EUROPEAN COMMISSION

Brussels, 18.2.2016

SWD(2016) 35 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT

Accompanying the document

Proposal for a Directive of the European Parliament and of the Council

on the recognition of professional qualifications in inland navigation and repealing Council Directive 91/672/EEC and Council Directive 96/50/EC

{COM(2016) 82 final}
{SWD(2016) 36 final}

Contents

1.GENERAL CONTEXT

1.1.Policy context

1.2.Legal framework

2.CONSULTATION AND EXPERTISE

2.1.Interservice group

2.2.Consultation of the IAB

2.3.Consultation of stakeholders

2.4.External expertise

3.PROBLEM DEFINITION

3.1.Description of the main problem

3.2.Negative consequences of the problem

3.2.1.Consequences for the IWT sector

3.2.2.Consequences for the EU economy

3.3.Underlying drivers of the problem

3.3.1.Problem Driver 1: Workers face difficulties with mutual recognition of professional qualifications

3.3.2.Problem driver 2: Knowledge of Specific Situations (KSSs) may create unnecessary difficulties for boatmasters operating on certain river stretches

3.4.Attempts by the sector to tackle the problems

3.5.Summary of the main problem and its underlying drivers

3.6.Who is affected by the problem?

3.7.How would the problem evolve, all things being equal (baseline scenario)

3.8.Does the EU have the right to act?

3.8.1.Legal basis

3.8.2.Subsidiarity

4.OBJECTIVES

5.POLICY OPTIONS

5.1.Step 1: Considered policy measures & mapping with problem drivers

5.2.Step 2: Combining the policy measures into policy options

6.ANALYSIS OF IMPACTS

6.1.Social impacts

6.1.1.Impact on labour mobility

6.1.2.Impact on access to the profession

6.1.3.Impact on safety in the IWT sector

6.1.4.Impact on job quality/attractiveness

6.1.5.Impact on labour costs

6.1.6.Impact on employment

6.2.Economic impacts

6.2.1.Impact on the contribution of IWT to the European industrial base

6.2.2.Impact on the contribution of IWT to the European transport energy efficiency

6.2.3.Impact on transport costs and on final consumer prices of goods

6.2.4.Investment costs

6.2.5.Impact on recurrent administrative costs

6.2.6.Impact on different regions

6.2.7.Impact on SMEs

6.2.8.Impact on third countries

6.3.Environmental impact

6.4.Summary of the economic, environmental and social impacts

7.Comparing the options

7.1.Effectiveness

7.2.Efficiency

7.3.Coherence

7.4.Summary on the comparison of policy options

7.5.Conclusion: preferred policy option

8.Monitoring and evaluation

Endnotes

1.General context

1.1.Policy context

A Deeper and Fairer Internal Market with a Strengthened Industrial Base is one of the ten policy priorities I of the Commission. As Europe’s best asset in times of increasing globalisation, the potential of the internal market needs to be exploited in all its dimensions. This includes maintaining and reinforcing a strong and high-performing industrial base for our internal market, bringing industry’s weight in the EU’s GDP back to 20% by 2020, from less than 16% today. Competitive industries rely on the ability to transport large volumes of freight in a cost-efficient way. Inland navigation plays a key role in this respect. Inland navigation vessels have a loading capacity that is equivalent to hundreds of trucks II , which could help to save transport costs III and decongest roads. The EU inland waterways network spans 20 Member States IV with about 41,527 kilometres of inland waterways V . Linked by the Main-Danube canal, the Rhine and the Danube directly connect 13 Member States VI from the North Sea to the Black Sea over a length of 3,500 km. Every year, these waterways transport around 500 million tons of cargo, with Rhine traffic alone making up 67% of transport volume. Over 75% of Inland Waterway Transport (IWT) within the EU is cross-border tranport. In Germany, Belgium and the Netherlands, the modal split share of IWT is 12.5%, 25% and 38.7% respectively and on the Rhine corridor, the industrial heartland of Europe, even above 50%. With cargo of 150 billion tonne kilometres VII on a yearly basis, IWT plays an important role in the functioning of the EU's multimodal logistic chains. According to recent studies VIII , the € 2.2 bn added value in the IWT sector leads to direct and indirect economic added value of € 13.2 bn, i.e. a multiplier of 6.3. Through its support to strenthening the EU’s industrial base, a more attractive IWT sector can help to maintain and further develop employment in the EU’s industries, thereby also contributing to Commission President Junckers’ priority of a New Boost for Jobs, Growth and Investment.

Transport also represents more than 30% of final energy consumption in Europe. 94% percent of transport relies on oil products, of which 90% is imported. As indicated in its Energy Union package IX , the Commission will pay special attention to those sectors with a huge energy efficiency potential, in particular the transport sector. In this context, considerable fuel savings could be realized by removing barriers to the development of less green-house gas intensive modes of transport such as inland waterways, and by making these modes more attractive and cost efficient.

At EU level, the IWT sector is small in relative terms with a 6.3% X share of total goods transported by inland modes. The potential of IWT is not sufficiently exploited. Even on the EU’s main waterway axes, Rhine and the Danube, there is still a lot of spare capacity, contrary to the road and rail network which are heavily congested XI . Multiple barriers faced by the IWT sector include the ageing of the workforce and the difficulty to recruit new entrants to the profession. They add to the economic difficulties following the economic and financial crisis which put also pressure on working conditions. Combined with the expected further increase in demand for IWT transport, the sector would, without mitigating actions, face severe shortages of skilled personnel over the coming decades.

The Commission's policy framework for promoting IWT is NAIADES II XII , which supports the IWT sector striving to develop its full potential. NAIADES II identifies "Skilled workforce and quality jobs" as a key area of intervention and pursues also better governance through improved cooperation with the international River Commissions, which have legislative powers in the field of inland navigation. As a result, the CESNI XIII has been created on 3 June 2015 by the CCNR, which is part of a new framework for the elaboration of uniform technical standards for all EU inland navigation activities coverring also professional qualifications, including on the Rhine. NAIADES II and EU action in the field of IWT professional qualifications thus contributes also to the realisation of a fourth out of the ten priority policy areas of the Juncker Commission: a Stronger Global Actor. Through the Trans-European Transport (TENT) network XIV and the Connecting Europe Facility (CEF), the Commission furthermore prioritises investments in inland waterway transport, for which co-financing rates are amongst the highest compared to other transport modes.

1.2.Legal framework 

IWT in the EU is administered under various legal regimes. The main regulatory actors in the inland navigation sector are the European Union (EU), the Central Commission for the Navigation on the Rhine (CCNR) XV , the Danube Commission (DC) XVI , the United Nations Economic Commission for Europe (UNECE) XVII , the Sava Commission XVIII , the Moselle Commission XIX and individual member states, with each organisation having a different (but, to an extent, overlapping) regulatory and geographical scope.

The various regulators also have different implementation mechanisms. Only the EU can adopt binding rules which are valid for the entire inland waterway network in the EU. The rules adopted by the CCNR, the Sava and Moselle Commission are binding for navigation on their respective rivers. In the framework of the Belgrade Convention for navigation on the River Danube, only 'Recommendations' can be adopted. The same applies for the UNECE.

In general, regulation on the IWT labour force aims at greater harmonisation. However, differences remain for the recognition of workers' professional qualifications, including in the area of requirements for boatmasters’ certificates, where efforts to harmonize have been mainly focussed.

The highest level of harmonisation for professional qualifications has been achieved by the CCNR that has drawn up rules governing navigation on the Rhine since 1868. Matters related to personnel are ruled by the Regulations for Rhine navigation personnel (RNP) XX . Stringent standards are defined for crew members' qualifications and for obtaining Rhine patents, which authorise boatmasters to navigate on the Rhine. In addition, CCNR has signed mutual recognition agreements for boatmasters’ certificates and Service Record Books of crew members XXI .

At EU level, two sets of rules are relevant for the recognition of professional qualifications. For crew members other than boatmasters, Directive 2005/36/EC on the recognition of professional qualifications XXII provides a general legal framework for professions that are regulated in a host Member State and for which no EU sector-specific regulation has been adopted. For boatmasters, a set of specific sectoral EU rules is applicable:

Council Directive 91/672/EEC of 16 December 1991 on the reciprocal recognition of national boatmasters' certificates for the carriage of goods and passengers by inland waterway provides for the mutual recognition by the Member States of each other’s boatmasters’ certificates and

Council Directive 96/50/EC of 23 July 1996 on the harmonisation of the conditions for obtaining national boatmasters' certificates for the carriage of goods and passengers by inland waterway in the Community lays down harmonised basic conditions for obtaining national boatmasters' certificates for inland waterway navigation between EU member States.

As far as UNECE is concerned, Resolution 31 provides measures for the issuance of Boatmasters Licenses XXIII . The Recommendations of the Danube Commission on boatmasters’ licenses are built substantively on the provisions of Resolution 31 of the UNECE and of Directive 96/50/EC. XXIV The Sava Commission has issued binding resolutions on qualifications for nautical personnel and set rules on minimum requirements for the issuance of boatmasters' licences. The Moselle Commission does not regulate on qualifications.

2.Consultation and expertise

This Impact Assessment Report (IAR) was elaborated with the support of internal and external consultation groups,    as well as with the expertise of external consultants.

2.1.Interservice group

This IAR was elaborated by DG MOVE. DG MOVE was assisted by a Commission Impact Assessment Steering Group (IASG). The IASG met several times: in September 2012, January 2013, February, October and December 2014, and February and October 2015. The following DGs were invited: Secretariat General, Legal Service, DG EMPL, DG ENTR, DG EAC, DG MARKT, DG ELARG, DG RTD, DG EAC, JRC and EEAS.

2.2.Consultation of the Regulatory Scrutiny Board

This IAR was reviewed by the Regulatory Scrutiny Board (RSB) a first time on 21 January 2015. Based on the Board recommendations, the IAR has been revised as following:

Firstly the main problem, the problem drivers as well as the objectives have been reformulated and better situated in the framework of the Commission's political priorities. The focus has been restricted to the mobility barriers hampering the future development of IWT sector. Whereas safety is not presented any longer as one of the problem drivers requiring EU intervention in the field of qualifications, it remains a key element within the IAR through the assessment of safety impacts for each measure as the level of safety has to be maintained (and wherever possible even improved).

Secondly, policy options have been re-designed. The former option on the recognition of professional qualifications at EU level based on minimum competence requirements for boatmen and boatmasters has been differentiated into two suboptions: one suboption including and one suboption excluding examination standards for training and education institutes.

Finally, the various policy measures have been further clarified, the rationale for grouping them into policy options has been better explained, quantitative data have been used in a more balanced way and the contribution of the initiative to the streamlining of international IWT governance has been updated.

The second version of the IAR received a positive opinion [link] on 31 July 2015. The present final version of the IAR takes into account the recommendations for improvements by the mean of clarifications or complementary information in the appropriate IAR section. The way some issues considered important by stakeholders (including safety and communication) have been addressed in the IAR has been clarified under section 2.3., the importance of IWT labour mobility relative to other factors that might hinder achieving full growth potential of the IWT sector has been highlighted under section 3.2., some measures have been further clarified under section 5.1. and the reasons for discarding a number of policy options have been also clarified under section 5.2. The impact of the different policy options on labour mobility, access to the profession and labour wages are addressed in detail under sections 6.1.1. , 6.1.2 and 6.1.5. It has to be noted, however, that the nature and diversity of the IWT sector as well as the lack of quantitative data makes it very difficult to provide further quantitative projections. On the impact on wages stakeholders, including social partners, were consulted following the first opinion of the Board. They considered it was not an issue raising concerns.

2.3.Consultation of stakeholders

An online public consultation on the essential elements of the IA took place from 26/3/2013 to 21/6/2013 XXV . The Commission services received a total of 94 replies from education and training organisations, entrepreneurs/ship owners, shipping companies, public authorities, ports, workers' organisations and river commissions. Responses came from a total of 16 countries; most responses were from Romania, Germany, the United Kingdom, Slovakia, the Netherlands, Hungary, Austria, Croatia and Belgium.

The online public consultation confirmed that the problems identified in this IAR (cfr. Chapter 3) are of high importance. The majority of the respondents considered the various problem drivers, and subsequent policy objectives identified, highly relevant. All issues considered important by stakeholders have been taken into account in the IAR XXVI . The responses indicated a high level of support towards regulatory measures in relation to the harmonisation of professional requirements, qualifications and examinations in inland navigation between EU Member States, whereas the introduction of voluntary measures or recommendations received a considerably lower level of support. There is a large degree of homogeneity between the views of the different stakeholder categories. There are no dissenting opinions, apart from the United Kingdom's responses, which reflect their special position as a non-interconnected inland waterway country. Stakeholders’ views expressed in the online public consultation are presented in more detail in Annex 1.

Common Expert Group: In 2012 the Commission created a Common Expert Group on professional qualifications and training standards in inland navigation (CEG). The objective of this group is to support the Commission in developing legislative measures concerning future European standards for professional qualifications, certification and a minimum level of training in inland navigation. The consultation within the CEG (E01036/'CEG') took the form of 11 expert meetings between September 2012 and November 2014. The following organisations were represented: 1) international river commissions: CCNR, DC, Sava Commission, 2) UNECE, 3) National administrations in charge of IWT policy-making and legislative and administrative activities, 4) Professional organisations: European Barge Union (EBU-UNEF) & the European Skippers Organisation (ESO), 5) Trade unions: European Transport Workers' Federation – IWT section, 6) PLATINA - Platform for the implementation of NAIADES XXVII , 7) IWT Training and education institutions in Europe EDINNA XXVIII , 8) AQUAPOL XXIX & European Federation for Inland Ports (EFIP). The studies prepared by the external consultants in support of the present IAR were presented to the CEG in order to receive feedback on the plausibility of the conclusions.

Meetings of the CEG confirmed a broad support for an initiative at EU level as expressed through the online consultation. There were only few contradictory opinions on the objectives to be pursued. In particular the CEG considered that the initially envisaged idea of a rapid introduction of electronic tools (e-Electronic Service Record Books –e-SRB– and e-logbooks) not mature enough and required further substantial analysis. This led to the decision to separate (at least for this first stage) this aspect from the general initiative on professional qualifications and to proceed for the introduction of electronic tools with a separate impact assessment (see sections 3.3.1.2. , 5.1. and Annex 11). The CEG provided the opportunity for useful exchanges on the measures envisaged for a possible Commission proposal.

The Sectoral Social Dialogue Committee for Inland Waterway Transport (SSDC) at European level XXX was regularly kept informed about progress in the framework of the meetings of this Committee. The social partners submitted a document called "social partners' position on professional qualifications and training standards for crew members on inland waterways transport vessels", dated 16/09/2013. In the framework of the preparation of this IAR, they were also invited, at the SSDC meeting of 05/05/2014, to provide specific comments on the social impacts of the envisaged measures through their representatives participating in the CEG. The SSDC instrument welcomed the initiative and confirmed the need for a modern and flexible regulatory tool regarding training and certification, which will allow the development of a fair and competence-based access to the profession improving also the level of safety. In this context, the social partners encouraged the use of CCNR's expertise and the work produced by EDINNA within the Platina I project XXXI . After having been informed about the negative IAB opinion, the Representatives of the employers' side re-affirmed at the SSDC meeting of 30 January 2015, their continuing support for this initiative. The Representatives from the trade unions pointed out that social partners have been heavily involved in the process which has started already in 2012 and that they would regret if the initiative would not go culminate in a Commission proposal.

From the numerous and repeated consultations with stakeholders, it can be deduced that experts and stakeholders largely support a regulatory initiative at EU level. The stakeholders’ and expert’s views are presented in more detail throughout this IAR where relevant. The minimum consultation standards of the European Commission have been respected.

2.4.External expertise

External expertise was used to evaluate the legal framework on professional qualifications in inland navigation XXXII . The study showed that the existing framework has been partially effective in fulfilling the objective of reciprocally recognising boatmasters’ certificates and harmonising conditions for obtaining boatmasters' certificates, but that several barriers remain. Based on this evaluation, an external impact assessment support study has been launched XXXIII . The study confirms the mobility problem as defined in this IAR. Furthermore, it analyses possible solutions and their impacts. The results of this study are referred to throughout this IAR where relevant.

3.Problem definition

3.1.Description of the main problem

The future development of the inland waterway sector is hampered by difficulties in terms of labour mobility, persistent vacancies and skills mismatches. The potential benefits of inland navigation can only be brought about if a skilled workforce is available to ensure that the sector can take on its role in the logistics chain in a safe way.

The situation on the IWT labour market is shaped by two market forces: the demand of workers, determined by transport volumes of both the passenger and the freight market, and the supply of workers, which is driven by career perspectives and new entrants to the sector. Several submarkets can be identified in IWT. They are presented hereafter as four distinct corridors. XL As regions are interconnected, workers tend to be mobile. As shown in Figure 1, there are nevertheless regional differences in supply and demand of workers on the various corridors:

Figure 1     Gap in number of workers between demand and supply for corridors in Europe in 2013

Source: Panteia (2014)

Deficits currently exist for the Rhine corridor, while there is a surplus of workers on the North-South and East-West corridor. As a result, a significant number of workers from Eastern-Europe, in particular from Poland and Czech Republic are working on vessels sailing under the flag of the Netherlands and Germany. XLI Annex 3 provides detailed information about the labour market model developed by the external consultants, on which figure 1 is based.

Overall, the current skilled workforce is ageing. The average age of Belgian, French and German boatmasters is older than the European average. Most of these boatmasters will retire within 10 to 20 years. There are also difficulties in recruiting young people. In recent years workers' shortfall in Western-Europe has partially been resolved by hiring crew members from Eastern European countries and to a lesser extent, from the Philippines and the 'hidden reserve'. XLII  

Whereas over 75% of IWT within the EU consists of cross-border transport, the internal labour market is still not accomplished due to the various drivers and root causes described below. The various regulatory regimes that are simultaneously applicable in Europe, as described under section 1.2., result in different procedures, standards and mechanisms for the recognition of professional qualifications. Difficulties remain despite progress towards harmonisation of the requirements applied under the various regulatory frameworks made over the last two decades. The Council of the European Union, in its Conclusions of 16 June 2011, stressed the complexity of the current organisational structure of the sector, and the need to facilitate decision-making and reinforce cooperation between the different actors in order to come to a more integrated and competitive EU inland waterway transport. 80% of participants in the online public consultation are of the opinion that the multiplication of national or transnational rules and regulations is an important or very important problem for the mobility of workers (see details in section 3.3.). Indeed, whereas some years ago most workers were generally only active in their native river basin, navigating personnel aboard a vessel nowadays have increasingly diverse origins and need to be increasingly mobile. The current organisational structure and legal frameworks governing the sector have proven to be a major obstacle to addressing these problems. Difficulties related to labour mobility therefore cannot be solved by the sector alone. They have an impact both at the level of the individual workers (barriers to free movement) and at European level (integrated market, regional differences in supply and demand of workers).

This IAR restricts itself to labour mobility issues. It does not address other problem drivers linked to the lack of qualified staff and more globally to lack of sector attractiveness. Increasing sector labour shortages can be further addressed through initiatives at other levels: e.g. supporting innovations aimed at improving physical and mental working conditions, dissemination of good practices of employability policies, IWT sector promotion campaigns, building a continuous recruitment strategy, for instance in the form of a shared funding, to make training of new employees a shared responsibility for all ship-owners XLIII . The need for electronic tools (smart tachograph and an individual crewmembers’ smart card) is addressed under section 3.3.1.2.

1.1.Negative consequences of the problem

1.1.1.Consequences for the IWT sector

Labour shortages in some regions in combination with difficulties related to mobility entails the risk of recruiting personnel that does not have the necessary competencies (see more explanation under section 3.3.1). AQUAPOL points out that the lack of uniform rules hampers effective enforcement, which makes the inland shipping sector vulnerable to illegal practices (e.g. forged documents) that threaten the level playing field. 

Without the safeguard of a solid framework that governs professional qualifications for the whole sector, fierce competition combined with unsolved difficulties described above will also further reduce the attractiveness of the profession to new entrants. In the long-term, this could potentially result in refusal of orders for shipping goods in regions with a shortage of workers. XLIV The resulting loss of reputation in the sector could negatively impact its competitiveness. It may also negatively impact the safety of inland waterway transport. Workers' competencies clearly have a correlation with human errors. Highly skilled workers on board ships have the ability to prevent accidents whereas workers lacking competence can cause accidents. It is important to highlight that when accidents do occur in IWT, they can have far-reaching consequences.

The cause of the “Waldhof” accident can be linked to competencies as an improper load distribution on the ship is considered to be the cause of the Waldhof’s poor stability. Another frequent cause of accidents is miscommunication/language problems, another matter related to skills XLV . As a third illustration of the importance of competence for safety is the increasing importance of Liquid Natural Gas (LNG) as a fuel for inland shipping. It has already been agreed among experts that specific knowledge and skills should be required from crew operating on vessels functioning with LNG.

It should be also underlined that current safety levels in IWT are not only a product of legislation in force but also of practices developed over many years by the profession. Navigation on large convoys or on cruise ships is an example. Although according to the regulatory framework a skipper can navigate these vessels with the patent/boatmaster certificate, shipping companies have put in place a career management system that includes additional requirements in terms of experience and lifelong training. However, increased competition between operators could lead to the degradation of these voluntary practices with negative effects on safety levels.

1.1.2.Consequences for the EU economy

XLVI XLVII The indirect value added of IWT to Europe’s GDP is substantial but not directly visible in official statistics. According to recent studies, the € 2.2 bn turnover in the IWT sector leads to direct and indirect added value of € 13.2 bn, i.e. a multiplier of 6.3. However, the potential of the IWT sector for strengthening the European industrial base is currently not fully exploited. 

Given that logistics, including transport and storage, account for 10-15% of the cost of a finished product, economies of scale provide an incentive for industries to concentrate their production in selected geographical areas where aggregate logistics costs are minimised. This can be achieved by locating production either in the largest markets or along axis where transport costs to the markets are low. Population density and transport costs therefore affect the degree of spreading of manufacturing across a region.

Figure 2: Eurostat statistical atlas: density of population by Nuts 3 region, 2012

Inland waterways play an important role for the location of industrial production capacity. Half of Europe’s population lives close to the coast or to inland waterways (see Figure 2). Since 2008, waterway transport, already at a low level, has fallen most compared to other transport modes (land and air transport) XLVIII . Increased use of inland waterway transport can help to keep the costs for exports low and hence stimulate industrial export orientated activity. In particular inland and sea ports are recognised as attraction poles of industrial activity. The 2014 European Competitiveness Report 'Helping Firms Grow' identifies transport costs associated with export as one of the factors influencing SMEs' decisions to enter foreign markets.

Figure 3: Overlay of TEN-T Inland Waterways with EU gross added value from industrial economic activity excluding construction

As can be seen from Figure 3 most of the regions with a high concentration of industrial activity have good waterborne – maritime and inland waterway – transport links. Many of the industries in these regions can be reached by inland waterways, either alone or in combination with other transport modes.

Comparing figure 3 with Figure 4 showing the untapped potential for transport by inland waterways of export of containerized continental cargo in north-western Europe, allows seeing that many regions with high industrial economic activity also have a high potential for increasing use of inland waterway transport.

Figure 4: Map of untapped potential of containerized continental cargo for export – North-west Europe

XLIX L The map in Figure 4 results from an analysis estimating that if only for the segment of intercontinental container cargo the untapped potential would be realised, the overall volumes transported in the EU by inland waterway transport would increase with 17%, with a resulting decrease in overall logistics costs of 899 million € per year for the industry. Another recent study for the Danube region has identified significant indirect employment effects if the share of IWT transport increased with 20% by 2020. Such increases can be captured by the sector without major investments. Free capacity is still available on the EU’s inland waterways. Even on the Rhine, the EU’s busiest river in the EU’s industrial heartland, transport density can be further increased with 100% without recourse to major infrastructure works.

LI Inland navigation is today a key asset for the manufacturing industry. For instance, inland waterway transport is the dominant transport mode on the Rhine-Alpine corridor, with 54% of the transport share in cross-border flows. However, if the use of IWT in multimodal corridors would not improve or even decrease, and the functioning of the IWT labour market is an important factor for this, the IWT sector’s contribution to the European industrial and the long term growth potential of the EU economy would not develop optimally.

LII As inland navigation is more than twice as energy efficient as road transport, barriers to its full development will also negatively impact the evolution of the overall energy efficiency of the EU’s transport system.

Inland navigation is also a priority for support by the TEN-T and Connecting Europe Facility Regulations. The EU is investing important budgets for the upgrading of Core network inland waterway infrastructure.

Realising growth will also require innovation. The innovation gap has negative consequences for the attractiveness, competitiveness, safety and sustainability of inland waterway transport. Investments and innovation are the most urgent needs for the sector development. However, they will only bring their full benefits if also the market-sided barriers are tackled, including barriers to labour mobility.

