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the contributions of AILOG, Assiterminal, Assoporti, Confcommercio-Conftrasporto and UIR for Strategic the National Plan of the Portualità and the Logistics
the sent documents in sight of States general of the Portualità and the Logistics
February 12, 2015
Below we publish some of the contributions for the editing of Strategic the National Plan of the Portualità and the Logistics sent from associations of the enterprises and harbour institutions and logistic Italians in sight of States general of the Portualità and the Logistics held monday to Rome on convocation of the Ministry of Infrastructures and the Transports with the objective to reform the national legislation on the ports and the logistics.
AILOG
Italian association of logistics and supply chain management
Milan, 5 February 2015
Dear dottor Puja,
below them shipment a synthesis of the contribution of AILOG, Italian Association of Logistics and Supply Chain
Management to the reunion of States general of next monday, 9 February.
It is necessary an organic design that it puts entirety industry, logistics/infrastructures and consumption, rethinking the logistic programming of the industrial woven one that still are based on productive poles of years ‘60, often dipped in the residential areas.
To extend to all the ports experienced how much to La Spezia: clearance of the container when the ship leaves the port of Suez. The idea underlying is that to use the time of displacement of the ship in order to carry out the customs procedures, earning time of delivery so.
To unify the harbour Authorities for wide basins (tyrrhenian from Liguria, high Adriatic…) to the aim of giving flexibility to the flows in arrival and clearing the operations from the conditions weather.
AILOG considers a normative participation opportune on the topic of the flexibility of the job in logistic within, accompanied from a careful review of the norm on the cooperatives that not always demonstrate themselves adapted to the requirements of the Companies outsourcers are under the profile of the quality are under the profile of the patrimonial solidity and the ability to investment.
Good bye to the encounter of next monday,
Cordial,
Paolo Bisogni
President AILOG
ASSITERMINAL
Italian association Terminalisti Harbour
EXACTLY
Object: some first considerations on managing Slowly strategic of the portualità and the logistics
i) Preliminarily the contained indications in our synthetic note are recalled on 29 September c.a., sent to the M.I.T., of first comment to the text of art. the 29 of the DL n. 133/2014.
In particular the Plan would have:
To be coherent with the European choices in topic of IT TRY and with the national priorities with regard to infrastructural nets and nodes;
To consider the existing in terms of infrastructural and structural equipments, they above all use and turned out reached with the appropriations carried out publics; current distribution of the harbour and logistic traffics for coastal ranges and territories of the hinterland; credible perspectives for sayings traffics; etc To this end among other things turns out useful to update the data reported to the ports that strategic infrastructures appear in attached III "the Program" of which to the note of update of DEF 2014.
To have with regard to contracts in being (eg. concessions) and to the agreements of program in course, let alone to the projects and engagements already approved of and/or programmed.
Ricomprendere in the number of the "correlated participations" also those not infrastructural and therefore sets in action apt to place in being measures of: good administration therefore of sburocratizzazione, simplification of procedures, certainty of rules, acceleration of the procedures, overcoming of overlaps of competences between Public Administration; support for the improvement of the competitive abilities to I finished operators. For these thematic profiles there is much to make, without to incur in increase of costs, indeed reaching also savings for Public Administration and achieving in same time positività for the concrete to operate of the distributing ones of harbour services. To such fine we consider must be taken in consideration the proposals that Assiterminal introduced to the On. Ministro of in March last infrastructures, as indicated in the note, than for memory riallega to anticipates itself. Naturally we do not intend with this note to enter in the examination of the launches our points, but we are available in order to deepen in the detail these prospettazioni and other linkable ones for matter.
The planning, to temporarily update (eg. every 4 years) in function is of the works and sets in action realized, is of the evolutions and market trends, would have not to assume substantially controlled connotations. It would have to indicate existing and to possibly characterize incentives, also new opportunities, to trace a general picture of the objectives to reach in a determined temporal arc, also medium, without to introduce elements of rigidity or new constraints species to the entrepreneurial activities, than, as famous, they are fundamental and strategic for the harbour economy, that trasportistica and for the entire Country. We consider and we wish therefore can be a matter of a document of planning and programming not only infrastructural, as mentioned above said, constituted a picture action to supply indication on the strategies that intends to assume the Government, but that it beginning from supplies of the pairs reference for the actions of the interested entrepreneurs those harbour ones, that they have invested and they have programmed other investments on the state property areas, also for the benefit of the public sector.
ii) He is comprehensible, species in the crossed delicate phase from Italy (than presumablly it will continue), and in the presence of the necessary present and future control of the public expense, than the strategic Plan of the portualità it is called to select the projects and to make of the reasoned choices, not painless for determined areas considered the varied elaborated projects, or under elaboration, in insistent marine ports of call on same ranges or that they intend to serve the same markets.
Therefore, it appears reasonable that:
the ports inserted in Core are taken above all in consideration Network Try a priori (not excluding some other truth), having with regard to the perspective of realization of the "European central net" within the 31/12/2030, based on "approach for corridors";
account in the choice of the participations holds that will introduce the Harbour Authorities of the opportunity to share of the priority with the national representations of the operators and the harbour users, which would have to be felt from the MIT, let alone for great infrastructures of net to consult Regions, RFI, ANAS, Freeways, etc
In order to complete the chosen motivated ones it is opportune to focus the factors (for good part already diagnosed in searches and studies) that the main Italian portualità and the logistics regarding the ports of the Europe north penalize and to the competitor Mediterranean, considering meanwhile the strengths and the potentialities of our harbour system, evidencing of the demonstrated vocations and specializations, which would go optimized.
