# C_2012143EN.01013001.xml

| 22.5.2012 | EN | Official Journal of the European Union | C 143/130 |
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22.5.2012

EN

Official Journal of the European Union

C 143/130

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Opinion of the European Economic and Social Committee on the ‘Proposal for a Regulation of the European Parliament and of the Council on Union guidelines for the development of the trans-European Transport Network’

COM(2011) 650 final — 2011/0294 (COD)

2012/C 143/26

Rapporteur: Mr BACK

Mr BACK

On 15 November 2011 the European Parliament and on 30 November 2011 the Council decided to consult the European Economic and Social Committee, under Articles 172 and 304 of the Treaty on the Functioning of the European Union, on the

Proposal for a Regulation of the European Parliament and of the Council on Union guidelines for the development of the Trans-European Transport Network

Proposal for a Regulation of the European Parliament and of the Council on Union guidelines for the development of the Trans-European Transport Network

COM(2011) 650 final – 2011/0294 (COD).

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 3 February 2012.

At its 478th plenary session, held on 22 and 23 February 2012 (meeting of 22 February), the European Economic and Social Committee adopted the following opinion by 133 votes to 1 with 6 abstentions.

This opinion is part of a five-opinions package prepared by the EESC on the Connecting Europe Facility (CEF) and its guidelines which were issued by the European Commission in October 2011. This package contains opinions TEN/468 on the CEF (rap. Mr HENCKS), TEN/469 on the Guidelines for Telecom Networks (rap. Mr LONGO), TEN/470 on the Guidelines for Energy Infrastructure (rap. Mr BIERMANN), TEN/471 on the Guidelines for Transport Infrastructure (rap. Mr BACK) and TEN/472 on the Project Bond Initiative (rap. Mr DUTTINE).

Connecting Europe Facility (CEF)

TEN/468

CEF

TEN/469

Guidelines for Telecom Networks

TEN/470

Guidelines for Energy Infrastructure

TEN/471

Guidelines for Transport Infrastructure

TEN/472

Project Bond Initiative

1.   Conclusion and recommendations

Conclusion and recommendations

| 1.1 | The European Economic and Social Committee (EESC) welcomes the Communication on a Growth Package (hereinafter referred to as the communication) and the Proposal for a Regulation on Union Guidelines for a Trans-European Transport Network (hereinafter referred to as the proposal). The approach proposed in the communication and the regulatory measures proposed to implement it in the field of transport suggested in the proposal are to a large degree in line with what the EESC has stated in earlier opinions. |
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1.1

The European Economic and Social Committee (EESC) welcomes the Communication on a Growth Package (hereinafter referred to as the communication) and the Proposal for a Regulation on Union Guidelines for a Trans-European Transport Network (hereinafter referred to as the proposal). The approach proposed in the communication and the regulatory measures proposed to implement it in the field of transport suggested in the proposal are to a large degree in line with what the EESC has stated in earlier opinions.

Communication on a Growth Package

Proposal for a Regulation on Union Guidelines for a Trans-European Transport Network

| 1.2 | In particular, the EESC agrees that multimodal and seamless cross-border infrastructure networks that include "the last mile" and with good links to third countries are vital for the successful implementation of the EU 2020 strategy and the aims defined in the 2011 White Paper, Roadmap to a Single European Transport Area (hereinafter referred to as the 2011 White Paper on Transport Policy). The EESC also appreciates the integrated approach toward infrastructure policy between the transport, energy and digital sectors to achieve synergies and resource efficiency. Nevertheless, the EESC has the following comments. |
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1.2

In particular, the EESC agrees that multimodal and seamless cross-border infrastructure networks that include "the last mile" and with good links to third countries are vital for the successful implementation of the EU 2020 strategy and the aims defined in the 2011 White Paper, Roadmap to a Single European Transport Area (hereinafter referred to as the 2011 White Paper on Transport Policy). The EESC also appreciates the integrated approach toward infrastructure policy between the transport, energy and digital sectors to achieve synergies and resource efficiency. Nevertheless, the EESC has the following comments.

