OTM Belgian Shippers' Council

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Belangenorganisatie logistiek - handel en industrie

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ESC richtlijnen voor verladers

ESC Memorandum on Transport and Environment

There´s no point going into denial - the environment is our number one challenge. Profound climatic changes are upon us and - if the science is correct - we have very little time to do anything about it. We need urgently to find ways to use less transport and find ways to minimize the emissions of GHGs from the transport which remains.

Will industry change its ways, its thinking, its behaviour and practices? YES

Will it do it in time? NO - not without HELP! Industry will naturally try and reduce waste to reduce costs; but some will move faster than others: there will be leaders, makers and shakers, and there will be followers, observers and procrastinators.

The majority will need help to invest in new technology and cover the set-up costs of implementing new measures, new practices, new systems; they will need to be informed of best practice and encouraged to proactively engage with associations - like the ESC, to find out more. The providers of freight services will need to work with their customers in order to find the economically and environmentally sustainable solutions. THIS WILL BE THE FUTURE. Policies from government are only needed where there are barriers to delivering what is required, quickly.

Therefore ESC makes the following policy recommendations to reduce the GHG emissions of freight transport in Europe.

•1. Open the way to Global ETS systems for aviation and maritime transport

The Emission Trade Scheme (ETS) makes the user aware of the GHG emissions of the different modes of transport. This may encourage more users to choose those modes with lower emissions. ESC places an important condition on the acceptance of the ETS for transport: it should become a Global regime and not regional. A global ETS scheme that extended to transport would prevent companies from locating in those countries where the rules happened to be less stringent and from creating unfair competition: Such a scenario is often referred to as ´carbon leakage.´

2. Open the way to eco-combi´s in Europe

What ever one feels about larger trucks the reality is that under certain circumstances and conditions, in a controlled environment, they can offer industry much needed efficiency and a greener alternative to many other current logistics solutions. The European Modular System (EMS), sometimes known as the Eco-combi, already operates today in certain parts of Europe; national regulations already allow them to operate today. Yet their sphere of operation is being greatly restricted by some Member States, and prevented in cross-border transport, for fear it will compete against rail freight alternatives. This has to change.

•3. Open the way to unrestricted cabotage

Restrictions on cabotage prevent the optimum utilisation of the existing transport network and assets. Cabotage means that a national transport operation is executed by a transporter from another EU member state. The EU recently limited the execution of these cabotage operations to 3 operations within 7 days. Whilst representing a slight improvement on previous restrictive cabotage rules it remains an obstacle to the achievement of more efficient freight transport, minimizing empty haulage, and reducing emissions. It also runs counter to one of the most fundamental principles holding up the European Union: the Single European Market and the freedom of movement of goods and people - a principal which has brought considerable prosperity to business and the economies of every member state.

Free cabotage will promote the establishment of more longer-term contractual partnerships with haulage providers and shippers; this in turn will facilitate the enhanced understanding and cooperation required to deliver the greater levels of performance, improved utilisation, greater efficiency and reduced requirements for road freight transport over a sustained period.

4. Open up the accessibility of hinterland and inland waterways

Infrastructure and its development represents the foundation stone for reliable and efficient freight services: without the adequate provision of the right type of infrastructure at the right time and at the right price, freight services would be unable to operate effectively and efficiently. More transport would be required to support industry´s needs, and this would create more emissions and environmental consequences. ESC supports greater investment in hinterland infrastructure wherever a sound business case and freight demand forecasts reveal it is necessary and represents good value for money. The balance must be made, however, between costs and environmental benefit.

5. Open access to rail freight infrastructure (including yards and marshalling areas)

Restricting access to rail freight facilities such as yards and terminals reduces the efficiency and productivity of rail freight services. It also negatively impacts on service reliability and increases costs - neither of which will attract new users to use rail freight services or retain existing users. A policy of open access would contribute to improving efficiency, reliability and lower costs, and therefore have environmental benefits in the form of reduced emissions for rail freight and for transport as a whole.

A large number of industry sectors and other regular rail freight users, unable to fill individually a regular block train service, rely on the provision of single-wagon services. These services, mainly provided by incumbent national rail freight operators, are now being widely cut-back. Increased access to essential infrastructure by new entrants and existing competitors in order to provide such services, reliably and cost-effectively, is required.

Nevertheless, it is important for politicians, civil servants and the public to understand that the viability and sustainability of such services may require some fundamental adjustments to the business models of the rail freight providers and customers alike. Together, rail freight customers and railway undertakings must look urgently for solutions to this problem. That does not mean turning to customers and demanding they pay more for such services; neither does it mean subsidizing economically unsustainable services. It means that industry and the rail freight sector must collectively seek to find real, practical solutions. Competition in the rail freight sector would encourage the customer-focused approach necessary to solve this issue; but competition is sadly still lacking in many European countries, and must be addressed as an urgent political priority.

