REPORT FROM THE COMMISSION TO THE COUNCIL on the Transit of Goods by Road through Austria
Date: 2000-12-21
Institutions: European Commission
Subjects: Austria, Union transit, carriage of goods, road transport, tradeable emission permit












EUR-Lex - 52000DC0862 - EN






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52000DC0862

REPORT FROM THE COMMISSION TO THE COUNCIL on the Transit of Goods by Road through Austria  /* COM/2000/0862 final */  









REPORT FROM THE COMMISSION TO THE COUNCIL on the Transit of Goods by Road through Austria1. Introduction and Current Situation1.1. Basis for the Report1.2. Definitions1.3. History of the ecopoint system1.4. Operation of the System1.4.1. General operation1.4.2. Lorries exempt from paying ecopoints1.4.3. Unauthorised transit journeys through Austria1.5. Current trends in traffic through Austria1.6. Developments in related areas1.6.1. Transit possibilities through Switzerland1.6.2. Road Pricing1.6.3. Possibilities for goods to transit Austria by rail1.6.4. The Mont Blanc Tunnel1.7. Achievement of the objective of the ecopoint system2. Developments in total NOx emissions in Austria2.1. Historical statistics2.2. Scenarios for years 2001 to 20032.3. Longer term forecasts2.4. Theoretical v actual emissions of NOx by lorries2.5. Total NOx emissions in Austria caused by lorries transiting the country.3. The environmental effects of road freight transport3.1. General aspects3.2. Noise3.3. Airborne pollutant emissions3.4. Congestion3.5. Effect of traffic in sensitive regions4. Conclusions and recommendations4.1. Conclusions4.2. Recommendations5. ANNEX I : the history of the ecopoint system6. ANNEX II : the operation of the ecopoint system6.1.1. The paper ecopoint system up to April 19986.1.2. The electronic ecopoint system6.1.3. The paper ecopoint system since April 19987. ANNEX III: pollution in Austria's alpine regions8. ANNEX IV : Statistical Tables1. Introduction and Current Situation1.1. Basis for the ReportProtocol No. 9 of the Act of Accession of the Kingdom of Norway, the Republic of Austria, the Republic of Finland and the Kingdom of Sweden [1] covers road, rail and combined transport operation in Austria. Articles 10-15 of the Protocol permit the operation of a regime to limit certain emissions from heavy goods vehicles transiting Austria. This regime shall have a maximum duration of until 31 December 2003.[1]  O.J. No. C241 of 29.08.1994, p. 361.However, Article 11(4) of the protocol requires that "Before 1 January 2001, the Commission, in co-operation with the European Environment Agency, shall make a scientific study of the degree to which the objective concerning reduction of pollution set out in paragraph 2 (a) [i.e. The total of NOx emissions from heavy goods vehicles crossing Austria in transit shall be reduced by 60% in the period between 1 January 1992 and 31 December 2003] has been achieved. If the Commission concludes that this objective has been achieved on a sustainable basis, the provisions of paragraph 2 [i.e. the operation of the ecopoint system] shall cease to apply on 1 January 2001".This report has, therefore, been written by the Commission services with the full assistance of the European Environment Agency [2].[2]   The European Environment Agency has produced a report entitled 'Road freight transport and the environment in mountainous areas' which complements this report. A full copy of this report can be found on the internet at: http://www.eea.eu.int1.2. DefinitionsFor the purpose of this report the term 'lorry' shall refer to- all lorries designed for the transport of freight with a maximum authorised weight of over 7.5 tonnes, and- all motor vehicles + trailer or semi-trailer combinations for the transport of freight where the trailer or semi-trailer has a maximum authorised weight of over 7.5 tonnes.Thus the term 'lorry' shall be synonymous with the type of vehicle to which, depending on its use, the ecopoint system applies.'Ecopoint system' is the name given to the regime for lorries transiting Austria.This report shall only look at the ecopoint system as used by the 15 EU Member States. In practice lorries from Norway, Iceland, Liechtenstein, Slovenia and Switzerland transiting Austria also use the ecopoint system.It must be emphasised that the ecopoint system deals with transit traffic by lorries through all of Austria: transit traffic in the Alpine areas of Austria, or in the Tirol region constitute only a part of the whole picture. This report seeks to look at the whole picture.1.3. History of the ecopoint systemFor a history of the ecopoint system see Annex I.1.4. Operation of the System1.4.1. General operationReaders of the report are assumed to be familiar with the general operation of the ecopoint system. However, a description of the working of the ecopoint system, in both the paper- and electronic format, is contained in Annex II to this report.1.4.2. Lorries exempt from paying ecopointsOne of the inconsistencies of the ecopoint system is that whilst all lorries produce NOx emissions not all lorries must pay ecopoints when travelling in Austria.The following lorries are exempted from having to use ecopoints:- all lorries with a maximum authorised weight of 7.5 tonnes or less;- all lorries making bilateral journeys to/from Austria;- all lorries circulating locally within Austria;- all lorries using ECMT [3] permits to transit Austria;[3]  ECMT = European Conference of Ministers of Transport- lorries registered in most Third Countries [4][4]  In practice there are some non-EU Member States that also use ecopoints in Austria. See paragraph 1.2.In addition, there are a limited number of categories of freight transport that are exempt from paying ecopoints when they transit Austria. These are listed in Annex C of Regulation 3298/94 [5] and cover specialist transport services which, quantitatively, account for few transit journeys.