Opinion of the Committee of the Regions on the 'Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the Regions - The Common Transport Policy: Sustainable Mobility: Perspectives for the Future'
Date: 1999-09-16
Institutions: European Committee of the Regions
Subjects: combined transport, common transport policy, organisation of transport, transport market, transport safety, transportation tariff

C 374/76

EN

Official Journal of the European Communities

23.12.1999

Opinion of the Committee of the Regions on the ‘Communication from the Commission to the
Council, the European Parliament, the Economic and Social Committee and the Committee of the
Regions — The Common Transport Policy: Sustainable Mobility: Perspectives for the Future’

(1999/C 374/17)

THE COMMITTEE OF THE REGIONS,

having regard to Communication from the Commission to the Council, the European Parliament, the
Economic and Social Committee and the Committee of the Regions — The Common Transport Policy:
Sustainable Mobility: Perspectives for the Future (COM(1998) 716 final);

having regard to the decision taken by the Commission on 10 December 1998, under the first paragraph
of Article 198c of the Treaty establishing the European Community, to consult the Committee of the
Regions on the matter;

having regard to the decision of its Bureau on 10 March 1998 to direct Commission 3 (Trans-European
Networks, Transport and Information Society) to draw up the relevant opinion;

having regard to its earlier opinions on:

— ‘Sea Ports and Maritime Infrastructure’ (CdR 331/98 fin) (1),

— ‘New Regulatory Framework for conditions of access to railway infrastructure’ (CdR 58/99 rev 1),

— ‘The Common Transport Policy Action Programme 1995-2000’ (CdR 406/95 fin) (2),

— ‘A sustainable transport strategy’ (CdR 255/97 fin) (3), ‘Developing the Citizen’s Network — why
good local and regional passenger transport is important and how the European Commission is
helping to bring it about’ (CdR 436/98 fin) (4),

— ‘The White Paper on — Fair Payment for infrastructure charging framework in the EU’ (CdR 408/98

fin) (5),

— ‘Transport and CO2 — Developing a Community Approach’ (CdR 230/98 fin) (6);

having regard to the draft opinion [CdR 189/99 rev. 1) adopted by Commission 3 on 15 July 1999
(rapporteur: Mrs Coffey (IRL, EA)],

adopted the following opinion unanimously at its 30th plenary session on 15 and 16 September 1999
(meeting of 16 September).

1.

Introduction

1.1.
The communication from the Commission serves as
an overview of the current trends and policy directions within
the Common Transport Policy (CTP). Looking at all of
the programmes within the framework, the Commission’s
Communication looks to the future of the CTP and what
directions it should take to lead on from. Many developments

(1) OJ C 93, 6.4.1999, p. 20.
(2) OJ C 337, 11.11.1996, p. 13.
(3) OJ C 180, 11.6.1998, p. 1.
(4) OJ C 198, 14.7.1999, p. 8.
(5) OJ C 198, 14.7.1999, p. 16.
(6) OJ C 198, 14.7.1999, p. 3.

have taken place since the publication of the Commission’s
Common Transport Policy action programme for 1995-
2000 (7) and the objectives of this programme remain valid for
the purpose of this framework.

1.1.1.
The Committee of the Regions (COR) has followed
the recent developments of the Common Transport Policy
from the Action Programme 1995-2000 through opinions on
the measures proposed on the basis of it. This opinion will
examine the current communication and its proposals for
future action in light of the COR’s previous opinions.

(7) COM(95) 302 final.

23.12.1999

EN

Official Journal of the European Communities

C 374/77

1.2. Objectives of the Common Transport Policy

Improving quality and the effectiveness of the exter-
1.2.1.
nal dimension of the Common Transport Policy are central
objectives of the Commission’s Communication and these
aspects must be considered in order to ensure a sustainable
transport strategy is pursued in all areas.

1.2.2.
Currently there are five major objectives in terms
of improving efficiency and competitiveness for the future
development of the CTP. Their overall aim is to ensure the full
potential of European transport systems and promote the
competitiveness of European business which will maximise
growth, employment, and environmental sustainability.