Roadmap to a Single European Transport Area

| 1.3 | The EESC regrets that the aim to obtain synergies with other networks does not appear as one of the planning priorities of the proposal, as defined in its Article 10. |
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1.3

The EESC regrets that the aim to obtain synergies with other networks does not appear as one of the planning priorities of the proposal, as defined in its Article 10.

| 1.4 | The EESC notes a problem of consistence between the very long term aims set in the proposal and the more practical and immediate measures on the time horizon 2020–2030. |
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1.4

The EESC notes a problem of consistence between the very long term aims set in the proposal and the more practical and immediate measures on the time horizon 2020–2030.

| 1.5 | The EESC agrees with the two layer approach of a comprehensive and a core network. However, the EESC questions whether the core network corridors (hereinafter referred to as the corridors) ought not in fact to be seen as a third layer that replaces the priority projects in the current guidelines. This is due to the fact that chapter IV of the proposal contains specific criteria as to the definition of the corridors and their development which give them a distinctive character, clearly discernible from the rest of the core network. The EESC observes that a problem of foreseeability and legal certainty is caused by the fact that the corridors and the predefined projects in them are listed in the annex to the Proposal for a Regulation of the European Parliament and of the Council establishing the Connecting Europe Facility (hereinafter referred to as the CEF proposal), set to apply for the period 2014 – 2020 only, while both the corridors and the projects are long term and need to have their priority character ensured beyond 2020. |
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1.5

The EESC agrees with the two layer approach of a comprehensive and a core network. However, the EESC questions whether the core network corridors (hereinafter referred to as the corridors) ought not in fact to be seen as a third layer that replaces the priority projects in the current guidelines. This is due to the fact that chapter IV of the proposal contains specific criteria as to the definition of the corridors and their development which give them a distinctive character, clearly discernible from the rest of the core network. The EESC observes that a problem of foreseeability and legal certainty is caused by the fact that the corridors and the predefined projects in them are listed in the annex to the Proposal for a Regulation of the European Parliament and of the Council establishing the Connecting Europe Facility (hereinafter referred to as the CEF proposal), set to apply for the period 2014 – 2020 only, while both the corridors and the projects are long term and need to have their priority character ensured beyond 2020.

Proposal for a Regulation of the European Parliament and of the Council establishing the Connecting Europe Facility

| 1.6 | The EESC therefore takes the view that the abovementioned problem of foreseeability and legal certainty could be resolved either by making a list of the core network corridors and predefined projects annexed to the proposal or by stipulating that the list will remain in force as long as the proposal, subject to future amendments. |
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1.6

The EESC therefore takes the view that the abovementioned problem of foreseeability and legal certainty could be resolved either by making a list of the core network corridors and predefined projects annexed to the proposal or by stipulating that the list will remain in force as long as the proposal, subject to future amendments.

| 1.7 | The EESC points to the important role of the coordination and governance organization foreseen for the core network corridors, to facilitate their implementation. Nevertheless, the EESC points to the importance of keeping this organization slim, to the point and cost efficient and with a clear aim to ensure that, with due regard to the principle of subsidiarity, cross border planning interfaces function optimally at all levels concerned and that bottlenecks in the corridors are avoided. The EESC calls for solutions that avoid parallel governance organizations and duplication of functions when different corridor systems coincide, for instance Core Network Corridors and elements of the European rail freight network for competitive freight. |
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1.7

The EESC points to the important role of the coordination and governance organization foreseen for the core network corridors, to facilitate their implementation. Nevertheless, the EESC points to the importance of keeping this organization slim, to the point and cost efficient and with a clear aim to ensure that, with due regard to the principle of subsidiarity, cross border planning interfaces function optimally at all levels concerned and that bottlenecks in the corridors are avoided. The EESC calls for solutions that avoid parallel governance organizations and duplication of functions when different corridor systems coincide, for instance Core Network Corridors and elements of the European rail freight network for competitive freight.

| 1.8 | The EESC raises the question if there should be an explicit possibility to provide the entire core network, including Motorways of the Sea (MoS) projects between core network ports, with a coordination function in order to facilitate adequate and timely implementation of the core network, in particular its cross border dimension. The EESC underscores that such a function could be a resource that could make it easier for planning authorities to strike a balance between national priorities at different levels and EU added value and also highlight the EU added value. |
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1.8

