Opinion of the European Economic and Social Committee on the Proposal for a regulation of the European Parliament and of the Council establishing the second ‘Marco Polo’ programme for the granting of Community financial assistance to improve the environmental performance of the freight transport system (‘Marco Polo II’) (COM(2004) 478 final — 2004/0157 (COD))
OJ C 234, 22.9.2005, p. 19–24 (ES, CS, DA, DE, ET, EL, EN, FR, IT, LV, LT, HU, NL, PL, PT, SK, SL, FI, SV)
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Opinion of the European Economic and Social Committee on the Proposal for a regulation of the European Parliament and of the Council establishing the second "Marco Polo" programme for the granting of Community financial assistance to improve the environmental performance of the freight transport system ("Marco Polo II")
(COM(2004) 478 final — 2004/0157 (COD))
On 15 February 2005 the Council decided to consult the European Economic and Social Committee, under Article 71 of the Treaty establishing the European Community, on the abovementioned proposal.
The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 21 February2005. The rapporteur was Mr Levaux.
At its 415th plenary session of 9 and 10 March 2005 (meeting of 9 March), the European Economic and Social Committee adopted the following opinion by 129 votes, with three abstentions.
1. Introduction: Outline of the Commission's explanatory memorandum
1.1 The Commission presents its proposal for a regulation for the "Marco Polo II" programme, setting out the reasons why freight transport infrastructures must be developed:
- freight transport is set to double by 2020 and existing networks are inadequate, resulting in road congestion, environmental degradation, accidents, and a loss of competitiveness; and
- sustainable development requirements are to be taken into account, which requires a more energy-efficient transport system.
1.2 The Commission reasserts that "a stronger reliance on intermodality is necessary", because intermodality makes better use of existing infrastructures by incorporating short sea shipping, rail and inland waterways into the logistics chain. Intermodal policy is already covered by the Marco Polo I programme (2003/2006), which aimed to shift the average yearly increase of international road freight towards the three other modes of transport mentioned above.
1.3 The Commission proposes that the Marco Polo II programme continue this policy over the 2007-2013 period, extending the programme's scope to cover all of the European Union's neighbours and adding two new types of action:
- motorways of the sea; and
- traffic avoidance action.
1.4 The Commission proposes an overall budgetary envelope of EUR 740 million for the 2007-2013 period, which should:
- shift more than 140 billion tonne-kilometres of freight off the road (equivalent to 7 million truck journeys of 1,000 kilometres) towards other modes of transport;
- reduce CO2 emissions by 8,400 million kg; and
- produce social and environmental benefits estimated at around EUR 5 billion. (This estimate was reached by a group of independent experts and appended to the Commission proposal, with an evaluation of the harmful effects of pollution on health).
2. General comments
2.1 Gist of the Committee's conclusions in its Opinion on Marco Polo I
2.1.1 Whilst sometimes highlighting the lack of ambition or the inadequacy of the resources provided, the Committee has on numerous occasions confirmed its support for the policy launched by the Commission to make it easier to transfer part of the inevitable and foreseeable growth in road freight transport to other modes of transport.
2.1.2 In particular, in its Opinion CES 842/2002 of 17 and 18 July 2002 on the proposal for a Regulation on Marco Polo I, the Committee did not believe that this programme would, by itself, make it possible to achieve the modal shift targets set by the Commission, and suggested complementing it with ten specific incentive measures, set out again here:
- tighter inspections and more severe penalties in the event of labour law infringements;
- public financing of modal transport infrastructure, such as terminals and access facilities;
- requiring operators to pledge to provide new ongoing services of general interest in order to secure modal shifts; failure to do this will mean that customers will not change their habits;
- procedures should be set out forthwith for extending the Marco Polo programme by two or three years in order to ensure that it continues to operate up to 2010 (there is a need to avoid the hiatus which occurred between the PACT and the Marco Polo programmes);
- the greatest possible benefit should be drawn from the experience gained from the PACT programme by concluding the external evaluation of the programme; the positive effects of the PACT programme have not so far been fully evaluated;
- a timetable should be established for the measures implementing the actions set out in the Marco Polo programme;
- a management committee should be given the task of monitoring actions on an on-going basis with a view to making the necessary mid-term adjustments to the Marco Polo programme;
- provision should be made for including in the projects eligible for support under the Marco Polo programme actions involving air and pipeline transport in a secondary capacity, provided that other modes are also involved;
- financial aid should be approved for projects involving actions taking place in just one Member State, provided that the impact of such projects will benefit all users of international shipments passing through the Member State in question; and
- a "European Guide", covering all multimodal platforms in the EU, describing their respective characteristics and laying down minimum standards, should be drawn up for the benefit of all users.
