- L'European Federation of Inland Ports (EFIP) ha reso nota oggi la propria posizione sul Libro Verde pubblicato lo scorso febbraio dalla Commissione Europea con l'obiettivo di aprire un dibattito sulle attuali linee guida del trans-European transport network (TEN-T).
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- Nel suo documento di risposta alla Commissione, che pubblichiamo di seguito, l'associazione dei porti interni europei ha evidenziato come sia giunto il momento di prendere in esame i punti di interconnessione tra le diverse modalità di trasporto e le loro infrastrutture. «Sinora - ha osservato l'EFIP - la rete TEN-T è stata concepita soprattutto come una serie di progetti di reti di trasporto trans-europee che si estendono da un punto iniziale ad un punto finale, mentre è stata prestata troppo poca attenzione agli stessi punti di inizio e fine, al collegamento tra i progetti TEN-T e le interconnessioni tra i progetti e le infrastrutture esistenti. EFIP ritiene che la Commissione Europea abbia molto correttamente riconosciuto la necessità di colmare questa lacuna al fine di realizzare un vero network».
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- «Nell'arco degli anni - ha rilevato il direttore di EFIP, Isabelle Ryckbost - gli inland port europei sono diventati veri punti nodali intermodali. Offrono eccellenti collegamenti di traffico con le ferrovie, le strade e le vie d'acqua interne e con le reti marittime e sono collocati lungo i principali corridoi e le aree industriali dell'Unione Europea. I porti interni possono giocare un ruolo vitale nell'ottimizzare la catena di trasporto co-modale e nel contribuire ad una catena logistica di trasporto sostenibile. È tempo di utilizzare il potenziale che gli inland port hanno. Si potrebbe fare un paragone con una staffetta: non si può vincere la corsa se ci si focalizza solo sulla corsa individuale dei componenti della squadra; si può vincere la corsa solo se il passaggio di testimone tra i corridori è fatto nella maniera più efficiente e corretta. I porti interni sono, in un certo senso, il luogo in cui il testimone passa di mano».
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- European Commission Green Paper: TEN-T: A policy review
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- Contribution of the European Federation of inland Ports (EFIP)
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- June 2009
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- INTRODUCTION
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- The European Federation of Inland Ports (EFIP) was founded in 1994 and is the official voice of nearly 200 inland ports in the EU, Switzerland, Moldova and Ukraine.
- EFIP welcomes the opportunity given by the European Commission to reflect on the review of the TEN-T guidelines and to see in particular how the European TEN-T policy can be improved and address the challenges the European transport system is facing as a consequence of the congestion and environmental problems. Moreover EFIP considers that this review can not be seen apart from the economic and financial crisis Europe is facing at this moment.
- An efficient European Transport system is of vital importance for the functioning of the internal market. The TEN-T are in a way the arteries of the internal market and the European integration as a whole. To function well, to restore and reinforce the health of Europe’s economy, the existing infrastructure has to be optimized, the remaining bottlenecks in the European Transport network have to be removed and where necessary bypasses have to be installed.
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- EFIP believes that inland ports can play a vital role in meeting the challenges Europe’s transport system is facing:
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- The inland waterborne transport has a double advantage: First, it can rely on a vast inland waterway network with ample free capacity that can be activated without or with only little financial resources. Second, looking at the externals costs of transport, inland waterway transport has by far the best environmental record.
- But of course, inland ports are a lot more than a place where barges are loading and unloading their goods and are much more than a node in the inland waterway network. Over the years, European inland ports have become real intermodal nodal points. They offer excellent traffic links to the rail, road and inland waterway and maritime networks and are located along the main corridors and industrial areas in the EU. They are as a consequence an essential link of the co-modal transport chain.