The EESC raises the question if there should be an explicit possibility to provide the entire core network, including Motorways of the Sea (MoS) projects between core network ports, with a coordination function in order to facilitate adequate and timely implementation of the core network, in particular its cross border dimension. The EESC underscores that such a function could be a resource that could make it easier for planning authorities to strike a balance between national priorities at different levels and EU added value and also highlight the EU added value.

| 1.9 | As for the configuration of the corridors, the EESC takes note of the fact that the proposal puts an emphasis on their multimodal and cross-border character. The configuration of the corridors, as listed in the annex to the CEF proposal, is bound to the rail freight corridors defined in Regulation (EU) 913/2010 concerning a European rail network for competitive freight. Since an overarching priority of the proposal is resource efficient multimodal transport and that each corridor should include at least three transport modes, other modes of transport should also be taken into account. |
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1.9

As for the configuration of the corridors, the EESC takes note of the fact that the proposal puts an emphasis on their multimodal and cross-border character. The configuration of the corridors, as listed in the annex to the CEF proposal, is bound to the rail freight corridors defined in Regulation (EU) 913/2010 concerning a European rail network for competitive freight. Since an overarching priority of the proposal is resource efficient multimodal transport and that each corridor should include at least three transport modes, other modes of transport should also be taken into account.

| 1.10 | The EESC takes the view that corridors should be defined on the basis of the multimodal and resource efficient approach set out in Articles 48-49 in the proposal and that they should cover the most important cross-border long distance flows in the core network, optimising the use of each mode and their cooperation. The configuration of the corridors should be guided by cost/benefit analyses and seek efficiency and sustainability (economical, ecological and social) with an innovation and co-modal focus. On that basis the needs of all modes, including nodes, should be addressed when defining the corridors. |
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1.10

The EESC takes the view that corridors should be defined on the basis of the multimodal and resource efficient approach set out in Articles 48-49 in the proposal and that they should cover the most important cross-border long distance flows in the core network, optimising the use of each mode and their cooperation. The configuration of the corridors should be guided by cost/benefit analyses and seek efficiency and sustainability (economical, ecological and social) with an innovation and co-modal focus. On that basis the needs of all modes, including nodes, should be addressed when defining the corridors.

| 1.11 | The EESC attaches great importance to the intention to earmark additional resources to attend to the needs of cohesion countries expressed in the CEF proposal and takes the view that the priority this expresses ought also to be reflected in the proposal, for instance by adding an objective in Article 4 or an additional priority in Article 10. |
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1.11

The EESC attaches great importance to the intention to earmark additional resources to attend to the needs of cohesion countries expressed in the CEF proposal and takes the view that the priority this expresses ought also to be reflected in the proposal, for instance by adding an objective in Article 4 or an additional priority in Article 10.

| 1.12 | The EESC takes note that according to the CEF proposal, Article 17 (3), 80 to 85% of available budget resources are to be reserved for the predefined projects, mainly within the core network corridors, and listed in the annex to the CEF proposal. The EESC deplores that there are no indications as to the criteria according to which these projects have been selected. The EESC recalls the multimodal character of the corridors also set out in the provisions on the corridor development plan in Article 53 of the proposal, which also seems to assume that there should be a reasonable spread of investment projects between modes – see Article 53 1 (f) of the proposal. |
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1.12

The EESC takes note that according to the CEF proposal, Article 17 (3), 80 to 85% of available budget resources are to be reserved for the predefined projects, mainly within the core network corridors, and listed in the annex to the CEF proposal. The EESC deplores that there are no indications as to the criteria according to which these projects have been selected. The EESC recalls the multimodal character of the corridors also set out in the provisions on the corridor development plan in Article 53 of the proposal, which also seems to assume that there should be a reasonable spread of investment projects between modes – see Article 53 1 (f) of the proposal.

| 1.13 | Considering the importance of the sustainability objective, set out for instance in Articles 37 through 39 of the proposal, the EESC questions whether the notion of green corridor solutions could not be employed as a quality label for the development of the freight transport services option addressed in Article 38. |
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1.13

Considering the importance of the sustainability objective, set out for instance in Articles 37 through 39 of the proposal, the EESC questions whether the notion of green corridor solutions could not be employed as a quality label for the development of the freight transport services option addressed in Article 38.