2.2.3.
The rail transport sector faces issues on several fronts
which the Commission’s communication goes some way
towards addressing. Market share has dropped steadily against
other modes and in terms of sustainability at least, the need
to prioritise rail transport cannot be overemphasised. Rail
transport can compete very favourably with other modes in
terms of environmental impact when a pricing regime which
incorporates the principles of polluter pays and internalisation
of external costs is established. The COR welcomes the series
of proposals by the Commission but acknowledges that
movement is required by all the actors in this sector to make
rail more competitive.

— Liberalising market access

2.3. Ports

— Ensuring integrated transport systems across Europe

— Ensuring fair and efficient pricing within and between

transport modes

— Enhancing the social dimension

— Making sure rules which have been agreed are properly

implemented.

2. Market Access and Functioning

The two main priorities for the Commission with
2.1.
regard to market access and functioning are the rail sector and
ports.

2.2. Rail

2.2.1.
Further to the Commission’s White Paper on the
revitalisation of the Community’s Railways, steps are being
taken on charging, capacity allocation, separation of infrastruc-
ture management and operation, and licensing. There will be
proposals on public service contracts and on State aids for
land transport and also a communication for the integration
of national systems including technical interoperability.

2.2.2.
The COR opinion on the package of measures on
railways welcomes the measures proposed by the Commission.
However,
the Commission should seriously consider the
different recommendations proposed by the COR which are
essential in order to ensure that restructuring of the rail sector
brings benefits to all the affected regions in Europe. For
example, in regard to pricing policy, the infrastructure manager
should be able to apply prices based on commercial decisions
and not solely on rigid and predetermined criteria. The
proposals in the directive could pose problems for infrastruc-
ture managers, who can be local/regional authorities, if they
do not have powers to take corrective measures to remedy any
malfunctioning of the system.

2.3.1.
The liberalisation of port services will be dealt with
by forthcoming Commission proposal following consultation
on its Green Paper on Sea Ports and Maritime Infrastructure.
The COR proposed several recommendations in its opinion
on the Green Paper in terms of competitiveness. Its conclusions
re-emphasised the need for uniform laws on protection of
the environment, workplace safety and conditions, external
security and border controls to ensure fair conditions for
competition. These rules and the pricing structure for the use
of port facilities should take account, however, of natural
(geographical etc.) and human (management/organisational)
differences in ports. To ensure free and fair competition in the
port sector also guidelines on state aid are required.

As the ports and maritime infrastructure of the EU is
2.3.2.
essential to the economic and social well-being of particular
regions in the Union, the COR emphasises the need to adhere
to the principle of subsidiarity. When decisions concerning the
establishment of port facilities are being considered, local and
regional authorities are most aware of what action needs to be
taken. Therefore the Committee of the Regions would empha-
sise the importance of final decisions concerning ports and
maritime infrastructure being taken by local and regional
public and private parties.

3.

Integrated Transport Systems

The integration of the Community’s transport systems
3.1.
has long been a priority for the Commission and this
Communication reaffirms this pledge. The implementation of
priority TENS projects defined at the Essen summit will be
encouraged by the Commission and new guidelines for the
TEN-T will be published. The Commission further recognises
the importance of extending the Trans-European Networks
into applicant countries. Combined transport and intermo-
dality will be promoted through the implementation of the
Action Plan for global navigation by satellite. Transport
telematics will assist intermodality and thus the efficiency of
different transport modes.

C 374/78

EN

Official Journal of the European Communities

23.12.1999

3.2.
The COR welcomes the attention given to the TENS by
the Commission in its proposed future work programme. The
emphasis on intelligent systems and telematics which will
increase the effectiveness of existing infrastructure rather than
solely concentrating on the construction of more infrastructure
is a trend to be encouraged. The launch by the Council of a
strategy for the promotion of innovation in transport and a
debate on the development of a global satellite navigation
system (Galileo) and transport telematics is a further step along
this path. The applications of such systems could include rail
signalling, maritime navigation, air traffic and even road traffic
control.

Although new rules for combined transport have been
3.3.
drawn up by the Commission to encourage intermodality, the
COR feel that the use of such technology could have far greater
benefits. Combined transport has a limited market and greater
emphasis on intelligent transport systems could bring about
more significant intermodal shifts than the means used to
promote combined transport with far reaching benefits in
terms of safety and the environment.

3.4.
As the COR opinion on a sustainable transport strat-
egy (1) pointed out, transport networks should be integrated
within regions across the different modes, between regional,
national and international systems and between the European
TEN-T and the transport networks of candidate countries.