[5]   O.J. No. L341 of 30.12.1994, p.20The majority of lorries on Austria's roads do not pay ecopoints as they are making bilateral journeys or local journeys. It is argued that such traffic, unlike transit traffic, provides a benefit to the Austrian economy. Nonetheless, it is clear that such traffic contributes to pollution in Austria but does not face any quantitative restriction for so doing. It is also clear that the exemption of bilateral traffic from the ecopoint system creates a potential loophole in the system: transit journeys through Austria could become "interconnecting bilateral journeys" simply by trans-shipment of loads on Austrian territory.As mentioned above holders of ECMT permits are exempt from paying ecopoints when transiting Austria. Currently there are 752 ECMT licences held by hauliers registered in the Member States that are valid for use in Austria. Whilst the quantity of ECMT permits is small it should be noted that there is no quantitative limit on the number of times each permit may be used [6]. Unfortunately, even though ECMT permits take the form of a logbook that records journeys made there is no statistical record whatsoever of how often the permits are used to transit Austria. Given that some of the major transit routes through Austria are relatively short - the main Brenner/Inntal transit corridor is only 110km in length whilst the Hörbranz corridor between Switzerland and Germany is less than 10km - it is thus quite feasible for operators to use a single ECMT permit to make multiple transit journeys in a single day.[6]  Even if one assumes that each permit is used on average only once per week this would allow some 40 000 transit journeys per year: more than the basis on which ecopoints were allocated to ten of the fifteen Member States.It is also worth noting that whilst coaches are powered by large diesel engines and thus individually produce emissions comparable to lorries (see Annex IV, tables 9-14) they fall outside the scope of the ecopoint system and so can make unlimited numbers of transit journeys through Austria.1.4.3. Unauthorised transit journeys through AustriaUntil April 1998 systematic border controls meant that it was very difficult for lorries to make unauthorised transit journeys through Austria. There were instances of drivers attempting unauthorised transit journeys by using forged ecopoints but these were few in number.However, with the abolition of border controls on Austria's frontiers with Italy and Germany the management of the system shifted from one of systematic controls to one of random roadside checks. (Systematic controls still occur at Austria's external frontiers). Consequently it is now possible for unscrupulous hauliers to risk transit journeys without ecopoints in the hope that they are not caught.The scale of the problem is known. Lorries fitted with electronic ecotags are registered every time they enter and exit Austria. The central computer therefore records when a lorry fitted with an ecotag makes a transit journey when the haulier has insufficient ecopoints. Indeed, the lorry's ecotag also identifies the vehicle's registration as well as the number of ecopoints it should have paid for the transit journey. Some 4 percent of all transit journeys through Austria are recorded by the electronic system as unauthorised, resulting in the fraudulent non-payment of around half a million ecopoints per year. Statistics for unauthorised journeys by lorries fitted with ecotags are contained in Table 2b of Annex IV.There is no information on the number of illegal transit journeys made by lorries not fitted with ecotags.1.5. Current trends in traffic through Austria [7][7]  Readers are reminded that statistics for the use of paper ecopoints since April 1998 are highly understated. However, the overall statistics for EU-15 cover at least 97% of all transit journeys made under the ecopoint system.Annex IV contains statistical tables relating to transit traffic through Austria.Table 2a shows the total number of trips, by nationality, made each year [8] where ecopoints should have been paid. This shows that there has been year-on-year growth in the number of transit journeys by lorries through Austria since the inception of the ecopoint system in 1993. Indeed it can be seen that the upper threshold of 1 617 600 journeys (108% of the 1991 coefficient for EU-15) was clearly exceeded in 1999.[8]  In 1998 during the introduction of the electronic ecopoint system there was a one-month transition period during which most lorries transited Austria without paying ecopoints. Consequently statistics for the year 1998 are low. Where appropriate a correction factor of 12/11 has been multiplied to the statistics to simulate the missing data in order for better comparison of annual statistics. Where this correction is not appropriate the data has been left blank.The table also breaks down the statistics by nationality of lorries transiting Austria. Lorries registered in Italy and Germany make the most ecopoint trips, between them accounting for over two-thirds of all transit journeys. The third most-important country, as far as transit journeys through Austria is concerned, is Austria itself - in 1999 Austrian lorries accounted for some 15% of transit trips. Furthermore, transit traffic by Austrian lorries has grown by 58% between 1997 and 1999, compared to 13.1% for the EU as a whole.However, the statistics in table 2a also includes unauthorised journeys. Table 2b shows the number and proportion of transit journeys that were unauthorised. It can be seen that there are over 50 000 unauthorised transit journeys per year - averaging around 4 percent of all transit journeys through Austria. Hauliers making unauthorised transit journeys are evading the payment of some 500 000 ecopoints annually.Table 3 and graph 1 show the average number of ecopoints used per transit trip. This has been calculated as the number of ecopoints used divided by the number of authorised trips made (and thus does not include the unauthorised journeys listed in table 2b with their average of 0 ecopoints