2.   Introduction

Introduction

| 2.1 | The TEN-T guidelines currently in force have the form of a decision and originate from 1996. Their aim is to improve connectivity and hence the functioning of the Single Market. |
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2.1

The TEN-T guidelines currently in force have the form of a decision and originate from 1996. Their aim is to improve connectivity and hence the functioning of the Single Market.

| 2.2 | However, the 1996 guidelines, as amended, do not create a coherent network. This is the case in particular as regards the priority projects, which aim to address certain points on the network where capacity or other problems of connectivity occur. |
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2.2

However, the 1996 guidelines, as amended, do not create a coherent network. This is the case in particular as regards the priority projects, which aim to address certain points on the network where capacity or other problems of connectivity occur.

| 2.3 | Implementation of the guidelines has been slow and there are considerable delays, in particular relating to the priority projects. |
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2.3

Implementation of the guidelines has been slow and there are considerable delays, in particular relating to the priority projects.

| 2.4 | The EESC has also noted insufficient implementation in the new Member States in Eastern Europe. |
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2.4

The EESC has also noted insufficient implementation in the new Member States in Eastern Europe.

| 2.5 | The communication and the proposal (the package) now submitted by the Commission are the fruit of a long consultation procedure. The EESC has been involved in this procedure and has provided opinions on the 2009 Green Paper on the TEN-T policy (1) and, at the request of the then upcoming Polish Presidency, an opinion on Sustainable development of the EU transport policy and planning for TEN-T
   (2). The EESC also addressed TEN-T issues in its opinion on the 2011 Transport Policy White Paper (3). |
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2.5

The communication and the proposal (the package) now submitted by the Commission are the fruit of a long consultation procedure. The EESC has been involved in this procedure and has provided opinions on the 2009 Green Paper on the TEN-T policy (1) and, at the request of the then upcoming Polish Presidency, an opinion on Sustainable development of the EU transport policy and planning for TEN-T
   (2). The EESC also addressed TEN-T issues in its opinion on the 2011 Transport Policy White Paper (3).

1

Sustainable development of the EU transport policy and planning for TEN-T

2

3

| 2.6 | The package aims to create an integrated infrastructure policy for transport, energy and digital networks to make it possible to obtain synergies, improve resource allocation and eliminate bottlenecks, capacity problems and missing links. |
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2.6

The package aims to create an integrated infrastructure policy for transport, energy and digital networks to make it possible to obtain synergies, improve resource allocation and eliminate bottlenecks, capacity problems and missing links.

| 2.7 | The package expressly aims to contribute to the implementation of the aims of the EU 2020 strategy, that is the achievement of a sustainable and competitive knowledge economy served by optimal and resource efficient networks. |
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2.7

The package expressly aims to contribute to the implementation of the aims of the EU 2020 strategy, that is the achievement of a sustainable and competitive knowledge economy served by optimal and resource efficient networks.

| 2.8 | The means chosen to implement these aims are separate regulations for each sector with planning, priority and implementation guidelines and a common financing framework, the CEF regulation for 2014–2020, with an annexed list of corridors and predetermined projects selected for financing during the period 2014-2020. The CEF regulation does not fall within the ambit of this opinion. |
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2.8

The means chosen to implement these aims are separate regulations for each sector with planning, priority and implementation guidelines and a common financing framework, the CEF regulation for 2014–2020, with an annexed list of corridors and predetermined projects selected for financing during the period 2014-2020. The CEF regulation does not fall within the ambit of this opinion.

| 2.9 | The proposal sets a number of aims for the transport sector. The most important one is the introduction of a coherent core network, which is to enable resource efficient multimodal transport in the Single Market and to ensure its connections outward. The proposal is intended to replace the patchwork character of the current TEN-T Guidelines, improve visibility of the network and facilitate its implementation. |
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2.9

The proposal sets a number of aims for the transport sector. The most important one is the introduction of a coherent core network, which is to enable resource efficient multimodal transport in the Single Market and to ensure its connections outward. The proposal is intended to replace the patchwork character of the current TEN-T Guidelines, improve visibility of the network and facilitate its implementation.

| 2.10 | Like the 2011 White Paper on Transport Policy, the package aims to facilitate seamless transport flows in the Single Market, including logistics services, to ensure sustainability and growth. The proposal wants to facilitate cross–border coordination between Member States by providing a framework for better allocation of resources and better planning. |
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2.10