, In saying moreover which aimed at it seems necessary to concentrate itself on:
Investments progettualmente and financially defined, supported from analysis cost/credible benefits, economic-financial plans; accompanied possibly (using also forms of public-private partnership) from investment plans and however from entrepreneurial initiatives of development, waves to assure really new flows of traffic, and not shunting lines from a port to another;
harbour projects of needed adaptation/potenziamento and improvement, also manutentivo, that they consolidate the current movements and amount of goods and passengers, with projection of they implementation (for example refers to deepening projects backdrops and dredgings to us; rifacimento outer dams).
iii) Even though the attention is in prevalence turned to the traffics container (where dominates the marine carriers of the foreign multinationals), to the systems and infrastructures dedicated to the same ones, let alone to the added value that these traffics generate, it does not go forgotten that they contribute not little is in terms of entrepreneurial activity (comprised that afferent variegated harbour user) and occupation, to the service of the industries and of the surrounding territories, it is in terms of entrances for the State and AP, the conspicuous flows of goods helter-skelter, that is liquid bulk (not only oil) and solid of miscellaneous type, the Ro-Ro traffics and ferries (field where he is prevailing the Italian armament) and those merceologie that do not regard the specialistic traffic of the ships container. All this represents for the Italian ports of call a tonnage of goods enlivened (boarding more disembarkation) advanced to about 75% regarding the total general.
iv) Also it would go not neglected that the conformation of the Italian portualità with the length of its coasts, the city dispersion and that of the woven one and of the several productive and industrial districts, the density of the population distributed in several territorial areas, the deficiency of modern railway infrastructures and an adapted railway service dedicated to the goods, is between the several elements that suggest to dedicate an attention to the conservation (than it necessarily does not mean new infrastructures) of the patrimony of the existing portualità, that is that inserting in the c.d. Comprehensive Network TRIES, having the courage, also in this case, to establish of the priorities motivated in the participations, to realize for a determined temporal horizon not beyond the 31/12/2050. In fact these ports of call, as famous, among other things constitute nodes for marine connections of the Freeways of the sea sea and the short shipping, alternative to the all road, for marine connections with the great islands, (some) interesting poles for the movement fleeting and of the important crocieristico segment, etc
v) In order to realize the works of interest of the Country, as such selected by the strategic Plan, are presumable are not sufficient the allocated public resources, stanziande or reperibili, comprised those usable with the financings of the program “Connecting Europe Facility” in the within nets TRY, and therefore it must be appealed to the investments of the private ones, beginning from those of the harbour entrepreneurs. To such purpose it is desirable that measures are previewed, to estimate itself to light of the demanialità of the harbour areas, that they stimulate such investments; this reasoning naturally is worth also for the recently realized investments or under performance by I finished operators, which, without aids publics (with the exception of other categories), has in the facts demonstrated to hold the trained foreign competition also in recessive period.
you) In order to accompany the programmatoria activity of field on a national level connected to being managed Slowly strategic, through a consultation process on the progettuali hypotheses and the normative, prescribed and administrative solutions, it could be a useful to create near the Prime Minister's Office a thin organism, not structure, that is at least a “conference” to meet periodically, where participate besides the competent Ministries the representations of more representative the national Associations of category of the section, with propositive functions to the aims of the performance of governmental politics of the portualità.
vii) For how much the harbour Authorities concern, he is condivisibile a rationalization of the same ones in the optical to be profitable some mainly efficient and economic the management, effective the actions, without traguardare back new models compounds (spurious) of autoritativo agency, administration and meanwhile with commercial proclivities in the harbour within, as such invasive ones of the sphere of competence (and the consolidated know-how-how) of the entrepreneurs. It is necessary of the pairs to avoid to delegate to other subjects publics autoritativi tasks today assigned to the harbour Authorities, or that they could be carried out from the same ones (in a logic to exceed duplications of tasks), under the control of the MIT, always had with regard to the range of activity and services that are carried out in the ports. A greater coordination between AP is certainly favorable insistent on the same basin of reference, that is a coordination between forecasts of P.O.T and P.R.P., waves to reach critical mass between near ports of call, to avoid phenomena of sovraccapacità (already happened) and of improper competition with no final advantage for the portualità and the System Country. We afford to express reserves on the creation of a new intermediate level of harbour and logistic government (logistic harbour Authority and), I yield also of a forced aggregation of the current Authorities harbour, without to achieve real decreases of costs and proven efficiencies, That is does not convince us to traguardare towards a theoretical model of governance, which rather than to consolidate and to improve the endoportuale role of AP of it projects generically the competences towards territorial withins, already regulated, not supporting this with cogenti and clear norms, neither confirming the design by means of rinvenibili positive experiences in other Countries. We consider instead possible the concretizzazione of some union between ports of call under the administration of same AP, let alone we believe coherent that the national planning can be articulated also on the base of intermediate territorial levels, faces to favor synergies and convergences, infrastructural and logistic. To this end they could be valued the material and immaterial participations (eg. projects infotelemati to us) finalized to integration of various logistic-harbour or interportuali systems. In such perspective we are not contrary in the participation of AP to the capital of active societies in the field of the extraharbour logistics, and/or of the intermodalismo, species in phase of startup of undertaken new, being given the primary competence of the initiatives of the private entrepreneurs in such field, comprised the their possible role of “integrator of system of the logistic chain”, let alone it stops remaining the necessity to safeguard the competition between operators.
All. 1
NOV. 2014
Short note on Doc. Strategic slowly national of the portualità and the logistics
Note for “States general”
It goes according to premised that the three strategic objectives are shared on which the Plan will be pivoted, of art. 29 L. 164/2014 and that is: to improve the competitiveness of national the harbour and logistic System, to favor the increase of the traffics of the goods and the people, to facilitate the promotion of the intermodalità in the traffic goods. The approach used from the Committee of experts is also shared, constituted from Minister On. Lupi, of articulating a recognition on three traditions: analysis of the question, analysis of the offer, location and selection of the main hypotheses of participation. That premising, in restating how much already brought back in our note of November 2014 (vd. attached), let alone of recent proposed contributions/also of Confindustria, some relative considerations to the “lines are expressed below in synthesis guide” exposed in the note of which to the object.