2.1.3 In the same opinion, the Committee added that the only way to achieve these aims was to adopt a global policy which would change certain practices and include firm commitments for building new or complementary transport infrastructures.
2.1.4 In particular, where large volumes of freight on long journeys are concerned and where the delivery is not urgent but must take place on a certain date, the Committee proposed that the Commission consider changing over gradually from the practice of zero stockholding to the concept of stock in circulation. This would help to reduce the number of urgent deliveries and to enable non-road transport to compete properly on cost and delivery times, whilst guaranteeing delivery dates. Everyone understands the economic rationale that has encouraged the growth of zero stockholding, which greatly reduces delivery times by making urgency the overriding commercial consideration. If the concept of sustainable development is taken into account, it is clear today that this practice and its consequences are very costly in terms of pollution and excessive energy consumption. These issues must therefore be discussed and the Committee reiterates its request to the Commission to be involved in these discussions. It considers that, although road transport remains irreplaceable for short distances, particularly for the final stage of deliveries, it is zero stockholding taken to the extreme and urgency as an absolute principle that have made it so difficult to shift some road freight transport to other modes of transport, which are more consistent with the desire for sustainable development.
2.1.5 Without prejudice to the outcome of a discussion on this matter, the Committee considers that, in order to bring about a change in the behaviour of the economic players involved, restrictions might have to be placed on some practices, which might have been efficient in years gone by but which are no longer in tune with today's objectives.
2.1.6 The Committee notes that only a few of the incentives it suggested have been taken on board. Taking the view that the situation in 2004 is not greatly different to that of 2002, the Committee is submitting the same proposals again in this opinion, expanding on some aspects of the proposals.
2.2 Evaluation of the initial results of the Marco Polo I programme: 2003-2006
2.2.1 The Commission considers the initial results of the Marco Polo I programme, which had a budget of EUR 100 million, to be encouraging. The Committee notes that the first selection of programmes was launched in October 2003 — in other words, barely one year ago — and that, to date, there has not been sufficient time to evaluate the real effectiveness of the intermodal actions that have been undertaken. The Committee also notes that:
- in the White Paper of 12 September 2001 on European transport policy for 2010: time to decide, EUR 120 million was earmarked for the Marco Polo I programme for four years, i.e. EUR 30 million per year;
- in its proposal for a regulation on the Marco Polo I programme, in early 2002, the Commission forecast a budget of EUR 115 million over five years, i.e. EUR 23 million per year;
- in the end, however, the Marco Polo I programme was given a budget of EUR 100 million for only five years, i.e. EUR 20 million per year;
- for the first operating year of the Marco Polo I programme, the Community budget provided only EUR 15 million.
2.2.2 The Committee is astonished at these successive reductions and questions the reliability of the forecasts, because demand is predicted to be constantly increasing, whilst resources are constantly decreasing.
2.2.3 In these circumstances and because no real information has been provided on the matter, the Committee fails to understand the Commission's assertion that: "one can [also] conclude that the budgetary means of the programme are largely insufficient to fund all good proposals …", nor can the Committee understand why, in the budgetary programming, the EUR 20 million have not been fully used.
2.3 Ex-Ante Evaluation and Stakeholders' Consultation
2.3.1 Section III(12) of the explanatory memorandum refers to a financial document that is important because it attests to the fact that the proposal for a regulation "takes full account of the evaluation and recommendation of the independent experts" following their ex-ante evaluation of the renewal of the Marco Polo II programme for the period 2007 — 2013. This 19-page document, written in English, has not been translated into other languages and is merely briefly summarised in section III(13) of the explanatory memorandum of the draft regulation, presenting the conclusions drawn by the Commission from the experts' evaluation.