used per trip).From the table it can be seen that the EU average is reducing steadily and, in fact, more rapidly than the theoretical EU target. This means that the ecopoint system has resulted in even greater reductions in lorry emissions than expected.Between 1993 and 1999 average NOx emissions per lorry declined by 44.7%. Furthermore, if one starts from the theoretical base year of 1991 and compares this with the provisional statistics for the first half of 2000 (an EU average of 7.00 ecopoints per trip) this shows an improvement of 55.7% over the life of the ecopoint system to date.Given that each ecopoint is equivalent to the production of 1 gram of NOx it can be stated that the amount of NOx pollution made per lorry transiting Austria (and paying ecopoints) has reduced, on average, by at least 8% per year (though initial figures for the first half of 2000 indicate that the improvement has slowed down). This is a very impressive rate of development in the environmental performance of lorries.It should also be noted that the relative improvement in the emissions standards of lorries is broadly similar regardless of nationality.Table 4 shows the total use of ecopoints (and thus the total level of NOx emissions) made by EU lorries transiting Austria. The total ecopoint use by the 15 Member States can be seen to have declined by over 24% from 1995 to 1999. This represents a 24% reduction in absolute terms in the NOx emissions made by lorries transiting Austria over this period.The statistics in table 4 are broken down by Member States and also shows the total number of ecopoints that each Member State has received from - or given to the ecopoint reserve. Between 1995 and 1999 no less than nine Member States (Italy, Germany, Greece, Belgium, United Kingdom, Sweden, France, Luxembourg, Spain and Portugal) have been net beneficiaries from the EU Reserve, having received more than the 3.34% of their ecopoint allocation that they contributed to the reserve - in the case of Spain they have supplemented their ecopoint quota by over 80%, and France by over 30%.Tables 5a and 5b show the environmental profile of the EU fleet of lorries in terms of ecopoints used.It can be seen that the proportion of lorries paying the maximum 16 ecopoints per transit trip has gone down from over 51% in 1993 to under 2% in 1999. In contrast, the proportion of lorries paying 7 ecopoints or less has risen from under 1% in 1993 to over 78% in 1999. It is also interesting to note that as early as 1993 there were small numbers of lorries whose NOx emissions levels were so low as to require only five ecopoints per trip. This shows that lorry manufacturers can build-, and operators will buy lorries to an environmental standard higher than required by law. Graph 2 shows clearly in illustrated form the developments.1.6. Developments in related areasA major reason for the creation of the ecopoint system was that transport policies in other countries (both within the EC and Third Countries) were affecting the level of transit traffic through Austria. In this respect the ecopoint system cannot be looked at in isolation, but should be seen in conjunction with developments in related areas.1.6.1. Transit possibilities through SwitzerlandPrior to accession into the EU the maximum authorised weight of lorries transiting Austria was 38 tonnes. Following accession this rose to 40 tonnes. In contrast, in Switzerland the limit is 28 tonnes. It is clear that the significantly lower limit in Switzerland acts as an artificial barrier to fully laden lorries. Lorries wishing to transit the Alps with more than 14 tonnes payload [9] are obliged to detour around Switzerland. Studies have shown that this traffic is diverted via Austria and France in approximately equal quantities.[9]  For the purposes of comparison it is assumed that the unladen weight of a lorry is 14 tonnes.As a result the EU - Switzerland Agreement will have important consequences for the level of transit traffic through Austria. The Agreement will raise the weight limit for lorries in Switzerland, first to 34 tonnes from the date of its adoption and then to 40 tonnes from 1.1.2005. Furthermore, until full liberalisation in 2005 the EU will receive a limited number of permits (300 000 permits in 2001 rising to 400 000 permits by 2004) each valid for an individual journey at up to 40 tonnes through Switzerland. Such transit journeys will be subject to a distance-related fee linked to the emissions performance of the lorry: for a 40 tonne lorry this will range from EUR0,35 to EUR0,50 per tonne-kilometre.1.6.2. Road PricingClearly, one can expect that a significant number of alpine transit journeys that currently pass through Austria will revert to a more direct route via Switzerland as soon as the permits become available.The European Commission is committed to developing a fair and efficient Community road pricing system based on the principle that all external costs, such as air pollution, accidents, noise and congestion, are covered in costs - both in the form of road charges and fuel taxes - to be paid directly by the road user. These objectives are described in the Commission's Green Paper 'Towards Fair and Efficient Pricing in Transport' [10] and in the White Paper 'Fair Payment for Infrastructure Use' [11].[10]  COM 95/691 final[11]  COM 98/466 finalIt is reasonable to assume that the primary (and perhaps only) determining factor when a haulier selects a route will be the total cost of the journey (where time is also seen in monetary terms). Given that in many cases the cost for a lorry to transit Germany is significantly less than the cost to transit France it is clear that many hauliers undertaking journeys between northern and southern Europe will choose to go via Germany (and thus via Austria), not because this is the shortest route but because it is, in fact, the optimal route on grounds of cost.In this respect Austria is unable to influence the issue to any significant degree. Under EU law Austria, like all Member States, may not set road tolls at a level higher than that which reflects the infrastructure costs [12]. In practice, given the relatively short route distances on Austria's north-south transit corridors it is not feasible for Austrian road tolls alone to be sufficiently high to discourage transit traffic.