About point 1, “strategic Planning over a long time span, mean and short period”, are suggested to that is manage the actions and the measures that the Plan will not only define on three temporal dimensions, but also placing them on three hypotheses of standardization and respective: invariance of enforced norms; new norms; new norms as a result of modification of Titolo V of the Constitution. How much precedes to the aim better to characterize the range than possibility of adoption of the measures more acconcie, conjugated with the temporal dimension and the objective of being effective already from quickly.
With regard to the Line it guides of which to point 2, “Specialization of the harbour truths, rationalization of the system of governance, integration of the logistic districts”, we would want to understand through which actions and rules of system one agrees “to address the private investments also through evolutionary models of oriented participation to the integrated development of harbour areas” (marine Federal property) “and manufacturers” (in great part outside from the marine Federal property). This for having a perception of the range of possibility of new investments that they would agree to leave the determination of the terminals operators, stops remaining the protection of those in being and/or course, reminding that the terminalisti broadly speaking carry out inquadrabile a framed economic activity/in the industry. It also becomes useful to understand in which specific context it can or one agrees to place a rationalization of the not conditioned harbour Authorities “from mutual vetoes of the local systems”, waiting for a modification of Titolo V of the Constitution, that is if reference to the current and which wished specialization for the future of the harbour truths, to the rationalization of the system of governance, to integration of the logistic districts is wanted to be made (term to define), or to all and three these factors. Moreover it is not secondary to know towards which type of Authority and with which functions it would intend to orient the hypothetical one I rearrange; to such purpose our position is expressed to par. the vii) of the mentioned note over of November 2014.
With regard to point 3 it is interesting to have contezza if with the creation of synergies (without to constitute new subjects) between actors key pertaining to the public sector agree to place in being new forms of collaboration, exceeding the simple coordination, or, as it appears preferable, the overcoming of overlap of competences between Public Administration and the amalgamation of offices and staff of the same ones.
With reference to point 6 one wonders to know which it is the series of participations of procedural and administrative simplification that agrees to activate, bearing in mind that draft not to only come true the simplification of many autorizzative procedures and control, including to you the reduction of the fragmentation and the acceleration of the procedures, but draft also of giving certainty of rules (possibly simple) to apply themselves on all the national territory and above all to realize the fundamental principle based on which they do not have to be introduced that is maintained levels of advanced regulations to those minimums demanded from the international and communitarian norms.
Online general, but also with regard to how much express in points 7 and 9 of the document in argument, how much in nearby is observed.
It is famous that:
our ports acquit above all to an important role in the flows of goods in import and export meeting in our Country, let alone they cover a not insignificant function for those of national marine cabotage;
the GDP national influences the harbour traffics.
Considered this, it is necessary to our clear warning to have the serious situation in which it pours the economy
of our Country and to adopt a centralized model of economic increase on the boosting of
question and therefore on an expansion of the Italian home market, let alone of that European.
This implies the necessity:
in communitarian center the affirmation of a valid strategy in order to exit from the inactivity;
in Italy to head at appropriate governmental measures, not only infrastructural, than, giving to more space to the internal question and the entrepreneurial initiatives, beginning from the fields harbour and of the logistics, they favor the increase of the economic transactions, let alone the increase of the occupation, also through a reduction of the costs of labor and the taxes, knowing that an estate or best an implementation of the Italian exports cannot alone guarantee a total increase of the traffics and entire our economy.
5 February 2015
ASSOPORTI Association of the Italian Ports
Object: First considerations on Slowly National the Strategic document of the logistic portualità and de/la. Note for “States general”
First of all it is set in evidence that already in the phase of conversion in law of the DL n. 133/2014, Assoporti express positive appraisals care the contents of the art, 29 of that bill (than in phase of conversion has had modifications than formal/little more procedimentali). The forecast was considered - and confirmation - totally condivisibile to equip the Country of National a Strategic Plan of the portualità and the logistics, to intend which necessary frame and indication of the development strategies to assume which reference for the action of the Harbour Authorities, just for the sake of those that concerns infrastructural participations how many not infrastructural participations.
Coherently with this we wished that the Plan indicated, besides the priorities between the progettuali proposals of the Harbour Authorities, also objectives that - esemplificativamente and not exaustively - we listed, which:
adaptation and update of the normative system finalized to the efficientamento of the model d administration of the ports;
simplification of the procedures that regulate essential aspects for the portualità, beginning from the procedures of approval of the PRP which slowly of layout of the port;
velocizzazione of the sub-procedures and the bureaucratic implementations.
Leaving these premises a positive appraisal of the “lines would have to be expressed guides” or “macros which aimed at strategic” exposed in “synthetic and opened” form in the document in argument. A positive appraisal parimenti must be expressed with regard to the methodology that has carried to the location of those macros objectives; based on the “recognition of the data of question and logistic offer and a selection of the main hypotheses of participation for the attainment of the purposes indicated from the cited legislative disposition”.
Moreover, perhaps to reason of that extreme synthesis and the interlocutoria characteristic of the reunions of the Committee of experts of which the verbalizzazioni are available, evincono useful care supply and demand and neither possible information is not realized contained and sets in action detailed lists of the future PSNPL. Perhaps so that, estremizzando, the risk cannot a priori be excluded that the carried out job ports to the auspicious and necessary location of specific, concrete and punctual actions - opportunely graded in the times short, medium and long (and it is agreed with this perspective vision) - but limits not to be illustrated, for general categories and not for specific topics, criticalities that by now are history de harbour and logistic field.
It achieves some therefore, considering an ulterior moment indispensable of I confront on more complete and which supported documents from adapted to regarding evidences supply and demand - to alternative scenes - of short, medium and long period, than to hour it is possible single to evidence some aspects that need d adapted to consideration and/or clearer explicitness and disambiguità
With regard to the concept of “specialization” note that it cannot agree as monofunctionality of single ports (if of the case in practice they exist terminal specialized) since also to national scale the monofunctional ports are exceptional. Rather it would seem opportune to specify refers to us to needs of ports in a position to offering to own basins of traffic (systems of enterprises and areas of consumption) and to the users, infrastructures; structures; services and connections, to the highest standard than specialization and efficiency; in a word competitive.