3.3.Underlying drivers of the problem

3.3.1. Problem Driver 1: Workers face difficulties with mutual recognition of professional qualifications

Since boatmasters and operational staff on board vessels are covered by different legislative frameworks, these two categories of workers are addressed separately below.

3.3.1.1.Difficulties with recognition of professional qualifications at boatmasters level

National boatmasters' certificates issued on the basis of the EU Directive are not automatically recognized for navigation on the Rhine

The CCNR celebrates this year its 200 year anniversary. The respective areas of competencies between this long established international organisation and the EU have evolved over time and have taken time to clarify. Because of this and because of the difference in the level of minimum standards envisaged for the whole of the EU and those for the Rhine which were more stringent, the Rhine was excluded from the scope of Directive 96/50/EC, which resulted in two different legal regimes for boatmaster certificates. The EU Directive recognizes the validity of the Rhine patent for all EU inland waterways but the national boatmasters' certificates issued on the basis of the EU Directive (hereafter, 'EU boatmasters' certificates') are not automatically recognised for navigation on the Rhine. The Rhine Patent imposes a higher threshold on age, physical and mental fitness, as well as experience and professional knowledge. A comparative table is presented in Annex 4 LIII .

As mentioned above, the CCNR recognizes boatmasters’ certificates issued by other EU countries via bilateral agreements, following voluntary requests submitted by these countries. At present, CCNR recognizes the national certificates of seven non-CCNR member states (Austria, Bulgaria, Hungary, Poland, Romania, Czech Republic and Slovakia), and three out of five CCNR member states (Belgium, Germany and the Netherlands).

Around 15% of the EU boatmasters' certificates are not covered (i.e. 6 Member States) by bilateral agreements and as such are not automatically recognised as valid on the Rhine. The requisites by the CCNR for automatic recognition are considered such an obstacle for some countries, like France (a CCNR Member State), that they have chosen to stay outside the CCNR recognition system. The main issue for France is that it has a different system for calculating professional experience (100 days of navigation time-count as one year, instead of 180 days under RNP). In addition to France, also Croatia LIV , Sweden, Finland, Lithuania and Estonia do not have their EU boatmasters' certificates recognised by the CCNR although these are issued in line with Directive 96/50/EC LV . In total, it represents around 1000 boatmasters. LVI  See Annex 5 for countries that mutually recognize each other's boatmaster certificate.

These bilateral agreements, which are administrative arrangements, also have several inherent limitations for the signatories (10 Member States):

1) Additional conditions are imposed for the certificate to be valid on the Rhine. These conditions LVII mainly concern, the minimum age, the renewal of the physical and mental fitness certificate and the knowledge of specific situations LVIII required on the Rhine. Only Germany is concerned only by the latter one. The other Member States (representing close to 70% of all EU boatmasters) have to meet additional conditions. They are attested by additional documents which must be presented at the same time as the national certificate.

2) The recognition process is based on a country individual request submitted to the CCNR and is a very lengthy procedure due to a thorough assessment of each individual dossier, with potential necessary adjustments in the legal system of the requesting party.

3) There is legal uncertainty regarding provisions for recognising EU certificates on the Rhine. The free movement of boatmasters within the EU is consequently not legally guaranteed even for recognised certificates as the CCNR is free to withdraw recognition. LIX The arrangements do not constitute an international agreement under public international law, involving the international responsibility of the contracting parties. If a change is made in an uncoordinated way, it could justify denunciation of the arrangement. The basis for this challenge is objective but could show a certain complexity of “proving” non-equivalent performance. Furthermore, it is difficult and complex to modernise the existing set of agreements in a coordinated way, as these have been negotiated on a bilateral basis. The profession of inland waterway transport is in constant evolution. Technologies such as River Information Services are under constant evolution, with the introduction of increasingly sophisticated navigational aids with a future perspective of evolution towards (semi-) automatic navigation. New vessel concepts are emerging (e.g. modular push-barges, new markets are under development (e.g. container transport), new vessel technologies require special competencies (e.g. LNG-fuelled vessels) and new training tools are under constant development (simulators).

Although the mutual recognition process initiated by the CCNR has to a significant extent enhanced labour mobility for boatmasters in the EU, it does not allow the full mutual recognition of boatmasters' certificates across the EU's inland waterway network and the system is difficult to adapt to evolution in the sector.

The legal frameworks are insufficiently focused on proven competencies

Under the existing system set up under the RNP and Directive 96/50/EC, it is possible to become a boatmaster after respectively 5 and 4 years of experience. Both Directive 96/50/EC and RNP require to pass an examination of professional knowledge with a specific list of subjects that have to be included in examination. RNP requires a theoretical exam whereas the EU Directive does not specify the method of examination. As a result, the majority of boatmasters navigating on the IWT network does not pass a practical examination for obtaining their navigation licence. The external evaluation pointed out that sailing records give no indication about navigation skills acquired. For instance, hotel crew on passenger ships can accumulate sailing time records without acquiring any navigation experience. The evaluation concluded that it is necessary to verify through a practical exam whether the required level of competence has effectively been reached. Competence-based standards have to be set for examination in order to improve the qualification of workers and to enhance trust necessary for eliminating barriers to labour mobility. LX  Regarding this latter aspect, it should be noted that in the last two decades training and education systems in general have been moving away from the traditional focus on knowledge towards more competence-based teaching and assessment. This reflects the desire to assess the knowledge and practical skills of candidates with differing abilities, cultural and linguistic backgrounds, LXI with the objective of favouring mobility. In a competence-based approach, the criterion for awarding qualifications is not duration of experience – it is based on whether candidates can prove they have mastered competencies – the skills, abilities, and knowledge required for the function. The best example illustrating how a competence-based system could facilitate cross-border mobility is the current dead lock between France and the CCNR over the counting of navigation experience as a criterion for recognition of boatmasters' certificates.

The existing possibility provided by RNP to exempt parts of the Rhine patent examination if certain subjects have already been tested in the framework of examination carried out by recognised education and training institutes LXII is not available in the EU legislative framework and is also under-used on the Rhine. In the absence of common competence-based standards for examination that could be applied by education and training institutes and backed up by a quality assurance system, it is understandable that the administrative authorities wish to keep responsibility for candidates' full assessment before issuing boatmaster' licences.

As a result of the fact that for both the EU and CCNR systems the point of departure is experience rather than competence, competencies obtained outside the IWT sector are only taken into account to a very small extent. The RNP and Directive 96/50/EC allow for reductions in required professional experience for obtaining the Rhine patent or boatmaster certificate respectively, as a result of experience acquired on a seagoing vessel. The RNP and Directive 96/50/EC allow a maximum reduction of two and three years respectively. However, the actual reduction allowed varies from country to country. LXIII Stakeholders in general consider that the required IWT experience for seafarers is too stringent, in particular on the Rhine and for countries applying a smaller reduction than the maximum allowed. Potential career changers from sea to inland navigation may need to spend two years on board of inland navigation vessels in a lower function and at reduced wages, which does not make the career switch attractive. It is a real problem in particular as the sector suffers from insufficient job attractiveness. A competence-based approach applied to the boatmaster exam would offer much more flexibility for lateral entrants, regardless of their background.

3.3.1.2.Difficulties with recognition of professional qualifications of operational staff

There is no EU sectoral legislation covering operational workers and there are limitations to the CCNR recognition system

Functions on board the vessel for operational staff are defined at national level and at the level of the River Commissions. At European level, there is no EU sectoral legislation for the recognition of professional qualifications for operational workers below the level of boatmaster, which represent around 65% of IWT workers LXIV .

Below the level of boatmaster, the main functions found in the manning regulations LXV are the following: 'deckhand', 'apprentice', 'boatman', 'able boatman' and 'helmsman'. The list is presented in hierarchical order and may be considered as the classical career path. Besides these functions, for certain convoys the function of 'engineer' also appears but this function is part of a distinct career. 'Deckhand' and 'apprentice' are the two lowest levels of entry into the career for which only minimum age and medical requirements apply. 'Boatman' is the first level for which specific skills are needed and the only one on which IWT education focusses. The set of competencies expected from a boatman is already very wide and demanding (it covers navigation, cargo handling, engineering, maintenance, communication, safety, operation of the ship) LXVI . ‘Boatman’ is also the minimum qualification which is required onboard of any vessels in addition to the boatmaster. Boatmen obtain the qualifications of 'able boatman' and 'helmsman' through additional navigation experience. Annex 6 shows the existing functions and an overview of the professional requirements for these functions in the main manning regulations LXVII . The national differences in defined functions and related professional requirements prevent a common understanding of what a function stands for, and what qualifications are required to carry out the function. 

The CCNR recognizes Service Record Books (SRBs) issued by other EU countries via a multilateral Administrative Arrangement LXVIII , following voluntary requests submitted by these countries. Service record book record the experience of crew on board ships. They are paper formulae that are manually filled out by the boatmaster and validated by authorities. SRB are intended to attest experience of crew members. At present, CCNR recognizes the SRBs of seven non-CCNR member states (Austria, Bulgaria, Hungary, Poland, Romania, Czech Republic and Slovakia), and three CCNR member states (Belgium, Germany and the Netherlands).  

Half of the EU Member States having inland waterways remain outside the scope of the recognition system. On the interconnected network, this includes again in particular France as well as Croatia, which represent more than 11% of the total operational workforce. Around 5% could be added if we consider workers from Estonia, Finland, Sweden, Lithuania. LXIX  

The agreement has also inherent limitations for its signatories (i.e. 10 Member States representing more than 55% of all operational workers):

1) Need for alignment to CCNR standards. SRBs covered by mutual recognition contain a separate page reserved for the listing of qualifications obtained in compliance with Rhine regulations. This page may only be filled in by a competent Rhine authority and the qualification listed on this page is the only qualification valid on the Rhine. To list the qualification in compliance with Rhine regulations, the competent Rhine authority only takes account of the number of years of experience the boatman has accumulated. It does not recognise the qualifications obtained through training and education outside the CCNR Member States.

2) The accession to the multilateral agreement is based on an individual request of a country, with potential necessary adjustments in the system of the requesting party. In addition, as indicated under paragraph 1), for workers from non-CCNR member states, it remains necessary to ask individually for the recognition of their qualification. There is no automatic recognition.

3) Regarding the provisions for the mutual recognition of SRBs, there is similar legal uncertainty and similar difficulties to adapt the system to evolution in the sector as for the bilateral agreement for the recognition of boatmasters' certificates.

At EU level, the general Directive 2005/36/EC on the recognition of professional qualifications is applicable to all EU State nationals LXX wishing to practice a regulated profession on a regular basis (establishment) or on a temporary basis (provision of services), in an EU Member State other than that in which they obtained their professional qualifications. IWT professionals do not fall under the system of automatic recognition foreseen for some specific professions but under the general system. This implies that each worker that wishes to have his or her professional qualifications recognised needs to introduce an individual request. Moreover, compensation measures could possibly be imposed by the host Member State to the professional wishing to exercise a regulated profession there, if the professional's qualifications are substantially different from those required in the EU Member State in question. The compensation measures may differ from one state to another, depending on the professional qualifications required in each state. With regard to the temporary provision of services, in most cases the qualifications do not have to be approved before the provision of service and only a prior declaration to the competent authority of the host country may be required. However, if the profession involves a potential risk to safety, as could be argued for IWT transport, the host States may verify the qualifications prior to the first provision of services. In this case, it is possible that each host country imposes different compensation measures on the IWT professional. Overall, it seems that the application of the general system under Directive 2005/36/EC is too burdensome, not streamlined and open to different requirements by each State concerned in a largely cross-border industry such as IWT. That the general directive is currently under-used in that given field seems to provide further evidence of this.

The recognition systems are not sufficiently based on proven competences

In the context of the recognition systems as described above, many potential candidates have difficulties in valorising their qualifications when working across borders as IWT administrations are reluctant to recognise qualifications obtained elsewhere in the EU.

LXXI According to an ETF representative, one of the aspects most frequently criticised regarding the existing systems for establishing minimum requirements concerns the qualifications of –candidate-boatmen. You can qualify as a boatman just by accumulating three years of sailing time. However there is no requirement for any training content in those three years, no log of the work carried out and no examination at the end.

LXXII In the absence of competence-based standards, the process of mutually recognising training programmes is difficult as there are substantial differences in EU Member States’ training requirements, both in terms of the share of theoretical and practical training, and the duration of the training programme. The complexity of putting in place such a recognition process was experienced by the CCNR with the education institute of Decin. Non-CCNR countries, in particular those with training and education institutes, underlined on several occasions in CEG meetings how problematic the absence of such recognition is for the mobility of their workers and for the attractiveness of the profession.

Workers are facing downgrading as a result

The lack of harmonisation represents an obstacle to labour mobility because it results in some workers being granted a lower function on the Rhine than in their country of origin and thus a lower salary. The external study LXXIII estimated that around 13% of all operational workers, are already now directly affected by such 'downgrading'. The main types of crew members concerned are helmsmen downgraded to boatmen, or able boatmen downgraded to boatmen. Reasons for downgrading crew members include the diverging approaches concerning the functions acquired through professional experience only LXXIV , differences in the requirements regarding professional experience after completing a training course LXXV  and the fact that education or training is not recognized by the CCNR. 20% of boatmen are downgraded to deckhands because of this latter reason whereas only 0.6% of their counterparts in CCNR countries experiences similar situation. LXXVI  

As explained under 3.3.1.1 for boatmasters, the fact that the reference point for granting IWT qualifications is sailing time as opposed to the level of competence does not allow a level playing field. The figures mentioned in the previous paragraph only reflect the number of operational workers that have actually suffered from downgrading. Much more workers would face such downgrading if they would decide to become mobile. These difficulties therefore also have a substantial deterrent effect on mobility. Close to 40% of all operational workers work on the interconnected IWT network outside of the Rhine corridor and could therefore potentially be concerned.

LXXVII Finally, as also pointed out under 3.3.1.1 for boatmasters, again because the basis for granting IWT qualifications is sailing time rather than competence, early competencies obtained outside the IWT sector are only taken into account to a small extent. The RNP and most EU countries take into account experience from the maritime sector for the qualification of boatman but still require one year of inland navigation experience.

LXXVIII The external study estimated that the number of workers from the maritime sector switching careers to IWT per year is very low. The amount of workers willing to change their career from maritime to IWT is obviously higher, as the existing requirements are regarded as a mobility barrier. Some stakeholders have repeatedly pointed out that persons from outside the waterborne sector should also be given the possibility of becoming a qualified boatman in a shorter period. In the online public consultation, 43% of respondents considered that difficulties with recognising relevant professional qualifications of workers from outside the sector was 'relevant' or 'very relevant' to the problem of restricted labour mobility.

Specific difficulties with Service Record Books as a tool for recognition and enforcement

SRBs are a source of recognition and enforcement problems due to their content and format.

The difficulty of the recognition of information contained in the SRBs and, in particular, the way navigation time and education are valued has already been addressed under the previous section. Furthermore, in the absence of a coordinated or central registration system it is possible for one person to be in possession of several SRBs. As a result, in some cases, entries in the SRBs are regarded as not fully trustworthy. The fact that it is easy to impede verification makes efficient or effective enforcement difficult. Finally and in close connection, it is also considered that the present paper format of SRBs is largely outdated and generates administrative burdens for both the authorities in charge of verification and for the crew members. With no secure mechanism for registering data, manipulation of SRBs will remain easy. It is clear for all stakeholders however that modernisation of SRBs is needed to alleviate administrative burden and improve mobility. Such a development is also necessary as regular abuses create unfair competition between those that play by the rules and those that do not, negatively affecting working conditions, attractiveness of the profession and safety. As mentioned under section 5.1, the decision to transition to an electronic version of these documents has been postponed and therefore the measure has been discarded in this IAR. The issues of harmonisation of SRBs content and registration remain however part of this IAR as first steps to tackle the problem.

3.3.2.Problem driver 2: Knowledge of Specific Situations (KSSs) may create unnecessary difficulties for boatmasters operating on certain river stretches

Member States may require boatmasters to obtain a certificate that attests their knowledge of the local situation in order to navigate on certain river stretches in Europe  LXXIX .  An overview of EU inland waterways where Knowledge of the Specific Situations (KSSs) is required and the procedures to obtain the relevant KSS certificate are presented in Annex 7. On the Rhine, for instance, KSS is required on the German sector between Iffezheim and Spijksche Veer (more than 500 km). In cases where boatmasters do not possess the relevant KSS-certificate, pilots need to be hired to navigate the stretch.

The external study concluded that 28% of total IWT performance in Europe is subject to KSS. LXXX They estimated the costs of KSS for the IWT sector (considered as the total costs of hiring pilotage services for this purpose) at around €8 million in 2011 LXXXI . The Rhine, Seine and Danube are the main contributors. LXXXII Mecklenburg-Vorpommern, Normandy, Île-de-France and Croatia are most affected in terms of extra percentage of transport costs; up to a maximum of 10% of the total transport costs.

KSSs are intended to increase safety in inland navigation. At the same time, the implementation of KSS regimes inevitably affects labour mobility. A boatmaster who wishes to acquire KSS has to make the required journeys at a lower function and then generally has to pass an examination before the competent authority. Alternatively, there are pilotage costs.

Although there can be no trade-off between labour mobility and safety - a high level of safety must prevail - there are two specific sub-problems related to KSSs which negatively affect labour mobility. Alternative approaches could offer similar levels of safety whilst removing unnecessary barriers to mobility:

1. No clear criteria for the definition of KSS: Under Directive 96/50/EC, Member States can set KSSs and unilaterally change them subject only to a non-binding consultation with the Commission. The absence of clear criteria for defining KSSs leads to a lack of transparency and legal uncertainty regarding the introduction and modification of KSSs. It may also have resulted in too many KSSs, which negatively impacts labour mobility. In the online public consultation, when asked whether KSSs in force in Member States are justified in view of the criteria considered relevant by the CEG (hydro morphological characteristics, absence of marking systems and local traffic regulations), 50% of respondents declared that KSSs are not justified and 32% judged them as only partially justified. Moreover, the fact that the evolution of River Information Services (RIS) are not taken into account in this context is confirmed by responses to the public consultation. 70% are of the opinion that the information provided by RIS could 'always' or 'sometimes' replace the need for KSSs.

2. Examination requirements to obtain a KSS certificate:

The application of the KSS regime under Directive 96/50/EC has also resulted in differing practices regarding requirements for proving knowledge of a specific situation (see Annex 7). Furthermore, the exams for KSS may only be taken in the local country or, in the case of the Danube and Rhine, any Danube Commission or CCNR member country, which requires large travel distances. Examination is often conducted in the local language, which is a further difficulty to passing the KSS examination if language skills are lacking. The external study LXXXIII concluded that taking into account transport costs, working time lost travelling to the exam location, language course costs and KSS exam costs, it is estimated that a worker would lose in certain cases, such as Romania and Bulgaria, up to 57-66% of their monthly salary.

1.2.Attempts by the sector to tackle the problems 

To facilitate mobility, the CCNR has recognized boatmasters’ certificates issued by other EU countries via bilateral agreements since 2008 LXXXIV . The CCNR has also signed a multilateral Administrative Arrangement LXXXV which allowed the signatories to recognize the Service Record Books issued by their respective competent authorities. The mechanisms for mutual recognition set up by the CCNR have however several inherent limitations (see 3.3.1.2). They were seen from the beginning by the stakeholders as a transitional step towards a new EU initiative and harmonized standards at EU level including the Rhine. The objective and composition of the CEG set up in 2012 as well as the constant fruitful cooperation of its members (see 2.3) confirms that view.

In 2013, the EU and CCNR signed an Administrative Arrangement LXXXVI , which further endorses that approach, as presented in the box below.

This cooperation is part of a broader approach under which uniform and high level technical standards for IWT will be adopted by a committee (called 'CESNI') LXXXVII composed of EU IWT stakeholders and consecutively integrated both into the EU legal framework and Rhine regulations. The Commission proposal LXXXVIII for technical requirements for IWT vessels, currently discussed by the EU co-legislators, already builds on common CCNR and EU standards. The European Parliament in its first reading strongly supported the use of CESNI and the General Approach reached on 11 June 2015 in the Council makes reference to such future CESNI standards. For the sake of coherence, a similar approach should apply to professional qualifications standards as the evolution of competencies has to go hand in hand with the on-going evolution of technical requirements for vessels.

In the online public consultation, stakeholders were also asked to assess the CCNR system of recognition agreements. 71% of the respondents stated that mobility barriers for boatmasters from non-Rhine EU Member States operating on the Rhine have only been partially or inadequately addressed. Regarding the recognition of SRBs, 40% of respondents stated that this system only partially serves its purpose, 21% considered that it does not serve its purpose, and only 13% considered that it serves its purpose fully. 

The social partners are also of the opinion that action is now to be taken by the EU. They encourage the Joint EC and CCNR's initiative to establish a legal framework regarding training and certification for the European IWT sector. LXXXIX They have expressed the need for a modern and flexible regulatory framework, which will allow the development of safety together with fair and competence-based access to the profession. EU intervention is needed as the goal is qualified as 'ambitious', and the process 'complex', requiring the participation of all stakeholders (regulatory actors, training institutes,…).

The European network of nautical schools (EDINNA), in close consultation with other stakeholders, has been working on the elaboration of Standards for Training and Certification in Inland Navigation (STCIN) XC in order to reach a level playing field in the IWT education and training sector. At the current stage, STCIN are considered as recommendations for common standards and could be used by EDINNA members to evaluate their situation with regards to compliance with STCIN. However EU legislative action by the EU is seen as necessary in order to effectively achieve harmonised education standards through the implementation of STCIN, by rewarding compliance with standards with mutual recognition and facilitation of certification.

1.3.Summary of the main problem and its underlying drivers

Figure 5: The main problem and its underlying drivers

1.4.Who is affected by the problem?

The main affected parties are boatmasters, other crew members, workers from outside the IWT sector, ship owners, barge operators, Member States regulators and enforcement bodies, river commissions, UNECE, education and training institutes, industry using IWT and freight forwarders. A description of these parties and their key interests are described in Annex 8.

3.7.How would the problem evolve, all things being equal (baseline scenario)

According to the baseline market outlook for inland waterway transport, there will be an increasing demand for IWT services, in particular in container transport. IWT performance is therefore expected to rise XCI . However, it must also be taken into account that other modes of transport will also show an increase in their performance. XCII In order to reach modal share growth for IWT compared to road and rail, additional efforts are needed.

Due to increasing demand for transport in the future, the IWT labour force will need to grow. However, the available labour force is expected to decrease in the long term due to the ageing workforce XCIII and because young people face difficulties to enter the profession. This results in a gap between the required and available amount of mobile workers.

As shown in figure 6 and further elaborated in Annex 2 XCIV , regional differences in the demand and supply of workers between corridors are expected to increase in the long-term. On the Danube corridor and the East-West corridor, by 2050 there will be a surplus of about 2,500 and 4,000 workers respectively. The Rhine corridor however will face a shortage of about 10,000 workers. On the North-South corridor, the situation will be balanced until 2020 and thereafter a shortage of labour will start too, gradually increasing to a shortage of about 3,600 workers by 2050. Figure 6 demonstrates that gaps between supply and demand develop slowly over decades. In the longer term, gaps between supply and demand will however become more pronounced, especially on the Rhine corridor and regional differences will further increase XCV . Only in the short term, the so-called 'hidden reserve', not taken into account in figure 6, may to some extent cushion the shortages. 

Figure 6 Evolution of the gap between supply and demand of workers in IWT per corridor (2013-2050)

Source: Panteia (2014)

It is likely that the obstacles to mutual recognition of professional qualifications of boatmasters and operational crew will remain. This is because EU Member States, aside from Croatia and potential new Member States (e.g. Serbia), will stay outside of the existing CCNR system of mutual recognition, both for boatmasters and operational workers, due to the unfavourable balance between the need to adapt national regulations unilaterally to the Rhine system which is not offset by the economic interest in obtaining recognition.

For boatmasters, the difficulties in terms of recognition of qualification as outlined under 3.2.1.1. are expected to remain unchanged under the baseline scenario. The recent Council Directive implementing the European Agreement concerning certain aspects of the organisation of working time in IWT XCVI , which entitles navigation personnel to a free annual health check, is not expected to alter the baseline scenario with respect to the frequency of medical check-up for boatmasters as this agreement is only applicable to employees and a very large proportion of boatmasters is self-employed.