[12]   ECJ ruling of 26 September 2000 (C-205/98): Commission v AustriaThere currently exists a harmonised European system that seeks to internalise "external costs" into the calculation of road use charges - the Eurovignette system. Under this system heavy goods vehicles are charged annual fees according to the damage caused to the environment and to road infrastructure. The charges are scaled according to emissions (EURO-standard) and vehicle size (number of axles) and range from EUR750 to EUR1550 per year. The system is restricted to six EU Member States (Belgium, Netherlands, Luxembourg, Germany, Denmark, and Sweden ) [13].[13]  Greece are allowed a 50% reduction in rates due to their geopolitical positionHowever, the Eurovignette system only partly achieves the core principle of fair and efficient pricing - that external costs are paid in full by the road user - since it is a fixed cost not linked to the annual distance driven per vehicle. Furthermore, as part of the Accession Treaty [14] Austria was obliged (from 1.1.1995) to bring the charges levied under its own system of road user charges into line with that of the Eurovignette. This had the effect of cutting charges by around 60 percent.[14]   Article 15 of Protocol No 9 of the Act of Accession.But the picture will change significantly if, as planned, Germany abandons the Eurovignette system and introduces road pricing for lorries. Under such a scenario a lorry travelling from Italy to Belgium, say, may then find it cheaper to transit via France than via Austria and Germany.1.6.3. Possibilities for goods to transit Austria by railIn addition to a fair pricing policy, which would reduce the demand of transport in general, a revitalisation of railways including combined traffic would lead to modal shifts from road to rail-based transport forms. Revitalisation can take place in the establishment of new freight freeways, but also in improvements in loading and unloading terminals to match modern-day customer requirements.Table 7a shows that transit traffic through Austria by rail has increased (by weight) by over 35% since 1991. In particular, the transport of lorries by piggyback on the train has grown by over 60% in the same period.Table 7b shows that the most important rail freight corridors through Austria are between Germany and Italy - accounting for 41% of all freight in tonnes - and between Germany and Hungary - accounting for 12%.Table 8 shows the additional capacity that, in theory, is available, for the transport of freight by train across Austria. One can see that an additional 36 million tonnes can be transported via the Brenner axis alone - this is equivalent to 1.5 million journeys by fully laden 40 tonne lorries.It should be noted that there is considerable additional infrastructure capacity to allow growth in freight traffic by rail for transit through Austria. That this additional capacity is not used in spite of the existence of the ecopoint system for several years would suggest that the ecopoint system in general, and the 108% ceiling on trips in particular, is not an incentive for freight transport undertakings to use rail to transit Austria. Rather, it would seem to suggest that the railway operators need to provide a better and more suitable rail service that will make transport undertakings more willing to use rail. In a market where there is an increasing demand for transport the provision of a better rail service should, in itself, ensure a growth in market share.Recently, various initiatives have been taken to improve the quality of service of rail and combined transport through Austria. Thus, since last year, combined transport operators and their railway partners are assessing the quality of combined transport through the Alps via commonly agreed standards and devise solutions to the perceived problems. Also, promising pilot projects have started. One aims to reduce the transit time Munich - Verona to six hours, and it is introducing a mid-day train to improve the offer. Its first results are encouraging. Another one aims at a better form of capacity management of combined transport trains, which would introduce differential pricing according to the time and punctuality requirements of customers. If these and other initiatives bear fruit, rail could indeed offer a true competitive alternative to road transport. Full use could then be made of the existing spare capacity.It is by such measures and not disincentives to use the road that modal shift of freight transport from road to rail will be encouraged. There is also a pan-European dimension to transit traffic by rail through Austria. A considerable volume of transit traffic through Austria is long distance north-south traffic that would go more directly by rail via Switzerland. Since freight transport undertakings choose to use road transport instead suggests that rail is probably unattractive elsewhere in the logistical chain, rather than through Austria. Indeed, it should be noted that disincentives to use the road in Austria may not result in modal shift to rail but rather increased road traffic through Switzerland following the EU-Switzerland Agreement  (see paragraph 1.6.1).In 2001 the Commission will present a report on international rail freight which will include the problem of alpine crossings.1.6.4. The Mont Blanc TunnelOn 24 March 1999 a disastrous fire occurred in the Mt Blanc road tunnel. Forty-one people died and the fire was so ferocious that the tunnel has remained closed for repairs ever since.Given that the Mt Blanc Tunnel was on the major road axis from France to Italy it was feared that its closure would result in additional diverted traffic