With reference to the synergies between actors key pertaining to the public sector, the hypothesis to engage the actors publics in order to exceed the simple coordination, by means of the “sharing” of a logistic strategy, could be forecast of force (insufficient) analogous to the coordination. It appears therefore necessary, against the punctual declination of cases in which that coordination it has not sortito the hoped effects, to characterize so covered and binding forms that allow to reach turned out in sure times, as demands the market.
The topic simplification of the procedures, is convene, it is strategic and it is connected to the other “creation of synergies”, since many procedures see the involvement of various articulations of the complex public car. The hypothesis to take part, in the sense of semplificazone and the velocizzazione, on with of the autorizzative functions and of control is in dubbia necessity. It is but necessary to hold on account of the public nature of the interested assets and from the field specialty, so that the specification seems necessary as well as generically not to eliminate controls and/or forms of regulation, how much more rather than to adapt them a lot to the requirements of market as for the effective general interest and to entrust them to who it answers of the efficiency and the regulation of the single segment of market.
With regard to the hypothesis of “rationalization of the not conditioned harbour authorities from the mutual vetoes of the local systems” brought back in closing of point 2. , it is not superfluous to emphasize that “rationalization” we can only lead back to reasons of better choices and infrastructural priorities. But ravvisa above all necessary a rationalization in the sense of the strengthening of the A.P which peculiar subjects in the ordering that, operating with fiction of regulation and promotion of nodes of a complex net, must necessarily be evolven towards the role of actors of the logistic net - also for the infostrutturali aspects - and not only of regolators of the harbour node.
With regard to the potesi of “rationalization of the conditioned harbour authorities from the mutual vetoes of the local systems” it is not always superfluous to remind that Assoporti for a long time has acknowledged of the importance that not as a result reaches forms of collaboration and passibile functional aggregation between today existing the Harbour Authorities - but - on the same base of a design from the intentional one of support to the Italian competitiveness on the European and world-wide markets and from a pure process of “review of the expense”, attended that the Harbour Authorities do not weigh on the public budget.
Indeed, citing literally a contribution of Assoporti to the Parliament and Government, the Association “an able organization of regulating shares the requirement of giving to the harbour system logistic Italian and programming the activities connected to the marine roots of the corridors the essential European (Cores ports and Core corridors) and of the logistic tentacles that connect them with their important Italian markets and to those of continental Europe that, as famous, are more and more moving to east and south. Ravvisa moreover the necessity that the tendential design first of all assumes to reference the principles dictated from the European Union.” However holding also it anticipates to necessity of protecting and valuing every member of the system of the national ports each of which it constitutes a resource of the Country.
Leaving from this, therefore, also not excluding hypothesis of aggregations of To P, necessarily one restates how much said in premised that is that the objectives of the PNPL could be reached “also through the rationalization, I rearrange and the amalgamation of the Portua Authorities the existing”, that is that rationalization, I rearrange and amalgamation of To P represents a hypothesis, not a obligation normative, that it would go persecuted if, and only if, functional to the attainment of the three objectives of the PSNPL.
In last which contribution to the aims of the indication in the Plan of singularly riconducibili the specific topics to the macros indicated categories and that would have to find answer or at least hypothesis of answers in the Plan, they are indicated below main, recalling of also some already cited:
Simplification of the procedures of approval of the PRP which slowly of layout of the port (functional to determine the operating withins, those of interconnection between the port and the territory, the logistic connections with the nets and knots insides) and not as mere town-planning instrument;
Simplification and valorazzazione of the procedures of realization of the harbour works, beginning from the dredging procedures;
Rivisitaziore of the environmental norm (eg. in topic of VIA, VAS); of safety and security according to the specificity and peculiarity of the harbour truths, having particular attention to maintain levels of regulation and to preview obligation and implementations - for the A.P and for operators - never advanced or severeer than those previewed from the communitarian ordering and of the partners of other systems - Country EU;
To adopt norms understandings to give to certainty to the A.P and the operators in topic of concessions, coherent with the ordering EU and the relevant regulations of the concurrent ports;
Verification and eventual rivisitazione of the norms in topic of harbour job also to the aim to assure adequate protection of the occupational levels;
Nautical services technical, tariff arrest warrants remaining criteria and mechanisms uniforms on a national level and the competence of the marine Authority in the fixation of the standards of safety, attribution to each A.P of the tariff power on the same services, in coherence with the principles and the rules EU emanated and emarande.
Rome, 5 February 2015
Confcommercio-Conftrasporto
Object: First considerations on note for “States general” strategic Slowly national of the portualità and the logistics
In taking note with regret of the synthetic and too much quick modalities with which it is decided to carry out I confront with the stakeholder of the field on a complex and so strategic topic that it would have deserved, instead, forms of concertazione and sharing very deeper and articulated, also in order to respect the indications of method brought by European integrated marine politics and of the strategy for the “Blue increase”, that is for the sustainable increase in the marine field, declination in the “section sea”, of the most general strategy for the intelligent, sustainable increase and inclusive Europe 2020, some first observations to the famous document advance for “States general” strategic Slowly national of the portualità and the logistics, Plan on which the Confederation it is promuovendo an internal deepening whose outcomes will be, soon, been profitable publics.