3.5.
Linking the TENS into local and regional passenger
transport networks is an essential principle which should be
framework in consideration of
included in any transport
Europe’s citizens. In its opinion on the financial rules for the
Trans-European networks (2), the COR highlighted the problem
of ‘missing links’. These occur where trans-European traffic
meets regional traffic and serious congestion occurs thus
defeating the flow and purpose of the TENS. Specific subsidies
are required for the funding of projects which will improve
local commuter transport infrastructure such as bus corridors,
light rail etc. It is hoped that infrastructure charging will
encourage intermodal shifts and relieve the pressure on local
and regional transport thus freeing the way for TENS traffic.

3.6.
The COR opinion on the regulations laying down
general rules on the granting of Community financial aid in
the field of trans-European networks outlines several points
which were overlooked in the Council regulation. These
points include the introduction of a larger budget allocation,

the administrative procedures,

simplification of
increased
funding for studies, a cost-efficiency evaluation of small
projects, give local and regional authorities a greater role and
a greater emphasis on PPPs. The Committee believes that these
points should be included in the revision of the guidelines
proposed for the period 2000-2004.

4. Fair and Efficient Pricing

the Committee of

for Infrastructure Use (3),

Following the Commission’s White Paper on Fair
4.1.
the
Payment
Regions endorsed the Commission’s principles on charging on
the basis of the marginal social cost principle. The White
Paper’s aim is to encourage intermodality and more efficient
use of transport infrastructure. The polluter pays principle and
point of use charging are also to be incorporated into charges
and levies. With regard to the principle of sustainability,
greater emphasis should be placed on the provision of
incentives for clean technologies and the design of charging
systems should be so that low emission vehicles and multiple-
occupancy of private vehicles etc. be encouraged.

4.2.
The COR however would wish that in the next period
(phase two 2001-2004) that the Commission will incorporate
the proposals made by the COR which include addressing user
behaviour not only by direct taxes or charges but also address
the problem of tax incentive schemes which serve to encourage
car use. Furthermore, the COR recommends that the establish-
ment of an EU transport strategy includes the private car,
an efficient global approach to transport costs should not
separately assess public transport and the use of private car.
Flexibility in the application of charges is a necessity for several
reasons and the COR reaffirms that modal shifts and changes
in user behaviour will only occur when there is a viable
alternative available which applies both for commercial and
private users. As a first step the COR would urge the
Commission to carry out a study on teleworking to examine
its feasibility and possible social, economic and environmental
benefits.

4.3.
It is essential that in the decision-making process for
the structure of charges and taxes that local and regional
authorities are fully consulted and appropriately represented
on the committee of experts on charging for the use of
infrastructure. The needs of particular regions must be given
due attention and flexibility applied in order that problems
such as inaccessibility and remoteness are not exacerbated.
Furthermore as the local and regional authorities will be
implementing a great deal of the principles and also tackling
the problems, they should have an input as to how revenue
from charges and taxes is spent.

(1) CdR 255/97 fin — OJ C 180, 11.6.1998, p. 1.
(2) CdR 217/98 fin — OJ C 93, 6.4.1999, p. 29.

(3) COM(1998) 466 final.

23.12.1999

EN

Official Journal of the European Communities

C 374/79

5. Economic and Social Cohesion

5.1.
Economic and Social cohesion is a priority for the
Commission and this was comprehensively dealt with in a
communication on transport and cohesion (1). This paper
outlines the role of the CTP in reducing regional and social
disparities in the EU alongside instruments such as the
Structural and Cohesion funds. An improved transport system
can make a less developed region attractive for investment as
well as contributing to the overall strength of the region for
economic development. The COR particular welcomes to
the attention given to sustainability and the promotion of
accessibility in the Commission’s communication. Accessible
and affordable public transport serves a social, economic and
environmental purpose and as such must continue to receive
state aid, complying with EU State aid regulations.

5.2.
The Commission is continually looking into how
competition in public transport can be opened up while
maintaining access for all. On the basis of a Commission study
of public service rules and practices in land transport, the need
to improve transparency and efficiency of public transport for
the benefit of disadvantaged regions and social groups has
been recognised. More power and responsibilities needs to be
devolved to local and regional authorities to enable them to
develop their own transport systems as they see fit. This
requires them having the necessary financial resources to take
action which should, where possible, be available to them
through the collection of local taxes.

