our water consumption figures, we first calculated the total consumption of freshwater. overall, demand has increased compared to 2017, both in terms of the total amount consumed and the amount per production unit equivalent. the total water consumption of 135,925 m3 in 2018 consists 82 % of well water and 18 % of drinking water. the consumption of well water and water from public utilities is depicted on the following page.
Well waterthe well water used in the plant is drawn by daimler aG from wells at the location, and it is used exclusively for production. the diagram in the bottom left corner shows that the amount drawn in 2018 increased by 19 % from 93,242 m3 to 110,972 m3 compared to the previous year. Consequently, the amount per production unit equivalent also increased by 9.1 % from 35.1 m3 to 38.3 m3. the increased demand for well water is, on the one hand, a consequence of increased production figures and, on the other, a consequence of the high temperatures during the summer months, which meant the cooling systems were used more intensively.
the process cannot be broken down further because the monitoring system shows only the total consumption of the plant. With the current monitoring system, it is not possible to assign consumption values to the individual stages of production. We are planning to improve the trans- parency of the monitoring process so that we can assign specific con- sumption figures.
Water from public utilitiesthis representation of water consumption figures refers to the consump-tion of drinking water (primarily for the sanitary facilities) provided by public utilities. in 2018, the drinking water production decreased by around 6.1 % to 24,953 m3 compared to the previous year. in terms of the production unit equivalents, consumption was also reduced by 13.7 % to 8.62 m3 per pU.
18 UpdatEd EnvironMEntal StatEMEnt 2019
Waste water
0
20
40
60
80
100
120
140
2014 2015 2016 2017 2018Total wastewater [10³ m₃] Treated wastewater [10³ m₃] Evaporated volume [10³ m₃]Wastewater from sanitary facilities [10³ m₃] Wastewater per PU equivalent [m₃] Treated wastewater per PU equivalent [m₃]
Wastewater development
Waste water is, on the one hand, dependent on production and, on the other, a base load in the production facilities, supplemented with a certain amount from the sanitary areas. the total amount is calculated by taking the freshwater consumption and subtracting the volume of water that has been calculated but not discharged. the waste water value in 2018, subject to the increased fresh water consumption compared to 2017, also increased significantly.
the waste water discharges occur exclusively into the municipal sew-erage system and are subject to continuous monitoring as an indirect discharge. thus, again in 2018, the discharge points were regularly tested by the municipal waste water system of the city of Mannheim. Based on this sampling, the city imposed a surcharge based on the parameters of the total nitrogen bound, phosphorus (tp), and the total organic carbon (toC) in accordance with the waste water regulations.
the waste water from the cathodic dip painting process (Cdp), the portal unit for surface treatment (pUSt), the pretreatment for the powder unit and the bus leakage test are tested in accordance with the applicable self-monitoring guideline for the state of Baden-Württemberg.
in 2018, the limit value was not exceeded at all during external waste water investigations.
the plant regularly shares information with the responsible authorities. determined limit value violations are communicated to them, but, if necessary, solutions to problems are also striven for, defined and implemented together.
UpdatEd EnvironMEntal StatEMEnt 2019 19
Waste
0
1000
2000
3000
4000
5000
6000
7000
2014 2015 2016 2017 2018Total [t] Recycled [t] of which, scrap metal [t] Disposed of [t]
0
500
1000
1500
2000
2500
3000
2014 2015 2016 2017 2018Waste recycled per PU equivalent [kg] Waste disposed of per PU equivalent [kg]
Production waste development Proportion of waste recycled/disposed of
Production wasteWaste is recycled or disposed of under the waste generator number of EvoBus GmbH Mannheim. the technical process has been conducted since 2016 at the disposal center on the premises of EvoBus GmbH.
the total volume of production waste was 6,352 metric tons in 2018, which represents an increase compared to the previous year. this increase can be traced back to higher body-in-white production, which is associated with a higher occurrence of scrap metal. the high percentage of scrap metal, amounting to 62.3 % or 3,956 metric tons, is characteristic of body-in-white production.