Confcommercio totally shares the scopes and the purposes that art. the 29 of law 164/2014 of conversion of the D.L. It unblocks Italy it has indicated for national the strategic Plan of the portualità and the logistics and follows with great interest which representative of the world of the terziario of market, that it generates beyond 40% of the P.I.L and comprises to its inside a meaningful part of the harbour and logistic marine cluster (Shipowner, Marine Agents, Enterprises of Road haulage and logistic-Conftrasporto, Railroads Ormeggiatori-ANGOPI goods-Fercargo, tourist Pilots of the Ports-Fedepiloti, Ports Assonat) the under way work in order to reach to a national system of the ports and the more efficient logistics, in a position to offering a more valid support to the perspectives of economic increase of the Country.
With specific reference to the lines it guides of the plan made available is observed how much follows:
- “2 specialization of the harbour truths, rationalization of the system of governance, integration of the logistic districts” OBSERVATIONS: the reference to the necessary specialization of the ports and the rear logistic areas appears condivisibile, in the optical of a greater systemic coherence, but such result can be opportunely persecuted own through the strengthening of national the planning strategic and introduction of a more incisive and selective cabin of central direction of the participations to realize in the single ports. Amalgamations and eventual abolitions of the existing Harbour Authorities would not have, therefore, to be descendant of the recalled purpose, how much more rather from the requirement than to heal pathological inefficiencies (in truth limited much) that see the presence of such Authority in some harbour truths without some justification neither on the front of the entity of the existing traffics, neither of the strategic perspectives of development. On the other hand, same art. the 29 of law 164/2014, recalling the possibility to proceed to the rationalization, I rearrange and amalgamation of the existing harbour Authorities, indicates express that such processes would have to be carried out according to the law n. 84 of 1994.
Such law indicates, already, in truth the parameters threshold for the constitution of new Harbour Authorities or the eventual abolition of those existing. Also noticing as the norm negatively omits to consider the fleeting traffics that, also, they imply requirements of organization of the harbour activities and could, therefore, equally to justify the presence of a Harbour Authority, is not considered, in any case, condivisibile to show the eventual abolition of such organisms when the parameters minimums, also partial, prescribed from the law come, instead, totally respected.
The callback, moreover, to the requirement “to also address the private investments also through oriented evolutionary models of participation to the integrated development of harbour and industrial areas” leaving to intend the condivisibile understanding to value the relationships and the ties of the economic ports with the surrounding truths, appears incomprensibilmente circumscribed, probably because of the synthesis requirements, to the single industrial section, neglecting, instead, all the field of the services, that it carries out a meaningful and increasing role in the national economy and could draw and offer great benefits with integrated policies. On the other hand, such limitation appears in contrast with the indications of European integrated marine politics, and of its strategy for the blue increase that it pursues, instead, a intersettoriale approach, having as aces totally carrying the sections of Renewable energies, of marine Tourism, the marine transports and the logistic activities. In such optical the Harbour Authorities, through opportune and complete ties with the surrounding economic truth, that they pass, also, through the participation in the organs of governance, could opportunely be characterized as precious facilitatori ganglia of the economy of the sea, contributing to pursue the objectives of the intelligent, sustainable and inclusive increase of Europe 2020. This does not want to say that “the sterile vetoes between local systems” do not have to be exceeded recalled, but simply wishes that the precious contribution does not come lost that such local systems can offer so for the increase of the ports as the their irrenounceable careful role of and continuous monitoring ddegli economic-social impacts of the harbour activities on the surrounding territory.
- “3 Creation of synergies between actors key pertaining to the public sector” OBSERVATIONS: Confcommercio appreciates the principle of the promotion of a “shared logistic strategy between the main institutional actors”, but the integrated and olistico approach would have to be extensive also to the private sector and the entrepreneurial system, through the introduction of structured instruments of involvement and concertazione of the field policies. From this point of view a good practice, from which being able to take cue it has been general Consulta for the Road haulage and the Logistics, that it has seen the positive collaboration of the various Administrations and the entrepreneurial representations to the aim to promote coherent and more careful policies to the requirements of economic development, but that unfortunately it is suppressed by a myopic participation of spending review.
- “4 co-ordinate Programming of the investments publics in the field of the portualità and the logistics”.OBSERVATIONS: The coordination of the investments in the field of the ports and the logistics is positive, but it would have to be extensive also to the private investments, that they assume an important and increasing role in the field and would have to mature which declination sector more general binding lines than participation on the entire system of the transports, the logistics and national mobility, dictated from a National Plan of the Transports and the Logistics, totally integrated with so-called “Attached Infrastructures” introduced with the objective Law.
- “5 Removal of bottlenecks infrastructural punctual”.OBSERVATIONS: Absolutely opportune the reference to the requirement to take part on those throttlings that limit accessibility to the harbour and interportuali nodes. Draft of an absolute measurement necessary in order to allow the development of the intermodalità, supporting some the competitiveness regarding the so-called transport “tuttostrada”. Confcommercio and Fedarlinea in a recent seminary for I throw again of the Freeways of the Sea have put in evidence as the throttlings to the harbour accesses and the not always efficient interactions with the flows of local mobility, are between the main brakes to the development of traffics RO-RO.
- “6 Simplification of the procedures and rationalization of the decisional processes” OBSERVATIONS: Positive the understanding to introduce participations of procedural and administrative simplification, finalized to improve the efficiency of the entire logistic process. In such within for Confcommercio the priorities would have to be: the simplification/velocizzazione of the controls legacies at the customs moment, the simplification of the procedures for the adoption of the Harbour Town development plans, the adoption of norms that facilitate the effettuazione of the escavi harbour.
- “7 intermodalità” OBSERVATIONS: Not there is doubt that the logistic competitiveness of the Country passes necessarily through the promotion of the intermodalità. The paragraph under investigation, but, under such name is limited to dealing issues tied to the rail shipment, without to consider, instead, the intermodalità sea/rubber, the freeways of the Sea and traffics RO-RO. Moreover between the points to promote in the railway field it would be opportune to explicitly ricomprendere the realization of adequate bundles of railroads on the harbour docks, the simplification of the railway maneuvers, the adoption of not discriminatory procedures for the confidence of the services and the eventual dedicated instruments of incentive.