The Commission is continually trying to balance
5.3.
competitiveness with working conditions and with proposals
on working time. Following the Working Time Directive, the
Commission has gradually dealt with the ‘excluded sectors’
which included transport workers. Full agreement has not
been reached on all aspects of transport workers’ working
conditions and this should be pursued as a matter of urgency
in order to resolve the difficulties and balance the priorities of
fair conditions of competition and social protection in a
sensitive way.

6. Making sure the rules are applied

6.1.
The transposition and correct implementation of com-
petition rules adopted by Member States is essential for the
good functioning of the transport internal market and the
Commission is resolute in its efforts to ensure compliance.
The Committee of the Regions supports the Commission in its
aim which will ensure fairness for all. It is proposed by the
COR that
in the continued clarification and revision of
legislation that the specific needs of Europe’s local and regional

authorities will be considered. Furthermore the COR would
wish to be represented on any bodies established to exercise
regulatory authority in the transport sector. For example the
Aviation Safety Authority will have an advisory panel of
experts and the COR would wish to be represented on this or
other regulatory authorities.

7.

Improving Quality

7.1.
The Commission’s communication dedicates an entire
section to the safety and environmental dimensions of the
European Transport Policy. The EU has a significant role to
play in providing a high level of safety for both consumers
and transport workers. The COR endorses the package of
measures currently underway and those proposed for 2000-
2004.

7.2. Safety

7.2.1.
Safety for both consumers and workers is a key
priority for the Commission in a market where volumes are
constantly increasing and congestion is growing. Proposals
have been made in civil aviation (2), ro/ro passenger ferries (3)
and road transport through the car testing programme EURO-
NCAP. In the COR’s opinion (4) regarding air transport safety,
the point was made that smaller airports have different needs
to larger ones and this should be considered when European
rules are being laid down.

Safety is a major consideration which is not
7.2.2.
adequately dealt with by this Commission Communication.
The COR Opinion on the Common Transport Policy Action
Programme 1995-2000 addressed the need for a review of
speed limits, measures to enforce traffic regulations and
prosecution of infringements. Limitations over the right to
drive could be introduced such as age/engine size consider-
ation. The COR in their opinion called for a survey of the
impact of safety measures in all Member States and awaits
with interest the Commission’s communication on road safety
action priorities. Furthermore, the COR proposed a new ‘zero
defect’ strategy as in industrial quality control which would
link transport safety activities with state health systems and
would like to see some movement on this.

(1) COM(1998) 806 final.

(2) COM(1997) 55 final; COM(1997) 382 final.
(3) COM(98)71 final.
(4) CdR 406/95 fin — OJ C 337, 11.11.1996, p. 13.

C 374/80

EN

Official Journal of the European Communities

23.12.1999

7.3. Environment

7.3.1.
The EU is obliged under Article 3c of the Amsterdam
Treaty to integrate environmental protection requirements
into the definition and implementation of Community policies
with a view to promoting sustainable development. Further-
more, the strategy of integrating environmental considerations
into EU policies will be vigorously pursued. Among the areas
being dealt with under the environmental portfolio are, air
transportation noise and pollution, ship generated waste and
cargo residues, problems caused by heavy goods vehicles
and emission standards in the context of the Auto/Oil II
programme. The Commission also envisages the development
of new initiatives not dealt with in the Council’s work
programme and strategy.

7.3.2.
In its Opinion on the Common Transport Policy
1995-2000 the COR called for special measures to supplement
the Action Programme for the protection of ecologically
sensitive regions and areas affected by the European transport
system. These included building regulations, integrated sol-
utions for the traffic infrastructure network and even the
complete restriction of choice over modes of transport in
exceptional cases where alternatives modes are available.
Furthermore, the COR wish to encourage research into the
production of vehicles with low CO2 and other emissions as
well as research into the area of renewable fuels.

The most effective and sustainable solution to reduc-
7.3.3.
ing the growth in emissions is to restrict the demand to travel.
Spatial planning is central to this aim and can help reduce
journey distances, along with complementary measures
resulting in emission reductions by about one third by 2010.
Although the Community does not have competence in the
area of spatial planning, this is an area where the Commission
could propose ‘soft’ policies which could have a significantly
positive effect for the environment and sustainable develop-
ment. Although an examination of the role of the CTP in the
European Spatial Development Perspective is welcomed, it falls
far short of the measures proposed by the COR which could
result in a significant halt to growth in CO2 emissions.