For operational workers, recent efforts have led to the conclusion of bilateral administrative arrangements for the recognition of the professional qualification of boatman acquired by training delivered by one institute in Romania and another one in the Czech Republic. The process is currently intended to be limited to these two education institutes. It is nevertheless plausible that if it were decided that no action would be taken at EU level, other bilateral agreements could be signed in the long-term for a limited number of education institutes of countries that signed the SRB multilateral agreement. Mobility of a limited number of operational workers from these countries to the Rhine would be facilitated as a consequence. In the absence of harmonisation of professional training objectives at EU level, it is nevertheless likely that the number of education and training institutes that have their education standards considered to be equivalent to those of Rhine countries will remain limited. Globally, both for boatmasters and for operational crew, it is unlikely that recognition would be eased substantially under the baseline scenario, as it would continue to be based on experience requirements rather than on competence-based requirements. As such, the related difficulties with mutual recognition of professional qualifications as identified in section 3.2.1 would continue to exist.

As a result of the increased transport demand and the 'hidden reserve' navigating in order to bridge the gaps between labour demand and supply, the external study estimated XCVII that the amount of accidents increases from around 1,200 accidents in 2014 up to 1,600 accidents in 2030 and 2,200 accidents in 2050, as presented in Figure 7 below.

Figure 7        Development of the amount of accidents per year (2013-2050)

Source: Panteia (2014), based upon the Problem Definition (Panteia, 2014) and NEA et al. (2011)

Furthermore, the legal framework governing IWT qualifications will remain fragmented, including a specific system for the Rhine managed by the Rhine authorities falling outside the scope of the EU legislative framework. The recognition of qualifications for operational workers through Directive 2005/36/EC is not expected to increase as it does not offer the appropriate response to regular cross-borders activities, as mentioned in section 3.3.1.2. Under the CCNR administrative arrangements, the inherent limitations outlined under section 3.2.1 will remain.

The 2013 Administrative Arrangement between the EU and the CCNR aimed to work on common standards between the EU and the CCNR and the on-going work on common Standards for Training and Certification in Inland Navigation (STCIN) would in itself not be able to remove the obstacles to mutual recognition of professional qualifications. The Arrangement and STCIN work were set up with the goal of incorporating the resulting work into an EU legal framework. Without such a framework, the resulting work would not have the legal authority to ensure mutual recognition of professional qualifications.

As far as KSS are concerned, based upon forecasts of future tonnage transported in IWT XCVIII , the external study XCIX for the assessment of impacts highlighted that the tonnage affected by KSS is expected to increase C . For 2011, around 23 million tonnes were transported on waterways affected by KSS. This figure is expected to increase to 30 million tonnes in 2030 and up to 42 million tonnes in 2050. As the volumes of cargo transport subject to KSS will double in the period 2011–2050, the Net Present Value (NPV) of costs due to KSS increases rapidly as well. In 2030, the sector will have paid around € 125 million for pilotage and € 215 million in 2050. See Figure 8 for a breakdown of the costs per river basin CI .

Figure 8 Accumulated Net Present Value of Costs due to KSS per river basin and total, base year 2013

Source: Panteia (2014)

3.8.Does the EU have the right to act?

3.8.1.Legal basis

The general competence for this initiative derives from the aim to complete the internal market as stipulated under Title I 'Internal Market' in Article 26 of the Treaty on the Functioning of the European Union. It is also in line with EU competence under Title VI 'Transport' of the Treaty on the Functioning of the European Union (in particular Article 91). The applicability of Title VI to transport by inland waterway is stipulated in Article 100.

3.8.2.Subsidiarity 

The necessity of an EU initiative aiming at the harmonisation and mutual recognition of professional qualifications is justified because the identified problems cannot be sufficiently addressed by Members States acting alone. The activity of inland navigation and all related aspects of transporting goods over the IWT network are generally transnational. Whereas Member States could enact national transport rules, they cannot do so for cross-border transport. Moreover, the introduction of different national legislation in each Member State undermines the functioning of the internal market for goods and workers. The completion of the Trans-European Transport Network would be jeopardised if barriers for its efficient use would not be addressed. Differences in legal regimes for professional qualifications in IWT throughout the EU cannot be entirely solved by the Member States individually, neither in the framework of international conventions, nor by the industry alone. The existing frameworks do not provide sustainable solutions for labour mobility problems in the long term. This results in suboptimal functioning of the internal labour market and legal uncertainty. These problems exist for both boatmasters and operational workers. Therefore, extending European action to operational workers is justified. This initiative would also enlarge the area of EU intervention to the Rhine river basin located on EU territory. Therefore, the initiative does not only provide added value compared to national or River Commission level action but is also necessary to achieve a well-functioning internal market at the level of the EU and to ensure the full contribution of IWT to Europe's industrial development.

The opinions and demands expressed by Member States and other relevant stakeholders during the wide consultation process and at various expert meetings on the issues above – i.e. the extension of EU action to the Rhine river basin, to operational workers and to competence-based standards for examination of future boatmen and boatmasters, including via education and training - underpin the justification for EU action in relation to professional qualifications in the IWT sector.

4. Objectives

The general objective is to improve the functioning of the IWT labour market to help ensure the sector can play its role in contributing to EU energy efficiency, growth and industrial development goals.

The specific objective is to facilitate labour mobility in the IWT sector by ensuring that qualifications of skilled workers are aligned with the competencies needed on-board. This leads to the following operational objectives:

Ensure mutual recognition of professional qualifications of workers

Ensure that KSS requirements are proportionate to their safety goal and do not unnecessarily hamper labour mobility

In Annex 10 a visual overview is given of the objectives and the link to the identified problems. The objectives are in line with other main EU policy objectives, such as the internal market and free movement of workers. They contribute to four of President Juncker's priorities: 'a deeper and fairer internal market with a strengthened industrial base','energy union', 'a new boost for jobs, growth and investment' and 'a stronger global actor'.

5.Policy options

The stakeholder consultation, the expert meetings, independent research and the Commission's own analysis have allowed the Commission to identify different policy options. The following process was applied for establishing the policy options:

Step 1: Identify policy measures addressing the problems (considered policy measures) and those which can be discarded after a preliminary assessment

Step 2: Combine the considered policy measures into policy options and identify options which can be discarded

5.1.Step 1: Considered policy measures & mapping with problem drivers

Problem driver 1: Workers face difficulties with mutual recognition of professional qualifications

Problem driver 2: Requirements on KSS may unnecessarily restrict labour mobility

Discarded policy measures

Several policy measures have been discarded after a first preliminary assessment (see Annex 11 for underlying justifications): rules for navigational workers operating on recreational boats, the mandatory issuing and mutual recognition of certificates for all skilled crew members after examination (in particular able boatmen and helmsmen, in addition to the boatmen), the introduction of the electronic service record book and electronic logbook, harmonised/identical EU wide requirements for professional qualifications (as opposed to minimum requirements), centralised decision-making on KSS, and no exemption for crew operating exclusively on non-interconnected waterways.

Stakeholders' opinions on the retained measures

In the framework of the CEG meetings, stakeholders had not only the opportunities to express their opinion on most of the above measures but were also closely associated to their formulation. Generally, stakeholders in CEG, most often represented at expert level from Member State authorities, are all supportive of measures 2, 3, 7, 8, 9, 10, 12, 15 and 16. Some measures or some of their sub-elements are particularly strongly supported by certain stakeholders e.g. modular system for large convoys under measure 2 by Danube countries, new proposed frequency for medical check-up by experts from the Netherlands and France, measure 8 (in particular the requirements for exam for candidates using the experience path) by experts from ETF, measure 10 by AQUAPOL and experts from the Netherlands, measure 12 by experts from the Netherlands, measures 3 and 9 by Edinna and experts from non-CCNR countries having IWT education and training programmes (e.g. Czech Republic and Romania), measure 15 by experts from Austria. Experts from some non-interconnected countries (e.g. United Kingdom and Sweden) also expressed their agreement with measures imposing common standards, subject to understanding that the possibility of exemption for crew non-interconnected countries would subsist. Furthermore, some reservations have been expressed by one expert from EBU regarding measure 8 and by experts from France, Germany and the United Kingdom regarding measure 16.

5.2.Step 2: Combining the policy measures into policy options 

To address the problem and its problem drivers in full, besides the business as usual scenario (option A), two policy options have been retained (option B and C), with option C subdivided into two suboptions:

Policy option A: Baseline scenario

Policy option B: Initiatives taken by the sector with support of the EU

Policy option C: Recognition of professional qualifications based on minimum competence requirements for boatmen and boatmasters,

oC1 including examination standards for training and education institutes,

oC2: excluding examination standards for training and education institutes.

Each option is composed of a series of considered policy measures and addresses all the problem drivers. As such, all policy options constitute true policy alternatives. Alternative combinations of these policy measures are limited as the nature of the EU intervention is different (via legal act or not) and coherence of the new system is to be ensured (see also hereunder 'discarded options').

Under option A, no new EU action is proposed.

In option B, the emphasis is on initiative taken by the sector – with EU support – as regards mututal recognition and also a Commission Recommendation on KSS is proposed to ensure all problem drivers are addressed. The rationale behind this option is to examine the impact if the sector (Member States, River Commission, Social Partners) would address the labour mobility problems by themselves by exploiting to a maximum extent the existing organisational and legal frameworks.

Option C consists of a regulatory intervention for mutual recognition of professional qualifications for IWT workers at EU level, with minimum competence requirements for boatmen and boatmasters. It also introduces binding EU criteria framing the designation of KSS and allow Member States to organise exams and issue authorisation for all KSS in Europe, whilst leaving the responsibility for defining the criteria and exam content to Member States concerned by the river stretches for which KSS is required. This option has been introduced to analyse the effect of replacing the 24 years old EU legal framework by new legislation that builds upon the new governance model for inland waterway policy developed under the NAIADES II programme and that tackles the root causes of remaining barriers to labour mobility in the sector. Two variants have been introduced for Option C in order to examine the impact if the proposed legislative framework would not establish standards for training institutes:

Option C1 ensures the uptake of these competence based-standards through exams carried out both by administrative authorities and by education and training institutes, to prevent that candidates with a diploma from an education institute have to go again through a set of examinations to obtain the certification of their qualifications.

Option C2 consists of the uptake of competence based-standards only through a mandatory administrative examination.

The table below shows how considered policy measures are packaged into the various policy options.

Discarded policy options

For the sake of clarity and to take account of subsidiarity concerns, only a limited number of policy options have been retained. Other options have been examined thoroughly but have been discarded because they would have represented only minor variations of the retained policy options, because they would not consistently address all the problems identified or because they would not have been consistent with the principle of subsidiarity.

For example, the option to adopt minimum standards identical to the Rhine standards or to those of the Directive 96/50/EC without a competence-based approach was discarded from the outset as it would not tackle adequately the problem linked to the lack of proven competencies in the inland waterway sector, as described in section 3.3.1. (knowing that scope and level of minimum standards in legal instruments is different). Action towards a competence-based approach is also a necessary move towards a modern qualification policy and the standard approach to qualifications in the European labour market. In the last two decades training and education systems in general have been moving away from the traditional focus on knowledge and experience towards more competence-based teaching and assessment, in particular in the field of transport. This reflects the desire to assess the knowledge and practical skills of candidates with differing abilities, cultural and linguistic backgrounds CVII , with the objective of favouring mobility. This is also expected to better accommodate future trends in man-machine interface in the context of training and assessment. The approach is in the line of the Recommendation of the European Parliament and of the Council on the establishment of the European Qualifications Framework for lifelong learning CVIII  

Also, the possible option to introduce mutual recognition of competence-based professional qualifications for boatmasters only, in combination with only soft instruments for boatmen, has been discarded as it would not have been a coherent approach and because of the limited overall impact. There are synergies between the regulatory measures for operational crew and boatmasters, which would be lost if only boatmasters would be addressed. This is particularly the case for the competence-based system which should be seen as a global approach to crew qualifications. Not addressing operational crew through EU regulatory measures would result in a much lower global impact as only one third of the workers are boatmasters and many of them already enjoy mutual recognition of their qualifications through the existing legal frameworks.

A third example of discarded option is a 'fully harmonised competence-based legal framework for operational workers and boatmasters on the whole EU territory'. Adopting EU requirements for qualifications in a uniform manner (identical instead of minimum requirements), including for KSS, and extending the requirements to crew working on non-connected inland waterways has been discarded for reasons of subsidiarity and proportionality. As a last example, the option of stopping all current EU action in the field was discarded. EU action is needed because there are problems which need to be addressed as shown by this impact assessment. Stakeholders are asking for EU intervention and the Commission CIX  has already announced its intention to act under the NAIADES II framework.

Stakeholder support for the retained policy options

Stakeholders have been extensively consulted on the policy options on several occasions to ensure the largest possible outreach. The CEG has been intensively involved in the process of the formulation of the options. They are most supportive of option C and more specifically of option C1. There is strong support for a regulatory competence-based approach, including practical exams for boatmasters and exams for boatmen. They support EU criteria framing the use of KSS. The CEG is not in favour of option A and judges option A (in particular the CCNR administrative arrangements) as only a transitory step towards EU regulatory action (option C). In the online public consultation, the wider inland waterway stakeholder community was targeted. With regard to mutual recognition of professional qualifications, stakeholders do not favour keeping the CCNR scheme of bilateral/multilateral agreements as the main regulatory framework (option B): only slightly more than 10% of the respondents agree that this scheme fully serves its purpose of removing labour mobility barriers. It is seen as a transitory instrument as a suboptimal response to the substantial shortcomings of the current EU legal framework which has not been revised since 1996, pending further action at EU level. EU mandatory requirements for professional qualifications and training standards (option C1) receive support from around 90% of the respondents (who find the measure either “somewhat appropriate” or “very appropriate"). The introduction of KSS related measures also receive large support from the respondents. Section 5 of Annex 1 provides more detailed information (e.g. on support per stakeholder category).

2.Analysis of impacts

Each policy option has been analysed in terms of its economic, environmental and social impact against the baseline scenario. Where possible, quantitative estimates are given. Because of the nature and diversity of the IWT sector and the lack of quantitative data, the calculations and assumptions needed to be aggregated and sometimes generalised. Thus, while the quantified estimates do indicate a trend-line, caution is needed in the interpretation of the figures. This is the reason why the quantitative estimates are often presented as being indicative or a means to illustrate the points made in the qualitative assessment. Under each section only measures are presented for which an impact has been identified or for which a specific explanation was considered useful. The impacts for option B and C (and when relevant making distinction between C1 and C2) are presented compared to the baseline scenario (option A).

6.1.Social impacts

2.4.1.Impact on labour mobility

A)Impact on labour mobility due to the measures on mutual recognition of professional qualifications

Option B

Boatmasters and workers entering the profession from outside the sector: no effect on labour mobility is expected as no specific measures are foreseen.

Operational workers: the introduction of CTT or CTF as proposed under amended Directive 2005/36/EC (measure 6) will have a positive impact on mobility. The impact however is expected to be rather small since CTT/CTF is a voluntary agreement on common standards for operational workers' qualifications and there is high uncertainty about the use of exemptions, which can be easily invoked by Member States. The adoption of a CTF/CTT in the IWT sector does not exclude maintaining parallel national training structures in the Member States. Training/examination schemes that are not elaborated according to CTF/CTT could remain valid (a) in the Member States opting-out or, (b) in the Member States adopting CTF/CTT. Workers who obtained their qualifications under these schemes would not be able to benefit from the mobility offered by CTF/CTT (in Member States that have adopted CTF/CTT), but could still exercise their profession in Member States by making an application under the general system of Directive 2005/36/EC which as explained in point 3.3.1.2 is rather burdensome in a cross-border industry such as IWT. In addition, CTF/CTT cannot address a number of supporting or organisational aspects that would need to be regulated for IWT professions in order to facilitate the recognition of qualifications e.g. the procedure for obtaining and checking SRBs. Finally, it is likely that the introduction of CTT or CTF would co-exist with the CCNR multilateral administrative agreement (measure 5), which would further fragment and complicate the framework for mutual recognition of qualifications. Alternatively or additionally to CTT/CTF, a CCNR multilateral administrative arrangement for the recognition of qualifications for crew members under boatmaster level (measure 5) could also have a positive mobility impact, though this is also expected to be minor as access would be limited to those that have signed the administrative arrangement for SRBs and the limitations inherent to the form of the arrangement as described under 3.3.1.2.will remain.

Option C

Boatmasters:

Option C is expected to significantly affect labour mobility in a positive way due to measures 2 and 3, in particular as regards the recognition of EU boatmasters' certificates on the Rhine.

Impact on labour mobility due to medical check-up frequency requirements: the impact will be limited, as the estimated difference in the yearly number of boatmasters entering and exiting the market resulting from changes in frequency (available workforce) is very small. CX  

Impact on labour mobility due to competence-based minimum requirements and mutual recognition of related boatmaster certificates: 

As the existing EU Directives already ensure mutual recognition in EU Member States with the exception for the Rhine, the most substantial impacts due to mutual recognition of boatmasters' certificates is expected on the Rhine River, with benefits for all Member States issuing EU boatmasters' certificates.

6.6% of the total estimated boatmaster workforce CXI and around 15% of the number of boatmasters working on the Rhine corridor could benefit from an automatic recognition of their qualification CXII if EU certificates are recognized on the Rhine. 65% of these boatmasters operate on interconnected IWT network (in particular from France and Croatia) CXIII and the remaining 35% come from Member States that have no interconnected inland waterways but issue certificates in line with the requirements of Directive 96/50/EC (i.e from Sweden, Finland, Lithuania and Estonia).

All Member States concerned by the CCNR bilateral arrangements would also enjoy mutual recognition benefits due to the elimination of the limitations inherent to the bilateral agreements as described under 3.3.1.1. In particular, the vast majority of their boatmasters would enjoy direct benefits as additional requirements would no longer be imposed on them CXIV . This concerns boatmasters coming from Austria, Bulgaria, Hungary, Poland, Romania, Czech Republic, Slovakia, Belgium and the Netherlands.

It should be underlined that the mutual recognition is made possible because of a competence-based system is put in place through measure 2. The most significant example is the case of France as highlighted under 3.3.1.1. It is only because of the increased confidence generated by the shift from a common means (time)-based system of qualifications to a system based on objectives (competence) that the automatic mutual recognition is possible.

The competence-based approach produces an additional benefit with respect to labour mobility compared to the baseline scenario as boatmasters will be active sooner on the labour market (workers operating on the Rhine would only need one year of professional experience after they have graduated instead of the two years before). The impact of this measure could be slightly lower if some Member States decide to keep two years as minimum required navigation time.

Impact on labour mobility due to the introduction of a limited certificate for vessels between 20 and 40 metres: this measure will have some effect on new entrants to the sector as they will be able to become boatmasters more quickly as less navigation time would be required. The expected impact of this measure is limited however considering the estimated number of additional boatmasters that would apply for limited boatmaster certificates CXV .

Impact on labour mobility due to the introduction of an extended certificate for large convoys: This measure will have a limited impact as it would only concern a very small number of crew yearly on the Danube corridor only (where these large convoys are found). For these workers the impact will be negative as they access boatmaster level less quickly than in the baseline scenario CXVI .

Labour mobility effect is broadly similar for suboptions C1 and C2 but is somewhat higher in case of C1 through the recognized recognized diplomas or certificates issued by education and training institutes (measure 3), which prevents that candidate-boatmasters with a recognised diploma/training certificate (85% of the inflow CXVII ) would be required to take additional examinations with an administrative authority. Section 6.2.3. shows the main difference between suboptions C1 and C2, namely, a reduced administrative burden in option C1 due to the fact that candidate boatmasters with a recognised diploma/training certificate do not need to take additional exams with an administrative authority.

Operational workers:

Impact on labour mobility due to mutual recognition of EU harmonized qualifications and additional competence-based requirements for boatmen (measures 7, 8 and 9): due to mutual recognition of qualifications, positive impact is expected for all Member States and on all rivers:

All skilled workers from any Member States who might postpone or renounce working on the Rhine or on another river in another Member State due to the fact that they have not reached yet the sailing time required for the qualification they have already been granted in their country of origin (as mentioned under section 3.3.1.2. close to 40% of all operational workers could potentially be concerned).

Concretely, around 13% of the crew below boatmaster level CXVIII operating on the interconnected IWT network who are currently working on the Rhine and are being downgraded (as described under 3.3.1.2.) due to the absence of a qualification system harmonised at EU level. This may concern workers from both CCNR and non-CCNR countries. Although no estimates exist, this phenomenon also exists outside of the Rhine depending upon the national legislation.

Boatmen from individual Member States like France that currently do not have the qualification of boatman in their system and would wish to have their competence recognised in another country.

In the same way as for boatmasters, it should be underlined that the mutual recognition of qualification at EU level is made possible because of a competence-based system is put in place through measure 8. It is only thanks to the increased confidence generated by a system based on objectives (competence) that experience (navigation time) becomes less central in the recognition process. As a result, the competence-based approach should generally allow boatmen, in particular those using the experience path, to access the qualification sooner. 

Labour mobility effect is broadly similar for suboptions C1 and C2 but is somewhat higher in case of C1 through the recognized diplomas or certificates issued by education and training institutes (measure 9) which prevents that candidate-boatmen with a recognised diploma/training certificate would be required to take additional exams with an administrative authority. 

Impact on labour mobility impact due to harmonised content of SRB/logbooks (measure 10): since almost all SRBs and logbooks on interconnected waterways are mutually recognised under BAU through the CCNR multilateral agreement, the impact of this measure on mobility should per se not be significant; it is mainly a supporting tool for the implementation of the other measures.

Workers entering the profession from outside the sector:

Option C introduces with measure 12 mutual recognition of a fully-fledged ‘third path’, an intensive training programme which includes a series of competence-based practical exams that allow lateral entrants to enter the IWT sector more quickly. The impact on cross-sector mobility is shown by the recent results of such programmes in the Netherlands where demand has increased since commencement of the programmes CXIX . It should be even more significant if mutual recognition of the qualification is guaranteed by an EU legislative framework. The extent to which other Member States would integrate this 'third path' is uncertain. The effect over the long-term is therefore difficult to quantify. However it is likely that countries with training capacity and/or a workforce deficit would put such a programme in place as the first experiences showed that it is a useful tool for increasing the attractiveness of the IWT sector for lateral entrants. Option C will therefore increase labour mobility possibilities for these workers: the ‘third’ path in place in some countries will be mutually recognized by all Member States. In the Member States where the 'third' path is not put in place, a positive but much smaller positive impact on the mobility of lateral entrants is expected. This would be due to a larger reduction of required navigation time for maritime or fisheries sector workers switching to IWT. This would be a consequence of the introduction of the mandatory exam as foreseen under measure 8. The external study estimated that aligning all EU IWT-interconnected countries with the reduction presently offered in Directive 96/50/EC by 2030 would benefit around 500 candidate-boatmasters originating from outside the sector and that furthermore, reducing the required navigation time by 3/4, instead of 2/3 as presently applied, could yield up to 250 additional lateral entrants at operational level.

The total effect as regards increased labour mobility on the supply-demand gap of workers: As described above, options B and C have both a positive impact on labour mobility, but to a varying extent. It is impossible however to estimate the exact impact on the worker supply-demand gap because the number of IWT workers that will ultimately take advantage of increased labour mobility possibility is unknown.

B)Impact of the policy options on labour mobility due to KSS measures

Option B (measure 14) could result in increased labour mobility, as the Commission Recommendation on KSS may incentivise Member States to re-evaluate their rivers stretches which are subject to KSS. If judged no longer appropriate or necessary, Member States may remove these stretches from their KSS list or may consider decreasing their knowledge related requirements. As a result, there might be positive effects on labour mobility. However, as the Commission Recommendation would not be binding, the effects are uncertain and no estimates can be given. Moreover, no detailed assessments are currently available which would indicate which specific rivers or Member States would be more likely to take this measure up. Each Member State would be expected to make its own judgement.

Option C Measure 15 will oblige Member States to re-evaluate existing river stretches that are subject to KSS. Removing or adapting non-justified KSS requirements may have a positive impact on labour mobility. As the detailed effects of this measure are not known as long as the stretches have not been evaluated by the Member States in the context of a revised EU regulatory framework, its magnitude cannot be estimated. It is nevertheless expected that there will be a greater impact than under option B because of the mandatory evaluation and the requirement to justify the KSS. The Seine, Rhine and Danube are most affected by this measure. A second impact from option C may arise through measure 16 from the possibility of Member States organising exams and issuing authorisations for all KSS river stretches in Europe. Compared to the baseline scenario, taking the KSS exam in a worker's home country may sharply reduce the cost as a percentage of a worker's monthly salary. According to the external study, CXX estimations of exam costs would be reduced to maximum 5% of a worker's monthly salary. At present, this percentage reaches 57% and 66% for workers from Romania and Bulgaria respectively. Although workers from all Member States would benefit from this measure, the greatest savings would be for Central and Eastern European countries. Reduced costs would increase labour mobility as a labour mobility barrier – attending a KSS exam in order to navigate on KSS stretches –, is lowered. In view of the estimated number of boatmasters per year that can’t do KSS exams in their own country CXXI , the Elbe and the Seine are particularly concerned by this measure. The exact impact of option C will depend on the extent to which Member States make use of the possibility of organising KSS exams for stretches located in other Member States.