Like the 2011 White Paper on Transport Policy, the package aims to facilitate seamless transport flows in the Single Market, including logistics services, to ensure sustainability and growth. The proposal wants to facilitate cross–border coordination between Member States by providing a framework for better allocation of resources and better planning.

| 2.11 | The proposal includes in the network measures to develop ITS, improve green transport solutions and innovation. |
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2.11

The proposal includes in the network measures to develop ITS, improve green transport solutions and innovation.

| 2.12 | The proposal divides the net into two layers, the comprehensive network and the core network. The EU resources and governance are concentrated to the core network, which is to be characterised by a high European added value (cross border missing links, bottlenecks, multimodal nodes). The core network is to be implemented before the end of 2030, the comprehensive network before the end of 2050. |
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2.12

The proposal divides the net into two layers, the comprehensive network and the core network. The EU resources and governance are concentrated to the core network, which is to be characterised by a high European added value (cross border missing links, bottlenecks, multimodal nodes). The core network is to be implemented before the end of 2030, the comprehensive network before the end of 2050.

| 2.13 | Within the core network a number of multimodal core network corridors are selected, they are provided with a strong governance mechanism and most of the budget resources. |
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2.13

Within the core network a number of multimodal core network corridors are selected, they are provided with a strong governance mechanism and most of the budget resources.

3.   General comments

General comments

| 3.1 | The EESC welcomes the communication and the proposal and agrees that a functioning infrastructure is essential for a functioning internal market. |
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3.1

The EESC welcomes the communication and the proposal and agrees that a functioning infrastructure is essential for a functioning internal market.

| 3.2 | The EESC on a number of occasions has called for an integrated approach between the different kinds of Trans-European networks. The EESC therefore appreciates that proposals in this direction are now made. |
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3.2

The EESC on a number of occasions has called for an integrated approach between the different kinds of Trans-European networks. The EESC therefore appreciates that proposals in this direction are now made.

| 3.3 | The EESC takes note that the proposal only deals with coordination possibilities between the different kinds of networks in very general terms. More concrete provisions are to be found in the CEF proposal. |
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3.3

The EESC takes note that the proposal only deals with coordination possibilities between the different kinds of networks in very general terms. More concrete provisions are to be found in the CEF proposal.

| 3.4 | The EESC appreciates that the proposal is consistent with the transport policy aims set out in the 2011 White Paper on Transport. The EESC has pointed out that there needs be to better consistence between the strategic measures proposed by the White Paper on the 2050 horizon and the more concrete measures on the 2020–2030 horizon. Similar problems occur in the communication and the proposal. |
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3.4

The EESC appreciates that the proposal is consistent with the transport policy aims set out in the 2011 White Paper on Transport. The EESC has pointed out that there needs be to better consistence between the strategic measures proposed by the White Paper on the 2050 horizon and the more concrete measures on the 2020–2030 horizon. Similar problems occur in the communication and the proposal.

| 3.5 | The EESC assumes that the two layer approach of the communication and the proposal is motivated by a wish to create a coherent transport network for the most important goods and passenger transport flows, which is a useful goal and also based on a need to set priorities for the employment of scarce financing resources. |
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3.5

The EESC assumes that the two layer approach of the communication and the proposal is motivated by a wish to create a coherent transport network for the most important goods and passenger transport flows, which is a useful goal and also based on a need to set priorities for the employment of scarce financing resources.

| 3.6 | The EESC questions if the core corridors the framework of which is outlined in the proposal but which are described in an annex to the CEF proposal do not in fact constitute a third layer for the predefined priority projects for the budget period 2014-2020. The EESC draws attention to the problems of foreseeability and legal security that may appear for corridors and projects that are not fully implemented when the applicability of the CEF proposal comes to an end in 2020. |
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3.6

The EESC questions if the core corridors the framework of which is outlined in the proposal but which are described in an annex to the CEF proposal do not in fact constitute a third layer for the predefined priority projects for the budget period 2014-2020. The EESC draws attention to the problems of foreseeability and legal security that may appear for corridors and projects that are not fully implemented when the applicability of the CEF proposal comes to an end in 2020.

| 3.7 | The EESC therefore questions if the list of corridors and predefined projects should not appear in the annex to the proposal. The EESC takes the view that the corridors as such, are more related to the proposal, where they are regulated, than to the proposed CEF regulation. |
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3.7