In the cited seminary on the Freeways of the Sea, as a result of a technical analysis and of I confront inside with all the associations of representation of various rings of the logistic-harbour row, it is emerged that, in transport of national cabotage, besides the existing connections from and for the greater Islands, than although their obliged nature, for the extension of the drafts by sea they can be considered totally alternative to the all road (Catania-Ravenna, Genoa-Term Imerese) and that they would go, therefore, confirmed, based on the data available on the traffics of goods on rubber between the North and the South of the Country it is possible to characterize 2 new ones alternative intermodal corridors to the all road to activate, articulate in 4 lines of ferries RO-RO with balanced transports (travels potentially cargos are to the gone one that to the return):
• Tirrenico Arco north (Genoa-Livorno) - side Tyrrhenian south (Naples, Salerno) • Tirrenico Arco north (Genoa-Livorno) - side Adriatic south (Bari, Brindisi) • Adriatic arc north (Trieste, Ravenna) - side Adriatic south (Bari, Brindisi) • Adriatic arc north (Trieste, Ravenna) - side Tyrrhenian south (Naples, Salerno).
Al fine of being able to realize such new freeways of the sea is characterized the organic proposal of participation, below synthetized, on infrastructures, the incentives, the ship, the rules and the activities of control that comprised the adoption of an instrument of national planning that individuals the priority tollbooths of the new freeways, but that could altogether be understood inside of the Strategic Plan of the Portualità and the Logistics, re-entering rightfully, in its natural within of participation.
Besides the national cabotage, they do not go neglected all the international traffics that happen through the Freeways of the Sea, that they represent, in particular in the basin of the Adriatic, a meaningful quota the flows of goods and that they deserve, therefore, detail attention by the participations of Strategic the national Plan.Freeways of Sea 2.0: a proposed new organic
A Pact for ADM 2,0, that is clearly institutional a political address that together puts all the various ones stakeholder involved
A programmatico instrument that participation priority translate in binding the strategic choices of the National Plan of the Logistics and organic measures for accessibility of the ports
boosting through notices of projects of new lines or widening of the existing promoted sinergicamente from all the subjects of the row
aimed boosting according to the goods transferred and addressed to the choices of traffic not accompanied (towings and semitowings)
slowly of reconversion of the motorization of the ships towards less impattanti solutions (LNG-methane), that it holds account of the refueling requirements
strengthening of the activities of control of the respect of the norms on safety of the street circulation
exemption from the respect of for vehicles adherent prohibition of circulation. (calendar heavy average prohibition of circulation outside from the centers inhabited) Turned out achieved with DM,533 on December 4, 2014 that it has exempted from the respect of the prohibition 2015 arranged transports marine)
- “8 technological Evolution as abilitatore of a new oriented more efficient operating model and more to logical than infrastructural market and upgrade technological” OBSERVATIONS: The computerized applications and the technology can offer an unquestionable contribution for the efficiency of national the logistic system. Al fine to avoid, but, duplications of systems and useless additional burdens for the enterprises users would be opportune to supply the indication online with Decreto of the Ministry of Transportation for the spread of the intelligent systems of transport (ITS) in Italy. to search the maximum interoperability of the systems heading for the valorization and eventual optimization of the existing platforms.
- “9 Integration between harbour and logistic system and entrepreneurial world” OBSERVATIONS: Although the title of the line guides is absolutely condivisibile, the synthetic version of the paragraph does not allow to comprise the contents totally. To judgment of Confcommercio inside such measure they would have to be priority ricompresi:
The requirement of giving to institutional and organizational performance to the reading of the national territory the work of analysis and reading of the territory in 7 integrated Logistic Platforms, contained in the Plan national of the Logistics of 2006 and become instruments of planning and programming in the Program Strategic Infrastructures Attached infrastructures (3° Attached Infrastructures DPEF 2006-2009, 8° Attached Infrastructures 2010). In attached to DPEF 2006-2009 in introducing the 7 territorial logistic Platforms, which nets integrated of ports and logistic nodes, came, in fact, indicated, that:
“… it is considered opportune to show an organic proposal in Logistic Plate matter that will have necessarily to characterize new woven connecting the infrastructural one of the Country. Woven connecting that will have to transform the current spontaneismo, the current existing entropy also in areas with great tradition of trasportistico type, as from Liguria area, the area of Padania, etc in functional and efficient system.”
The same scope persecuted, to our judgment, from Strategic the National Plan of the Portualità and the Logistics, that it would have, therefore, to treasure the work and of the proposals of analyses and integration previously recalled.
To inside guarantee the involvement of the entrepreneurial woven one through the Chambers of Commerce in the process of nomination of the President of the Harbour Authorities and of the organisms of governance of the same ones, to guarantee of the greater public-private integration of the strategies of economic and territorial development and of a greater attention towards the requirements of making enterprise.
Regarding others important issues not explicitly dealt in the “lines guide” are observed that:
For how much it concerns to the nature and the functions of the Harbour Authorities, the inspirational principle of Legge 84/94 was that to open the harbour services at the market, maintaining however the harbour asset under the public control. The model of governance famous best in literature with the name of second Landlord which the harbour Authority acts as organ of regulation and “heads of household”, while the harbour operations and services are carried out by privately-owned companies, would not have to be disavowed from the reform, but on the contrary improved returning it more effective and transparent. To such purpose, as mentioned, they would go strengthened the ties with the entrepreneurial woven one, previewing a presence in the organs of governance, besides the entrepreneurial categories today you anticipate and to confirm, also of representatives of the enterprises of the commerce and tourism, today excluded from such organisms and therefore disabled to supply the own direct contribution to the harbour development. It would go, moreover, strengthened the power of coordination of the Harbour Authorities regarding all the operating administrations to miscellaneous title in the ports, proceeding, also to upgrade the Autonomy Financial institution of such organisms, against effective instruments of central control of the effectives employs of the resources to the aims of the development of the traffics. It is considered, instead, the so-called “autonomy impositiva” of the Harbour Authorities, not condivisibile, in contrast with the nature and the functions of sayings organisms and potentially dangerous for the “goods”.
