15. 12. 75 Official  Journal  of the European  Communities No C 286/1 
II 
(Preparatory  Acts) 
ECONOMIC  AND  SOCIAL  COMMITTEE 
Opinion  on  the  communication  from  the  Commission  to the  Council  on  the 
development  of the common  transport  policy 
The text  referred  to the Committee  has not yet been  published  in the Official  Journal 
of the European  Communities. 
In accordance  with  the third  paragraph  of Article  20 of the  Rules  of Procedure,  the 
Bureau  of the  Committee  decided  on 26 November  1974  to deliver  an additional 
Opinion  on the abovementioned  communication. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  prepared  its Opinion  on the above  matter  at its 
133rd  plenary  session,  held  in Brussels  on 24 and  25 September  1975. 
The full  text  of the Opinion  is as follows: A. LEGAL  BASIS  FOR  THE  OPINION 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, Having  regard  to the  report  drawn  up  by  the 
Rapporteur,  Mr  Renaud,  and  the  co-Rapporteurs, 
Mr Bonety,  Mr Fredersdorf  and  Mr Masprone; 
Having  regard  to its Opinion  adopted  on 28 March 
1974  on the  'Commission  communication  to the 
Council  on the  Development  of the  common  trade 
policy',  in which  the  Committee  reserved  the  right 
'to return  to this  question  at a later  date'  (x); Having  regard  to the discussions  at its meeting  on 25 
September  1975  (133rd  plenary  session  of 24 and  25 
September  1975); 
Having  regard  to the decision  taken  by its Bureau  on 
26 November  1974  authorizing  the  section  for 
transport  and  communications  to draw  up  an 
additional  Opinion  on the matter; Having  regard  to the  third  paragraph  of Article  20 
of its Rules  of Procedure; Whereas  it needs  to be examined  how  the  common 
transport  policy  can  contribute  to  good  area 
planning,  regional  balance,  an improved  quality  of 
life and  social  progress,  with  particular  emphasis  on 
the protection  of  the  environment  and  the 
preservation  of intangible  values  — all goals  which 
were  agreed  upon  at the  1972  Paris  Summit 
Conference  in  connection  with  the  aimed-for 
economic  and  monetary  union; 
(*) OJ No C 126,  17. 10. 1974,  p. 28. Whereas  the  regional  development,  energy  and 
financial  aspects  of  transport  are  particularly 
important  at the present  time; 
No C 286/2 Official  Journal  of the  European  Communities 15.12.  75 
Whereas  it is therefore  necessary  to examine  the 
implications  of these  questions  for  the  common 
transport  policy, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
unanimously,  less  12 abstentions: 
1. General  comments 
1.1. In  its communication  to the  Council  on the 
development  of the  common  transport  policy,  the 
Commission  shows  how  it intends  to integrate 
transport  policy  more  closely  with  the  other 
Community  policies.  In view  of this  intention,  the 
Committee  has decided  to produce  a further  Opinion 
which  enlarges  upon  particularly  important  and 
relevant  implications  of  certain  other  common 
policies  for  the  common  transport  policy.  These 
other  policies  are: 
—• energy  policy, 
— regional  development  policy  and 
— fiscal  and expenditure  policies. 
The report  of the  Section  for  Transport  and 
Communications  which  is appended  to this  Opinion, 
is an overall  study.  Some  of the  main  ideas  it 
develops  are aired  in this  document,  too. 
1.2. The  Commission  has  shown  great  interest  in 
the Committee's  work  and  has  given  it much  help. 
For this,  the  Committee  would  like  to thank  the 
Commission.  It has come  to the Committee's  notice, 
however,  that  while  it has been  working  on the new 
Opinion  over  the  past  few  months,  the 
Commission's  Directorate-General  for Transport  has 
produced  several  working  papers  on the organization 
of the  transport  market.  In connection  with  these 
papers,  consultations  have  been  held  with  socio-
economic  organizations,  national  governments  and 
university  experts  from  various  Member  States. 
1.3. The  Committee  is generally  not  consulted  on 
proposed  Community  legislation  until  a later  stage 
of the  procedure.  Nevertheless,  it would  like  to 
reiterate  what  it said  in its Opinion  of 28 March 
1974  on the  organization  of the  transport  market: 
'The  transport  market  will  still  need  to  be 
supervised  after  the transitional  period,  even  if the 
starting  conditions  are  aligned,  because  special 
measures  are  required  to  maintain  healthy 
competition  on the  transport  market,  owing  to the 
special  features  this  market  has  and  their  cumulative 
effect.' 1.4. Organization  of the  transport  market  must 
not be  of a merely  transitory  nature,  in the 
Committee's  view.  Market  organization  becomes 
ineffective  if intervention  is limited  to cases  where 
there  is a crisis  or a serious  disturbance. 