The EESC therefore questions if the list of corridors and predefined projects should not appear in the annex to the proposal. The EESC takes the view that the corridors as such, are more related to the proposal, where they are regulated, than to the proposed CEF regulation.

| 3.8 | The EESC also notes a coherence problem as regards the interaction between the core network and the corridors for which the proposal provides a strong and useful coordination and governance mechanism. While the EESC certainly sees a point in setting very strict priorities when it comes to the use of resources, a well-developed coordination and governance mechanism could be useful also for the entire core network, the implementation time limit of which is after all not far off, in terms of infrastructure planning. The EESC particularly underscores the usefulness of this mechanism for striking a balance between national planning and EU added value and including the EU added value aspect in national planning. The need for a strong coordination and governance mechanism is particularly pertinent for projects that, by definition, are cross-border, such as Motorways of the Sea. |
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3.8

The EESC also notes a coherence problem as regards the interaction between the core network and the corridors for which the proposal provides a strong and useful coordination and governance mechanism. While the EESC certainly sees a point in setting very strict priorities when it comes to the use of resources, a well-developed coordination and governance mechanism could be useful also for the entire core network, the implementation time limit of which is after all not far off, in terms of infrastructure planning. The EESC particularly underscores the usefulness of this mechanism for striking a balance between national planning and EU added value and including the EU added value aspect in national planning. The need for a strong coordination and governance mechanism is particularly pertinent for projects that, by definition, are cross-border, such as Motorways of the Sea.

| 3.9 | The EESC considers that corridors should be truly multimodal. This might sometimes mean fairly wide corridors that encompass both land or fixed links and maritime links, for instance in the form of Motorways of the Sea. Appropriate room should be given to road transport, since it is important that the network is also based on today's demand realities. As a matter of fact a growth rate in transport of goods of 34% is expected between 2005 and 2020 and road transport today is carrying about 75% of transport volume. The EESC thinks it important that this multimodal character should be reflected also in the selection of projects, which should cover all modes. |
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3.9

The EESC considers that corridors should be truly multimodal. This might sometimes mean fairly wide corridors that encompass both land or fixed links and maritime links, for instance in the form of Motorways of the Sea. Appropriate room should be given to road transport, since it is important that the network is also based on today's demand realities. As a matter of fact a growth rate in transport of goods of 34% is expected between 2005 and 2020 and road transport today is carrying about 75% of transport volume. The EESC thinks it important that this multimodal character should be reflected also in the selection of projects, which should cover all modes.

| 3.10 | The EESC agrees with the assessment made in the communication that the time may now be opportune for proposals regarding infrastructure, since infrastructure investments are drawing accrued interest as a consequence of the current financial crisis. Nevertheless, the EESC notes that the assessment of financing possibilities must be more long term in a document that is set on the 2030 and 2050 horizons. |
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3.10

The EESC agrees with the assessment made in the communication that the time may now be opportune for proposals regarding infrastructure, since infrastructure investments are drawing accrued interest as a consequence of the current financial crisis. Nevertheless, the EESC notes that the assessment of financing possibilities must be more long term in a document that is set on the 2030 and 2050 horizons.

| 3.11 | The EESC notes the ambitious planning for the 2014–2020 period as set out in the annex to the CEF proposal. While appreciating the positive effects on implementation of the coordination and governance mechanism for core network corridors foreseen in the proposal and the monitoring provided for in the CEF proposal, the EESC nevertheless draws attention to the difficulty in foreseeing the duration of national planning procedures, since planning decisions are often subject to appeal and lengthy procedures therefore quite common. |
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3.11

The EESC notes the ambitious planning for the 2014–2020 period as set out in the annex to the CEF proposal. While appreciating the positive effects on implementation of the coordination and governance mechanism for core network corridors foreseen in the proposal and the monitoring provided for in the CEF proposal, the EESC nevertheless draws attention to the difficulty in foreseeing the duration of national planning procedures, since planning decisions are often subject to appeal and lengthy procedures therefore quite common.

| 3.12 | The EESC in its opinion on the 2011 White Paper on Transport Policy has emphasised the importance of the interface between long distance transport and distribution in urban areas. The EESC therefore approves the approach of the proposal on this point. |
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3.12

The EESC in its opinion on the 2011 White Paper on Transport Policy has emphasised the importance of the interface between long distance transport and distribution in urban areas. The EESC therefore approves the approach of the proposal on this point.