Recycling/disposala positive note is the fact that almost all of the total production waste, 99.7 %, to be exact, was recycled in 2018, the same proportion as in the previous year. a total of 6,336 metric tons were recycled, and 16 metric tons were disposed of.
Because the amount of waste for disposal has been very low since 2014, it is no longer represented in the diagram below.
20 UpdatEd EnvironMEntal StatEMEnt 2019
transportation & external companies
0
10
20
30
40
50
60
70
80
90
100
2014 2015 2016 2017 2018Body shipment by train [%]
Body transport (shipping)
TransportationSince 2016, we have been delivering bodies-in-white to our sister plant in neu-Ulm exclusively by train. Because of the greatly divergent transportation costs, we are continuing to deliver bodies-in-white to ligny-en-Barrois (France) by truck. in 2018, 85.6 % of these products were transported by train. the current record value of 89.4 % was reached in 2016.
We are continuously optimizing the filling levels of our load carriers for internal and external product deliveries.
the completed buses leave the plant on their own axles.
External companies on the plant site and inclusion of suppliersthe external companies that operate at our location are bound to con- tractual agreements. in addition, at least once a year, they attend an informational event at our location, where they recommit themselves to fulfill the requirements of our management system.
UpdatEd EnvironMEntal StatEMEnt 2019 21
Core indicators according to EMaS iiithe amended EU directive EMaS iii requires us to evaluate our environ- mental performance.
We are expected to present the core indicators of our energy and materials efficiency, water consumption, waste generation, land con- sumption in relation to biological diversity, and emissions and to indicate the relationship between these core indicators and the plant’s overall output or value creation.
Energy consumption consists of the figures for electricity, natural gas, hot water and heating oil.
Based on the amendment of appendix iv of the EMaS directive, the pro- duction unit equivalents are selected as a new relationship indicator and thus replace the added vehicle-related and model-related mass of the vehicle deliveries and bodies-in-white shipped as a relationship indicator. a detailed representation of the environmental performance is enabled using this approach, as is the observance of special characteristics. the efficiencies of the core indicators for the years 2016 and 2017 were also updated with regard to the new production unit equivalent rela-tionship indicator.
the comparative development of the plant‘s environmental performance can be represented by means of the specific key figures and the core indicators we have used. Because of the unique nature of the activities at the location, no cross comparisons or sector comparisons are possible.
the core indicators are represented in a table on the following pages.
Year Ipsum 2016 2017 2018
production unit equivalents ¹ 2.572 2.638 2.885
Core indicator
Energy consumption absolute amount [MWh] 62.083 64.667 67.692
Efficiency [MWh/Stk] 24,14 24,51 23,46
proportion of energy from renewable sources ² absolute amount [MWh] 0 0 0
Mass flow input ³,⁴ absolute amount [t] 42.688 41.863 66.474
Efficiency [t/Stk] 16,60 15,87 23,04
Water consumption ⁵ absolute amount [m3] 124.763 119.814 135.925
Efficiency [m3/Stk] 48,51 45,42 47,11
land consumption in relation to biological diversity ⁶ absolute amount [m2] 267.808 258.703 258.703
Efficiency [m2/Stk] 104,12 98,07 89,67
Core indicators according to EMAS III – Input
¹ determined integral bus coordinated production system² no renewable energy is produced at the plant³ Sum of tonnage and production waste⁴ 2018 value using new calculation method⁵ total water consumption⁶ Sealed area due to buildings and asphalting
22 UpdatEd EnvironMEntal StatEMEnt 2019
Core indicators according to EMAS III – Output Part 1