(“0” refers to a neutral effect compared to the baseline scenario; "+" refers to the strength of a positive correlation; the small sign “+” just above the main sign indicates an (additional) positive effect but of a lower magnitude than a “+”).

2.4.2.Impact on access to the profession

Under the baseline scenario (option A) the profession is regulated in a different way at various levels, e.g. the UN ECE level, the European level, the level of River Commissions (CCNR level and administrative arrangements) and the national and regional levels. As described under section 3.3.1 this has led to difficulties with regard to mutual recognition of professional qualifications, thereby making access to the profession more difficult in certain countries. As both policy options B and C will have a positive impact on the conditions for mutual recognition of professional qualifications (see section 6.1.1.), these options will also to the same extent ease the access to the profession, both for workers having started their career in the IWT sector or for lateral entrants. The impact of option B will thus be smaller than for option C. Under option C, the benefits of the career prospects offered by the competence-based minimum requirements (see also section 6.1.4 on 'job attractiveness') for boatmen and boatmasters are expected to largely outweigh the difficulties that the necessary examination requirements could represent for a number of individual candidates (in particular boatmen using the experience-based path). The recognition of diplomas/training certificates and the associated exemption from exams taken with an administrative authority under suboption C1 represents significant additional benefits for access to the profession compared to C2. Overall the competence-based approach should not be perceived as imposing stricter requirements for the access to the profession as its expected impact on the inflow of new intrants is positive.

2.4.3.Impact on safety in the IWT sector

A)Impact of the policy options on safety due to measures linked to mutual recognition of professional qualifications

Option B

Boatmasters and workers from outside the sector: no effect is expected as no specific measures are foreseen.

Operational workers: the impact on safety from the implementation of CTF/CTT, as proposed under amended Directive 2005/36/EC (measure 6), would be positive because the common minimum standards for operational workers' qualifications would refer to common standards that ensure a high degree of safety. The extent of the effect however is unsure (for the same reasons as those mentioned under section 6.1.1.). The impact of the extension of the CCNR mutual recognition system to operational workers (measure 5) would also be positive but limited. The arrangement would be based on an alignment with CCNR standards that ensure that navigation safety levels are high. However, participation would be limited to those that already signed the administrative arrangement for SRBs and the inherent limits of the instrument, as described under 3.3.1.2., would remain. Moreover, the administrative arrangement cannot put in place a competence-based system with an organised and permanent quality system. For ensuring stability and sustainability of the system, a stronger legal framework is needed that establishes clear responsibilities of the Member States regarding verification and evaluation of assessment and certification methods.

Option C 

Boatmasters (measure 2):

Impact on safety due to standards linked to the frequency of the medical check-up: As mentioned under section 5.2, three levels of standards on the frequency of the medical check-up are considered for application at EU level. The CCNR standards would be most stringent: as a result, more accidents will be avoided, thereby positively affecting safety. The new frequency proposing the lowest frequency of the medical check-ups, results in a negative impact on safety. Directive 96/50/EC standards score in between. If all costs and benefits are taken into consideration and considering proportionality, the new frequency (with savings in terms of administrative costs estimated at 13,2 million by 2050) can be considered as the most efficient level of minimum standards. Compared to the baseline scenario, according to the estimates of the external study, the new frequency could lead to a limited number of extra accidents, estimated at a maximum of 5 yearly, potentially leading to extra costs (NPV) up to 3.3 million by 2050. CXXII  

Impact on safety due to competence-based minimum requirements and mutual recognition: Positive effect on safety in terms of avoided accidents is expected thanks to the following elements:

The competence based approach – in comparison to the baseline scenario – sets high standards. Increasing the coverage of competence required and making them up-to-date with technological development will have a positive effect on safety both in CCNR and non-CCNR countries.

The practical examination as a prerequisite to becoming a boatmaster will ensure that every candidate has the required competencies. Under the baseline scenario, only a theoretical examination is imposed. This new practical examination will target the entire new boatmaster population. This should result in a yearly increasing safety effect in countries where such an exam was not required (e.g. the Netherlands, Germany, Slovakia, Czech Republic.) and particularly for the candidates using the experience path.

Increased mutual recognition in itself will also slightly improve safety by increasing the size of the workforce and thereby ending (or at least limiting) the use of the "hidden reserve" which is more accident-prone as not active on a regular basis.

The external study has provided some indication of possible safety effects in monetary terms. CXXIII Results should only be seen as illustrative. A methodological remark has been included in Annex 12. Overall, according to the study, the NPV of the benefits of competence-based minimum requirements and mutual recognition as defined under measure 2, in terms of accidents avoided per year is estimated at around €73 million for 2030 and € 183 million for 2050.

Impact on safety due to limited certificates for vessels between 20 and 40 m: in order to obtain such a certificate, reduced navigation time would be required. Although it could be expected that less experienced boatmasters have a higher accident probability, option C includes a competence-based approach built on relevant competencies to be tested, including a practical exam. In addition, accidents involving smaller ships on average cause less damage than larger ships and, under the baseline scenario, there is a small patent under the RNP that can be considered as an equivalent to the new EU limited certificate. As a result, it is concluded that the safety effect of this certificate is insignificant.

Impact on safety due to certificates for large convoys: A complementary boatmaster certificate for navigating on large convoys will have a positive impact on safety. It is difficult to quantify the safety effects of this measure as no data is available on the number of accidents in which large convoys are involved. However, public authorities responsible for the Danube (river commissions and Member States) have been asking with a single voice for an EU regulatory qualification framework including that aspect for safety reason. According to them the lack of specific competence/experience in navigating on large convoys is the cause of a significant number of accidents involving this type of vessels.

Operational workers:

Impact on safety due to EU harmonized qualifications for operational crew (measure 7) and additional competence-based requirements for boatmen (measure 8): 

The harmonised qualifications with regard to age and fitness for all operational workers (measure 7) is expected to have an insignificant effect on safety as these EU standards are expected to be very similar to those applied under the baseline scenario. The possible reduction of minimum navigation time required is not considered to have a safety impact in view of the higher safety benefits of the competence-based approach.

The competence-based standards for boatmen tested through examination (measure 8) will in a significant way positively affect safety in terms of avoided accidents on a yearly basis in both CCNR and non-CCNR countries. This is because - compared to the baseline scenario – the competence-based approach introduces an examination of competencies as a prerequisite to becoming a boatman; competencies which are based on high standards that are up-to-date with technological development. In principle, a more significant impact is generally expected from the application of the measure to workers that acquire their qualifications through the experience-based path as they do not go through specific tests/training under the baseline scenario.

The external study has provided some indication of possible safety effects due the competence-based approach and mutual recognition at operational level. CXXIV The NPV of harmonised standards as foreseen under option C for 2030 and 2050 amounts to around €4.2 million and €11.8 million respectively in terms of work related accidents avoided. These results should only be seen as illustrative and a methodological remark has been included in Annex 12. It can nevertheless be noted that these estimates take into account only the impact for non-CCNR Member States whereas – as mentioned above – a positive impact is also expected for candidates from CCNR Member States.

Impact on safety due to harmonised content of SRB and logbooks (measure 10): the effect on safety from the harmonisation of the models can be considered small but not insignificant.

The SRB is mainly a support for the other measures and the logbook a means to check the information inserted in the SRB. The single SRB format and improved registering of related information will contribute to improved compliance and have a positive effect on safety.

Workers entering the profession from outside the sector:

A positive impact on safety is expected from the new possibilities for external workers to enter the IWT labour market through the recognised third path consisting of an intensive training and testing programme (measure 12). This results from the additional guarantees the required competencies are obtained, in comparison with the experience path (based on number of years of navigation) as defined under the baseline scenario. The impact would remain modest however in view of the size of the population targeted (i.e. a maximum 15% of new entrants CXXV in countries having put in place such a system). 

All the benefits in terms of safety outlined for option C are valid both for suboptions C1 and C2 as all candidates will have to go through examination in accordance with the same high level and up-to-date standards to obtain their qualification. Under suboption C1, a higher impact can be expected in terms of less work-related accidents involving boatmen from non-CCNR countries as the standards used in education will improve more significantly for these countries as shown in the comparative analysis of curricula of navigation education institutes of figure 9 below. The analysis has been elaborated by the external study based on the work of the PLATINA I project CXXVI . The analysis presented in figure 9 also indicates that not only non-CCNR countries can benefit from competence-based standards in education, but also CCNR countries, in particular for the level of boatmaster.

Figure 9 Percentage of relevant competences mentioned in STCIN covered by boatmasters and operational workers curricula in two groups of Member States

Source: Panteia (2014), based on data from PLATINA 1 D3.8

B)Impact of the policy options on safety due to KSS measures

None of the KSS related measures of options B and C are expected to impact safety as all measures aim at ensuring that KSS requirements are proportionate to their safety goals and do not unnecessarily hamper labour mobility. The intention is only to target disproportionate KSS requirements. Any changes would therefore not affect the safety levels.

2.4.4.Impact on job quality/attractiveness

Regardless of the policy option, most of the measures are aimed at reducing labour market barriers in the EU. The job quality and attractiveness of IWT careers in the sector will improve. As a result of measures which have positive impact on safety, job quality and attractiveness will also improve as the risk of accidents decreases.

The impact of option C: Measures that introduce EU wide minimum competence-based standards for boatmen and boatmasters also increase job quality as they positively influence work autonomy and participation as well as workers' health. The external study used indicators CXXVII for the various aspects of job quality/attractiveness and assessed which aspects were affected by each measure. Table 1 shows the overall score for each of the measures included in Option C, taking into account the population size of the targeted group. Measures related to the mutual recognition of competence-based minimum requirements, both for boatmasters and boatmen have the highest (positive) impact on job quality and attractiveness.

Table 1: Job Quality scores per measure

Source : Panteia (2014), adjusted by the Commission. Total score takes into account the size of the impact and of the targeted group.

Table 1 shows that suboption C1 with its recognition of diplomas and training certificates brings additional benefits compared to option C2 in terms of attractiveness. As already explained previously this is due to the exemption from taking additional examinations with an administrative authority for candidates coming from education institutes.

A number of measures under option C will affect the speed of the career path of workers: some measures will speed up the career path, whereas others will slow it down. The career path is expected to influence the received wage in a given year, thereby affecting job attractiveness from the point of view of the workers:

- The boatmaster certificate for large convoys: one extra year of experience in the function of helmsman is needed before becoming a boatmaster on large pusher vessels. During that year, the wage level could be lower. The external study CXXVIII estimated the NPV of the total accumulated salary difference for the EU workers at around € -0.1 million in 2030 and € -0.2 million in 2050.

- The introduction of the competence-based approach for boatmasters: there is a positive effect in terms of salaries paid to workers that now work on the Rhine, as it will only take one year before they become boatmaster, against two under the baseline scenario. The external study CXXIX estimated the NPV at around € 21.0 million by 2030 and € 31.6 million in 2050.

- The mutual recognition of harmonised competence-based qualifications for operational crew members: as under BAU 6.6% of the operational workers do not have their qualifications recognised, resulting in a lower function and a lower salary, the effects of mutual recognition of their qualifications can also be calculated in terms of wage gains. The external study CXXX estimated the NPV benefits up to around € 10.4 million in 2030 and € 15.9 million in 2050.

Overall, option C is expected to lead to faster career paths compared to option B and the baseline option, thereby positively influencing job attractiveness.

The benefits of option B for job quality and attractiveness will be smaller than those under option C if CTT/CTF are put in place, because mobility benefits will be smaller. Also, if a CCNR multilateral agreement is signed for the mutual recognition of qualifications, the impact on attractiveness would be smaller than under option C, because existing CCNR standards are likely to remain predominant over a potential competence-based approach. Moreover, as previously mentioned, the degree of uncertainty of the effect is rather high.

2.4.5.Impact on labour costs

In the baseline scenario, several regions face a supply/demand gap of workers. In line with general wage trends in these countries, differences also exist in IWT wages. In regions with labour shortages, e.g. in the Rhine area, this might result in labour cost increases. However, the way wages will react to this supply/demand gap in the baseline scenario cannot be estimated, as a lot will depend on the rigidity of wages in the various countries and on other external factors. As the EU as a whole and certain regions face shortages of workers, it is however likely that no decrease in labour cost will occur in regions with labour surpluses.

Policy options B and C will increase labour mobility and attractiveness and could to some extent reduce the supply/demand gap of workers. Labour shortages would therefore decrease in the respective regions and could as a result diminish the upward pressure on IWT labour costs, compared to the baseline scenario.

The effect of possible wage gains by individual workers resulting from higher classification and fasters career paths, as described in section 6.1.4, on labour costs for employers, is limited. This is because an employer will not have to face higher labour costs for the same set of required qualifications. Policy options B and C only make it possible for employees to move faster towards certain higher crew categories, but this does not result in a higher pay for a given crew category. Taking into account manning requirements as set in the relevant manning regulations, it remains the prerogative of the employer to determine the composition of its crew.

In all options, also in the baseline scenario, several vacancies related to skilled workers remain open. Under the baseline scenario there is thus already a willingness to pay from the employer side for more skilled crew. To a large extent, options B and C will make it easier for employers to recruit these required skilled workers, thereby giving them the opportunity to further expand their businesses. This is particularly valid for SMEs who often face difficulties in fulfilling their staffing needs.

In the last round of stakeholder consultations during the process of revising the first IAR, representatives of the industry confirmed that they do not expect higher labour costs as a result of the policy options B and C.

To conclude, as other external factors will also play an important role in wage levels, it is almost impossible to accurately single out the effect of the policy options on wages. However, as argued above, compared to the baseline scenario the effects are expected to be limited.

2.4.6.Impact on employment

Compared to the baseline scenario, options B and C are not expected to result in significant job creation or job losses for inland waterway crew. However, options B and C aim to contribute to reducing the supply-demand gap by stimulating job mobility across regions and improving the sector's attractiveness in order to fill existing vacancies. Options B and C will therefore have a positive impact on employment through a higher filling-rate of vacancies. For each option, the impact will be proportionate to their impacts on mobility and attractiveness. On a very small scale new jobs could be created as a result of option C (and particularly under C1) in the fields of quality standards, assessment of competence and examination, as well as in the embryonic simulator business. With respect to potential negative impact, KSS creates a small but distinctive labour market for pilots. Under all scenarios, but slightly more likely under C, some pilots could lose their jobs if a stretch is no longer considered as KSS or if the demand for pilotage services decreases if KSS examination for the stretch is facilitated. It is difficult to make projections for both aspects, but in practice the impact on pilot employment should remain very limited. In view of the expected shortage of skilled personnel, pilots who could lose their job should be expected to find easily a job as boatmaster.

2.1.Economic impacts

2.1.1.Impact on the contribution of IWT to the European industrial base

As discussed in section 3.2.2, the IWT sector has a role to play in strengthening the European industrial base. Under the baseline scenario, this contribution is threatened as the suboptimal labour mobility will hamper the efficient functioning of the IWT sector. As under option B and C, the functioning of the labour market will be improved, these options will also contribute to maintaining or improving the strength of the European industrial base. For each option, the impact will be proportionate to their impacts on mobility and attractiveness.

2.1.2.Impact on the contribution of IWT to the European transport energy efficiency

As discussed in section 3.2.2, the IWT sector has a role to play in strengthening the European industrial base. Under the baseline scenario, this contribution is threatened as the suboptimal labour mobility will hamper the efficient functioning of the IWT sector. As under option B and C, the functioning of the labour market will be improved, these options will also contribute to maintaining or improving the contribution the IWT sector can make to energy efficiency goals by taking up a higher part of the overall transport in the EU. For each option, the impact will be proportionate to their impacts on mobility and attractiveness.

2.1.3.Impact on transport costs and on final consumer prices of goods

Transport costs could be marginally influenced by changes in labour costs in the IWT sector (that only concern a small proportion of the total transport costs). However, as explained under section 6.1.5. the impact of all policy options on labour costs is insignificant from an EU-wide point of view. Furthermore, IWT is facing fierce competition with other transport modes. It is therefore unlikely that there will be any subsequent effect on transport costs. Nevertheless, there may be an indirect benefit for transport costs as inland waterway transport is more cost-efficient compared to other modes of transport under certain conditions. Eliminating barriers for the uptake of inland waterway transport can therefore reduce the overall costs of transport for certain industry sectors. However, it is unlikely that any of the policy options influence consumer prices of goods at a European scale, knowing also that transport costs only concerns a small proportion of the price of goods.

2.1.4.Investment costs CXXXI

Under option B, the investment in human resources time for the implementation of new instruments proposed under the amended Directive 2005/36/EC (measure 6), in particular for national administrations and training institutes, is significant as the sector has to take the initiative and come with a CTF or CTT proposal. Some of the costs related to developing a competence-based approach for operational workers will also be needed for the CTF or CTT. Costs will be linked to the setting up a quality system which includes certifying/recognising training institutes and their curricula. However, few costs for adapting the curricula should be incurred at EU level since setting up the platform does not require replacement of the national system, unless a Member State decides otherwise. Investment costs would also be incurred if the CCNR set up a multilateral administrative arrangement for the recognition of crew qualifications. This would include audit, reporting and meeting costs for Member States and staff costs to manage the recognition process for the CCNR. The CCNR estimated that two audits could be processed per year with a maximum of 5-6 additional requests in total. Contrary to CTT/CTF, there will be costs for adaptation of curricula of education institutes as the CCNR requires alignment to their standards. For both alternatives, it is possible that mandatory examination is not included under option B. In this case, the related investment costs (in particular for the development of the programme) may not be necessary under option B. At EU level, investment costs under option B will be lower than under option C since the number of participants will be lower. No significant investment costs are expected for the Commission Recommendation on KSS.

Investment costs related to option C are presented in the table below. Only significant costs are presented. They are all related to measures linked to mutual recognition of professional qualifications. Further information on the underlying assumptions and calculations can be found in Annex 13.

Table 2: Significant investments costs per measure

In total, upfront investment costs of 8.0 million for suboption C1 and of 5.6 million for suboption C2 are expected for the public sector and, in case of C1, for IWT education and training institutes. For the private IWT sector itself, no significant investment costs are expected, neither for employers nor for employees.

(the sign’-’ just above the main sign indicates a negative effect i.e. costs but of a lower magnitude that a ‘-’).

2.1.5.Impact on recurrent administrative costs

The impact on recurrent administrative costs is presented in the table below for option C. The impacts for option B are presented thereafter. Further information on the assumptions and the underlying calculations can be found in Annex 14.

Table 3: NPV (in million) of the recurrent administrative costs under option C 2030 and 2050

(‘+’ represents administrative savings and ‘-‘ administrative costs; optional costs are put between brackets)

From the above table the following conclusions can be drawn:

-The total administrative savings for suboptions C1 and C2 are relatively similar, with a small advantage on the long term for suboption C1.

-With regard to the minimum standards linked to the frequency of the medical check-up, the suboption “new frequency” has the most beneficial cost-benefit ratio over time (based on the comparison between negative safety impact of only 3.3 million by 2050 and the above-mentioned administrative costs benefits). This new frequency already received explicit support in the CEG from some experts (e.g. from NL and FR). Savings generated by this measure are relatively high resulting in a positive ratio for total administrative costs/savings.

-The most significant administrative costs are related to the mandatory examination to test the competencies at boatmen and boatmaster levels (more significantly for boatmen and under C2) and, in case of C1 only, to the recognition/accreditation system for exam programs. For the first cost category, it should be noted that that the estimates take into account a number of scenarios related to the examination, including more costly ones. As regards the second cost category, the estimates is based also upon the assumption that that some Member States will opt for an accreditation system whereas it is likely that most Member States adopt a (cheaper) recognition that will be integrated in existing national quality assurance systems.

-Significant costs are also related to the organisation of practical exams for lateral entrants but this is optional for the Member States.

-For a number of measures, e.g medical checks or exams, it is not possible to clearly identify whether the private or the public sector will bear the costs. Already in BAU this varies from one Member State to another. However suboption C1 should be more costly for the public sector (due to quality assurance system covering also education/training institutes) but less costly for the private sector (SMEs). Comparing both suboptions, C1 represents overall less administrative burden due the exemption from taking administrative exams for those using the education path. 

Under option B, no significant savings are generated as there is no measure tackling medical check-up for boatmasters. On the other hand, less administrative costs will be incurred as the number and scope of measures are less important. However, for the CTF or CTT for operational workers (measure 6), there will be similar recurrent costs related to organising the competence based approach. These relate, in particular, to the management of the quality system including the compliance check that will be required on a regular basis. In addition, under Directive 2005/36/EC, also for professions under automatic recognition, in case of provision of services, there is an obligation to submit a declaration to the authorities of the host country. Beyond the administrative burden it represents, this could involve some costs for applicants as some Member States charge a fee for processing the declarations. This might also be the case under CTT/CTF. The setting up by the CCNR of a multilateral agreement for the recognition of crew qualifications (measure 5), would require less administrative costs as no permanent quality system is put in place. Only costs inherent to regular meetings related to the implementation of the agreement would be incurred. In view of the fact that these already exist for the agreement for SRBs, additional costs are considered negligible. For both measures, due to the fact that mandatory examination may not be included under option B, related administrative costs that were unavoidable under option C might not be incurred under option B. At EU level, administrative costs to incur under option B will be lower than under option C since the number of Member States adopting CTT/CTF will be lower. With the Commission guidelines on KSS, no significant administrative costs are expected. In total, however, in the absence of significant savings, the ratio savings/costs is expected to be less favourable under option B.

(‘+’ represents administrative savings and ‘-‘ administrative costs)

2.1.6.Impact on different regions

All IWT Member States will be positively affected in terms of labour mobility, safety and increased attractiveness of the profession. Any implementation costs are outweighed by benefits. Experts from IWT Member States, representatives from the main River Commissions (Rhine, Danube, Sava) as well as social partner organisations representing at EU-level the IWT employers and the employees actively contributed in a positive way to the development of EU initiative and did not signalled any overall negative impacts on certain regions or countries. Only the representative of some non-interconnected countries (in particular from UK and SE) called upon the Commission to keep the possibility of exemption as currently foreseen under Directive 96/50/EC.

This said, some European regions or individual Member States may be affected in a different manner depending on the measure. The section below highlights the most significant variations of impacts.

In terms of mobility,

In general, the Member States on the interconnected IWT network with the largest workforce will have more benefits: CCNR countries (NL, DE, FR, BE), and RO.

With regard to mutual recognition of professional qualifications, the workers from non-CCNR countries and from FR will enjoy larger benefits. This is because in policy option C, non-CCNR countries' boatmaster certificates and operational workers’ qualifications will, contrary to the BAU situation, automatically be recognised on the Rhine, thereby increasing possibilities for labour mobility.

Suboption C1 will have a higher impact in non-CCNR countries with IWT training/educations institutes (AT, BG, CZ, HU, PL, RO and SK) as their education/training programmes are, with only a few exceptions, not recognised by CCNR countries. In view of the yearly number of entrants in IWT institutes per country, RO will by far be the biggest beneficiary among these countries, followed to a much less extent by PL, CZ and BG (see table 2 under Annex 2).

The increased labour mobility resulting from options B and C will have a positive effect on reducing the gap between the supply and demand of workers and on labour mobility in the different regions. As mentioned under section 6.1.1., it is impossible however to estimate the exact impact on the worker supply-demand gap because the number of IWT workers that will ultimately take advantage of increased labour mobility is unknown. The Rhine region - which under the baseline scenario is expected to face a large labour deficit – is very likely to benefit much more in this respect. Indeed, due to increased labour mobility, workers from the Danube (AT, BG, HU, RO and SK), the East-West (NL, DE, PL, CZ), and the North South (BE, FR, NL) corridor will gain access to the Rhine labour market more easily. On the other hand, surplus workers from the Danube, the East-West and the North South (till 2020) corridors will also benefit as they will be able to leave the saturated labour market in their own region.

Depending on its effectiveness as regards mutual recognition, option B could also have similar effects with respect to operational workers in case of full uptake of the instruments. As explained in previous sections, it is however unlikely that option B would achieve similar results as option C. On a different note, the online public consultation, when comparing harmonised requirements (option C) with the voluntary approach (option B) for two important river areas, the Rhine and the Danube, indicates that mandatory harmonised professional qualifications and training standards will, according to 85% of CCNR stakeholders, and a bit less than 80% of Danube stakeholders, result in fairly to very positive effects on labour mobility. For voluntary measures these percentages are respectively around 50% and 60%.

In terms of safety

In general, the Member States on the interconnected IWT network with more IWT freight transport volumes will have more safety benefits i.e. CCNR Member States (NL, DE, BE and FR). From the point of view of the workers, the competence-based qualification system should have more safety benefits for workers from non-CCNR countries as training standards in general have kept up less with technological developments.

By the way, the online public consultation indicates that mandatory harmonised professional qualifications and training standards (option C) will, according to around 90% of CCNR stakeholders, and more than 85% of Danube stakeholders, result in fairly to very positive safety effects. For voluntary measures (option B) these percentages are for both rivers only around 60%.

