There are many good elements, but we are not quite sure how it all works together. Thats how you could summarise the comments on the new Mobility Package made by the leading road transport associations in the Nordic countries in a joint letter to the Nordic ministers prior to the meeting on June 8 in the EU Transport Council.
On May 31 the Commission presented its new Mobility Package and on June 8 the Ministers of Transport will have the opportunity for a first discussion on the text. The Nordic road transport associations organised in NLA used the opportunity to send preliminary comments to the Nordic ministers in a joint letter.
"The Nordic associations acknowledge, that the basic reasons for the action by the Commission and the arguments are based on what we have been saying for years - that the EU transport market needs readjusting and needs fair competition", comments CEO of NLA Soren Larsen. "What we are not sure about at this stage, is if the Commissions proposals deliver. There are many positive points taken separately, but do they outweigh each other so the net result is zero or even negative? Thats what we need to analyse and discuss with the Commission."
The letter gives the preliminary comments. As concerns cabotage and the application of the posting of workers directive, the associations express appreciation of the clarity on application of the posting of workers. But also ask a question: Will it still be possible to be absent from home country for months, in different member states, combining cabotage, international transport – and even combined transport – and thus escape these proposed new rules? The fear is it will and such a situation is not acceptable. The simplest solution could be to keep the present restrictions of 7 days and 3 operations, combined with application of the posting of workers directive.
That combined transport is not included in this package is a major problem. The inclusion of combined transport operations in the posting of workers directive should be stated clearly already now.
"The steps taken on vehicles below 3,5 tons, on the fight against letterbox companies and on the procedures and obligations on control and enforcement are welcomed", says Soren H Larsen. "But these proposals are only first steps, or steps that could be taken already now voluntarily by the Member States. Particularly on control and enforcement, and fight against letterbox companies, the Member States already have measures they can take, if they are willing."
As concerns changes to the legislation on road charging abolishing the Eurovignette is not acceptable. The Commission does not make a convincing case that it will be an improvement. Particularly not in a situation, where the Commission is basing the future km-based charging system on CO2 emission, for which data is still lacking.
As concerns CO2 and HGVs vehicles it is a relevant and important discussion. But the Commission is rushing things and has a limited field of vision. The system the Commission is proposing is relying on the VECTO simulation tool, which has only just been developed and adopted, but hardly tested – and so far only covers very few vehicle types and driving situations. On this weak basis the Commission is already jumping ahead assuming that standards will be adopted within 1-2 years. The Nordic associations are still calling for a serious discussion on how to ensure that these kind of systems will reflect the reduced CO2 emissions from a longer and heavier vehicle as well as when using biofuels. VECTO will not cover these types of situations!
The letter also refers to the joint declaration from now 10 European road transport association representing nearly 47.000 operators and 425.000 vehicles on what needs to be solved in todays road transport market. You can read the letter here and the 10 association declaration here.