making the journey between northern Europe and Italy via Austria. However, the effect has not been as significant as expected as the Frejus tunnel (also on a major route between France and Italy) has been able to cope with significantly increased levels of traffic.1.7. Achievement of the objective of the ecopoint systemThe objective of the ecopoint system is laid down in Article 11(2)(a) of Protocol No 9. It states:The total of NOx emissions from heavy goods vehicles crossing Austria in transit shall be reduced by 60% in the period between 1 January 1992 and 31 December 2003.On 1 January 1992 there was, in theory, 23 556 220 ecopoints available for EU-15. Since every ecopoint is equivalent to one unit of NOx the objective of the ecopoint system will therefore have been achieved if only 40% of this total - i.e. 9 422 488 ecopoints - are used in a calendar year.Current statistics show that in the first nine months of 2000 a total of 8 384 297 ecopoints were used. Based on this level of ecopoint use one can estimate that some 11.2 million ecopoints will be used in total in 2000. This is considerably above the figure of 9 422 488 ecopoints.Furthermore, the objective of the ecopoint system is only deemed to have been met in 2000 if it can be demonstrated to have done so on a sustainable basis. There is no evidence to show that the level of total emissions from lorries transiting Austria would remain stable if the ecopoint system were abolished on 31.12.2000.2. Developments in total NOx emissions in Austria2.1. Historical statisticsTotal NOx emissions in Austria from all sources have declined since 1990. According to the report of the European Auto Oil II Programme [15] a total of 212 000 tonnes of NOx was produced in Austria in 1990. This declined to 187 000 tonnes in 1995 and is forecast to be down to 157 000 tonnes in 2000. This represents an improvement of over 25% in a decade. This is slightly better than the improvement in the EU as a whole, where NOx emissions from all sources declined by 22% between 1990 and 2000.[15]  Reference to be addedThe same report also breaks down EU sources of NOx by sector. This shows that in 1990 transport accounted for 47% of total NOx production in the EU, but by 2000 this had declined to under 40%. Nonetheless, transport remains by far the largest producer of NOx.2.2. Scenarios for years 2001 to 2003If the ecopoint system continues until 31.12.2003 then the number of ecopoints for EU-15 will decline from 11.4 million in 2000 to 9.3 million in 2003. Thus, even if all ecopoints are used the NOx emissions of lorries transiting Austria in 2003 will still be some 20% less than the actual emissions in 1999. This improvement compares with the forecast in the Auto Oil II report that NOx emissions from road transport as a whole will be reduced by 35% over the period 2000-2005.2.3. Longer term forecastsThe Auto Oil II report predicts that NOx emissions in Austria will continue to decline. By 2005 a total of 126 000 tonnes of NOx is forecast to be produced. This will drop to 98 000 tonnes in 2010, 88 000 in 2015 and decline to 84 000 tonnes in 2020 - almost half of the current level of NOx production.As regards road traffic the Austrian authorities [16] estimate that transit traffic through Austria will grow from 25.3 million tonnes in 1994 to 57.9 million tonnes in 2015. This estimated growth rate of 4% per annum is faster than the 2.3% annual estimated growth of all freight traffic by road and would mean that transit traffic would account for 14% of freight on Austria's roads in 2015 compared with 10% in 1994.[16]  "Guterverkehr in Österreich", report of the Austrian Ministry of Transport, 28.11.97, p158, table 77Of the 57.9 million tonnes estimated to be transiting Austria the majority - 65% or 37.6 million tonnes - would be for journeys with both origin and destination in Western Europe.2.4. Theoretical v actual emissions of NOx by lorriesThe ecopoint system is based on the NOx emissions of a lorry during its type-approval certification procedure. It thus assumes that the emissions of a lorry remain constant during its working life.However, it does not follow that the actual emissions of a lorry bear little or no relationship to the theoretical test values. Clearly, a lorry will produce more emissions when fully laden and labouring up a steep hill then when it is lightly laden and proceeding along a flat road. However, European type-approval certification requires that engines undertake defined average test cycles. These replicate a series of different operating conditions and, as far as realistically possible, will even out differences to give a realistic average figure.Another issue is whether the emissions performance of a lorry deteriorates with age. A lorry's performance depends largely on the degree of maintenance it receives, rather than age per se. Perhaps surprisingly, tests show that there is no difference in the NOx emissions performance of a well-maintained engine compared to a poorly maintained engine.However, this is not the case for gaseous emissions in general. In this respect there exists European legislation that requires that lorries are examined at least once every year for their roadworthiness [17] and an integral part of the examination is a smoke test. Such testing is the most reliable way of ensuring that lorries are regularly maintained and thus stay within their design standards.