1.5. In  these  circumstances  it would  be unwise  for 
the Community  to introduce  measures  which  would 
dismantle  the  fragile  structure  of  existing 
Community  rules  on the organization  of the market. 
2. Specific  comments 
2.1. Transport  and  energy  policy 
2.1.1.  Events  since  the  autumn  of 1973  have 
changed  the situation  in which  Europe  had  relatively 
cheap  supplies  of  raw  materials,  particularly 
petroleum  products,  and  the  Member  States  had 
considerable  scope  for  taxing  the  consumption  of 
these  products. 
This  profound  change  will  have  fairly  considerable 
repercussions  on the  shape  of our  economy,  our 
growth  and  our  lifestyle.  Energy  will  go on being  a 
valuable  and  expensive  commodity,  to be used  as 
sparingly  as possible.  Since  transport  is doubly 
concerned  here,  being  both  a transporter  and 
consumer  of energy,  we  must  examine  all energy 
conservation  measures  closely. 
2.1.2.  Energy  consumption  in  transport  is, 
however,  relatively  inelastic.  Gross  energy  efficiency 
is not the only  factor  to be taken  into  consideration 
when  assessing  the  consumption  — and  hence  the 
cost — of energy  in transport.  Transport  impinges  in 
varying  degrees  on  external  trade,  the  domestic 
economy,  individual  working  and  living  conditions, 
and the environment.  Due  importance  must  be given 
to energy  conservation,  but  all the  aforementioned 
repercussions  must  be borne  in mind  when  taking 
decisions  about  the  organization  of  transport, 
promoting  new  techniques,  and  about  bringing  other 
modes  of transport  (especially  air transport,  and  also 
to some  extent  sea  transport)  under  the  common 
policy. 
2.1.3.  The  slowdown  in economic  activity  in 1974 
and 1975  has  led  to a general  reduction  in energy 
consumption  in all sectors  and  has  automatically 
brought  about  a decline  in the demand  for transport, 
and hence  in the  energy  consumption  of transport. 
Thus  it appears  that  the transport  industry's  energy 
15.12.  75 Official  Journal  of the  European  Communities No C 286/3 
consumption  follows  the pattern  set by the economy 
generally. 
2.1.4.  The  Committee  discussed  the  papers 
submitted  by  the  Commission  on  short-  and 
medium-term  reduction  of energy  consumption  and 
approved  the  policies  put  forward  therein.  In the 
Committee's  view,  the  savings  attainable  through 
rationalization  of car  traffic  (encouraging  public 
transport,  speed  limits)  and  changes  in vehicle  design 
are only  part  of the solution. 
2.1.5.  The  Community  should  make  a determined 
effort  to rationalize  certain  sectors  — particularly  air 
transport  — which  are big consumers  of energy.  The 
Committee  would  refer  in this  connection  to its 
Opinion  of 27 November  1973  on a proposal  for  a 
Council  Decision  on the first  measures  of a common 
approach  to air transport  (1). In this  Opinion,  the 
Committee  called  for  an overall  coherent  approach 
to air transport  within  the Community,  and  between 
the EEC  and  non-member  countries. 
2.1.6.  Rationalization  of transport  in large  urban 
areas  is a key  aspect  of  energy  conservation. 
Rationalization  of urban  transport  is closely  bound 
up with  the improvement  of the  working  and  living 
environment,  and  hence  with  social  policy  and  area 
planning. 
The first  need  is  to  promote  and  provide 
infrastructures  for public  transport.  National  budgets 
should  be examined  by the  Community  to compare 
what  the  different  Member  States  are  doing  in this 
area. 
2.1.7.  The  Committee  discussed  what  changes 
need  to be made  to the  Commission's  transport 
strategy  (already  commented  on in the Opinion  of 28 
March  1974)  in the light  of the new  energy  situation. 
It came  to the  general  conclusion  that  everything 
should  be done  to avoid  duplication  and  wastage,  to 
encourage  schemes  for  better  coordination  of 
different  types  of transport,  and  to ensure  better  use 
of equipment. 
2.1.8.  The  emphasis  of the  common  policy  is, 
however,  on investment  and  the  rules  of the  market 
organization.  Here,  the  Committee  considers  that 
there  must  be a proper  balance  between  market forces  on  the  one  hand  and,  on  the  other, 
intervention  by the  public  authorities  to safeguard 
the general  interest. 
2.1.9.  This  said,  the  free  market  is not  the  only 
vehicle  for  allocating  resources.  Selection  of 
investment  projects  in transport  must  take  into 
account  other  criteria  too. 