- Moreover, inland ports are increasingly serving as back up and feeder for the major European seaports and can be a part of the solution for the congestion in the seaports. In, some cases, inland ports are developing as a hinterland extension of seaports. Indeed, inland ports allow for de/re-consolidation of cargo flows, helping seaports to fully exploit potential economies of scale. Services developed in inlands port can be very broad, ranging from mere nodal points for multimodal container flows, to providing logistics and administrative services (customs, container depot, goods handling, warehousing, etc…).
- Being at the crossroad between different transport modes, inland ports are becoming more and more clusters of logistic services. They offer logistic service providers efficient and flexible choices
and allow customers to combine the different transport modes depending on the demands of the market or the goods to transport and handle.
- For all these reasons, EFIP strongly believes that it is time to use the potential that inland ports have to optimize the co-modal transport chain and to contribute to a sustainable transport logistic chain.
- THE GREEN PAPER
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- EFIP welcomes the green paper of the European Commission as an open and honest way of looking at the achievements and weaknesses of the current TEN-T guidelines and the TEN-T policy in general. EFIP believes indeed that the green paper is a good starting point of the TEN-T review process. EFIP and its members recognize that reviewing the TEN-T policy is not an easy exercise and remains at the Commission’s disposal to provide factual information or reflect further on the issues at stake in this revision.
- EFIP’S RESPONSE TO THE GREEN PAPER
- In its green paper the European Commission is considering three structural options for the shaping of the TEN-T.
- EFIP believes option 3 - even if it looks like the most ambitious option - is the best way to go forward with the revision of the TEN-T guidelines. EFIP supports the dual layer consisting of a "core network" and a comprehensive network. This for different reasons:
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- In a comodal transport chain, the overall efficiency and quality of transport depends not only of the quality of the individual transport modes in the chain, but depend largely of the efficiency of the interconnection points and nodes. It is time to recognize the importance of optimizing the infrastructure and the operational aspects of these interconnection points.
- Taking into consideration the limited financial resources, the linking up of the different TEN-T priority into a core "network" would without any doubt, add the most value to the already achieved and the ongoing priority projects at the least possible cost. Optimizing the nodal points between inland water, maritime, rail and road transport will often reveal a lot less expensive than creating completely new infrastructure.
- Maintaining the comprehensive network is also important as an access function for the different regions of the European Union and offers a balanced and well defined scope for European (transport) legislation, that shouldn’t be put into question.
- Nevertheless, EFIP has some reserves as concerns the "conceptual pillar". It is not entirely clear what this concept would mean in practice:
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- EFIP could back this conceptual pillar if it implies that the current priority projects should be linked into an network that is "truly multimodal, enabling major freight and passenger traffic flows to cross the European union as efficiently, economically and environmentally as possible, on a co-modal basis" and that it is necessary to work towards an "optimal interconnection of modes…",
- EFIP could also support the conceptual pillar if this would be based on general but well defined concepts allowing for concrete projects to be introduced in application of this general concept. As such, the conceptual pillar could be integrated in the TEN-T guidelines, as has been the case with the "Motorways of the Sea project", by way of a conceptual approach setting out objectives and procedures for identifying projects of common interest. In this case however, more efforts should be made to simplify the procedures and to put forward clearer objectives and criteria in order to avoid the problems encountered with the Motorways of the Sea project.
- In the light of the assessment made in the Green paper about the need to put more emphasis on the nodes, EFIP would favor in particular "the development and optimization of intermodal nodes or interconnection points" as a new conceptual approach to be introduced in the TEN-T guidelines. In this concrete case projects could be submitted fulfilling the conditions set out in the general concept in order to address concrete bottle necks and aim at the seamless flows of traffic from one mode to another in an interconnection point, f.i. an inland port, port or intermodal terminal.
- EFIP can however not support the conceptual pillar if it would imply that concrete and agreed priority projects could be altered or put into question during their implementation phase.