In terms of costs,

Under option C, the introduction of mandatory practical examinations for boatmasters will impact regions and individual Member States in a different way as certain Member States do not have such exams (e.g. DE, NL, CZ or SK) nor use training ships or simulators (most Danube countries e.g. BG, CZ, HR). It should nevertheless be stressed that the measure is supported by all stakeholders, including from the expert in the CEG that do not organise such exams for the moment.

Regarding suboption C1, Member States with more education/training programmes will in general face higher costs for their recognition (RO, NL, FR, BE, DE). Furthermore, non-CCNR countries will face more significant costs per programme for their adaptation to the new competence-based requirements. These Member States are in favour of establishing such a recognition system for professional training as recognition/employment benefits should largely compensate the costs. CEG experts unanimously supported the establishment at EU level of a quality system for recognition that would allow using the recognised diplomas/training certificates in the procedure for the issuance of boatmasters' certificates.

Option C will also reduce the administrative burden of the CCNR countries and the countries with which the CCNR has concluded administrative arrangements (AT, BG, CZ, HU, PL, RO, SK), because these recognition agreements could be abolished and related administrative costs for their implementation would no longer be incurred.

As a side note, the online public consultation indicates that mandatory harmonised professional qualifications and training standards (option C) will, according to 54% of CCNR and more than 70% of Danube stakeholders, result in fairly to very positive effects on the administrative burden. For voluntary measures (option B) these percentages are respectively around 23% and 62%.

As far as KSS is concerned, the Rhine, the Seine and the Danube area will be more significantly affected, as they represent the largest share of transport affected by KSS requirements (see 3.3.2). Therefore, those regions will be more impacted by the KSS related measures under both options B and C. It should be noted that CEG experts from FR and UK opposed KSS examination by other Member States.

2.1.7.Impact on SMEs

The IWT is sector composed almost exclusively of SME's. CXXXIV Therefore, the direct private sector impacts described in the previous sections are all affecting SME's only. 90% of enterprises in the Netherlands are micro-enterprises with 1 to 5 people employed CXXXV . In many cases, the vessels are owned and operated by a family. The rest of the Western part of Europe where most of the IWT activities takes place i.e. Belgium, France and Germany, shows a similar business structure. Policy options B and C will both positively impact SMEs. As described above, these policy options will have positive effects on labour mobility and safety compared to the baseline scenario. In particular, increased labour mobility resulting from option B and – with significantly higher effectiveness – from option C will make it easier for SMEs to recruit staff from across the European Union, thereby reducing labour shortages. Increased safety will also reduce accident costs for SMEs. Effectiveness with regard to safety is expected to be higher under option C compared to option B. These benefits are estimated to largely off-set administrative and investment costs, which are anyway largely borne by the public sector, rather than the private sector. SMEs will therefore have to bear only a small proportion of the costs (e.g. those related to participating in some Member States in administrative exams), which will be more than off-set by the positive labour effects with respect to labour mobility, safety and attractiveness of the profession. In addition, under suboption C1, significant benefits for SMEs are expected in terms of reduced administrative burden compared to C2 as candidates entering the profession via the education path will be exempt from taking an administrative exam. More information on quantitative estimations of the costs and benefits for SME's can be found in a table under Annex 15.

The European Skipper Organisation (ESO) which represents the independent IWT entrepreneurs has actively participated in the preparation of the initiative at EU level, including the impact assessment, through its active participation in the CEG meetings. ESO is in favour of the adoption of a modern and flexible regulatory tool for training and certification at EU level, which will improve safety and provide fair and competence-based access to the profession.

2.1.8.Impact on third countries

The impact on third countries is limited for options B and C. Switzerland would need to adapt its legislation in case of changes in regulations on the Rhine river. The same would apply for Serbia and Bosnia and Herzegovina in case of changes of the legislation for the Sava river. Ukraine, Russia, and Moldova may adjust their legislation in case of modification of the Danube recommendations. In any case, crew from third countries will need to adhere to the future new prescriptions on crew qualifications.

The impact of measures linked to mutual recognition of professional qualifications would be positive for both options B and C. The external study CXXXVI has identified the following benefits by 2030 under option C for third countries: firstly, administrative savings as a consequence of the new frequency of medical check-ups (€ 0,6 million); secondly, gains in salary due to the quicker recognition of qualifications of boatmasters resulting from a competence-based approach (€2,1 million); and thirdly, and this would also be valid for option B, gains in salary due to the recognition of harmonized qualifications of other crew members (€1 million). Conversely, the introduction of certificates for large convoys would be associated with some limited costs, corresponding to the loss of salaries for the additional experience the boatmaster has to gain on large convoys before obtaining the special authorization (€ -0,1 million). The benefits from prevented accidents however are expected to largely outweigh these costs.

Measures related to KSS are considered to have little impact on third countries. There would be benefits if some KSS requirements are dropped or reduced or if boatmasters of third countries could take their KSS exams in one single country.

2.2.Environmental impact

While an increased use of IWT will contribute to the overall energy-efficiency of the whole transport system, the proposed policy options on their own are not expected to have a significant impact on modal shift and thus on the environment including fuel use, emissions, pollution etc.

2.3.Summary of the economic, environmental and social impacts

The table below summarizes the impacts addressed under sections 6.1., 6.2. and 6.3. CXXXVII Information on quantitative estimations of the costs and benefits for the private and public sector can be found under section 7.2. and in Annex 15.

Table 4: Summary of the economic, social and environmental impacts compared to the baseline scenario

(number of "+" refers to the strength of a positive correlation, “ –“ refers to a negative correlation; ; the small sign “+” just above the main sign indicates an (additional) positive effect but of a lower magnitude than a “+”).

Apart from investment and recurrent costs, all the other impacts are estimated to be positive. This was also confirmed through the online public consultation. More than 75% of the respondents expect a positive impact on labour mobility and more than 85% on safety in case of regulatory intervention (option C). As regards impact on job quality 70% of the respondents have a positive opinion and for impact on SMEs, 65% of the respondents expect a positive impact. For the voluntary support measures (option B), the respondents estimate the positive impacts to be considerably lower. Certain categories of stakeholders expect more positive impacts than others: boatmasters, public authorities and training institutes. But each stakeholder category the balance is always positive: a substantial larger proportion of the respondents expects positive impacts from the proposed measures.

3.Comparing the options

3.1.Effectiveness

The ineffectiveness of policy option A, the baseline scenario, has been demonstrated above when describing the identified problems and its likely evolution in the future (see section 3).

Policy option B is expected to be more effective than option A in reaching the objectives of this initiative based on the following considerations:

the mutual recognition of professional qualifications of workers (operational objective 1) will be promoted further by the use of new instruments under directive 2005/36/EC (CTF and CTT) and/or through a CCNR multilateral agreement covering crew qualifications.

it is most likely that a Commission Recommendation on KSS will only marginally impact the proportionality of KSS requirements (operational objective 2).

However, the improvement of the effectiveness of option B is uncertain, because these measures rely on initiatives and commitments to be made at the initiative of the profession, which proved to be only partially effective in the past. (see section 3.4).

Moreover, the adoption of a CTF/CTT does not exclude maintaining parallel training structures in the Member States. In addition, CTF/CTT cannot address a number of supporting or organisational elements needed to support the recognition of qualifications that would still need to be regulated for the profession e.g. the procedure for obtaining and checking SRB. Finally, in view of the possibility of exemption for Member States to adopt CTT/CTF under Directive 2005/36/EC, it is likely that the CCNR would maintain their agreements or conclude new ones to cover the exempted countries. The existing fragmentation of the legal framework would even likely increase since Directives 96/50/EC and 91/672/EEC would most likely not be repealed. When a new CCNR administrative arrangement would be created, existing problems related to the coverage and legal uncertainty linked to the form of the arrangement as explained in sections 3.3.1. would remain.

Policy option C is judged to be more effective than options B and A, as all boatmasters and a larger proportion of operational workers on interconnected waterways would be mutually recognised throughout the EU (operational objective 1). In comparison to option B, all the remaining drawbacks from the use of the new instruments under Directive 2005/36/EC or the administrative arrangements with the CCNR would be eliminated. The fact that Member States will be allowed to organise exams and issue authorisations for all KSS in Europe could further promote the proportionality of KSS; the same applies to binding EU criteria framing the use of KSS (operational objective 2).

With a broadly comparable impact in terms of mobility, the effectiveness of suboptions C1 and C2 is comparable, with some advantage for suboption C1, in particular if the linkage with attractiveness is considered. This is due to the more positive impact on attractiveness generated by the recognition of diplomas and training certificates during the procedure for obtaining a qualification.

3.2.Efficiency

As shown in previous sections, it was not possible to monetize all costs and benefits. Some estimates are available for option C for investments costs, administrative costs, safety effects and job quality/attractiveness. For other impacts, only qualitative assessments are available.

Comparing only the total monetised cost and benefits for option C yields benefits in terms of safety (NPV of around € 75 million (2030) and € 191 million (2050) and job quality/attractiveness (around € 31 million (2030) and € 47 million (2050)) which more than compensates the upfront investment costs (NPV estimated at € 8 million for suboption C1 and € 5.6 million for suboption C2). Investment costs are all borne by the public sector. Considering only the benefits in terms of administrative savings (€ 13.2 million by 2050 due to the new medical check-up frequency), they would already outweigh the to-be-incurred administrative costs (for suboption C1 around € 4 million by 2030 and € 6 million by 2050 and for suboption C2 around € 5 million by 2030 and € 8 million by 2050). It should also be noted that the administrative cost for suboption C1 are significantly lower than for suboption C2. Under suboption C2, education/training institute examinations for boatmen and boatmasters are not mutually recognized, which generates a substantial additional administrative burden compared to suboption C1 as candidates have to go through additional examinations before obtaining their qualification (administrative exams after education exams). It is estimated that this would affect 85% of the candidates. Suboption C1 is therefore considered to be more efficient than suboption C2. Further details on these estimates can be found in Annex 15.

Apart from these available monetised impacts, other impacts are also relevant for assessing the efficiency of option C. For example, as far as labour mobility is concerned, the impact was calculated in terms of extra workforce available on the labour market, and not in monetary terms. It has been demonstrated in section 6 that a positive impact is to be expected in this respect. A significant number of boatmasters would be added to the available workforce on the Rhine if all certificates issued under Directive 96/50/EC are recognized on the Rhine and those that are already part of the CCNR recognition system will also benefit from a more automatic recognition. Moreover, whereas a significant number of operational workers will directly benefit from the measure on recognition of qualifications as they are currently facing downgrading; many others will see mobility as a real opportunity since they can access sooner with equivalent qualification to navigation on the Rhine. Finally, other main impacts for which qualitative assessments are available (e.g. reduction of vacancies in the sector – ‘the employment effect’) further add to the effectiveness and efficiency of policy option C.

Investment and administrative costs are expected to be lower for option B compared to option C. However, the positive effects are more than proportionally lower, due to the partial uptake of instruments. Option B is therefore less cost-effective than option C. More information can be found in sections 6.2.1. and 6.2.2.

3.3.Coherence

Compared to the baseline scenario, options B and C are more coherent with the completion of the internal transport market and the EU policy objectives reflected in the Europe 2020 growth strategy and the political priorities of the Juncker Commission. As option C (regardless of its suboption) will be most effective in contributing to the mutual recognition of workers, it would also contribute most to the EU energy efficiency, growth and industrial development political priorities of the Juncker Commission. Therefore, option C is considered to be more coherent than option B. The competence-based standards for examination of future boatmen and boatmasters appears to be necessary to fully achieve the mutual recognition of professional qualifications of boatmen and boatmasters. As both boatmen and boatmasters are skilled workers and need to possess certain competencies, another Member State needs to be confident about the skill levels of these workers before granting the recognition of professional qualifications. For workers using the education path to access the profession, these skills are developed and tested through the education system. In order to come to mutual recognition of diplomas and training certificates, EU minimum requirements would need to be set for the competencies to be demonstrated by candidates before the award of their diplomas and certificates. These competencies only cover the aspects which are relevant for the safe operation of vessels and therefore do not interfere with the general education aspects which remain under the competence of the Member States. The EU minimum requirements set minimum levels of competencies, necessary for the safe navigation of vessels. These requirements do not entail a full harmonisation of training and education in IWT. Member States can continue to differentiate IWT training and education to take account of the national situation. The identification of the required minimum competencies is supported by the efforts of the European network of nautical schools (EDINNA) which has developed (competence-based) Standards for Training and Certification in Inland Navigation (STCIN). In the framework of two recent bilateral agreements, the CCNR considered these standards necessary for assessing training institutions prior to granting recognition of diplomas. The approach is coherent with the spirit of the European Qualifications Framework CXXXVIII which focuses on learning outcomes rather than on the duration of training schemes. The reference to these minimum standards is considered essential for developing a European internal market for employment in IWT as it helps Member States, education institutions, employers and individuals compare qualifications across the EU’s diverse education and training systems. Moreover, in line with measures taken for other modes of transport, competence-based EU minimum requirements are only foreseen for skilled crew - boatmen and boatmasters. For unskilled crew, such as deckhands, only minimum requirements with regard to age, physical and mental fitness are considered, in order to facilitate labour mobility. As such the proposed intervention is necessary and proportionate to its goals.

The policy options were developed with a balance between economic and social measures, in order to avoid that action on one pillar would negatively affecting the other. No significant environmental impacts are expected.

3.4.Summary on the comparison of policy options

Table 5: Effectiveness, efficiency and coherence of the policy options compared to the baseline scenario

("+" refers to the intensity of a positive correlation, “0” refers to a neutral impact, the small sign “+” just above the main sign indicates an (additional) positive effect but of a lower magnitude than a “+”, no negative correlation has been identified)

3.5.Conclusion: preferred policy option

Taking into account effectiveness, efficiency and coherence, option C is preferred over option A and B. Under option C, suboption C1 is judged to be slightly more effective and efficient than suboption C2.

This Impact Assessment Report leaves it up to the political decision-makers to decide on the preferred policy suboption under option C. The difference between suboption C1 and C2 is the introduction under C1 of minimum competence-based standards for examination of future boatmen and boatmasters in education and training institutes and additional administrative exam waivers for those with a diploma or certificate issued by those institutes. The minimum standards only cover the aspects with are relevant for the safe operation of vessels and therefore don't interfere with the general education aspects which remain under the competence of the Member States. Similar Union legislative requirements for education and training institutes already exist for the rail and air transport sector. In these sectors, the requirements go further as they also entail continuous training requirements. Under option C2, no requirements are set for training and education institutes as all boatmen and boatmasters are required to pass an administrative exam organised under the responsibility of a competent authority in order to have their qualifications recognised across the EU, also if they are already in the possession of a diploma or certification of an IWT education or training institute.

The two suboptions are in line with stakeholders' opinion expressed both in the online public consultation and in the Common Expert Group (CEG). Opinions indicated a high level of support towards regulatory measures in relation to the harmonisation of professional requirements, qualifications and examinations, whereas the introduction of voluntary measures received a considerably lower level of support. The experts from the competent authorities in the Member States represented in the CEG considered the mutual recognition of diplomas and training certificates based on competence-based standards as a necessary step towards improved mobility of workers.

The two suboptions are also in line with the proportionality principle. In line with measures taken for other modes of transport, competence-based EU minimum requirements, verified through examinations, are only foreseen for skilled crew - boatmen and boatmasters. For unskilled crew, such as deckhands, only minimum requirements with regard to age, physical and mental fitness are proposed. The recognition of a third path via an intensive training programme is proportionate as its introduction is made optional. Under option C1, the measure to certify training programmes is considered proportionate to its goals as it does not interfere with the national education curricula on general subjects and it allows preventing those who have already successfully completed an approved training programme in the EU be obliged to pass additional administrative exams on the same subjects that were already covered by their training programme. To instil the necessary confidence for the mechanism of mutual recognition, the requirements of quality standards with respect to assessment of competences, recognition of programmes and monitoring of the whole certification system are considered proportionate. Finally, introducing common criteria for establishing requirements for knowledge of specific situations is necessary as the establishment of such requirements should be justified on safety grounds and the knowledge required should be proportional to the safety issues at stake.

Regarding implementation and compliance issues with respect to option C, it should be noted that a final decision has not been taken yet on the form of the legislative instrument to be proposed (directive or regulation). There was already some discussion with the sector in CEG about a reasonable implementation period as well as specific and realistic transitions measures and periods for various measures.

4.Monitoring and evaluation

The Commission services will monitor the implementation and effectiveness of this initiative through a set of core progress indicators, listed in the table below. It is foreseen that seven years after the end of the transposition period date of the proposed legislation, the Commission services will carry out an evaluation to verify whether the objectives of the initiative have been reached. This evaluation will be carried out inter alia based on the core progress indicators referred to below. This evaluation will be in line with Commission's evaluation requirements.

Table 6: Core progress indicators for monitoring purposes

Endnotes

(I)

A New Start for Europe: My Agenda for Jobs, Growth, Fairness and Democratic Change Political Guidelines for the next European Commission, Opening Statement in the European Parliament Plenary Session Strasbourg, 15 July 2014

(II)

1 convoy with four pushed lighters (=7 000 net tons) is the equivalent of 280 trucks at 25 net tons each. Source: Via Donau.

(III)

 Recent research carried out by the PLATINA II project indicates that seizing the potential for IWT continental container transport would reduce transport costs for the industry every year with 899 million of Euros ( http://naiades.info/repository/public/documents/Downloads/118_Study_Market_Potential_Continental_Market_2015_04_24.pdf )

(IV)

AT, BE, BG, DE, CZ, FR, HR, LU, NL, HU, PL, RO, SK as well as EE, IT, LT, FI, PT, SE and UK. CY, DK, EL, ES, IE, LV, MT and SI are considered not having inland waterways transport in the framework of this study.

(V)

European Commission (2014) EU transport in figures: Statistical pocketbook 2014.

(VI)

AT, BE, BG, DE, CZ, FR, HR, LU, NL, HU, PL, RO, SK.

(VII)

European Commission (2014) EU transport in figures: Statistical pocketbook 2014, p.42.

(VIII)

 CE Delft (2012), Medium & Long Term Perspectives of IWT in the EU and NVB/Erasmus Universiteit (2012), Blue Ports: de onmisbare schakels , p. 11 Conclusion.

(IX)

Communication from the Commission to the European Parliament, the Council, the European Parliament, European Economic and Social Committee, the Committee of the Regions and the European Investment Bank on A Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy, COM/2015/080 final

(X)

European Commission (2014) EU transport in figures: Statistical pocketbook 2014, p.82.The figure is the average for the 28 EU Member States. The average also includes Member States in which there are no navigable rivers, which results in a downward distorting effect. Figures on modal split share is according to CCNR-EU-Panteia (2014) Market Observation, p.50-51.

(XI)

E.g. Extract from TEN-T project “Upper Rhine, a connected corridor”: La région du Rhin Supérieur dispose d'une offre infrastructurelle dense. D'une part, le Rhin, et son réseau de canaux connectés (notamment au Danube, au Neckar et au Main), constitue la voie fluviale la plus fréquentée d'Europe mais dispose encore d'importantes réserves de capacités. D'autre part, les réseaux ferroviaire et routier présentent une offre de capacités très importante. Plusieurs points de saturation ont néanmoins été relevés aux niveaux ferroviaire et routier dans le cadre de l'étude sur les capacités des réseaux magistraux et portuaires conduites par les ports du Rhin Supérieur en 2014. According to the Study on TEN-T Core Network Corridor “Rhine–Danube” (http://ec.europa.eu/transport/themes/infrastructure/ten-t-guidelines/corridors/doc/2014-11-05-tent-rhi-dan-draft-final-report-v4.pdf), lock capacity utilization on the Danube is situated between 11 and 37%.

(XII)

Communication: Towards Quality Inland Waterway Transport Naiades II COM(2013) 623 final.

(XIII)

European Committee for the elaboration of standards for inland navigation

(XIV)

EU Transport infrastructure policy that connects the continent between East and West, North and South.

(XV)

 The CCNR is an international intergovernmental organization established by the Revised Convention for Navigation on the Rhine - referred to as the Mannheim Convention - of 17 October 1868. It has five member states: BE, CH, DE, FR and NL. See: http://www.ccr-zkr.org  

(XVI)

The DC is an international intergovernmental organization established by the Convention regarding the regime of navigation on the Danube signed in Belgrade on 18 August 1948. The Member States of the Danube Commission are AT, BU, HU, DE, MD, RU, SR, SK, UA, HR). See http://www.danubecommission.org  

(XVII)

 United Nations Economic Commission for Europe has 56 member states and two working parties dealing with inland waterways. See: http://www.unece.org/trans/main/sc3/sc3.html  

(XVIII)

The Sava Commission is an international organisation established by the Framework Agreement on the Sava River Basin (FASRB) in 2002 between HR, SR, BA and SI. See http://www.savacommission.org  

(XIX)

The Moselle Commission is an international intergovernmental institution established by the Moselle Convention signed by DE, FR and LU in 1956.  http://www.moselkommission.org  

(XX)

RNP was adopted through Resolution 2010-I-8-Annex 1.

(XXI)

 The composition and functioning of these agreements will be developed under section 3.2.1. Service Record Books (SRBs) register navigation time and qualifications. They as also provide proof that mental and physical fitness requirements have been met by each crew member. In this respect, SRBs are an important factor for obtaining a certificate to operate in a certain Member State or river basin.

(XXII)

Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition of professional qualifications, OJ L. 255, 30.09.2005, p. 22.

(XXIII)

UNECE, ‘Resolution No. 31 Minimum Requirements for the Issuance of Boatmasters Licenses in Inland Navigation with a view to their Reciprocal Recognition for International Traffic’, Doc ECE/TRANS/SC.3/WP.3/2009/8/Rev.1 (18 May 2009).

(XXIV)

Danube Commission, ‘Recommendations of the Danube Commission on Boatmasters’ Licenses’, Doc. CD/SES/77/7.

(XXV)

21All relevant documents can be found on: http://ec.europa.eu/transport/media/consultations/2013-06-21-inlandnavigqualifications_en.htm  

(XXVI)

Note that the way some issues are presented might be different in the publication consultation report and in the IAR. For example, as explained under section 2.2. safety is no longer a problem driver but a key element in the analysis of impacts; level of safety has to be maintained (and even possibly improved). In a similar way, language is not considered any more as an individual problem driver but is included in the more global need for 'competence-based standards'. As one of the consequence, 'River Speak' is no longer proposed as an individual measure but remains targeted as a 'communication' competence under the common minimum standards on competence. The specific issue of SRB has been addressed under section 3.3.1.2.

(XXVII)

http://ec.europa.eu/transport/modes/inland/promotion/platina_en.htm

(XXVIII)

 see http://www.edinna.eu

(XXIX)

Self-governing association of maritime and inland navigation related law enforcement authorities from EU Member States and Switzerland.

(XXX)

The European Inland Waterways Transport Social Partners include EBU (European Barge Union), ESO (European Skippers' Organisation) and ETF (European transport Workers' Federation).

(XXXI)

Within PLATINA, the European network of nautical schools (EDINNA) is elaborating Standards for Training and Certification in Inland Navigation (STCIN), similarly to the existing system of Standards for Training and Certification and Watch keeping for Seafarers (STCW) by the international maritime organisation (IMO).

(XXXII)

The evaluation of the current framework can be found on:

http://ec.europa.eu/transport/facts-fundings/evaluations/doc/2014-03-evaluation-report-directive-1996-50.pdf  

(XXXIII)

The external impact assessment study can be found on:  http://ec.europa.eu/transport/modes/inland/studies/inland_waterways_en.htm

(XXXIV)

See Annex 2. Source: Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding the recognition of professional qualifications in inland navigation, p.10. Figures for 2011. Source Ecorys (2013) updated by Panteia. These employment figures include the owner-operators, part-time and temporary employment in the IWT freight and passenger transport (excluding land-based personnel). From the total mentioned, the Commission has deducted the figures related to ES, DK, LV, SI and CH. It is important to note that these numbers do not include a ‘hidden reserve’ of personnel who have the necessary sailing licenses, but are not active on a regular basis.

(XXXV)

Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding the recognition of professional qualifications in inland navigation, Panteia et al, 2014, p.15.

(XXXVI)

EU Transport in figures 2014, p.25.

(XXXVII)

In particular BE, NL, FR and DE.

(XXXVIII)

CCNR, EC, Panteia (2013), Market Observation 2013, p.98.

(XXXIX)

Study on the costs and benefits of the implementation of the European Agreement on working time in inkand waterway transport – A comparison with the status quo, Ecorys, 2013, p.12.

(XL)

For the Danube corridor, countries concerned are AT, BG, HU, SK and RO. The Rhine countries are BE, CH, DE, FR and NL. The North-South corridor includes the following river basins: Scheldt, Rhône, Meuse and Seine. In terms of countries, it includes NL, BE and FR. The East-West corridor includes the following river basins: Elbe, Weser and Odra. In terms of countries, it includes NL, DE, PL and CZ.