Year 2016 2017 2018
Equivalent unit of production ¹ 2.572 2.638 2.885
Core indicator
Mix of recyclable materials absolute amount [t] 1.052 986 958
Efficiency [t/Stk] 0,4090 0,3738 0,3321
Emulsions absolute amount [t] 294 341 268
Efficiency [t/Stk] 0,1143 0,1293 0,0929
Sludges from the plant’s wastewater treatment absolute amount [t] 258 271 298
Efficiency [t/Stk] 0,1003 0,1027 0,1033
other waste fractions < 200 t absolute amount [t] 729 585 873
Efficiency [t/Stk] 0,2834 0,2218 0,3026
Scrap metal absolute amount [t] 3.549 3.342 3.956
Efficiency [t/Stk] 1,3799 1,2669 1,3712
total amount of production waste absolute amount [t] 6.044 5.652 6.352
Efficiency [t/Stk] 2,3499 2,1425 2,2017
total amount of hazardous production waste absolute amount [t] 748 719 713
Efficiency [t/Stk] 0,2908 0,2726 0,2471
total amount of construction waste ⁷ absolute amount [t] 889 2.239 898
¹ determined integral bus coordinated production system ⁷ no calculation of efficiency
UpdatEd EnvironMEntal StatEMEnt 2019 23
Core indicators according to EMAS III – Output Part 2
Year 2016 2017 2018
Equivalent unit of production ¹ 2.572 2.638 2.885
Core indicator
Greenhouse gas emissions ⁸ absolute amount [t] 1.933 1.825 2.081
Efficiency [t/Stk] 0,7516 0,6918 0,7213
pollutant emissions noX ⁹ absolute amount [t] 2.190 2.312 2.504
Efficiency [t/Stk] 0,8515 0,8764 0,8679
pollutant emissions So₂ ⁹ absolute amount [t] 310 158 187
Efficiency [t/Stk] 0,1205 0,0599 0,0648
pollutant emissions pM ⁹ absolute amount [t] 1.029 1.090 1.428
Efficiency [t/Stk] 0,4001 0,4132 0,4950
pollutant emissions voC ¹⁰ absolute amount [t] 67 72 62
Efficiency [t/Stk] 0,0260 0,0273 0,0215
¹ determined integral bus coordinated production system ⁸ Co₂ due to gas, heating oil, refills of refrigerants (new GWp conversion factors starting in 2016). Up to 2015, coolant with CH₄, n₂o from personnel and freight transport ⁹ due to natural gas and heating oil. Calculation according to GEMiS 4.2¹⁰ due to sealing of surface areas
24 UpdatEd EnvironMEntal StatEMEnt 2019
UpdatEd EnvironMEntal StatEMEnt 2019 25
26 UpdatEd EnvironMEntal StatEMEnt 2019
validation
UpdatEd EnvironMEntal StatEMEnt 2019 27
the undersigned, dipl.-Geol. Bernhard Schön, EMaS environment expert of tÜv SÜd Umwelt-gutachter GmbH with the registration number dE-v-0321, accredited or authorized for Unit 29 (naCE code) confirms that he has assessed whether the location, as published in the Environ-mental Statement 2019 of the organization EvoBus GmbH, Mannheim plant, with the registra-tion number dE-153-00022, fulfills all the requirements of the directive (EC) no. 1221/2009 of the European parliament and of the Council of november 25, 2009, and the directive (EU) 2017/1505 from august 28, 2017, concerning the voluntary participation of organizations in a shared system of environmental management and environmental audit measures (EMaS).
By signing this declaration, i confirm that
» the audit and the validation were conducted in full conformity with the requirements of directive (EC) no. 1221/2009 and directive (EU) 2017/1505,
» that the result of the audit and the validation confirms that there is no evidence of nonconformity with the applicable environmental regulations,
» and that the data and the content of the location‘s Environmental Statement provide a reliable and truthful picture of all of the activities of the location within the unit speci-fied in the Environmental Statement.
this declaration cannot be equated with an EMaS registration. the EMaS registration can be completed only by a competent authority in accordance with directive (EC) no. 1221/2009 and directive (EU) 2017/1505. this declaration must not be used as an independent basis for infor-ming the general public. the present Environmental Statement has been audited and declared valid.
Munich, May 31, 2019
Bernhard SchönEnvironmental verifierdE-v-0321
daimler aGMercedesstraße 13770327 Stuttgart Germanywww.daimler.com