- EFIP stresses that the review of the TEN-T, how fundamental it should be, should in any case not jeopardize or put into question the current priority projects, For EFIP in particular, the proper maintaining and full completion of the ongoing projects n° 18, the Rhine-Meuse- Danube project, and n° 30, the Seine Scheldt project is of paramount importance.
- Apart from the choice between one of the three options put forward by the Commission in its green paper, EFIP would like to seize the opportunity of a fundamental review to reflect on some other aspects of the TEN-T policy of the European Union:
- In terms of transport traffic flows, the EU is not isolated, and it should give particular attention to its connections to countries beyond its borders in order to ensure sustained development of exchanges with other important trade partners. This is more in particular the case with the candidate countries and the new neighbouring countries of the Union.
- EFIP strongly believes that the European Coordinators, appointed by the Commission to prepare and implement certain priority projects have proven to be effective. They have shown to have the ability to put certain projects in a wider perspective and as such to come through their contacts to solutions for some obstacles, that were considered to be invincible.
- As regards the Motorways of the Sea priority project, EFIP subscribes the assessment made by the Commission that the procedures are too complex and the objectives and criteria not clear enough. Moreover EFIP supports the idea put forward in the annual report of Mr Valente de Oliveira, the European Coordinator for the Motorways of the Sea project, to turn the existing Short Sea Shipping Promotion Centres into Co-modality Promotion Centres looking at the whole logistic chain. EFIP also encourages the idea that Motorways of the Sea Status should not be given to lines that serve a port that is underperforming as regards environment-friendly hinterland connections. Moreover TEN-T Funding for Motorways of the Sea should be given to investments in infrastructure that benefit the whole logistics chain, i.e. port/hinterland infrastructure.
- EFIP likes to draw particular attention to the problem some inland ports are facing due to their smaller size. Smaller inland ports are facing problems comparable to those SMEs are facing when they want to submit a project proposal: a lack of manpower, of expertise and of time to duly develop a proposal. In the light of the forthcoming review, EFIP asks the Commission to reflect on this problem in order to avoid that smaller projects, because of these practical problems, refrain from participating in project proposals.
- As the European Parliament stated very clearly in its opinion on the green paper from 22nd April EFIP believes that, once TEN-T status is granted to projects, the Member States or other stakeholders should not abuse the European environmental legislation in order to block the implementation of TEN-T projects; It is indeed very important for reasons of legal certainty to solve unclear or contradictory provisions relating to declarations of common interest and the application of environmental legislation.
- EFIP stresses furthermore the importance of having a level playing field amongst Member States in application of TEN-T rules. The TEN-T network should be subject to the same rules in the European Union. Disparities can lead to distortion of traffic flows that are not sane.
- EFIP is fully aware of the huge financial impact of achieving a better integrated Trans-European network. EFIP however considers that investment in transport infrastructure is an essential means to counter the economic and financial crisis Europe is suffering at the moment. Up to now, the political support in the Member States for the TEN-T projects was never reflected in an equivalent support by the Member States for a stronger TEN-T budget. EFIP hopes that this changes and that Member States will give more attention to the TEN-T when the midterm review of the financial perspectives is being discussed. In any case, it is clear that substantial progress in the implementation of the TEN-T network can only be made if the European Union, the Member Sates and the regions are engaging themselves altogether.
- Finally, it should be noted that until now only circa 1% of the European Infrastructure funds have been spent to inland waterway transport.
- CONCLUSION
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- So far, the TEN-T "network" was above all conceived as set of TEN-T projects with a starting point and an end point. Too little attention was made to the starting and endpoint itself, to the connection between the TEN-T projects and the interconnection between the projects and the existing infrastructure. The European Commission has very rightly recognized the need to fill in this gap in order to realize a real "network". EFIP and its members encourage the Commission to follow this path further and to look with all other stakeholders how the optimizing of the "network" aspect of the TEN-T can be developed taking in to account the environmental and congestion problems the European transport policy is facing and bearing in mind the difficult economic and financial situation Europe is living in at the moment.
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