2.3.2 The Committee wishes to point out that, for the sake of accessibility, documents must be translated and that, if a complete translation of the experts' report is not available, the experts should be asked to produce a summary of the report which, once translated, would give all those concerned instant access to the gist of their conclusions, accompanied by the relevant arguments.
2.3.3 Moreover, the Committee recalls that, in its Opinion (842/2002) on the Marco Polo I regulation, it welcomed the fact that the Commission heard "the views of the parties concerned before presenting its proposals". It does, however, "regret the fact that it was involved in this consultation process only at a late stage" (point 2.5).
2.3.4 The Committee is, therefore, unable to comment on the conclusions of this evaluation except to note that the Commission expects an appropriate increase in the budget being presented and makes this a fundamental prerequisite for the programme's effectiveness.
2.3.5 The Committee notes that the Commission has provided it with assessments of three projects that have been undertaken:
- the creation of an Intermodal Rail service between Germany and Italy via Austria, operated by a private company;
- the IKEA-RAIL project, launched in 2002, consisting of a platform in Duisburg (Germany), which receives products sent by rail (1,044 km) from Almhut (Sweden) for distribution to the rest of Europe. In 2002 and 2003, around 400 trains undertook this journey carrying IKEA freight alone;
- the establishment of regular sea crossings, for heavy goods vehicles, between several ports in Italy and Spain.
2.3.6 These three projects illustrate the possibilities offered by the monitoring mechanism put in place by the EU. The Committee notes, however, that these projects have been undertaken as part of the Pilot Actions for Combined Transport (PACT) programme, which preceded Marco Polo I.
2.3.7 The idea behind these projects is particularly interesting; they reinforce the measures currently being undertaken and the Committee is extremely keen to be informed in due course of the precise results of the current Marco Polo I programme and how these results are being used.
2.4 The Marco Polo II programme (2007/2013)
2.4.1 The Marco Polo II programme does not change the 3 current types of action:
- modal shift (start-up aid);
- common learning.
2.4.2 It provides broader geographical scope by covering not only the Europe of 25 and the other applicant countries, but also the EFTA and EEA countries. The Committee agrees with this approach and accepts the Commission's statement that: "Production and supply chain patterns do not stop at the border of EU 25". It also expresses its hope that the Commission adds the word "trade" after "production" at the beginning of this phrase.
2.4.3 The Committee suggests that the Commission quote the example of the Danube-Corridor VII, which typifies this wider Europe, because it has the exceptional characteristics of an intermodal transport infrastructure that links all modes of transport, and these are:
- river transport, by means of a continuous link between the North Sea and the Black Sea, with the mid-point located in Austria, at approximately 1500 km from each end;
- road and rail transport which, through trade platforms, will make it easier to irrigate large areas surrounding the river; and
- maritime and sea-river transport which, in the West extend this river by means of the Rhine-Main-Danube link to the Channel Islands and the North Sea and, in the East, towards Russia (the Volga), Ukraine and Turkey by means of the Black Sea.
2.4.4 The Marco Polo II proposal provides for two new types of action:
- Motorways of the sea, a concept for which the Committee has expressed strong support on several occasions. Wider Europe of course has thousands of kilometres of maritime coastline, hundreds of ports and river estuaries, which are all potential points of access to hinterland regions and to the entire mainland. It is therefore important to encourage and assist transport and freight distribution projects everywhere, by increasing the number of multimodal trade platforms located on coasts or on estuaries.
- Traffic avoidance action, a concept designed to improve production, distribution and supply patterns and eliminate unnecessary journeys. Examples include:
- transporting goods in dehydrated form obviates the need to transport water, which is added once the goods arrive;
- locating component-manufacturing sites near to assembly sites obviates the need for long-distance journeys.
The Committee is in favour of experiments and projects along these lines.
2.4.5 The Commission wishes to "create rail synergies" and recommends, for example, the use of dedicated tracks, with high-speed trains for freight and express mail. The Committee supports projects of this nature even though — where "express mail" is concerned — it considers that developments in the transmission of information electronically means that most mail can be sent this way now and increasingly so in the future.
2.4.6 Nevertheless, whilst there is a need to create dedicated high-speed freight lines, the interoperability of material, equipment and rail regulations must first be guaranteed. Furthermore, before new lines are built, optimum use must be made of existing networks and the possibility of using abandoned or underused lines studied, in seeking to shift passenger traffic to other modes of transport, in particular to high-speed lines.