With reference to the nautical services technical, it is considered that safety of the activities must be guaranteed in uniform way on a national level, not being a corrected lever through which promoting the competition between ports. To judgment of Confcommercio the true challenge would have to be that to succeed in contemperare the requirements of safety with those of the operativity of the ports and the relative surrounding economic clusters. In the field of the road haulage and in particular of the prohibition of circulation for heavy means outside from the inhabited centers, such contemperazione safety/operativity of the enterprises, graces to an initiative of recalled the good practice of General Consulta for the road haulage and the logistics in 2012 is returned possible (through an amendment to the Reg of execution of the Highway code) and from then it has allowed to define calendars of less heavy prohibition of circulation to forehead, for other, of sensitive improvements on the front of street safety and the incidentalità. Such experience shows, therefore, than safety and economic development is not in antithesis but they can, instead, if correctly and carefully governed, to supply mutual benefits. In the field of the technical-nautical services such positive one and advanced contemperazione could be achieved on one side confirming the discipline of the nautical services technical inside of art. the 14 of the law 84/1994 that could be improved recependo the contents of the interassociativo agreement for the reform of the same ones and from the other, with specific reference to the pilotage, proceeding to the introduction of solutions in a position to ulteriorly reducing the burdens supported from the ships, especially for those engaged in recurrent traffics, also through the harmonization with the experiences in other European Countries.
At last, in consideration of city localization of the main national ports, and the meaningful contribution that the increase of the nautical one from diporto can offer for the economic development and the quality of the life in the cities, it is considered opportune that the Plan previews organic measures for the requalification of the not used harbour areas, to the aims of I throw again of the nautical one from diporto
The Secretary Generale Conftrasporto Dr. Pasquale Russo
Vice-president Confcommercio Dr. Paolo Uggè
Union To interpose Reunited you
Strategic slowly national of the portualità and the logistics
Encounter 9 February 2015
INDISPENSABLE INTERPOSING TO YOU TO THE PORTS AND AL ARRANGES LOGISTIC NATIONAL
GENERAL ASPECTS – Reflections
In picture national that anticipates an insufficient situation to support the international competitiveness in the field of the portualità and the logistics, we want to evidence role carried out in time to interpose you for development of intermodalità with constant engagement, so as they evidence the data that are gained from the relationship that comes attached in copy where the specific weight of interposing to you is very evidenced through the job of analysis lead from UIR during the last few years, this although reduced and by now the remote resources which put on from the state. In the middle of an optimal logistic positioning in fact the INTERPORTO is placed that represents one of logistic infrastructures more complex and articulates.
The Interporto is a “organic complex of structures and services integrated and finalized to the exchange of the goods between the various modalities of transport, however comprising suitable a railway port of call to form or to receive complete trains and in connection with ports, airports and practicability of great communication”. The peculiarity of such structure is therefore that to represent an INTEGRATED SYSTEM OF TRANSPORTS AND LOGISTIC SERVICES.
The first aspect (the intermodalità) is in fact the common denominator of interposing to you, drawn symbol on which the State and pure the private investor, through our societies have engaged themselves in the years; a engagement often taken advantage of from the foreign flows but to which instead the system of the national transport it has not given followed adapted. To such gap it is necessary to place remedy (in order very famous economic, strategic, environmental reasons); but it will be able to be tried to only study an immediate solution through interposing you existing using political of boosting of shift modal and the elimination of the “necks of bottle”.
Secondarily the location of “community of business of the logistics” – served from international intermodal flows and (is hoped) national and in correlation with the ports - characterized in localized territorial withins on the nodes of the European nets, represents a possibility of heterogenous development (production, transport, services) able, if very structured in qualitative terms (customs services, INFORMATION AND COMMUNICATION TECHNOLOGY, etc…), to attract investor. Such “communities” can see in interposing you - in relation with the competent Ministries, the EE.LL., the harbour manager of the railway net and authorities - the catalyzing subjects.
WITHOUT TO INTERPOSE THE DOCKS TO YOU THEY WILL NOT BE ABLE TO SUPPORT THE FLOWS OF THE GREAT SHIPS. As Slide evidences the Analysis of the question of study EY introduced in January 2015 (pag.25), the dimensioning of the harbour terminals for the management of the new great container vessels that preview a handling of 2.500 to the 4,000 TEU for every touched enough not to guarantee the efficiency of the system.
As it is being evidenced already from 2014 in the ports of the Europe North, new ULCV (ultra large container vessels) are creating unthinkable problems even if we consider that draft of the most advanced harbour structures between in Europe. In the ports as Amburgo where the congestion has already hit, they are evidenced of the managerial models that they preview, with a handling also of 10-12.000 boxes in a single port of call the “once single production” of flows in that would demand 12 ships of connection, 60 trains and 3,000 trucks (source: Fraunhofer Centre for Maritime Logistics and Services).
The Italian harbour System today Is not READY to face these flows. With a synergy with the interportuale system this will only be able to be supported in fast times that the docks will face in the next few years.
ATTENTION AL RETROPORTUALITA' CONCEPT. He is indispensable to comprise that the “retroportualità”, especially in the greater national examples, is not tied to the geographic vicinity. Indeed, the intermodalità iron-rubber that connects the docks to inland the terminals is convenient in directly proportional way to the distance, for which the relationship PORTO-INTERPORTO it regards, for that concerns the railway connections, distant truths between they. The Retroportualità is a not geographic but FUNCTIONAL concept as legacy to the presence of flows that need to go to the boarding being used the train.Moreover, it does not exist an univocity in the retroportualità, a INTERPORTO in fact, will have many railway connections with various destinations and for ognuna of they it will be able to act as “retroporto”.Attention therefore “not to formally ingessare” important interportuali truths of European breath regarding integrations forced only derived from a territorialità principle.