(XLI)

Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding the recognition of professional qualifications in inland navigation, Panteia et al, 2014, p.66.

(XLII)

The "hidden reserve" is a capacity reserve which consists of persons with the right qualifications but that are available for IWT work on an incidental basis only. This concerns for example persons that are of an age older than 65 years and/or relatives that may provide support in exceptional cases.

(XLIII)

Panteia/PWC(2014),Analysis of the trends and prospects of jobs and working conditions in transport,Annex 13.

(XLIV)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation: technical support for an impact assessment, p 28.

(XLV)

Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding the recognition of professional qualifications in inland navigation, p.53-57.

(XLVI)

CE Delft (2012), Medium & Long Term Perspectives of IWT in the EU , chapters 1, 2 and 3.

(XLVII)

 CE Delft (2012), Medium & Long Term Perspectives of IWT in the EU and NVB/Erasmus Universiteit (2012), Blue Ports: de onmisbare schakels , p. 11 Conclusion.

(XLVIII)

EU Industrial Structure Report 2013, Competing in Global Value Chains, See http://ec.europa.eu/enterprise/policies/industrial-competitiveness/competitiveness-analysis/eu-industrial-structure/files/report_euis_2013_final.pdf  

(XLIX)

Panteia/Nea (2015 – forthcoming), Macro analysis of the market potential in the continental cargo market

(L)

Ecorys et al (2014), Danube+20, Job creation scenarios from a 20% increase of IWT on the Danube by 2020 compared to 2010.

(LI)

HaCon (2014), Rhine-Alp corridor study, p. 17, p.48, p.88-89.

(LII)

NAIADES II Commission staff working document “Greening the fleet: reducing pollutant emissions in inland waterway transport”, SWD(2013) 324 final

(LIII)

 As far as the boatmasters are concerned, the focus in this IAR is mainly on the differences between the RNP and Directive 96/50/EC. This is because the Danube Commission and UNECE do not issue binding legal rules, and because the national certificates issued by EU member states that fall out of the scope of Directive 96/50/EC are considered not to affect free navigation in the EU (source: study on the evaluation of the existing legal framework).

(LIV)

Croatia has submitted a request for recognition on 28 November 2013.

(LV)

Other countries like Portugal, United Kingdom, Italy and Luxembourg do not issue certificates in line with Directive 96/50/EC.

(LVI)

Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding the recognition of professional qualifications in inland navigation, p.10. Figures for 2011.

(LVII)

 See http://www.ccr-zkr.org/12020300-en.html .

(LVIII)

See more information on this specific aspect see problem driver 2.

(LIX)

As stipulated in the 7th Protocole to the Mannheim Convention.

(LX)

Panteia (2014), Evaluation of the relevant directives related to the initiative on recognition and modernisation of professional qualifications in inland navigation (Directives 91/672/EEC and 95/50/EC), p.29-30, p.48.

(LXI)

  Susan Farber, Expanding the Potential for Competency-Based Models, See http://www.evolllution.com/  

(LXII)

See article 7.13 of RNP.

(LXIII)

 For example, the Netherlands grants a reduction of only two years to a seafarer on all its waterways. This is based on Dutch regulation: Besluit tot goedkeuring examenreglementen en examenprogramma's voor de binnenvaart 2013. Most of the EU countries outside of the Rhine grant a reduction of three years.

(LXIV)

Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding the recognition of professional qualifications in inland navigation, p.10. From the total mentioned, the Commission has deducted the figures related to ES, DK, LV, SI and CH.

(LXV)

Rhine Regulations, UNECE regulation and Sava Commission regulation.

(LXVI)

See Platina competence table for operational level, available under http://www.platina1.naiades.info/platina/downloads

(LXVII)

49 Overview prepared by EDINNA as input for meetings with the Common Expert Group E01036, focused on recognition and modernisation of professional qualifications in inland navigation. This overview was meant to support the discussion and to reach an agreement on the relation between the existing functions and professional qualifications. EDINNA is the educational network of inland waterway navigation schools and training institutes, see http://www.edinna.eu  

(LXVIII)

CCNR (December 2010), ‘Administrative Arrangement on the Mutual Recognition of Service Record Books, Strasbourg.

(LXIX)

Countries that are not part of the interconnected IWT network but already issue boatmasters certificate in line with Directive 96/50/EC and could therefore more likely consider issuing also other qualifications in line with EU requirements. Note that if we would also add workers from Portugal, Italy and United Kingdom (2848), it is a total of 7,136 operational workers, i.e. 27% of the operational workers within the EU, who do not have their qualification recognised on the Rhine and in other EU member states.

(LXX)

and, under certain conditions, to third country nationals.

(LXXI)

ILO working paper, Living and Working Conditions in Inland Navigation in Europe, December 2013.

(LXXII)

In December 2015 the bilateral agreements that recognise specific training programmes provided by the training institutes of Decin (CZ) and CERONAV (RO) should enter into force. In view of the different education systems, recognition was only made possible thanks to the use of the STCIN and following a relatively long process. The reference framework allowed the CCNR to indicate the shortcomings in terms of competence and find an agreement on the adjustments to be made to reach CCNR standards. Both Romania and Czech Republic emphasised how important such recognition is for the mobility of their workers and the attractiveness of the profession.

(LXXIII)

Panteia (2014), Recognition and modernisation of professional qualifications in Inland Navigation, Technical support for an impact assessment, Final report, p.57-58, based on SAB data.

(LXXIV)

 See example for the qualification of boatmen in annex 6.

(LXXV)

 CCNR awards the function of Able Boatman after successfully finishing an educational program of three years in inland navigation, whilst the Dutch authorities award the function of helmsman.

(LXXVI)

 Only a list of diplomas delivered by specific training centers all located in CCNR member states are recognised by the CCNR

(LXXVII)

Germany is however less strict regarding lateral inflow, as it generally requires only six months experience in inland navigation.

(LXXVIII)

i.e. 27 boatmasters and 7 operational workers. Source: Panteia (2014), Recognition and modernisation of professional qualifications in Inland Navigation, Technical support for an impact assessment, Final report, p.91-93 based on Nederland Maritiem Land (2012) and Guy Sulpice (2011).

(LXXIX)

Article 8(2) of Directive 96/50/EC, supra note 4; Article 2.05 of the Rhine Patent Regulation, supra note 5.

(LXXX)

 Equivalent to 38,525,854,822 tonne kilometres. Data communicated by Panteia to the Commission on 10/12/2014.

(LXXXI)

Panteia (2014), Recognition and modernisation of professional qualifications in Inland Navigation, Technical support for an impact assessment, Final report, p.106-107. The assumptions, methodology and calculations behind KSS figures and a regional breakdown of the costs can be found in pages 100-110 of the report.

(LXXXII)

In total, € 2,613,661 of extra costs are made on the Danube due to pilotage. On the Rhine, this figure equals € 2,990,652. Also the Maritime Seine has got a large contribution to pilotage costs: € 2,058,778 .

(LXXXIII)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, p. 118-119

(LXXXIV)

In the aftermath of 2004 EU enlargement, the possibility to recognize non CCNR document was given by the entry into force in December 2004 of the additional Protocol No. 7 to the Mannheim Convention.

(LXXXV)

 CCNR (December 2010), Administrative Arrangement on the Mutual Recognition of Service Record Books, Strasbourg.

(LXXXVI)

 Administrative Arrangement concerning a Framework for Cooperation between the Secretariat of the Central Commission for the Navigation of the Rhine and the Directorate-General for Mobility and Transport of the European Commission (2013). See http://ec.europa.eu/transport/modes/inland/doc/2013-05-22-rhine.pdf  

(LXXXVII)

CESNI (Comité Européen pour l’élaboration des standards pour la navigation intérieure) has been created on 3 July 2015.

(LXXXVIII)

 Commission proposal of 10 September 2013, which aims at repealing Directive 2006/87/EC.

(LXXXIX)

 Social partners' position on professional qualifications and training standards for crew members on inland waterways transport vessels, September 2013.

(XC)

Within PLATINA, the European network of nautical schools (EDINNA) is elaborating Standards for Training and Certification in Inland Navigation (STCIN), similarly to the existing system of Standards for Training and Certification and Watch keeping for Seafarers (STCW) by the international maritime organisation (IMO).

(XCI)

NEA et al (2011), Medium and Long Term Perspectives of IWT in the European Union. p.21” for an estimation of the forecasted IWT performance in the EU up to 2040. It is consistent with the 2013 EU Reference Scenario ( http://ec.europa.eu/transport/media/publications/doc/trends-to-2050-update-2013.pdf )

(XCII)

Idem.

(XCIII)

Regarding boatmasters, the ageing is more significant in BE, FR and DE (with majority that will retire within 10-20 years). As far operational workers are concerned, ageing is an issue for BE and DE but not for FR and NL that have an age curve below the EU average. Source: CCNR, EC, Panteia (2014), Market Observation 2014, p.97-98.

(XCIV)

The demand for workers has been estimated in relation to the total number of vessels (and the amount of cargo transported) and the manning requirements. Assumptions used to determine the supply of workers are based on expert judgements from the external consultant.

(XCV)

As in the calculations the lateral in/outflow has not been taken into account, it is not possible to exactly predict how large the gaps exactly are. Furthermore, it must be noted that the “hidden reserve”  can be used but is not integrated in the supply/demand model.

(XCVI)

Council Directive 2014/112/EU of 19 December 2014 implementing the European Agreement concerning certain aspects of the organisation of working time in inland waterway transport, concluded by the European Barge Union (EBU), the European Skippers Organisation (ESO) and the European Transport Workers' Federation (ETF) Text with EEA relevance , OJ L 367, 23.12.2014, p. 86–95.

(XCVII)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, p. 71.

(XCVIII)

NEA et al (2011), Medium and Long Term Perspectives of IWT in the European Union, p.21.

(XCIX)

 Panteia (2014), Recognition and modernisation of professional qualifications in Inland Navigation, Technical support for an impact assessment, Final report, p.105.

(C)

 With a number of KSS remaining identical.

(CI)

The assumptions, methodology and calculations behind these figures can be found in Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, p. 100-110.

(CII)

Though RNP mentions a possible maximum reduction of 3 years under article 7.01. Appendix 1 to the instructions for the services mentions in practice a maximum of 2 years. See http://www.ccr-zkr.org/files/documents/reglementSTF/stf2_122013_fr.pdf  

(CIII)

Under Directive 96/50/EC, medical check-up is foreseen at minimum every year after 65 years old. Under RNP every 5 years between 50-65, yearly after 65 years old. Based on a study, a "Dutch proposal" has been put forward i.e. medical checks at 60, 65 and 70 and thereafter every two years. When the IAR refers to the "new proposed frequency", it refers to that proposed measure.

(CIV)

Measures 5 and 6 are rather to be seen as alternatives as these are two different ways aimed at facilitating mutual recognition of qualifications. The two measures/instruments target similar population, both in terms of scope (crew) and voluntary Member States. Analysis of impacts of these measures will therefore be very similar as shown under section 6. Nevertheless, it should be noted that it is possible that the two measures co-exist in a limited way. In particular if the sector would opt for measure 6 it is likely that a number of CCNR arrangements would remain/be needed to cover countries or limited aspects not covered by CTT/CTF. This would of course add a certain legal and administrative complexity compared to BAU.

(CV)

Directive 2013/55/EU sets the conditions for CTT/CTFs adoption and of their potential scope. CTT/CTFs are introduced by delegated acts of the Commission. The Directive clearly provides that Member States may, under certain conditions, opt out of the delegated act. It is not legally possible for a delegated act by the Commission to deny Member States a right that they enjoy under the Directive itself and which is not conditional upon a decision of the Commission.

(CVI)

 Full application of measures 5 and 6 together does not make sense (see footnote 96). For the sake of simplification they are however integrated in the same option.

(CVII)

  Susan Farber, Expanding the Potential for Competency-Based Models, See http://www.evolllution.com/  

(CVIII)

Recommendation of the European Parliament and of the Council of 23 April 2008 on the establishment of the European Qualifications Framework for lifelong learning, OJ C 111, 6.5.2008. http://www.eqavet.eu/gns/policy-context/european-vet-initiatives/european-qualifications-framework.aspx .

(CIX)

COM(2013) 623 final

(CX)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, Final report, p. 45-46. Ranging from a decrease of 2 workers in case of alignment with existing CCNR standards, to an increase of respectively 2-4 and 6-9 workers in case alignment on Directive 96/50/EC or new frequency.

(CXI)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, Appendix 5 as adjusted by the Commission.

(CXII)

 Boatmasters still need to prove knowledge of specific situations on the Rhine.

(CXIII)

657 boatmasters from France + 20 from Croatia - 19 French boatmasters that have a Rhine patent. This results in 658 boatmasters that have more difficulties to be accepted the Rhine. Note, that French boatmasters are allowed on the Rhine too if they possess a Directive 96/50/EC license and can prove at least 4 years (720 days under CCNR system instead of 400 under the French system) of navigation experience.

(CXIV)

 see: http://www.ccr-zkr.org/12020300-en.html Putting the issue of KSS apart, all boatmasters have additional conditions to fulfil with the exception of those from DE.

(CXV)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, p. 45-46

(CXVI)

Ibidem.

(CXVII)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, Appendix 4.

(CXVIII)

Percentage based on figures from CCNR, EC, Panteia (2014), Market observation 2014, p.95.

(CXIX)

In 2013, STC Group organised exams for 32 applicants at boatman level and for 7 candidates at boatmaster level. “Onderwijscentrum Binnenvaart” reported that 54 applicants passed the boatman practical exam program in 2013 and that, for the first half of 2014 they had an average of 8 applicants a month. In June 2014, they also reported 10 candidates enrolled for the practical exam at boatmaster level.

(CXX)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, p. 120.

(CXXI)

Idem, p.115.

(CXXII)

Idem p.65-67

(CXXIII)

Panteia (2015), Addendum, complementary figures on safety impact in the context of the technical support for the impact assessment on the recognition of professional qualifications in inland navigation.

(CXXIV)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, p.74-75.

(CXXV)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, Appendix 4.

(CXXVI)

PLATINA 1 D3.8, Strategy for harmonized IWT education and training standards, Annex II (BDB, 2010)

(CXXVII)

European Parliament (2009), Indicators of job quality in the European Union.

(CXXVIII)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment, p. 39-42.

(CXXIX)

Idem, p. 47-49.

(CXXX)

Idem, p. 58-60.

(CXXXI)

Investment costs are considered as upfront costs necessary to implement a measure.

(CXXXII)

The figures shown in the table as administrative costs for boatmaster practical exam represent average costs between estimates in case exam has to be carried out on a dedicated training ship that needs to be chartered for a day or in case the candidate uses his own. Source: Panteia (2015), Addendum, complementary figures to Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment.

(CXXXIII)

The figures shown in the table as administrative costs for boatmaster practical exam represent average costs between two averages: 1) for the scenario where the MS would opt putting an assessment only through a theoretical exam and 2) for a combination of both theoretical and practical exams. In each case, several options including various form of exams have been taken into account. Source: Panteia (2015), Addendum, complementary figures to Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment.

(CXXXIV)

Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding the recognition of professional qualifications in inland navigation, p.11.

(CXXXV)

Market observation 2013, CCNR-EC-Panteia, based on Dutch Central Bureau of Statistics, p.102.

(CXXXVI)

Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for an impact assessment.

(CXXXVII)

Impact on different regions has not been inserted as by its nature it cannot be expressed in one single trend.

(CXXXVIII)

  http://www.eqavet.eu/gns/policy-context/european-vet-initiatives/european-qualifications-framework.aspx  

(CXXXIX)

The difficulty to specify suitable core indicators for monitoring, in particular to monitor the impacts of the initiative on labour mobility and the filling of the demand supply gap of IWT workers, should be noted. As explained in the introduction of section 6 (analysis of impact), this is due to the existing situation where the availability of specific data for IWT us very limited. Quantitative monitoring is therefore focussed on measurable outcomes expected to result from the future implementation of the initiative.

EUROPEAN COMMISSION

Brussels, 18.2.2016

SWD(2016) 35 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT

Accompanying the document

Proposal for a Directive of the European Parliament and of the Council

on the recognition of professional qualifications in inland navigation and repealing Council Directive 91/672/EEC and Council Directive 96/50/EC

{COM(2016) 82 final}
{SWD(2016) 36 final}

List of annexes

Introduction

In the context of the impact assessment accompanying a potential legislative proposal on the recognition and modernisation of professional qualifications in inland navigation, the Commission services have conducted an online public stakeholder consultation . The goal of the potential initiative is the removal of barriers between EU Member States for exercising professions in the field of inland navigation, thus subscribing to the main goal of the European Commission's common transport policy of the free movement of persons and goods across the EU. The harmonisation of national legal and administrative regulations is of high importance for creating fair conditions for competition within and between the different transport modes 1 . The aim of this public online consultation was to collect the stakeholders' views in order to have their opinion on the identified problems and policy objectives and to assess their support to the proposed policy measures.

The public consultation was open for 13 weeks (26/03/2013 to 21/06/2013), and it contained a total of 90 questions, both quantitative and qualitative. The Commission services received a total of 94 replies. This note follows the structure of the consultation document and provides a summary of the nature of responses of different stakeholders. It is important to note that the sample of respondents is not statistically representative, and thus results should be interpreted with caution.

1. Identification of the respondents

1.1 Overall breakdown of consultation respondents by stakeholder type

The Commission services received a total of 94 contributions. 10 stakeholder groups (divided by organisation type) 2 were represented among the respondents. Education and training organisations were the largest participating group, with 18 responses, followed by entrepreneurs/ship owners (15) and shipping companies (13). Public authorities account for a total of 17 responses, divided between Member State representatives (7) and other public authorities (10). The other categories had relatively few respondents (see graph below).

The graphs accompanying each section of this report indicate the proportions of each category of respondents that gave a certain answer. Given the low number of responses received from workers' organisations (1), river commissions (1) 3 and ports (4), these categories will not be included in the graphs throughout the report, but will be qualitatively assessed and referred to in the text when appropriate.

Figure 1. Consultation respondents by stakeholder type

1.2 Overall summary of responses by nationality

The responses came from a total of 16 countries. Romania (15), Germany (13), the United Kingdom (11) and Slovakia (9) account for the largest number of respondents, followed by the Netherlands (7), Hungary (6), Austria (6), Croatia (6) and Belgium (5).

Figure 2. Responses by nationality

1.3. Specific geographical range(s) for which stakeholders have experience

Figure 3 presents the geographical ranges for which the respondents to the public consultation have experience. The information provided reflects that a lot of respondents have experience in multiple river basins. 47 stakeholders have experience in the Danube and Sava Basin, 38 have it for the Rhine basin and 30 for the Moselle Basin.

Figure 3. Respondents by geographical range of experience

2. Problems to be addressed

In this section of the public consultation, the European Commission sought to understand to which extent stakeholders agree with the existence of the pre-identified problems regarding the recognition of professional qualifications and training standards in inland navigation and to identify other problems that would need to be taken into account.

2.1. Is the problem of restricted labour mobility relevant?

Almost 80% of all respondents rated the problem of restricted labour mobility derived from the differences between countries in professional qualifications and training standards in inland navigation as "important" or "very important". Education and training organisations are the group that rates it as most important (95%), followed by public authorities and employers' organisations (around 89% each). Entrepreneurs/ship owners present a more dispersed distribution of responses, with almost 50% of the respondents considering the labour mobility restrictions as "very important" or "important".

Figure 4. Relevance of the problem of restricted labour mobility by stakeholder type 4

The river commission and the worker's organisation that contributed to the public consultation rated this problem as highly important. The four ports provided responses that range from "somewhat important" to "very important".

2.2. Is the problem of safety relevant?

Around 70% of all respondents consider that safety problems derived from the differences between countries in professional qualifications and training standards in inland navigation are "important" or "very important". Nevertheless, responses vary by group of stakeholder: whereas 83% of public authorities, boatmasters and education and training organisations consider this problem as "very important" or "important", the percentage is of around 45% for entrepreneurs/ship owners and employers' organisations. Despite this, it is important to note that more than 60% of respondents of each group of stakeholders consider this problem at least "somewhat important".

Figure 5. Relevance of the problem of safety by stakeholder type

3. Problem drivers

3.1. Problem of Restricted Labour Mobility: Overall perception of relevance of different problem drivers

This section presents the overall perception of the relative importance of different drivers to the problem of restricted labour mobility. It is important to note that these are the aggregated responses of all stakeholders. Disaggregation by type of stakeholder is found in the following section 3.2.

As shown in Figure 6, difficulties due to different requirements for professional qualifications of workers within the inland navigation sector (56%) and the difficulties with the recognition by national authorities of service record books (SRBs) or of the information contained in the SRBs (55%) are in relative terms considered the aspects contributing the most to the problem of restricted labour mobility. Around 50% of all respondents find that local knowledge requirements (LKRs) preventing boatmasters to operate on a certain stretch (51%) and language problems preventing crew members of different nationalities to perform duties on vessels sailing on the EU inland waters (48%) are "relevant" or "very relevant" problem drivers. Finally, difficulties with the recognition of relevant professional qualifications of workers from outside the sector are considered as the least important problem driver in relative terms (43% rating it "very relevant" or "relevant").

The stakeholders were asked to assess the current system of mutual recognition of Service Record Books operated through multilateral agreements between the CCNR and a number of non-Rhine EU Member States. 40% of the respondents stated that this system serves its purpose only partially, 21% consider that it does not serve its purpose and only 13% of them consider that it serves its purpose fully.

When asked whether the current system of mutual recognition of boatmasters certificates adequately addresses the labour mobility barriers for boatmasters from the Non-Rhine EU Member States on the Rhine, 45% of the respondents say that mobility barriers are only partially addressed, 26% think that they are not adequately addressed, and only 12% consider that they are fully addressed through this system.

Figure 6. Relevance of different problem drivers to the problem of restricted labour mobility

3.2. Relevance of different problem drivers by type of stakeholder

3.2.1. Problem driver 1: Difficulties due to different requirements for professional qualifications of workers within the inland navigation sector (requirements for experience, exam programmes, physical and mental fitness)

Around 78% of education and training organisations and employers' organisations that responded to the public consultation consider this problem driver as highly relevant, followed by around 67% of boatmasters and public authorities, and 46% of shipping companies. Most entrepreneurs/ship owners rated it as "somewhat relevant" (47%).

Figure 7. Relevance of problem driver 1 (different requirements for professional qualifications) by type of stakeholder

Additionally, the river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant, whereas three out of four ports rated it as "somewhat important". It is important to note that only 11% of the total number of respondents finds this problem driver as "not relevant" or of "little relevance".

3.2.2. Problem driver 2: Difficulties with recognition of relevant professional qualifications of workers from outside the sector (such as the maritime or fishing sector)

The distribution of responses with regard to the second problem driver differs substantially by group of stakeholder. An important percentage of education and training organisations (72%) and employers' organisations (56%) consider it a highly relevant problem, followed by shipping companies (46%). All the other groups consider it mainly "somewhat relevant", in particular boatmasters (67%). Around 67% of public authorities and 60% entrepreneurs/ship owners consider it at least "somewhat relevant".

Figure 8. Relevance of problem driver 2 (recognition of qualifications of workers from outside the sector) by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant, whereas three out of four ports rated it as "somewhat important".

3.2.3. Problem driver 3: Local Knowledge Requirements (LKRs) may prevent boatmasters to operate on a certain stretch (relevant for boatmasters only)

Perceptions of the relevance of this problem driver vary between types of stakeholders, as shown in Figure 9. Education and training organisations and employers' organisations are the groups that consider it more important, with 67% of their respondents rating it as highly relevant, followed by shipping companies (62%). At the same time, entrepreneurs/ship owners and boatmasters are the groups of stakeholders that perceive this problem driver as less relevant, in relative terms, with 67% of their respondents rating it as highly important or somewhat important. With regards to public authorities, it should be noted that despite presenting a relatively low percentage of "highly relevant" responses, only 11% of them consider the issues with LKRs of no relevance. Additionally, the river commission and the worker's organisation that contributed to the public consultation consider this problem driver as highly relevant.

Figure 9. Relevance of problem driver 3 (Local Knowledge Requirements) by type of stakeholder

The public consultation also asked the stakeholders about the justification of local knowledge requirements. As shown in Figure 10, 70% of the respondents consider that LKRs are justified when there are some special hydro morphological characteristics of the river sector which make navigation very difficult; 60% of them consider they are justified when there are specific local traffic regulations in place due to safety concerns, and 49% of them refer to the absence of appropriate marking systems.