2.4.7 The Committee therefore calls on the Commission to ask Member States once again to list all ways of revitalising disused or reduced-volume networks for freight transport. This mainly concerns the rail network, but also inland waterways, the aim being, wherever possible, to implement faster solutions than roads and which also provide greater benefits in terms of sustainable development.
2.4.8 Lastly, in order to give credibility to freight rail transport and indeed to other non-road modes of transport, the Committee again points out that it is time to translate intentions into action by reserving or allocating a larger share of appropriations for rail, sea and river infrastructures than they receive today, in particular in TEN-T project funding, and in funding granted to the new Member States, as well as the Balkans region.
2.4.9 The Committee is pleased to note that the Commission underscores the "considerable" demand in industry for funding infrastructures which are necessary and adequate for achieving the service targets under the Marco Polo programme. As for funding ancillary infrastructures, the Committee recalls that this was a recommendation made in its Opinion (842/2002) on Marco Polo I.
3. Specific comments on the proposed Regulation on the Marco Polo II programme
3.1 Article 1: Subject matter
3.1.1 The Committee notes that the Commission is presenting its proposal in 2004 for a regulation for the 2007-2013 period. This should make it easier to ensure the continuity of the Marco Polo programme and to avoid the delay seen in 2001/2002 when Marco Polo I was launched. Today, therefore, the Commission is not presenting an approach that is significantly different to the implementation of Marco Polo I. Acting in advance in this way will mean that it is possible to give"a management committee [that should be given] the task of monitoring actions on an on-going basis with a view to making the necessary mid-term adjustments to the Marco Polo programme", as the Committee called for in its Opinion 842/2002.
3.2 Article 2: Definitions
3.2.1 The Committee notes, in its definition of a "consortium" that at least two undertakings are required. The Committee reiterates its earlier call for a consortium to be any "arrangement by which at least two undertakings, which do not form part of the same group and one of which is not a subsidiary of the other, execute together …"…
3.3 Article 3: Scope
3.3.1 The Committee reiterates the call made in Opinion 842/2002, considering that the rules stipulated in this Article are, in its view, too restrictive, insofar as they require the actions to involve at least two States, or one State and the territory of a close third country. The Committee also considers that there are localised actions which affect one single state but whose impact would benefit all users of the relevant modes of transport passing through that state. One example of this would be actions on the use or development of multimodal platforms situated in an infrastructure hub within a single territory.
3.3.2 The Committee welcomes the move to open up the scope to cover third countries (whether or not they are applicants for accession) and notes that the costs of actions still being taken in those territories are not covered by the programme except in the circumstances provided for in paragraphs 3 and 4 of this article.
3.3.3 To ensure consistency, however, it would like the regulation to state that, as regards funding for actions in third countries, this should be dedicated, insofar as possible, to measures for developing non-road modes of transport or those which encourage intermodality.
3.4 Article 4: Eligible applicants and beneficiaries
3.4.1 The EESC endorses Article 4, subject to account being taken of its comments above on the composition of a "consortium". The Committee would, however, point out, as it did in Opinion 842/2002, that in the exceptional cases where actions are being carried out in a single country, the requirement for undertakings to be established in at least two Member States or in one Member State and a third country, does not apply.
3.5 Article 5: Eligible actions and funding conditions
3.5.1 In points 3.5, 3.6 and 3.7 of its Opinion 842/2002 on Marco Polo I, the EESC stated that the minimum subsidy thresholds per action were too high. It called for the minimum subsidy thresholds proposed by the Commission to be reduced:
- from EUR 1 million to EUR 500,000 for modal shift actions;
- from EUR 3 million to EUR 1.5 million for catalyst actions;
- from EUR 500,000 to EUR 250,000 for common learning actions.
3.5.2 The Committee notes that, where Marco Polo II is concerned, the indicative minimum subsidy thresholds for actions set by the Commission in the annex detailing the funding conditions referred to in Article 5 of the proposal are still too high, (except for common learning actions, for which the threshold has been reduced to EUR 250,000 as the Committee had wanted). The Committee considers it crucial to set lower and thus more attractive thresholds, to encourage the start-up of projects that might be on a smaller scale but which are often more effective at local level.