6. Open the way to European Rail Freight Corridors

There is a wide and genuine interest in the potential of a truly open and interoperable rail network for international rail freight across Europe. The time has come for a step-change in the way we manage the infrastructure and services. As with many of the highways running across the internal borders of the EU, our railways must provide a seamless, reliable, efficient journey for international freight. The proposal from the European Commission to establish international rail corridors along which freight is given, at the very least, an equal status alongside that of passengers in the compilation of the rail timetables and infrastructure management plans, would greatly improve the reliability and efficiency of rail freight services, and increase the utilisation of the infrastructure. Managing corridors, that run across borders and through member states, as a single entity rather than separate rail networks would represent a major opportunity to be grabbed with both hands for the sake of the economy and the environment.

7. Open the debate on implementation of IMO marine fuel requirements

Newly introduced requirements on the use of low sulphur fuel for the maritime sector are inconsistent with the principles of the European Single Market. The requirements to use ultra-low sulphur fuel for all shipping entering and operating within the English Channel, North Sea and Baltic Sea has the very real potential of introducing significant costs for ship operators and users, and raise serious competitive issues for the ports, terminal operators and other freight industry service providers within those areas. The policy, therefore, results in unfair discrimination against those businesses in northern and north-western Europe, whilst favouring those sometimes competing businesses in the west, east and south. This could create a distortion of trade and unfair competition, and as such should not be implemented as currently presented.

The policy could deter many freight transport users from using shipping services; whilst some may switch to rail if the services are available, the majority will switch instead to road. Whereas ESC does support lower emission of sulphur oxides from ships and believes that both the shipping industry and the users should take their responsibility to proactively seek and invest in ways to achieve this aim, it finds the regional rules in the North European (so-called) Emissions Control Areas (ECAs) unacceptable due to the competitive disadvantages it would create.

•8. Open up the debate on the ´polluter pays´

Whereas ESC is not against the ´user´ paying for preventative measures and contributing towards the costs of the environmental consequences of their activities, this should be done in a fair and equitable way, for all the modes and for passengers and freight customers alike. The latest Eurovignette proposals will raise costs of road freight transport only; but it will not create a modal switch or significantly benefit the environment. Neither will it save lives on the roads or improve the health of people living close to roads. Industry does believe that there is a need to reduce the costs of congestion, noise and accidents. These priorities are best achieved by tackling the causes of each rather than purely finding a cure for the symptoms once the damage is done.

•9. Open the way for removal of Operating Restrictions

Removal of operating restrictions that result in less efficient and increased freight transport activity must be examined. Often, the night time or weekends can be the best time for freight to move, avoiding peak time traffic congestion and the associated higher emissions; reducing accidents, delays and the need for more transport to compensate. Yet these are often the periods of the day or week when restrictions apply.

Restrictions placed on industry need to be evaluated on the basis that they may be increasing road transport congestion, accidents, pollution, noise and traffic. Industry too should be cognizant of the benefits of adjusting their work patterns (deliveries, production schedules, opening hours etc), avoiding the peak traffic periods, improving the turn-around time of freight vehicles and trailers (loading/unloading), to optimize and reduce their use of transport. Industry, planners and regulators need to work more closely together and have equal responsibility to find the optimum solutions.

•10. Open Skies and airport capacity

The Single European Sky legislative package adopted in 2004 aims at comprehensively reforming Air Traffic Management. It will increase the safety and efficiency of air travel. It will help reduce the environmental impact per flight by 10% by increasing available capacity of air corridors threefold and reduce congestion. One estimate (from IATA) suggests CO2 emissions alone could be reduced 12% (some 12 million tonnes) by implementing the Single European Sky (SES).

Greater reliability of air freight services as a result of fewer delays in the air and on the ground will positively contribute to lower emissions. Furthermore, shippers will need less air freight services because they can reduce their inventories and only ship what is needed when it is needed, rather than holding excess freight in storage as a buffer stock.

However, ESC believes further impetus is needed in this area: firstly to encourage member states to release their traditionally strongly guarded hold on air space over national territory if the targets and benefits of the SES are to be achieved and fully realised; secondly to give greater consideration to the environmental benefits of increasing airport capacity and associated ground-based infrastructure that relieves congestion, and reduces delays.

Open up your mind!

Comparison of the environmental benefits between rail and road should be undertaken with care. Invariably one is not comparing like with like. Trains may run on electricity or diesel: both have environmental consequences in terms of their use and production. Freight trains often run empty or below their full capacity but the comparisons do not always reflect this. Track conditions (affecting traction) and geography can also increase the energy required to move train-loads. Most train journeys have a road leg at either end: the handling and road legs are often omitted from any road-rail comparisons.

Standard measures of emissions and pollution need to be developed to help industry identify what, for example, their carbon footprint is for different logistics and supply chain models. Only when it is standardised can effective decisions and choices be made. Various sectors are already producing and developing measures to help, but ESC is willing to proactively help facilitate a co-ordinated approach that seeks to find one standard acceptable by all.

Simply relying on tired stereotype images and perceptions of different modes, the actors and their roles within the supply chain, may prevent you from seeing the reality: industry, policy makers and all stakeholders from both the public/private transport sector and the freight industry need to engage together and open their minds more in order to find and make the best decisions for business and the environment together.

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