[17]  Council Directive 96/96/EC of 20 December 1996 on the approximation of the laws of the Member States relating to roadworthiness tests for motor vehicles and their trailers. Published in Official Journal L46 of 17.02.1997, p.12.5. Total NOx emissions in Austria caused by lorries transiting the country.There is no accurate information on the amount of NOx pollution in Austria as a whole that is caused exclusively by lorries.What is known from general studies is that road transport is the biggest producer of NOx and that the major producer of NOx in road transport is diesel engines. This can be seen in Table 15 of Annex IV which details the total NOx emissions made in Austria by the transport sector. This clearly shows that whilst NOx pollution from transport as a whole in Austria is declining the proportion produced by heavy road vehicles is increasing. Indeed, in the period 1995-1999 NOx emissions from heavy road vehicles rose in total by 2 percent from 44 450 tonnes to 45 550 tonnes.However, for the period 1995-1999 it is known that the NOx emissions from lorries transiting Austria fell by 24 percent, since the consumption of ecopoints over this period declined from 15.6 million ecopoints to 11.9 million ecopoints (see Annex IV, Table 4).If total emissions by heavy road vehicles in Austria are not declining in line with the reduction in ecopoint consumption one must conclude that real reductions in NOx emissions from transit traffic is not being matched by that traffic that falls outside the ecopoint system - bilateral lorry traffic, local lorry traffic, tractors and buses.3. The environmental effects of road freight transport3.1. General aspectsRoad freight transport has experienced a substantial growth in the EU since the 1970s. In 1998 it accounted for a modal split of 73,7% compared to 47,9% in 1970. The increased share of road transport was at the expense of rail, inland waterways and pipelines. The total transport volume of freight transported by road in 1998 was 1.26 billion tonne/kms.Road freight transport has a significant effect on the environment. In 1995 lorries accounted for 22% of all transport CO2 emissions in the EU and 35% of acidifying emissions (NOx) from transport in the EU. Furthermore, 43% of particulate matter (PM10), which is currently a priority concern as it affects health, is generated by road freight transport in the Union. Even though fuel quality regulations and emission standards for lorries have become more stringent (and will continue to be strengthened following the Auto-Oil programme), compared to other land-modes (rail, inland waterways) transporting freight by road is still the least eco-efficient: lorries consume significantly more energy per tonne-km than rail or ship transportRoad freight is also the least efficient inland transport mode regarding emissions, as is illustrated for Austria in fig 1.Figure 1:Emissions of different modes of freight transport in Austria 1995&gt;REFERENCE TO A GRAPHIC&gt;&gt;REFERENCE TO A GRAPHIC&gt;&gt;REFERENCE TO A GRAPHIC&gt;The use of lorries is increasingly governed by the need for just-in-time deliveries, the rising value (as opposed to tonnage) of freight, the reduction of the average consignment size and the importance of costs other than fuel cost. The growth in road freight transport, and dropping shares of rail and inland waterways contribute significantly to the growing CO2 emissions in the sector.3.2. NoiseTraffic noise constitutes a serious problem in the Union [18]: it is estimated that about 120 million people in the EU (more than 30 % of the total population) are exposed to road traffic noise levels above 55 decibels. More than 50 million people are exposed to noise levels above 65 decibels.[18]  It should be noted that railways are also a major cause of noise pollution.The means of reducing the noise of the motor and drive train of lorries are now largely exhausted, although some limited improvements can be expected from secondary measures such as noise encapsulation.Far greater potential for noise reduction lies not in the lorry itself but in the tyre/road system. By using special tyres and road surfaces in combination noise levels can be halved. However, it is clear that whilst operators may be able to choose the design of tyre used on their lorries they have no influence on the infrastructure design.Within the Alpine region the morphological shape of the valleys ensures that noise emissions are intensified. Whereas soil and vegetation in lowland areas may dampen noise, sparse vegetation means this is not the case in mountainous areas.However, it should be noted that the ecopoint system is not a particularly good tool for dealing with noise pollution. Noise pollution is a localised problem and yet the ecopoint system is a general tool for dealing with transit traffic through Austria as a whole. It cannot limit traffic (and thus traffic noise) in specific areas where lorry noise may be a problem. For example in the Brenner valley lorries make some 1 million transit journeys annually and noise pollution is significant. However, the ecopoint system has no effect on the noise levels in the Brenner valley: indeed, it is perfectly permissible for the number of transit journeys via the Brenner to rise by 50% to 1.5 million per year and still stay within the quantitative limits of the ecopoint system.3.3. Airborne pollutant emissionsThe ecopoint system focuses on the gaseous emissions of lorries and, in particular, NOx emissions. NOx was chosen as the target indicator as it is generally accepted that improvements in NOx emissions will happen in parallel with similar improvements in other gaseous emissions.European legislation has been at the forefront in setting progressively stricter emissions standards for lorries. Directive 88/77 [19] laid down so-called 'Euro 0' standards for emissions in 1988. Improved standards became mandatory in 1992 (Euro 1) and again in 1995 (Euro 2) - both as a result of Directive 91/542 [20]. In 2000 a new set of norms [21] - Euro 3 - has become mandatory for new lorries. Lorries meeting Euro 3 norms will therefore have to pay a maximum of 5 ecopoints per transit journey The full requirements of Euro norms on gaseous emissions can be seen in Figure 3.