Figure 10. Criteria for the establishment of Local Knowledge Requirements 5

When asked about whether the LKRs which are currently in force in Member States are justified in view of the criteria referred to above (hydro morphological characteristics, absence of marking systems, local traffic regulations), the responses provided were the following:

Figure 11. Justification of the currently enforced LKRs 6

3.2.4. Problem driver 4: Difficulties with the recognition by national authorities in the Member States of Service Record Books (SRBs) or of the information contained in the SRBs

The difficulties with the recognition of SRBs are considered by 78% of employers' organisations responding to the public consultation as "relevant" or "very relevant" drivers to the problem of restricted labour mobility. A slightly lower percentage is registered for public authorities and shipping companies (around 70% in each case). Entrepreneurs/ship owners are the group of stakeholders that registers a lower percentage of "highly relevant" responses (20%). Despite this, it is important to note that 67% of them consider it either "somewhat relevant" or "highly relevant". Boatmasters present a divided position: half of the respondents consider it very relevant, whereas the other half consider it of little relevance.

Figure 12. Relevance of problem driver 4 (recognition of Service Record Books) by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this problem driver as "very relevant" or "relevant", whereas three out of four ports rated it as "somewhat relevant".

3.2.5. Problem driver 5: Language problems prevent crew members of a different nationality to perform duties on vessels sailing on the EU inland waterways

Language problems are considered a relevant barrier to labour mobility in inland navigation by education and training organisations and by boatmasters (67% each), while it is considered as "somewhat relevant" by most employers' organisations responding to the consultation (67%). Public authorities, shipping companies and entrepreneurs/ship owners have an intermediate position, with around 40-50% of them rating language problems as highly relevant.

Figure 13. Relevance of problem driver 5 (language problems) by type of stakeholder

Furthermore, the river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant, whereas the ports present a more dispersed opinion. In total, 80% of the respondents consider language problems as somewhat relevant to very relevant with regard to labour mobility issues.

3.3. Safety problem: Overall perception of relevance of different problem drivers

This section presents the overall perception of all stakeholders of the relative importance of different problem drivers to the problem of safety. In order to do this, the responses "relevant" and "very relevant" were aggregated. Responses by type of stakeholder are found in the following section 3.4.

As shown in Figure 14, language problems caused by crew members of different nationalities resulting in communication problems is, in relative terms, considered the aspect contributing the most to the problem of safety (85% of the respondents considering it either highly relevant or somewhat relevant). Around 76% of all respondents find that the standards for professional training in inland navigation which are set at national level have not kept up with technological development, making it a highly relevant or somewhat relevant problem driver.

Figure 14. Relevance of different problem drivers to the problem of safety

3.4. Relevance of problem drivers by type of stakeholder

3.4.1. Problem driver 1: The standards for professional training in inland navigation which are set at national level have not kept up with technological development

The importance of this problem driver is perceived by the different groups of stakeholders as relatively lower with respect to others, with the exception of education and training organisations, with 78% of its respondents rating it as "relevant" or "very relevant". Despite this, more than 60% of the respondents of each group of stakeholders consider it, at least, "somewhat important", reaching 83% in the case of public authorities and boatmasters. Employers' organisations and entrepreneurs/ship owners are the groups that consider it less important, in relative terms.

Figure 15. Relevance of problem driver 1 (standards for professional training have not kept up with technological development) by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant, whereas the responses of the four ports range from "somewhat relevant" to "very relevant". In total, 75% of the respondents consider language problems as somewhat relevant to very relevant with regard to safety issues.

3.4.2. Problem driver 2: Language problems caused by crew members of different nationalities, resulting in communication problems

The perception of the importance of language problems for safety differs between groups of stakeholders. Whereas education and training organisations and boatmasters rate it as highly relevant (89% and 83% respectively), shipping companies and entrepreneurs/ship owners find it relatively less relevant. Despite this, almost 80% of both groups consider it either highly relevant or somewhat relevant. As shown in Figure 16, the opinion of employers' organisations is the most polarized.

Figure 16. Relevance of problem driver 2 (language problems) by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant.

4. Assessment of policy objectives

In this section of the public consultation, the Commission sought to identify the degree to which Member States and stakeholders agree with the proposed objectives of the future initiative.

4.1. Overall perception of relevance of different policy objectives

This section presents the overall perception of all stakeholders of the relative importance of different policy objectives of the future initiative regarding the recognition and modernisation of professional qualifications in inland navigation. Responses by type of stakeholder are found in section 4.2. As shown in Figure 17, the three policy objectives (eliminate barriers to labour mobility and improve safety both by addressing the human factor and by bringing training standards in line with new technological development) are considered equally relevant, with around 75% of respondents considering them "very important" or "important". Overall, less than 10% of respondents consider the different policy objectives as not important.

Figure 17. Relevance of different policy objectives

4.2. Relevance of policy objectives by type of stakeholder

4.2.1. Policy objective 1: Eliminate barriers to labour mobility

An important percentage of education and training organisations (89%), employers' organisations (89%), shipping companies (84%), public authorities (71%) and boatmasters (67%) consider this policy objective as "very important" or "important". Entrepreneurs/ship owners present a more dispersed opinion, with 40% of them considering it "somewhat important" and 20% of them stating that it is not an important objective.

Figure 18. Relevance of policy objective 1 by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this policy objective as "very important", whereas the responses of the four ports range from "somewhat important" to "very important". As shown in Figure 18, the overall support to this policy objective is very high, with only 7% of total respondents considering it not important.

4.2.2. Policy objective 2: Improve safety in the IWT sector by addressing the human factor

With regards to policy objective 2, responses differ considerably between groups of stakeholders. Education and training organisations and public authorities consider that addressing the human factor to improve safety is a highly important objective (with 94% and 89% of them, respectively, stating that it is "very important" or "important"). The groups that in relative terms consider this objective as less important are entrepreneurs/ship owners and employers' organisations.

Figure 19. Relevance of policy objective 2 by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this policy objective as very important, whereas the responses of the four ports range from "somewhat important" to "very important".

4.2.3. Policy objective 3: Improve safety in the IWT sector by bringing training standards in line with new technological development

As shown in Figure 20, the support to this policy objective is high in almost all groups of stakeholders, with only 7% of total respondents considering it not important. All education and training organisations participating in the public consultation consider it either "very important" or "important", whereas the percentages are of 83% in the case of boatmasters and of 78% in the case of public authorities and employers' organisations. Moreover, more than 50% of entrepreneurs/ship owners and shipping companies find it highly relevant, a percentage that increases notably if responses "somewhat relevant" are also aggregated.

Figure 20. Relevance of policy objective 3 by type of stakeholder

The worker's organisation that contributed to the public consultation rated this policy objective as "very important", the river commission considers it "important" and the responses of the four ports range from "somewhat important" to "very important".

5. Assessment of policy options

The European Commission has identified a number of possible policy measures that may address the problem areas referred to above. The results presented in this section reflect the opinions of the different stakeholders with regards to the suitability of the different measures.

PROBLEM OF RESTRICTED LABOUR MOBILITY

5.1 Overall perception of relevance of different policy measures to deal with the problem of restricted labour mobility due to different requirements for professional qualifications of workers within the inland navigation sector

This section presents the overall perception of the relative suitability of different policy measures to deal with the problem of restricted labour mobility. It is important to note that these are the aggregated responses of all stakeholders. Disaggregation by type of stakeholder is found in section 5.2.

As shown in Figure 21, the harmonisation of definitions for certain professional qualifications in inland navigation and mandatory harmonized requirements for these qualifications (74%) and the harmonisation of EU minimum training standards for professional qualifications in inland navigation (71%) are, in relative terms, considered the most adequate policy measures, followed by the mandatory harmonisation of requirements for age and physical and mental fitness (68%). Introducing voluntary measures from the inland navigation sector towards lowering labour mobility obstacles is considered the least adequate policy measure in relative terms by all stakeholders (56%), followed by the measure of extending the CCNR initiated process of mutual recognition of boatmaster certificates by establishing a mechanism for mutual recognition of professional qualifications in Service Record Books (60%). It is important to note that less than 10% of respondents find these policy measures as not appropriate, with the exception of the introduction of an EU central register (15%). Therefore, there is an overall high support to these measures.

Figure 21. Relevance of different policy measures to deal with the problem of restricted labour mobility due to different requirements for professional qualifications of workers within the inland navigation sector

5.2. Relevance of policy measures to deal with the problem of restricted labour mobility due to different requirements for professional qualifications of workers within the inland navigation sector, by type of stakeholder

5.2.1. Policy measure 1: Extending the CCNR initiated process of mutual recognition of boatmaster certificates by establishing a mechanism for mutual recognition of professional qualifications in Service Record Books

As shown in Figure 22, extending the CCNR initiated process of mutual recognition would be considered "very adequate" or "adequate" by 72% of public authorities and education and training organisations and by 67% of employers' organisations that responded to the public consultation. At the same time, the responses of around 70% of entrepreneurs/ship owners, shipping companies and boatmasters range between "very appropriate" and "somewhat appropriate". Entrepreneurs/ship owners are the group that register more "not appropriate" responses.

Figure 22. Relevance of policy measure 1 by type of stakeholder

The workers' organisation that contributed to the public consultation rated this policy measure as "very appropriate", the river commission rates it "somewhat appropriate" and the responses of the four ports range between "very appropriate" and "somewhat appropriate".

5.2.2. Policy measure 2: Mandatory harmonised requirements for age and physical and mental fitness for all crew members

All boatmasters, 88% of employers' organisations, 83% of education and training organisations and 72% of public authorities that answered to the public consultation consider that this policy measure would be "appropriate" or "very appropriate" to deal with the problem of labour mobility. The percentages are lower for the other types of stakeholders, in particular for entrepreneurs/ship owners (40%). Despite this, it is important to note that 85% of shipping companies and 73% of entrepreneurs/ship owners consider it, at least, "somewhat appropriate".

Figure 23. Relevance of policy measure 2 by type of stakeholder

The river commission contributing to the public consultation rated this policy measure as "appropriate", whereas the workers' organisation considers it "somewhat appropriate".

5.2.3. Policy measure 3: Harmonisation of definitions of certain professional qualifications in inland navigation and mandatory harmonised requirements for these qualifications

This measure is considered "very appropriate" or "appropriate" by all employers' organisations and boatmasters that contributed to the public consultation, and by a high percentage of education and training organisations (94%), and public authorities (83%). The majority of shipping companies consider it "somewhat appropriate" (53%), whereas the opinion of entrepreneurs/ship owners is more divided. Moreover, the river commission and the worker's organisation contributing to the public consultation rated this policy measure as "very appropriate".

When asked for which crew members they consider that policy measures 2 and 3 would be most appropriate, 60% of respondents said that they should apply to boatmasters and other crew members, whereas 24% answered they should only apply to boatmasters.

Figure 24. Relevance of policy measure 3 by type of stakeholder

5.2.4. Policy measure 4: Harmonised EU minimum training standards for professional qualifications in inland navigation

Harmonising the EU minimum training standards for professional qualifications in inland navigation is considered a highly appropriate policy measure by all education and training organisations and by all boatmasters that contributed to the public consultation, as well as by 67% of employers' organisations, 61% of shipping companies and 61% of public authorities. The opinion of entrepreneurs/ship owners is more divided, but only 13% consider it not appropriate. It is important to note that more than 90% of all respondents consider this policy measure at least "somewhat appropriate".

Figure 25. Relevance of policy measure 4 by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this policy measure as "very appropriate", whereas the four ports consider it either "appropriate" or "very appropriate".

When asked about which crew members they consider that this policy measure would be most appropriate, 61% of respondents stated that it should apply to boatmasters and other crew members, whereas 28% answered it should only apply to boatmasters.

5.2.5. Policy measure 5: Introducing at EU level of a central register for EU boatmaster certificates

Introducing a central register for EU boatmaster certificate is perceived by the majority of education and training organisations and by public authorities that participated in the public consultation as highly appropriate (with 89% and 78% of their respondents considering it "very appropriate" or "appropriate", respectively), followed by boatmasters (67%). Around 40% of shipping companies and entrepreneurs/ship owners consider it highly appropriate, and the percentage increases notably when "somewhat appropriate" is also taken into account.

Figure 26. Relevance of policy measure 5 by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this policy measure as "very appropriate", whereas the four ports consider it either "appropriate" or "very appropriate".

5.2.6. Policy measure 6: Introducing voluntary measures from the inland navigation sector towards lowering labour mobility obstacles

As shown in Figure 27, approximately 80% of respondents of all groups of stakeholders consider this policy measure, at least, "somehow appropriate". The groups that register higher percentage of highly appropriate responses are employers' organisations, with 89% of respondents considering the measure as either "very appropriate" or "appropriate", boatmasters (67%) and education and training organisations (61%). The workers' organisation that contributed to the public consultation rated this policy measure as "very appropriate", the river commission considers it "somewhat appropriate" and the responses of the four ports range between "very appropriate" and "somewhat appropriate".

Figure 27. Relevance of policy measure 6 by type of stakeholder

5.2.7. Additional issues: certification of professional qualification

Stakeholders were invited to comment on a number of aspects related to the policy measures previously presented. In particular, this section presents the answers given to questions related to the system of certification of professional qualifications for boatmasters. One of these questions was: "Do you think it is necessary to extend the requirement for certification also to the highest rank under the level of boatmaster?" Responses differ substantially by type of stakeholder (see graph below). While the majority of respondents from education and training organisations gave a positive response (83%), followed by boatmasters (67%), the majority of respondents of other groups of stakeholders consider that only boatmasters should be required to have a certificate, in particular employers' organisations (78%), shipping companies (70%) and entrepreneurs/ship owners (60%).

Figure 28. Extension of certification to the highest rank of responsibility below boatmasters

Stakeholders were also asked about the appropriateness of introducing a modular certification system for boatmasters, which would imply the introduction of specific requirements for certificates with regard to waterways on maritime character, operation of only small vessels on small waterways, and operation of large convoys. Figure 29 presents the stakeholders' responses. In this case, more than one answer was allowed. Half of the respondents considers that such a modular system should maintain the current specific requirements for boatmasters that operate on waterways of maritime character, 42% of them consider that the modular system should introduce specific more stringent requirements for boatmasters operating large convoys, and 39% of them consider that it should introduce less stringent requirements for boatmasters operating in small vessels on small waterways.

Figure 29. Differentiation of boatmasters certificates

5.3. Relevance of policy measure 7 ("Introduction of a common method for lowering the barriers for maritime sailing time/experience to qualify as inland navigation sailing time/experience") to deal with the problem of restricted labour mobility due to different requirements for professional qualifications for workers from outside the sector

The majority of stakeholders answering to this public consultation find this policy measure at least somewhat appropriate. 67% of education and training organisations and 44% of employers' organisations find it either "very appropriate" or "appropriate", whereas boatmasters are the group of stakeholders presenting a lower percentage of these responses. Nevertheless, it is important to note that more 80% of them consider it at least somewhat appropriate. Public authorities, entrepreneurs/ship owners and shipping companies are considerably divided in their responses. Additionally, the workers' organisation, the river commission and two of the four ports contributing to this public consultation rate this policy measure as "somewhat appropriate".

When asked about which crew members they consider that this policy measure would be most appropriate, 53% of respondents said that it should apply to boatmasters and other crew members, 17% answered it should only apply to boatmasters, and 17% answered that answered it should only apply to other crew members.

Figure 30. Relevance of policy measure 7 by type of stakeholder

5.4. Overall perception of relevance of different policy measures to deal with the problem of restricted labour mobility due to LKRs potentially preventing boatmasters to operate on a certain stretch of a river

This section presents the overall perception of all respondents of the relative suitability of different policy measures to deal with the problem of restricted labour mobility due to local knowledge requirements. As shown in Figure 31, the harmonisation of competency/examination requirements (59%) and the establishment of mandatory common criteria for establishing LKRs in the EU (57%) are, in relative terms, considered the most adequate policy measures. The two remaining measures implying non-binding recommendations are perceived as relatively less appropriate.

Figure 31. Relevance of different policy measures to deal with the problem of restricted labour mobility due to LKRs potentially preventing boatmasters to operate on a certain stretch of a river

53% of the respondents consider that the use of simulators in training programmes or exams could lead to a reduction of training or experience requirements for LKRs, whereas 37% of respondents do not agree with the previous statement.

5.5. Relevance of policy measures to deal with the problem of restricted labour mobility due to LKRs potentially preventing boatmasters to operate on a certain stretch of a river, by stakeholder

5.5.1. Policy measure 8: Mandatory common criteria for establishing LKRs in the EU

This policy measure is considered highly appropriate by the majority of employers' organisations (89% of them rating it either "very appropriate" or "appropriate"), education and training organisations (78%), boatmasters (67%) and shipping companies (62%), whereas it receives lower support from entrepreneurs/ship owners (40%) and public authorities (44%). However, more that 50% of them rate this policy measure at least "somewhat appropriate". Additionally, the river commission contributing to this public consultation considers this measure as "very appropriate".

Figure 32. Relevance of policy measure 8 by type of stakeholder

5.5.2. Policy measure 9: Harmonisation of competency/examination requirements for LKR

As shown in Figure 33, the distribution of opinions about the appropriateness of this policy measure varies by type of stakeholder. The majority of education and training organisations consider it highly appropriate (89%), followed by shipping companies (69%), boatmasters (67%), employers' organisations (67%) and public authorities (56%). Even though 40% of entrepreneurs/ship owners find it "not appropriate", it should be noted that 53% of their respondents consider the measure at least "somewhat appropriate". The river commission contributing to this public consultation considers this policy measure as "very appropriate".

Figure 33. Relevance of policy measure 9 by type of stakeholder

5.5.3. Policy measure 10: Non-binding recommendations regarding criteria for establishing LKRs in the EU

In general, this policy measure receives low support by the different groups of stakeholders, with the only exception of boatmasters. As shown in Figure 34, most of the other groups of stakeholders consider this policy measure as either "not appropriate" or only "somewhat appropriate".

Figure 34. Relevance of policy measure 10 by type of stakeholder

The river commission and two of the four ports contributing to this public consultation consider this policy measure as "not appropriate", whereas the other two ports and the workers' organisation did not provide an answer.

5.5.4. Policy measure 11: Non-binding recommendations regarding criteria for examination requirements for LKR

Similarly to the previous measure, the establishment of non-binding recommendations regarding criteria for examination requirements for LKR is in general not considered an appropriate measure to deal with the problem of restricted labour mobility. This policy measure registers the lowest support among stakeholders, with the only exception of boatmasters. The river commission and two of the four ports contributing to this public consultation consider this policy measure as "not appropriate". The other two ports and the workers' organisation do no provide an answer.

Figure 35. Relevance of policy measure 11 by type of stakeholder

When asked whether the information provided by River Information Services could replace in certain cases the need for local knowledge requirements, 52% of the respondents answered "yes, sometimes", 22% answered "never", and 18% answered "yes, always".

5.6. Relevance of policy measure 12 ("Introduce a mandatory electronic SRB and a central register for e-SRB") to deal with the difficulty of extracting reliable information from SRBs needed for workers to prove their professional qualifications, by stakeholder

Introducing a mandatory electronic SRB is considered appropriate by 78% of education and training organisations, 78% of employers' organisations and 72% of public authorities. Despite registering a lower percentage of "very appropriate" and "appropriate" responses than the previously mentioned groups, more than 60% of shipping companies, boatmasters and entrepreneurs/ship owners consider it at least "somewhat appropriate". The specific distribution of responses is shown in Figure 36.

Figure 36. Relevance of policy measure 12 by type of stakeholder

The workers' organisation participating to this public consultation consider this policy measure "very appropriate", whereas the river commission rates it as "very appropriate".

When asked about which crew members they consider that this policy measure would be most appropriate for, 52% of respondents answered boatmasters and other crew members, 16% answered only boatmasters and 16% answered only other crew members. When asked whether they think that introducing electronic SRBs would be beneficial for inland navigation, 74% of the stakeholders responded positively. Furthermore, 64% of the respondents consider that the introduction of electronic SRBs should be accompanied by the introduction of electronic logbooks (for instance to verify entries made in the e-SRB with regard to sailing time).

Stakeholders where additionally asked for what purposes would the e-SRB be used. Figure 37 below shows the percentage of total stakeholders that stated that they "totally agree" or "tend to agree".

Figure 37. Use of the e-SRBs

5.7. Relevance of policy measure 13 ("Introduction of River Speak") to deal with the problem of restricted labour mobility derived from language problems

The introduction of River Speak or other language-neutral means of communication in the training programmes and as a part of professional qualifications is considered by 72% of stakeholders contributing to the public consultation as a measure that could help addressing the problem of mobility of IWT workers. As shown in Figure 38, education and training organisations are the group that presents a higher support to this measure (94%), followed by public authorities (78%) and entrepreneurs/ship owners (73%). 60% of shipping companies rate the measure as relevant to improve labour mobility, despite being the group that gives the lowest support to the measure, in relative terms. The river commission and the workers' organisation that participated in the public consultation also consider this measure as very appropriate.

Figure 38. Relevance of policy measure 13 to deal with the problem of mobility, by type of stakeholder

PROBLEM OF SAFETY

5.8 Overall perception of relevance of different policy measures to deal with the safety problem related to the fact that the standards for professional training in inland navigation have not kept up with technological development

This section presents the relative importance of different policy measures to the problem of safety, as results from the responses of all the stakeholders participating in the public consultation. Responses by type of stakeholder are found in the following section 5.8. As shown in Figure 39, the harmonisation at EU level of minimum training standards for all professional qualifications in inland navigation is in relative terms considered more appropriate to deal with safety problems than introducing voluntary measures (83% of respondents consider harmonisation “somewhat appropriate”, "appropriate" or "very appropriate", versus 66% in the case of voluntary measures). Only 10% considers the harmonisation measures as not appropriate, whereas this figure rises up to 23% for the voluntary measures.

Figure 39. Relevance of policy measures to deal with the safety problem related to the fact that standards for professional training have not kept up with technological development

Stakeholders were asked whether the use of simulators in inland navigation training and education programmes would increase safety in the sector. The majority of respondents (84%) answered positively.

5.9. Relevance of policy measures to deal with the safety problem related to the fact that the standards for professional training in inland navigation have not kept up with technological development, by type of stakeholder

5.9.1. Policy measure 14: Harmonisation at EU level of minimum training standards for all professional qualifications in inland navigation

The distribution of responses with regards to the appropriateness of this policy measure differs notably by group of stakeholder. Approximately 90% of education and training organisations consider it highly appropriate, followed by 67% of boatmasters and 61% of public authorities. At the same time, employers' organisations, shipping companies and entrepreneurs/ship owners present a higher percentage of "somewhat important" responses.

Figure 40. Relevance of policy measure 14 by type of stakeholder

The river commission contributing to this public consultation considers that this policy measure is "very appropriate", whereas the workers' organisation finds it "appropriate". The opinion of ports is highly dispersed in this case. It is important to note that, in general, more than 80% of respondents find this policy measure, at least, "somewhat important".

When asked for which crew members you consider that this policy measure would be the most appropriate, 71% of respondents answered boatmasters and other crew members, whereas 17% stated only boatmasters.

5.9.2. Policy measure 15: Introducing voluntary measures from the inland navigation sector towards improving safety

The perception of the appropriateness of this measure to deal with the problem of safety is comparatively more dispersed than in previous cases. The majority of respondents of all groups of stakeholders perceive this measure as at least "somewhat appropriate". Education and training organisations and boatmasters are the groups registering a higher percentage of "very appropriate" or "appropriate" responses, with 50% of the respondents in each case.

Figure 41. Relevance of policy measure 15 by type of stakeholder

The river commission participating in this public consultation considers that this policy measure is "somewhat appropriate".

5.10. Relevance of policy measure 13 ("Introduction of River Speak") to deal with the safety problem derived from language problems

Around 80% of the respondents consider that the introduction of River Speak or other language-neutral means of communication in the training programmes and as a part of professional qualifications would help improving the levels of safety in the sector. As shown in Figure 42, all employers' organisations that participated in this public consultation give support to this measure, followed by 94% of education and training organisations, 89% of public authorities, 80% of entrepreneurs/ship owners and 77% of shipping companies. The workers' organisation and the river commission participating in this public consultation also have a positive opinion on this measure.

Figure 42. Relevance of policy measure 13 to deal with problem of safety, by type of stakeholder

6. Regional differences in the impact of the measures as perceived by the stakeholders

The stakeholders in the online public consultation were asked to compare harmonised requirements measures with voluntary measures. The main results for two important river areas, the Rhine and Danube, are summarized below:

-With regard to labour mobility, mandatory harmonised professional qualifications and training standards will, according to 85% of CCNR stakeholders, and a bit less than 80% of Danube stakeholders, result in fairly to very positive effects on labour mobility. For voluntary measures these percentages are respectively around 50% and 60%.

-With regard to administrative burden: mandatory harmonised professional qualifications and training standards will, according to 54% of CCNR stakeholders and more than 70% of Danube stakeholders, result in fairly to very positive effects on the administrative burden. For voluntary measures these percentages are respectively around 23 and 62%.