At all events,  those  responsible  for  transport  policy 
must  combat  monopoly  situations  in transport  and 
equip  themselves  with  powers  to  secure  equal 
treatment  for the various  modes  of transport  and  to 
maintain  the service  to the public. 
2.1.10.  The  Section's  report  contains  a list  of 
fields  in which  the  Community  should  take  action. 
The Committee  thinks  it especially  important  that 
concrete  action  should  be taken  in the  following  of 
those  fields: 
— the  master  plan  for  transport  in the  EEC,  in 
liaison  with  the national  programmes, 
— charging  for the use of transport  infrastructure, 
— social  regulations, 
— urban  and  suburban  transport, 
— control  of capacity, 
— vehicle  weights  and  dimensions. 
The Commission  should  work  towards: 
— better  coordination  of the  work  of the  various 
Commission  DG's  involved, 
— improvement  of statistics  on energy  consumption 
by transport, 
— coordination  and  alignment  of national  policies 
on industrial  redevelopment. 
2.2. Transport  and  regional  policy 
2.2.1.  The  purpose  of regional  policy  is to create  a 
better  balance  between  areas,  some  of which  are 
over-developed  and  others  under-developed.  It is 
essential  that  the  national  and  Community 
authorities  should  take  action  in this  field. 
(*) OJ No C 100,  22. 11. 1973,  p. 1. 2.2.2.  Transport  is one  of the  chief  instruments  at 
the disposal  of regional  policy  for  achieving  such  a 
No C 286/4 Official  Journal  of the  European  Communities 15.12.  75 
balance.  There  should  be a comprehensive  European 
transport  network  plan  (covering  sea,  inland 
waterway,  air  and  overland  transport,  including 
submarine  tunnels,  oil pipelines  and  new  techniques) 
in which  each  mode  of transport  is assigned  the job 
it can do best. 
2.2.3.  The  methods  proposed  by the Commission 
for the  organization  of the  Community  transport 
system  may  conflict  with  the aims  of regional  policy. 
This  conflict  is most  apparent  in the  financing  of 
infrastructure:  market  forces  are  clearly  not 
sufficient  to relieve  congestion  in highly  developed 
areas  and  at  the  same  time  provide  the 
infrastructures  needed  to stimulate  development  in 
backward  areas.  Any  moves  to balance  out  regional 
differences  must  be compatible  with  a Community 
system  for the financing  of infrastructures. 
Given  the  importance  and  genuine  Community 
character  of the goal,  some  of the revenue  from  taxes 
levied  on the  transport  sector  might  be used  to set 
up a Community  fund,  in so far  as revenue  from 
taxes  levied  on  transport  in the  Community  is 
allocated  to the  development  and  maintenance  of 
infrastructures  under  the  Commission's  system  of 
charging  for the use of infrastructures.  The  EIB  too, 
if adequately  topped  up,  could  contribute  to the 
financing  of infrastructure  which  is of European 
interest. 
2.2.4.  Regional  policy  can  also  provide 
opportunities  for  experimenting,  under  ideal 
economic  conditions,  with  new  transport  techniques 
in congested  areas  (public  passenger  transport). 
2.2.5.  Transport  planning  for  backward  areas 
must  include  sea  and  air links  and  port  facilities. 
These  have  so far not  been  covered  by Community 
action. 
2.2.6.  To  ensure  that  funds  earmarked  for 
developing  transport  infrastructures  under  regional 
policy  are used  to the  best  advantage,  the  methods 
applied  in each  Member  State  for  evaluating  the 
effectiveness  of infrastructure  investments  should  be 
aligned. 
2.2.7.  It  is possible  to subsidize  rates  charged  by 
transport  undertakings  serving  areas  which  receive 
special  aid.  However,  such  subsidies  should  be 
provided  only  in cases  where  they  are more  effective or fairer  than  other  forms  of regional  aid (e.g.  aid to 
industry,  consumer  subsidies,  tax  relief,  etc.).  Rate 
support  must  on no account  be allowed  to distort 
competition  between  different  types  of transport. 
2.2.8.  There  are,  however,  gaps  in the Community 
rules  on compensation  for public  service  obligations. 
These  rules  do  not  yet  apply  to all  modes  of 
transport.  The  revision  of Council  Regulation  (EEC) 
No 1191/69  (*) of 26 June  1969  on Public  Service 
Obligations  should  therefore  be speeded  up  and 
extended.  The  Committee  has  called  for this  before 
in other  Opinions  (2). 