[19]  O.J. L36 of 9.2.1988, p.33[20]  O.J. L 295 of 25.10.1991, p.1[21]  Directive 98/69/EU. Published in O.J. L 350 of 28.12.1998 p.1Figure 3: EURO EMISSION STANDARDSIn grams per Kilowatt-hour (g/kWh)&gt;TABLE POSITION&gt;As an indication of how great the reduction in gaseous pollution of individual lorries has been as a result of the mandatory "Euro" standards it should be noted that the "Euro 0" norm for NOx emissions in 1988 was 14.4g/kWh. Therefore, the NOx emissions of lorries have dropped by 65% over a period of 12 years (with similar reductions in CO and HC emissions).Furthermore, additional standards - Euro 4 and Euro 5 - are already planned. Euro 4, which should come into force in 2005, will see the maximum NOx emissions reduced to 3.5g/KWh, and Euro 5 should set an NOx limit of 2.0g/KWh from 2008.Particulate emissions can be dealt with in two ways. They can be minimised within the engine, or they can be collected after leaving the engine. The first approach requires that engines have catalytic after-treatment systems to reduce NOx emissions, whilst the second approach requires the use of particulate traps. Both systems work efficiently at present, but existing technology will have to be improved if the planned Euro 5 norms are to be met.Today a 40-ton lorry combination requires around 25% less fuel than on average in the 1980s. Clearly the more efficient that the motor of a lorry burns fuel then the fewer emissions - both gaseous and particulates - will occur.Unfortunately, one negative consequence of the ecopoint system as it currently operates is that it does not act as an incentive to develop ultra-low emission lorries. This is because of the existence of an upper ceiling on the number of journeys that may be made (the so-called "108% clause"). This clause can only come into effect if the average ecopoint use per lorry is better than was predicted back in 1991 (thus enabling more journeys with the same number ecopoints). Effectively, as the number of ecopoints is reduced by around 8 percent per year this is only possible if the environmental performance of lorries improves by more than that. Thus the "108% clause" acts as a disincentive to radically improving the emissions performance of lorries transiting Austria by penalising the large-scale use of very clean lorries. This is clearly contrary to the aim of a system that seeks to encourage environmentally friendly vehicles.3.4. CongestionLorries add to road congestion. Furthermore, some of Austria's motorways do suffer badly from congestion. However, it should also be noted that the greatest traffic congestion in Austria occurs on the A1 and A2 motorways on the approaches to Vienna and yet neither route are major transit corridors for lorries using ecopoints.3.5. Effect of traffic in sensitive regionsAs was already mentioned in chapter 1.3 Austria is susceptible to transit traffic in both north-south and east-west directions. In general, transit traffic heading in the east-west direction travels along the relatively wide Danube basin and the Hungarian plain. Neither of these areas have been defined as environmentally sensitive regions.In contrast north-south transit traffic is largely concentrated in a few Alpine valleys - the narrow Brenner, Tauern and Pyhrn valleys, and the somewhat wider Inn valley. The Alpine region of Austria with, on the one hand its high biodiversity of species and habitats and, on the other hand, the pressures from human activities, can be described as environmentally sensitive.Table 9 in Annex IV shows the volume of ecopoint traffic on the major corridors. From this one can see that around 60% of transit traffic passes via the Brenner Pass, and a further 10% via the Tauern and Pyhrn passes combined. East-west Traffic (on the so-called Donau corridor) accounts for less than 10% of all ecopoint journeys.Therefore, one has the situation where the greatest volume of transit traffic is passing through the most environmentally sensitive region of Austria. However, the operation of the ecopoint system is such that it applies to the entire Austrian territory. It is therefore not possible to limit traffic by means of the ecopoint system in sensitive regions or on particular corridors. Indeed, it is theoretically possible that transit traffic on the Brenner pass, say, could increase by a further 500 000 trips per year and still stay within the limits of the ecopoint system.Oxides of nitrogen resulting from emissions from diesel engines have a toxic effect on plants. However, NO gases emitted directly from diesel engines are not harmful - rather, it is when it oxidises (generically described as NOx) that it becomes a pollutant. For this reason it is possible to see healthy plant life living alongside roads whilst the oxides of nitrogen are forming (and therefore polluting) some distance from the road.The morphological shape of the Alpine valleys (U- or V-shape) and the narrowness of these valleys ensures that emissions from combustion cannot escape and therefore the situation of ambient air pollution along these valleys is often as bad as in urban areas. The meteorological particularities in Alpine valleys (little wind bringing fresh air, localised wind systems, higher amounts of precipitation along the northern side of the Alps and therefore higher deposition of pollutants) impede the transportation and breakdown of pollutants. These meteorological conditions result in concentrations of nitrogen oxides in the ambient air in mountainous areas being three times higher than in lowland areas with the same traffic levels.Furthermore, in narrow valleys temperature inversions can form during the night. This means that a layer of warm air sits on top of cooler air below it. The result is that the warm air acts as a blanket stopping pollution escaping. Thus if pollution sources remain high when a temperature inversion takes place then the effects can be very significant. An extreme example is the famous London fogs that occurred when temperature inversions would prevent emissions from coal fired homes and power stations from dissipating, with very serious consequences.In Austria's alpine valleys there is no pollution source to create similar problems to that experienced in London in the past. However, temperature inversions have the effect of increasing the polluting effect of vehicle emissions by up