With regard to safety: mandatory harmonised professional qualifications and training standards will according to around 90% of CCNR stakeholders, and more than 85% of Danube stakeholders result in fairly to very positive safety effects. For voluntary measures these percentages are both only around 60%. For the voluntary approach, respectively 8 and 4 % of CCNR and Danube respondents foresee negative effects.

The online public consultation revealed similar support both from the CCRN and the Danube region

7. Conclusions

The responses received within the online public stakeholder consultation on the "Recognition and modernisation of professional qualifications in inland navigation" confirm that the problems of restricted labour mobility and safety identified by the European Commission are of high importance and need to be dealt with, in order to remove the barriers between EU Member States for exercising professions in the field of inland navigation. The majority of the respondents considered the different problem drivers and subsequent policy objectives identified as highly relevant.

The online consultation also gathered information about the opinion of different groups of stakeholders with regards to the appropriateness of 15 different policy measures. The responses received confirm a high level of support to measures implying the harmonisation of professional requirements, qualifications and examinations in inland navigation between EU Member States, whereas the introduction of voluntary measures or non-binding recommendations receives a considerably lower level of support.

The voice of the stakeholders on specific problems and measures gathered through this public consultation will help the European Commission to devise a set of appropriate policy measures during the process of elaboration of the impact assessment accompanying a potential legislative proposal on the recognition and modernisation of professional qualifications in inland navigation.

Introduction

In the context of the impact assessment accompanying a potential legislative proposal on the recognition and modernisation of professional qualifications in inland navigation, the Commission services have conducted an online public stakeholder consultation . The goal of the potential initiative is the removal of barriers between EU Member States for exercising professions in the field of inland navigation, thus subscribing to the main goal of the European Commission's common transport policy of the free movement of persons and goods across the EU. The harmonisation of national legal and administrative regulations is of high importance for creating fair conditions for competition within and between the different transport modes 7 . The aim of this public online consultation was to collect the stakeholders' views in order to have their opinion on the identified problems and policy objectives and to assess their support to the proposed policy measures.

The public consultation was open for 13 weeks (26/03/2013 to 21/06/2013), and it contained a total of 90 questions, both quantitative and qualitative. The Commission services received a total of 94 replies. This note follows the structure of the consultation document and provides a summary of the nature of responses of different stakeholders. It is important to note that the sample of respondents is not statistically representative, and thus results should be interpreted with caution.

1. Identification of the respondents

1.1 Overall breakdown of consultation respondents by stakeholder type

The Commission services received a total of 94 contributions. 10 stakeholder groups (divided by organisation type) 8 were represented among the respondents. Education and training organisations were the largest participating group, with 18 responses, followed by entrepreneurs/ship owners (15) and shipping companies (13). Public authorities account for a total of 17 responses, divided between Member State representatives (7) and other public authorities (10). The other categories had relatively few respondents (see graph below).

The graphs accompanying each section of this report indicate the proportions of each category of respondents that gave a certain answer. Given the low number of responses received from workers' organisations (1), river commissions (1) 9 and ports (4), these categories will not be included in the graphs throughout the report, but will be qualitatively assessed and referred to in the text when appropriate.

Figure 1. Consultation respondents by stakeholder type

1.2 Overall summary of responses by nationality

The responses came from a total of 16 countries. Romania (15), Germany (13), the United Kingdom (11) and Slovakia (9) account for the largest number of respondents, followed by the Netherlands (7), Hungary (6), Austria (6), Croatia (6) and Belgium (5).

Figure 2. Responses by nationality

1.3. Specific geographical range(s) for which stakeholders have experience

Figure 3 presents the geographical ranges for which the respondents to the public consultation have experience. The information provided reflects that a lot of respondents have experience in multiple river basins. 47 stakeholders have experience in the Danube and Sava Basin, 38 have it for the Rhine basin and 30 for the Moselle Basin.

Figure 3. Respondents by geographical range of experience

2. Problems to be addressed

In this section of the public consultation, the European Commission sought to understand to which extent stakeholders agree with the existence of the pre-identified problems regarding the recognition of professional qualifications and training standards in inland navigation and to identify other problems that would need to be taken into account.

2.1. Is the problem of restricted labour mobility relevant?

Almost 80% of all respondents rated the problem of restricted labour mobility derived from the differences between countries in professional qualifications and training standards in inland navigation as "important" or "very important". Education and training organisations are the group that rates it as most important (95%), followed by public authorities and employers' organisations (around 89% each). Entrepreneurs/ship owners present a more dispersed distribution of responses, with almost 50% of the respondents considering the labour mobility restrictions as "very important" or "important".

Figure 4. Relevance of the problem of restricted labour mobility by stakeholder type 10

The river commission and the worker's organisation that contributed to the public consultation rated this problem as highly important. The four ports provided responses that range from "somewhat important" to "very important".

2.2. Is the problem of safety relevant?

Around 70% of all respondents consider that safety problems derived from the differences between countries in professional qualifications and training standards in inland navigation are "important" or "very important". Nevertheless, responses vary by group of stakeholder: whereas 83% of public authorities, boatmasters and education and training organisations consider this problem as "very important" or "important", the percentage is of around 45% for entrepreneurs/ship owners and employers' organisations. Despite this, it is important to note that more than 60% of respondents of each group of stakeholders consider this problem at least "somewhat important".

Figure 5. Relevance of the problem of safety by stakeholder type

3. Problem drivers

3.1. Problem of Restricted Labour Mobility: Overall perception of relevance of different problem drivers

This section presents the overall perception of the relative importance of different drivers to the problem of restricted labour mobility. It is important to note that these are the aggregated responses of all stakeholders. Disaggregation by type of stakeholder is found in the following section 3.2.

As shown in Figure 6, difficulties due to different requirements for professional qualifications of workers within the inland navigation sector (56%) and the difficulties with the recognition by national authorities of service record books (SRBs) or of the information contained in the SRBs (55%) are in relative terms considered the aspects contributing the most to the problem of restricted labour mobility. Around 50% of all respondents find that local knowledge requirements (LKRs) preventing boatmasters to operate on a certain stretch (51%) and language problems preventing crew members of different nationalities to perform duties on vessels sailing on the EU inland waters (48%) are "relevant" or "very relevant" problem drivers. Finally, difficulties with the recognition of relevant professional qualifications of workers from outside the sector are considered as the least important problem driver in relative terms (43% rating it "very relevant" or "relevant").

The stakeholders were asked to assess the current system of mutual recognition of Service Record Books operated through multilateral agreements between the CCNR and a number of non-Rhine EU Member States. 40% of the respondents stated that this system serves its purpose only partially, 21% consider that it does not serve its purpose and only 13% of them consider that it serves its purpose fully.

When asked whether the current system of mutual recognition of boatmasters certificates adequately addresses the labour mobility barriers for boatmasters from the Non-Rhine EU Member States on the Rhine, 45% of the respondents say that mobility barriers are only partially addressed, 26% think that they are not adequately addressed, and only 12% consider that they are fully addressed through this system.

Figure 6. Relevance of different problem drivers to the problem of restricted labour mobility

3.2. Relevance of different problem drivers by type of stakeholder

3.2.1. Problem driver 1: Difficulties due to different requirements for professional qualifications of workers within the inland navigation sector (requirements for experience, exam programmes, physical and mental fitness)

Around 78% of education and training organisations and employers' organisations that responded to the public consultation consider this problem driver as highly relevant, followed by around 67% of boatmasters and public authorities, and 46% of shipping companies. Most entrepreneurs/ship owners rated it as "somewhat relevant" (47%).

Figure 7. Relevance of problem driver 1 (different requirements for professional qualifications) by type of stakeholder

Additionally, the river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant, whereas three out of four ports rated it as "somewhat important". It is important to note that only 11% of the total number of respondents finds this problem driver as "not relevant" or of "little relevance".

3.2.2. Problem driver 2: Difficulties with recognition of relevant professional qualifications of workers from outside the sector (such as the maritime or fishing sector)

The distribution of responses with regard to the second problem driver differs substantially by group of stakeholder. An important percentage of education and training organisations (72%) and employers' organisations (56%) consider it a highly relevant problem, followed by shipping companies (46%). All the other groups consider it mainly "somewhat relevant", in particular boatmasters (67%). Around 67% of public authorities and 60% entrepreneurs/ship owners consider it at least "somewhat relevant".

Figure 8. Relevance of problem driver 2 (recognition of qualifications of workers from outside the sector) by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant, whereas three out of four ports rated it as "somewhat important".

3.2.3. Problem driver 3: Local Knowledge Requirements (LKRs) may prevent boatmasters to operate on a certain stretch (relevant for boatmasters only)

Perceptions of the relevance of this problem driver vary between types of stakeholders, as shown in Figure 9. Education and training organisations and employers' organisations are the groups that consider it more important, with 67% of their respondents rating it as highly relevant, followed by shipping companies (62%). At the same time, entrepreneurs/ship owners and boatmasters are the groups of stakeholders that perceive this problem driver as less relevant, in relative terms, with 67% of their respondents rating it as highly important or somewhat important. With regards to public authorities, it should be noted that despite presenting a relatively low percentage of "highly relevant" responses, only 11% of them consider the issues with LKRs of no relevance. Additionally, the river commission and the worker's organisation that contributed to the public consultation consider this problem driver as highly relevant.

Figure 9. Relevance of problem driver 3 (Local Knowledge Requirements) by type of stakeholder

The public consultation also asked the stakeholders about the justification of local knowledge requirements. As shown in Figure 10, 70% of the respondents consider that LKRs are justified when there are some special hydro morphological characteristics of the river sector which make navigation very difficult; 60% of them consider they are justified when there are specific local traffic regulations in place due to safety concerns, and 49% of them refer to the absence of appropriate marking systems.

Figure 10. Criteria for the establishment of Local Knowledge Requirements 11

When asked about whether the LKRs which are currently in force in Member States are justified in view of the criteria referred to above (hydro morphological characteristics, absence of marking systems, local traffic regulations), the responses provided were the following:

Figure 11. Justification of the currently enforced LKRs 12

3.2.4. Problem driver 4: Difficulties with the recognition by national authorities in the Member States of Service Record Books (SRBs) or of the information contained in the SRBs

The difficulties with the recognition of SRBs are considered by 78% of employers' organisations responding to the public consultation as "relevant" or "very relevant" drivers to the problem of restricted labour mobility. A slightly lower percentage is registered for public authorities and shipping companies (around 70% in each case). Entrepreneurs/ship owners are the group of stakeholders that registers a lower percentage of "highly relevant" responses (20%). Despite this, it is important to note that 67% of them consider it either "somewhat relevant" or "highly relevant". Boatmasters present a divided position: half of the respondents consider it very relevant, whereas the other half consider it of little relevance.

Figure 12. Relevance of problem driver 4 (recognition of Service Record Books) by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this problem driver as "very relevant" or "relevant", whereas three out of four ports rated it as "somewhat relevant".

3.2.5. Problem driver 5: Language problems prevent crew members of a different nationality to perform duties on vessels sailing on the EU inland waterways

Language problems are considered a relevant barrier to labour mobility in inland navigation by education and training organisations and by boatmasters (67% each), while it is considered as "somewhat relevant" by most employers' organisations responding to the consultation (67%). Public authorities, shipping companies and entrepreneurs/ship owners have an intermediate position, with around 40-50% of them rating language problems as highly relevant.

Figure 13. Relevance of problem driver 5 (language problems) by type of stakeholder

Furthermore, the river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant, whereas the ports present a more dispersed opinion. In total, 80% of the respondents consider language problems as somewhat relevant to very relevant with regard to labour mobility issues.

3.3. Safety problem: Overall perception of relevance of different problem drivers

This section presents the overall perception of all stakeholders of the relative importance of different problem drivers to the problem of safety. In order to do this, the responses "relevant" and "very relevant" were aggregated. Responses by type of stakeholder are found in the following section 3.4.

As shown in Figure 14, language problems caused by crew members of different nationalities resulting in communication problems is, in relative terms, considered the aspect contributing the most to the problem of safety (85% of the respondents considering it either highly relevant or somewhat relevant). Around 76% of all respondents find that the standards for professional training in inland navigation which are set at national level have not kept up with technological development, making it a highly relevant or somewhat relevant problem driver.

Figure 14. Relevance of different problem drivers to the problem of safety

3.4. Relevance of problem drivers by type of stakeholder

3.4.1. Problem driver 1: The standards for professional training in inland navigation which are set at national level have not kept up with technological development

The importance of this problem driver is perceived by the different groups of stakeholders as relatively lower with respect to others, with the exception of education and training organisations, with 78% of its respondents rating it as "relevant" or "very relevant". Despite this, more than 60% of the respondents of each group of stakeholders consider it, at least, "somewhat important", reaching 83% in the case of public authorities and boatmasters. Employers' organisations and entrepreneurs/ship owners are the groups that consider it less important, in relative terms.

Figure 15. Relevance of problem driver 1 (standards for professional training have not kept up with technological development) by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant, whereas the responses of the four ports range from "somewhat relevant" to "very relevant". In total, 75% of the respondents consider language problems as somewhat relevant to very relevant with regard to safety issues.

3.4.2. Problem driver 2: Language problems caused by crew members of different nationalities, resulting in communication problems

The perception of the importance of language problems for safety differs between groups of stakeholders. Whereas education and training organisations and boatmasters rate it as highly relevant (89% and 83% respectively), shipping companies and entrepreneurs/ship owners find it relatively less relevant. Despite this, almost 80% of both groups consider it either highly relevant or somewhat relevant. As shown in Figure 16, the opinion of employers' organisations is the most polarized.

Figure 16. Relevance of problem driver 2 (language problems) by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this problem driver as highly relevant.

4. Assessment of policy objectives

In this section of the public consultation, the Commission sought to identify the degree to which Member States and stakeholders agree with the proposed objectives of the future initiative.

4.1. Overall perception of relevance of different policy objectives

This section presents the overall perception of all stakeholders of the relative importance of different policy objectives of the future initiative regarding the recognition and modernisation of professional qualifications in inland navigation. Responses by type of stakeholder are found in section 4.2. As shown in Figure 17, the three policy objectives (eliminate barriers to labour mobility and improve safety both by addressing the human factor and by bringing training standards in line with new technological development) are considered equally relevant, with around 75% of respondents considering them "very important" or "important". Overall, less than 10% of respondents consider the different policy objectives as not important.

Figure 17. Relevance of different policy objectives

4.2. Relevance of policy objectives by type of stakeholder

4.2.1. Policy objective 1: Eliminate barriers to labour mobility

An important percentage of education and training organisations (89%), employers' organisations (89%), shipping companies (84%), public authorities (71%) and boatmasters (67%) consider this policy objective as "very important" or "important". Entrepreneurs/ship owners present a more dispersed opinion, with 40% of them considering it "somewhat important" and 20% of them stating that it is not an important objective.

Figure 18. Relevance of policy objective 1 by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this policy objective as "very important", whereas the responses of the four ports range from "somewhat important" to "very important". As shown in Figure 18, the overall support to this policy objective is very high, with only 7% of total respondents considering it not important.

4.2.2. Policy objective 2: Improve safety in the IWT sector by addressing the human factor

With regards to policy objective 2, responses differ considerably between groups of stakeholders. Education and training organisations and public authorities consider that addressing the human factor to improve safety is a highly important objective (with 94% and 89% of them, respectively, stating that it is "very important" or "important"). The groups that in relative terms consider this objective as less important are entrepreneurs/ship owners and employers' organisations.

Figure 19. Relevance of policy objective 2 by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this policy objective as very important, whereas the responses of the four ports range from "somewhat important" to "very important".

4.2.3. Policy objective 3: Improve safety in the IWT sector by bringing training standards in line with new technological development

As shown in Figure 20, the support to this policy objective is high in almost all groups of stakeholders, with only 7% of total respondents considering it not important. All education and training organisations participating in the public consultation consider it either "very important" or "important", whereas the percentages are of 83% in the case of boatmasters and of 78% in the case of public authorities and employers' organisations. Moreover, more than 50% of entrepreneurs/ship owners and shipping companies find it highly relevant, a percentage that increases notably if responses "somewhat relevant" are also aggregated.

Figure 20. Relevance of policy objective 3 by type of stakeholder

The worker's organisation that contributed to the public consultation rated this policy objective as "very important", the river commission considers it "important" and the responses of the four ports range from "somewhat important" to "very important".

5. Assessment of policy options

The European Commission has identified a number of possible policy measures that may address the problem areas referred to above. The results presented in this section reflect the opinions of the different stakeholders with regards to the suitability of the different measures.

PROBLEM OF RESTRICTED LABOUR MOBILITY

5.1 Overall perception of relevance of different policy measures to deal with the problem of restricted labour mobility due to different requirements for professional qualifications of workers within the inland navigation sector

This section presents the overall perception of the relative suitability of different policy measures to deal with the problem of restricted labour mobility. It is important to note that these are the aggregated responses of all stakeholders. Disaggregation by type of stakeholder is found in section 5.2.

As shown in Figure 21, the harmonisation of definitions for certain professional qualifications in inland navigation and mandatory harmonized requirements for these qualifications (74%) and the harmonisation of EU minimum training standards for professional qualifications in inland navigation (71%) are, in relative terms, considered the most adequate policy measures, followed by the mandatory harmonisation of requirements for age and physical and mental fitness (68%). Introducing voluntary measures from the inland navigation sector towards lowering labour mobility obstacles is considered the least adequate policy measure in relative terms by all stakeholders (56%), followed by the measure of extending the CCNR initiated process of mutual recognition of boatmaster certificates by establishing a mechanism for mutual recognition of professional qualifications in Service Record Books (60%). It is important to note that less than 10% of respondents find these policy measures as not appropriate, with the exception of the introduction of an EU central register (15%). Therefore, there is an overall high support to these measures.

Figure 21. Relevance of different policy measures to deal with the problem of restricted labour mobility due to different requirements for professional qualifications of workers within the inland navigation sector

5.2. Relevance of policy measures to deal with the problem of restricted labour mobility due to different requirements for professional qualifications of workers within the inland navigation sector, by type of stakeholder

5.2.1. Policy measure 1: Extending the CCNR initiated process of mutual recognition of boatmaster certificates by establishing a mechanism for mutual recognition of professional qualifications in Service Record Books

As shown in Figure 22, extending the CCNR initiated process of mutual recognition would be considered "very adequate" or "adequate" by 72% of public authorities and education and training organisations and by 67% of employers' organisations that responded to the public consultation. At the same time, the responses of around 70% of entrepreneurs/ship owners, shipping companies and boatmasters range between "very appropriate" and "somewhat appropriate". Entrepreneurs/ship owners are the group that register more "not appropriate" responses.

Figure 22. Relevance of policy measure 1 by type of stakeholder

The workers' organisation that contributed to the public consultation rated this policy measure as "very appropriate", the river commission rates it "somewhat appropriate" and the responses of the four ports range between "very appropriate" and "somewhat appropriate".

5.2.2. Policy measure 2: Mandatory harmonised requirements for age and physical and mental fitness for all crew members

All boatmasters, 88% of employers' organisations, 83% of education and training organisations and 72% of public authorities that answered to the public consultation consider that this policy measure would be "appropriate" or "very appropriate" to deal with the problem of labour mobility. The percentages are lower for the other types of stakeholders, in particular for entrepreneurs/ship owners (40%). Despite this, it is important to note that 85% of shipping companies and 73% of entrepreneurs/ship owners consider it, at least, "somewhat appropriate".

Figure 23. Relevance of policy measure 2 by type of stakeholder

The river commission contributing to the public consultation rated this policy measure as "appropriate", whereas the workers' organisation considers it "somewhat appropriate".

5.2.3. Policy measure 3: Harmonisation of definitions of certain professional qualifications in inland navigation and mandatory harmonised requirements for these qualifications

This measure is considered "very appropriate" or "appropriate" by all employers' organisations and boatmasters that contributed to the public consultation, and by a high percentage of education and training organisations (94%), and public authorities (83%). The majority of shipping companies consider it "somewhat appropriate" (53%), whereas the opinion of entrepreneurs/ship owners is more divided. Moreover, the river commission and the worker's organisation contributing to the public consultation rated this policy measure as "very appropriate".

When asked for which crew members they consider that policy measures 2 and 3 would be most appropriate, 60% of respondents said that they should apply to boatmasters and other crew members, whereas 24% answered they should only apply to boatmasters.

Figure 24. Relevance of policy measure 3 by type of stakeholder

5.2.4. Policy measure 4: Harmonised EU minimum training standards for professional qualifications in inland navigation

Harmonising the EU minimum training standards for professional qualifications in inland navigation is considered a highly appropriate policy measure by all education and training organisations and by all boatmasters that contributed to the public consultation, as well as by 67% of employers' organisations, 61% of shipping companies and 61% of public authorities. The opinion of entrepreneurs/ship owners is more divided, but only 13% consider it not appropriate. It is important to note that more than 90% of all respondents consider this policy measure at least "somewhat appropriate".

Figure 25. Relevance of policy measure 4 by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this policy measure as "very appropriate", whereas the four ports consider it either "appropriate" or "very appropriate".

When asked about which crew members they consider that this policy measure would be most appropriate, 61% of respondents stated that it should apply to boatmasters and other crew members, whereas 28% answered it should only apply to boatmasters.

5.2.5. Policy measure 5: Introducing at EU level of a central register for EU boatmaster certificates

Introducing a central register for EU boatmaster certificate is perceived by the majority of education and training organisations and by public authorities that participated in the public consultation as highly appropriate (with 89% and 78% of their respondents considering it "very appropriate" or "appropriate", respectively), followed by boatmasters (67%). Around 40% of shipping companies and entrepreneurs/ship owners consider it highly appropriate, and the percentage increases notably when "somewhat appropriate" is also taken into account.

Figure 26. Relevance of policy measure 5 by type of stakeholder

The river commission and the worker's organisation that contributed to the public consultation rated this policy measure as "very appropriate", whereas the four ports consider it either "appropriate" or "very appropriate".

5.2.6. Policy measure 6: Introducing voluntary measures from the inland navigation sector towards lowering labour mobility obstacles

As shown in Figure 27, approximately 80% of respondents of all groups of stakeholders consider this policy measure, at least, "somehow appropriate". The groups that register higher percentage of highly appropriate responses are employers' organisations, with 89% of respondents considering the measure as either "very appropriate" or "appropriate", boatmasters (67%) and education and training organisations (61%). The workers' organisation that contributed to the public consultation rated this policy measure as "very appropriate", the river commission considers it "somewhat appropriate" and the responses of the four ports range between "very appropriate" and "somewhat appropriate".

Figure 27. Relevance of policy measure 6 by type of stakeholder

5.2.7. Additional issues: certification of professional qualification

Stakeholders were invited to comment on a number of aspects related to the policy measures previously presented. In particular, this section presents the answers given to questions related to the system of certification of professional qualifications for boatmasters. One of these questions was: "Do you think it is necessary to extend the requirement for certification also to the highest rank under the level of boatmaster?" Responses differ substantially by type of stakeholder (see graph below). While the majority of respondents from education and training organisations gave a positive response (83%), followed by boatmasters (67%), the majority of respondents of other groups of stakeholders consider that only boatmasters should be required to have a certificate, in particular employers' organisations (78%), shipping companies (70%) and entrepreneurs/ship owners (60%).

Figure 28. Extension of certification to the highest rank of responsibility below boatmasters

Stakeholders were also asked about the appropriateness of introducing a modular certification system for boatmasters, which would imply the introduction of specific requirements for certificates with regard to waterways on maritime character, operation of only small vessels on small waterways, and operation of large convoys. Figure 29 presents the stakeholders' responses. In this case, more than one answer was allowed. Half of the respondents considers that such a modular system should maintain the current specific requirements for boatmasters that operate on waterways of maritime character, 42% of them consider that the modular system should introduce specific more stringent requirements for boatmasters operating large convoys, and 39% of them consider that it should introduce less stringent requirements for boatmasters operating in small vessels on small waterways.

Figure 29. Differentiation of boatmasters certificates

5.3. Relevance of policy measure 7 ("Introduction of a common method for lowering the barriers for maritime sailing time/experience to qualify as inland navigation sailing time/experience") to deal with the problem of restricted labour mobility due to different requirements for professional qualifications for workers from outside the sector

The majority of stakeholders answering to this public consultation find this policy measure at least somewhat appropriate. 67% of education and training organisations and 44% of employers' organisations find it either "very appropriate" or "appropriate", whereas boatmasters are the group of stakeholders presenting a lower percentage of these responses. Nevertheless, it is important to note that more 80% of them consider it at least somewhat appropriate. Public authorities, entrepreneurs/ship owners and shipping companies are considerably divided in their responses. Additionally, the workers' organisation, the river commission and two of the four ports contributing to this public consultation rate this policy measure as "somewhat appropriate".