7.3.4.
As road and air transport produces the most CO2
per passenger per kilometre, these should be tackled as a
matter of priority. The transport of freight by road and air is
also problematic for similar reasons. In its opinion on Trans-
port and CO2, the COR proposed a series of taxes on fuels for
private transport and a realignment on taxes for kerosene for
air transport. However, the COR recognises that a flexible
approach should be taken with regard to road and air transport

in peripheral areas due to their efficiencies. Although the
Commission’s proposals to introduce infrastructure charges
should encourage intermodal shifts for the more efficient use
of infrastructure, such fiscal policies must be combined with
structural changes to infrastructure use such as land-use
planning policies.

7.4. Public Passenger Transport

7.4.1.
Specific consumer protection measures are intended
in order to enhance consumer confidence. The action pro-
gramme on local public transport, which is the only form of
transport available to all citizens, will cover areas such as
best practice,
integrated passenger services and
benchmarking. Under the fifth framework programme for
research and development, a series of targeted research actions
have been proposed to improve the efficiency and sustain-
ability and enhance the safety and intermodality of
the
transport system.

intermodal

7.4.2.
Research activities carried out under the fifth Frame-
work Programme for Research and Development should
involve the participation of local and regional authorities. They
are the ideal partners in the execution of research programmes
as they function at
to the citizen and
the level closest
understand local needs best. Furthermore, several of the actions
proposed in the fifth framework are of particular relevance to
local passenger transport, for example ‘Sustainable Mobility
and Intermodality’, ‘Systems and Services for the Citizen’ etc.

7.4.3.
A greater emphasis on the liberalisation of public
transport is necessary in order to ensure a high standard of
service for the public for less outlay by the public exchequer.
Competitive tendering in the transport market can help reduce
the requirement
for public subsidy. Franchised local bus
services, whereby operators bid competitively on routes deter-
mined by the local or regional authority is one example. The
relevant authority determines the quality of service and offers
contracts only on the conditions set out. The awarding of
transport contracts will free resources which can be used to
fund better public transport and make public transport more
efficient. Furthermore, privatisation and the involvement of
public private partnerships will ensure greater quality of service
which will be to the benefit of consumers. This should be a
priority in the Commission’s programme 2000-2004.

7.4.4.
In terms of the overall strategy that should be applied
in the view of the COR, linking into local passenger transport
networks is essential.
In its Opinion on Developing the
Citizen’s Network (1), the Committee of the Regions highlights

(1) CdR 436/98 fin — OJ C 198, 14.7.1999, p. 8.

23.12.1999

EN

Official Journal of the European Communities

C 374/81

the importance of local and regional authorities in public
passenger transport. It emphasised:

9. Recommendations

— the importance of a well-functioning local and regional
transport network to the proper functioning of a national
and European transport system;

— the economic, environmental and social value of an

efficient transport system;

— the necessity of flexibility allowing for the creation of an

integrated and intermodal system;

— that a properly functioning citizen’s network is central to

sustainable urban development.

8.

Improving External Effectiveness

The Community is anxious to be effective in the
8.1.
enlargement process and ensure the smooth integration of the
accession countries into the EU. The experience of the creation
of the internal market is helpful in the large task ahead of
identifying and adapting legislation. Already negotiations are
underway with third countries in the areas of civil aviation,
HGVs, coach services and inland waterways. In the longer
term, the Community will constantly review the operation of
the transport market and to do this the European Transport
Data System will monitor the impact of transport on regional
development, the environment and safety.

8.2.
In time, the regulatory framework will need to be
revised, especially to deal with changes to the State Aid
guidelines and the COR recommend greater simplification of
these regulations. The current structure can be cumbersome in
terms of administration and simplicity will ensure greater
efficiency and transparency. The TEN-T will need to be
further revised in line with enlargement developments and the
financial regulations must consider the specific needs of
applicant countries. In fact all the above areas will need to be
reassessed in light of enlargement. Furthermore, EU enlarge-
ment and development of transport networks within and
between new Member States must not compromise environ-
mentally sensitive areas of applicant countries.
If general
policies cannot guarantee the highest levels of environmental
protection,
the Commission should consider an ecopoint
system similar to the current Alpine regime.