4.   Specific comments

Specific comments

| 4.1 | The EESC underlines that it is important to make room for local conditions, when implementing the guidelines, as far as technical criteria are concerned, to the extent that security or safety are not endangered. There should be a possibility to adequately address this issue, as a matter of resource efficiency. |
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4.1

The EESC underlines that it is important to make room for local conditions, when implementing the guidelines, as far as technical criteria are concerned, to the extent that security or safety are not endangered. There should be a possibility to adequately address this issue, as a matter of resource efficiency.

| 4.2 | The role of the Motorways of the Seas concept is in part not clear with respect to an MoS link between ports in different corridors or ports with different status for instance between a core network port and a comprehensive network port or between two core network ports that belong to different corridors – see for instance the proposal Article 25 2(c). The EESC deplores this lack of clarity, which could cause practical problems when sewing together MoS projects. |
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4.2

The role of the Motorways of the Seas concept is in part not clear with respect to an MoS link between ports in different corridors or ports with different status for instance between a core network port and a comprehensive network port or between two core network ports that belong to different corridors – see for instance the proposal Article 25 2(c). The EESC deplores this lack of clarity, which could cause practical problems when sewing together MoS projects.

| 4.3 | The provisions in Article 38 of the proposal in reality address the green corridor concept, as introduced by the Commission in the 2007 Freight Transport Action Plan. The EESC deplores that this flagship notion is not used in the proposal as a quality label. |
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4.3

The provisions in Article 38 of the proposal in reality address the green corridor concept, as introduced by the Commission in the 2007 Freight Transport Action Plan. The EESC deplores that this flagship notion is not used in the proposal as a quality label.

| 4.4 | The EESC agrees with the requirements to be met by the road transport infrastructure of the core network (Article 45 of the proposal). Ancillary infrastructure as rest areas every 50 km on motorways and adequate and safe parking areas for commercial road transport drivers is of paramount importance: such facilities enabling proper rest are vital for the improvement of both drivers working conditions and road safety. They also represent a contribution to counter organised crime. |
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4.4

The EESC agrees with the requirements to be met by the road transport infrastructure of the core network (Article 45 of the proposal). Ancillary infrastructure as rest areas every 50 km on motorways and adequate and safe parking areas for commercial road transport drivers is of paramount importance: such facilities enabling proper rest are vital for the improvement of both drivers working conditions and road safety. They also represent a contribution to counter organised crime.

| 4.5 | The requirement on the availability of alternative clean fuels should be reinforced as it will be crucial to link the TEN-T guidelines to the "Alternative transport fuels strategy" (including electricity, biofuels, synthetic fuels, methane, LPG) that the European Commission is preparing to launch in order to allow the EU wide circulation on the core network of clean and energy efficient vehicles. In this context the EESC considers that the rollout of adequate refuelling infrastructure for alternative fuels is necessary in order to substantially accelerate market uptake of clean vehicles in the EU. |
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4.5

The requirement on the availability of alternative clean fuels should be reinforced as it will be crucial to link the TEN-T guidelines to the "Alternative transport fuels strategy" (including electricity, biofuels, synthetic fuels, methane, LPG) that the European Commission is preparing to launch in order to allow the EU wide circulation on the core network of clean and energy efficient vehicles. In this context the EESC considers that the rollout of adequate refuelling infrastructure for alternative fuels is necessary in order to substantially accelerate market uptake of clean vehicles in the EU.

Brussels, 22 February 2012.

The President of the European Economic and Social Committee

Staffan NILSSON

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(1)  EESC opinion on TEN-T: A policy review, OJ C 318, 23.12.2009, p. 101.

1

TEN-T: A policy review

(2)  EESC opinion on Sustainable development of the EU transport policy and planning for TEN-T, OJ C 248, 25.08.2011, p. 31.

2

Sustainable development of the EU transport policy and planning for TEN-T

(3)  EESC opinion on Roadmap to a Single European Transport Area (White Paper), OJ C 24, 28.01.2012, p. 146.

3

Roadmap to a Single European Transport Area (White Paper)

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