3.5.3 The Committee consequently calls for
- the minimum subsidy thresholds to be halved, or reduced:
- from EUR 1 million to EUR 500,000 for modal shift actions;
- from EUR 3 million to EUR 1.5 million for catalyst actions;
- from EUR 4 million to EUR 2 million for motorways of the sea actions;
- from EUR 1 million to EUR 500,000 for traffic avoidance actions;
the minimal subsidy threshold for common learning actions, to remain at EUR 250,000, as set out in the proposal;
a specific category to be created for sea-river transport and river transport with a minimum threshold of EUR 500,000. Although the minimum threshold of EUR four million (reduced to EUR two million as the Committee proposes) for motorways of the sea is acceptable for maritime transport, given the size of vessels and the volumes transported, it is not appropriate for inland waterways.
3.5.4 Lastly, the Committee agrees that maximum time periods should be set for carrying out the various actions, with completion by the deadline ensuring that an action is eligible. The Committee considers, however, that the 36 month deadline for modal shift actions is too short and that it should, as for the other actions, be set at 60 months.
3.6 Article 11: Budget
3.6.1 The EESC pointed out earlier that it does not have the necessary information to assess the sum of EUR 740 million that the Commission wishes to earmark for the Marco Polo II programme. It simply notes that the Commission considers that this budgetary envelope of EUR 740 million must help to achieve the savings totalling EUR 5 billion in social and environmental benefits referred to above in point 1.4.
3.6.2 The Committee hopes that the Commission will, in the course of 2005, halfway through the Marco Polo I programme, publish an assessment of the projects that have been completed and of the savings actually made.
3.6.3 As the Committee suggested in Opinion 842/2002, the Commission should, in the course of the programme, propose an increase in the budget to provide additional funding should there be a larger number of projects put forward.
3.7 Article 14: Evaluation
3.7.1 The Committee is pleased to note, because this is one of the requests it made in Opinion 842/2002, that the Commission is to present to the EESC as well as to the European Parliament and the Committee of the Regions, an assessment report on the results of the Marco Polo I programme for the period 2003/2006, by 30 June 2007 at the latest.
3.7.2 It hopes to have sufficient information to be able to deliver an opinion and possibly submit proposals with a view, if necessary, to adjusting the Marco Polo II programme, which will have begun on 1 January 2007 and will therefore be in the initial stages of its implementation.
4.1 The Committee supports Marco Polo II, as it previously supported the PACT and the Marco Polo I programme. These three programmes have been useful in implementing initiatives that help to adapt freight transport systems to improve their environmental performance. Increasing the planned financial contribution from EUR 100 million for Marco Polo I to EUR 740 million for Marco Polo II demonstrates the EU's desire rapidly to achieve a more sustainable form of freight transport management.
4.2 In order to achieve the targets for freight transfer set by the Commission, the Committee wishes to recall some of the measures put forward in its Opinion CES 842/2002 of 17 and 18 July 2002 concerning Marco Polo I:
- in order to establish fair competition between the various transport modes, inspections should be strengthened and penalties in the event of infringements of labour laws should be increased;
- operators benefiting from the Marco Polo programmes must, on an ongoing basis, commit themselves to providing services of general interest to secure transfers;
- the Marco Polo programme must provide for the possibility of financing projects involving actions taking place in just one Member State, provided that the impact of such projects will benefit all users of international shipments passing through the Member State in question;
- a European Guide, covering all multimodal platforms in the EU, describing their respective characteristics, should be drawn up for the benefit of all users;
- provision should be made for including in the projects eligible for support under the Marco Polo programme actions involving air and pipeline transport with a break-off terminal located on a multimodal platform.
4.3 To ensure that river and river-sea transport benefit from the Marco Polo programme, the Committee calls for a specific category to be established with a minimum subsidy threshold lowered to EUR 500,000. River transport cannot be compared to maritime transport, for which the investment needed is proportionate to vessel size.
4.4 The Committee wishes to hold discussions with the Commission to achieve a switch from the practice of zero stockholding to stock in circulation for deliveries that are not urgent (for certain heavy goods, only the delivery date needs to be respected).
Brussels, 9 March 2005
of the European Economic and Social Committee