9.1.
The COR wish to make the following proposals
in addition to the remarks made in connection with the
Commission’s communication. The following are supplemen-
tary recommendations to issues which the COR wish to be
considered in the framing of future common transport policy
which are not addressed in the communication.

9.2.
In line with the call made in the COR opinion on a
sustainable transport policy for local and regional authorities,
The COR re-emphasise the need for local and regional
authorities to be involved in all stages of the development of a
European Transport Policy. As local and regional authorities
are regularly called upon to co-finance transport projects,
there should be close involvement in policy formation to
ensure that local needs are considered and integrated.

the recommendations of

9.3.
Although the Community does not have competence
in the area of spatial planning, the Commission should ensure
that
the COR opinion on the
European Spatial Development Perspective are considered in
future policy development. As the COR opinion on a sustain-
able transport strategy pointed out an improved transport
system, as part of a programme of urban renewal, can be a key
factor in the economic and social regeneration of a deprived
urban area. Spatial planning is central to any sustainable
transport strategy as it can, among other things, reduce the
requirement to travel.

9.4.
The Commission has a role to play in the education of
the public towards a new approach for transport. Public
approval
is intrinsic to the success of any new policy.
Furthermore local and regional authorities are best placed to
communicate the messages of sustainability and environmental
protection to the citizens and close co-operation between the
two should be fostered to this aim.

Compulsory public consultation is a necessary require-
9.5.
ment in advance of the commencement of infrastruction
projects. These requirements can, on occasion, extend the
project lead in time resulting, in extreme cases, in the loss of
fund or the escalation of costs over budget. This problem
should be addressed by making the public consultation systems
more effective where possible, and at the same time protecting
the democratic rights of the citizen. This is an issue that the
Commission could address and propose solutions such as best
practice when drawing up future guidelines for the Common
Transport Policy.

9.6.
The Commission has a significant role to play in
attracting private investment into public transport. The Com-

C 374/82

EN

Official Journal of the European Communities

23.12.1999

mission could play a greater role when allocating funding or
framing proposals and projects to ensure that they address

inter alia, transport safety measures or research into cleaner
technologies.

Brussels, 16 September 1999.

The President

of the Committee of the Regions

Manfred DAMMEYER

Opinion of the Committee of the Regions on the ‘Proposal for a Council Directive amending
Council Directive 96/53/EC laying down for certain road vehicles circulating within the
Community the maximum authorized dimensions in national and international traffic and the
maximum authorised weights in international traffic’

(1999/C 374/18)

THE COMMITTEE OF THE REGIONS,

having regard to the list of Commission proposals pending on 1 May 1999 for which the entry into force
of the Amsterdam Treaty entails a change in the legal basis and/or procedure (SEC(1999) 581 final);

having regard to the Proposal for a Council Directive amending Council Directive 96/53/EC laying down
for certain road vehicles circulating within the Community the maximum authorised dimensions in
national and international traffic and the maximum authorised weights in international traffic (COM(1998)
414 final — 98/0227 COD ex-SYN) (1);

having regard to the Council decision, as notified by letter of 14 June 1999, to consult it on the matter,
under Articles 261 (first paragraph) and 71 of the Treaty establishing the European Community;

having regard to the decision taken by its Bureau on 15 September 1999 to appoint Mr Walsh (UK,
ELDR) as rapporteur-general, with a view to drawing up an opinion on the matter in accordance with
rule 39 of its rules of procedure,

adopted the following opinion unanimously at its 30th plenary session of 15 and 16 September 1999
(meeting of 16 September).

1.

Introduction

1.1.
Council Directive 96/53/EC deals with, amongst other
matters, the introduction of 44-tonne lorries onto Europe’s
roads. The European Commission proposal is to modify that
Directive to permit a range of vehicles over 40-tonnes all with
11.5-tonne drive axle weights for combined transport.

(1) OJ C 261, 19.8.1998, p. 13.

Notwithstanding its support for combined transport
1.2.
generally the European Parliament,
in its first reading on
15 April 1999, rejected the Commission proposal and request-
ed alternative options.

1.3.
The key question for local and regional authorities is
whether the proposed transport units will cause more damage
that
to road infrastructure and require strengthening of
infrastructure, notably bridges, insofar as local and regional
authorities have responsibilities in this area.