Leaving from these premises one considers that, to beyond the produced norm during the last few years and of the several bills in parliament that giacciono on the various tables, any legislative participation that concerns to the logistics and to the transport of the goods it would have to hold in consideration the circumstance that the programmatico picture of reference is that afferent one to the project of Net TRIES and of the European Corridors. The infrastructures to which addressing they are those existing; he is indispensable to put aside the mega-projects, often announced and never realized, and to concentrate the resources available on the co-financing of works inserted in the European context and on the c.d. “necks of bottle” of the infrastructural system and this in order not to lose the opportunities tied to the economic resumption and the sustainable increase. In fact we are called to today offer to the infrastructures to investor and operators, asking for indetermination and the uncertainties that have contributed to do so as that our country lost the total competitive challenge.It is necessary to give impulse to a new and shared modality of access to the net infrastructure to all the private operators who operate in the railway field goods and passengers, with consequent greater opening to the competition and fall of national the protezionistiche barriers.
OBJECTIVES
We consider that it is necessary an adapted reform of the governance of the harbour system and logistic and from this principle we would not avoid in order to complete a deep internal analysis, even if we consider opportune goes constituted a new pillar on which founding the review of the Italian logistic system towards the editing of the Plan.
It is in this context that must be persecuted the strategic objective of throws again of the system economic-manufacturer of the country using as the logistics raises competitive. In such optical it is necessary “to couple” infrastructures to the logistics and, these, jointly, to the productive system.
The “National Plan of the Logistics”, it could pursue this objective, identifying the guiding ones of traffic, that is, specifically, merceologici enterprises and fields that develop between they intense relations of purchase/sale. From therefore in order evidencing the “spinal columns”, that is infrastructures of connection in the within of the integrated customs logistic systems here, around which the commercial relations are articulated.
It in agreement finds us that the programming functions could be acquitted from a “national Committee for the intermodalità and the proposed logistics” to the job table and previewed also from the rough draft of framework law in matter To interpose to you: an instrument of able industrial politics “to guide” the system of the production towards the logistics.
The amalgamation of second geographic logical infrastructures is not, same, in itself sufficient to support the industrial increase and the competitive ability to the country.
The rough draft of framework law in matter To interpose to you, already for a long time approved of from the Chamber and months to the examination of the Senate, defines the territorial logistic platform as “the compendium of infrastructures and present services on an interregional territory destined to carry out connecting functions of strategic value for the national territory, to the aim to favor the interconnection and the competitiveness of the Country” and is from considering a good line of departure on which to construct a logistic offer online with the demands for a more and more globalizzato and aggressive market.
In this perspective the ports and interposing become you factor of integration and government of a system of infrastructures and services that, whereby previewed, is combined to the European corridors.
In short the participation of the legislator would have:
to carry to term the iter of approval of the law on interposing, it does not preview details to you costs for the public sector, but it introduces of the definitori obstructions based on the traffics effectives that prevent the birth of not useful initiatives for the system;
to define a national organism of programming and coordination so as expected from the framework law in matter to interpose to you and from the lines guides of the plan of the logistics;
to give the possibility to approach forms of facilitated credit (as already it happens for the ports) for the initiatives of investments to interportuale level. Given the public compartecipazione of the interportuali societies, often the interportuali companies is enough disadvantaged regarding the private ones as Great Enterprises are considered having all the economic parameters from PMI;
to identify the realizable works and the relative resources financial institutions in period 2014-2020 in coherence with the availability of the communitarian resources, favoring works with system valence, the improvement of the existing (Core nodes), the overcoming of the “necks of bottle”;
to return (in logic of the concurrent activity) the regional initiatives with those national ones coherent on the base of the communitarian programming;
to improve the efficiency of the customs and railway services in the exposed sense over;
to favour to territorial level integration between infrastructures and operators with logical of market and row and not as simple institutional and geographic aggregations, however in coherence with the European Corridors;
to sburocratizzare: for example the norm on the prevention fires has inexplicably created a burden to the companies “interporto” creating a kind of objective responsibility of obtaining of the Certificate Prevention Fires also for the companies in functional autonomy installed in the defined area “interportuale” and regarding the other logistic structures and enterprises that simply do not use the term “interporto”. Moreover it is necessary to simplify all the administrative procedures in order to allow the development that the same ones can assure in the still free areas bringing back in head to the regions the iter bureaucratic authorized (be read to you VIA, VAS, Town-planning Planning), accelerating the procedures for the performance of the customs only doors and the “Customs Corridors Controlled” guaranteeing the fast decongestion of the docks;
it is necessary to at least facilitate their strategic function with a reduction of the fiscal pressure in member IMU (assimilating them to the ports of call goods that practically replacing give the progressive abandonment of same by the system the Railroads of the State);
to favor an extensive application of the concept of CUSTOMS ONLY DOOR, unifying the points of effettuazione of the controls; to upgrade the function of organization and binding coordination of the Agency of Customs and the Monopolies, to unchanged legislation; to favor the passage to an ONLY AUTHORITY of the competences, the responsibilities and the staff of all relative the administrative procedures to the processes of import/export of the goods. All this could allow to rationalize the implementations that the operators now are forced to carry out with all the administrations involved in the clearance process; to qualify the “customs corridors”, diffusing the praxes own of certifyd operators AEO to the aim of the computerized clearance in procedure domiciled for the goods in entrance by sea.
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Below we publish some of the contributions for the editing of Strategic the National Plan of the Portualità and the Logistics sent from associations of the enterprises and harbour institutions and logistic Italians in sight of States general of the Portualità and the Logistics held monday to Rome on convocation of the Ministry of Infrastructures and the Transports with the objective to reform the national legislation on the ports and the logistics.
- Via Raffaele Paolucci 17r/19r - 16129 Genoa - ITALY