2.3. Transport  and  the financial  implications 
2.3.1.  Financial  problems  are posed  by the energy 
and regional  policy  goals  assigned  to transport.  So it 
is fair  to ask  whether,  and  to what  extent,  the 
transport  policy  measures  introduced  to date  should 
help to achieve  such  goals. 
2.3.2.  It  is hard  to give  a precise  answer  to this 
question,  as we do not have  any  estimate  of the cost 
of attaining  the abovementioned  goals  of energy  and 
regional  policy.  "What  is clear  is that  transport  can  be 
a source  of  revenue,  and  can  entail  specific 
expenditure  (e.g.  allocation  of infrastructure  costs, 
subsidizing  of transport  rates).  The  Community's 
work  on the  development  of uniform  methods  of 
implementing  transport  policy  has  not  yet produced 
concrete  results,  except  in  a few  cases  (e.g. 
normalization  of railway  accounts).  This  lack  of 
progress  shows  how  difficult  it is to define  the 
financial  implications  for  transport  of the  other 
common  policies. 
2.3.3.  These  difficulties,  which  have  emerged  from 
the application  of the common  transport  policy,  are 
aggravated  by the absence  of Community  fiscal  and 
budgetary  policies.  In spite  of this,  the principle  of 
neutrality  should  be followed  in the  taxation  of 
competing  transport  undertakings  and  modes  of 
transport.  It cannot  be overlooked  that  earmarking 
specific  transport  charges  for  the  development  of 
infrastructures  represents  a certain  automatic 
financing  mechanism  for infrastructure  development. 
H OJ  No  L 156,  28.  6. 1969,  p. 1 (see  special  English 
edition  1969  (*). 
(2) E.g.  OJ No C 86, 16. 10. 1973,  p. 1. 
15.12.  75 Official  Journal  of the  European  Communities No C 286/5 
This  has a beneficial  effect  on coordination  and  long-
term  planning  of  infrastructure  measures  in 
transport.  It must  be pointed  out,  however,  that  in 
the implementation  of  integrated  infrastructure 
plans,  a lack  of funds  can  lead  to budgetary 
restrictions,  with  the result  that  some  infrastructure 
measures  will  have  to be axed  and,  for  financial 
policy  reasons,  earmarked  funds  will  have  to be used 
for other  purposes. 
2.3.4.  However,  tax  incentives  should  be used  to 
promote  measures  which  are  in the  public  interest, 
especially  to solve  traffic  and  transport  problems  in 
conurbations. 
2.3.5.  The  allocation  of infrastructure  costs  is 
complicated  by the difficulty  of calculating  external 
costs.  Consequently,  the Committee  doubts  whether 
an objective  system  of infrastructure  charging  can  be 
worked  out. 
2.3.6.  Progress  can  be made,  however,  towards 
aligning  the  vehicle  and  fuel  tax  systems,  and  the 
rules  for VAT  exemption  and  deductibility. 
2.3.7.  As  far as regional  policy  is concerned,  credit 
must  be made  available  at Community  level  in order 
to complement  the  measures  taken  by individual 
Member  States. 
In principle,  decisions  should  be taken  on the basis 
of a cost-benefit  analysis.  In this  connection,  it is 
Done  at Brussels,  on 25 September  1975. essential  that  the requisite  data  should  be established 
on a uniform  Basis  and by uniform  methods. 
2.4. Conclusions 
In the light  of previous  developments,  the Committee 
now proposes  that  the  following  action  be taken 
within  the  framework  of the  common  transport 
policy: 
— amplification  of the  initial  objectives  of the 
common  transport  policy  to take  into  account 
new factors  resulting  from  the  changes  brought 
about  by the new  energy  situation, 
— establishment  of a European  transport  network, 
with  a clear  distribution  of  political  and 
management  responsibilities  at  Community, 
national  and  regional  levels, 
— definition  of criteria  for  choosing  investments, 
the aim  being  to guarantee  better  utilization  of 
resources, 
— tailoring  of financial  policy  to land-use,  regional 
policy  and  energy  policy  objectives,  making  sure 
that action  is integrated  more  dosely  in these 
different  fields,  an  aim  to be  achieved  by 
speeding  up  the  process  of  approximating 
conditions  of competition,  especially  in the field 
of taxes. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the proposal  for a Council  Directive  relating  to pollution  of sea water  and 
fresh  water  for  bathing  (quality  objectives) 
The text  referred  to the  Committee  was  published  in the  Official  Journal  of the 
European  Communities  No  C 67 of 22 March  1975,  page  1. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 17 February  1975,  the  Council  referred  the  abovementioned  proposal  to the 
Economic  and  Social  Committee  under  Article  100  of the  Treaty  establishing  the 
European  Economic  Community.