to 6-fold in mountainous areas in summer during night-time compared with daytime. In this regard it should be noted that Austria has strict rules on night-time driving by lorries. Whilst not solving the problem the night-time lorry ban will help in reducing the environmental problems resulting from temperature inversions.Ambient air quality in the Alps is also degraded by long-range air pollution, i.e. by plumes of ozone and nitrogen oxides from outside the Alpine area. The long-range air flows from the peripheral alpine areas as the Po plateau, the Danube corridor, the conurbation of Munich or the Rhône-Saône corridor are an additional source of air pollutants that have to be added to the already considerable concentration caused by local emissions (i.e. NO2, ozone).Annex III looks specifically at the effects of pollution in Austrian alpine valleys4. Conclusions and recommendations4.1. ConclusionsThe purpose of this report is to ascertain whether the NOx pollution made by EU lorries transiting Austria has both reduced by 60% over the period 1991-2000 and has done so on a sustainable basis.A 60% reduction would result in fewer than 9 423 000 ecopoints - 40% of the 1991 level for EU-15 - being used in 2000. Given that consumption of ecopoints is highly likely to exceed 11 million ecopoints in 2000 then the conclusion is that the first objective has not been achieved. It is therefore not necessary to consider if the second objective - sustainability of reduction - has been met. In any case there is no evidence to show that the reduction in NOx emissions would be sustainable should the ecopoint system be abolished.Nonetheless, the ecopoint system has had a very positive effect on encouraging road hauliers with lorries registered in the EU to use environmentally friendly lorries to transit Austria.Unfortunately, actual reductions in NOx emissions from lorries transiting Austria do not appear to be matched by lorries driving on Austrian territory but which are not subject to the ecopoint systemIn this regard it is clear that the majority of lorries on the road in Austria at any given time are not subject to the ecopoint system. Under such circumstances it is therefore unrealistic for lorries transiting Austria to be held solely, or even primarily, responsible for traffic pollution on the territory as a whole. However, it is clear that transit traffic is the significant cause of pollution in specific areas, most notably in the Brenner Valley.Similarly the ecopoint system is based on the premise that the entire territory of Austria is environmentally sensitive and that all transit journeys across it - regardless of their length and routing - are equally damaging to the environment. This is clearly not the case. The environmental effects of transit traffic in the Brenner valley are different from those made by the longer, but less numerous transit journeys via the Danube plain, or the very short transit journeys through Austria between Germany and Switzerland. Unfortunately the ecopoint system is not designed to differentiate according to the environmental sensitivity of the route. This argument is true for both airborne pollutants and noise pollution.The above points highlight that the ecopoint system is a broad tool for limiting pollution by lorries transiting Austria as a whole. It is not designed to effectively solve local environmental problems within Austria. Whilst it is therefore not realistic to expect the ecopoint system to solve such problems the European Commission should examine ways in which the specific environmental concerns arising from road traffic may best be addressed in Austria.Thus, the Commission should, in conjunction with the Austrian authorities, examine localised environmental problems in Austria caused by heavy vehicles with the aim of highlighting the specific problems and suggesting ways to alleviate the situation. Furthermore, before the expiry of the ecopoint system the European Commission should undertake a study to consider how any environmental gains that have accrued from the operation of the ecopoint system can be preserved on a sustainable basis.Another major inconsistency of the ecopoint system is the upper limit on the number of transit trips that may be made in any year - the so-called "108% clause". This clause can only apply if the overall environmental performance of lorries improves by more than 8% per annum. However, since the aim of the ecopoint system is to encourage hauliers to use more environmentally friendly lorries when transiting Austria it is hard to justify a sanction that actually arises from lorries being "too green".It should be noted that the deterrent effect of the 108% clause has negative consequences throughout Europe, not just in Austria. Many lorries making transit trips through Austria are undertaking long journeys through several countries. The environment in all these countries will benefit from the use of the most environmentally friendly lorries. This benefit is lost as long as the 108% clause of the ecopoint system exists since it offers no incentive for operators to opt for the most environmentally friendly lorries.Furthermore the sanctions that arise from the "108% clause" are disproportionate. In 1999 the 108% clause was exceeded by some 100 000 journeys, but the resulting sanction requires a cut in ecopoints that is equivalent to a reduction not of 100 000 journeys, but rather some 150 000 trips.Under such circumstances the Commission cannot justify that the 108% clause should continue.However, it is also clearly disproportionate that 4 percent of lorries are transiting Austria in an unauthorised manner (i.e. without ecopoints) without any consequences if they are not detected by a roadside check when on Austrian territory. The Commission notes that the electronic system identifies lorries fitted with ecotags that make unauthorised journeys yet Member States appear unwilling to take any form of action against these hauliers. The Commission does not have the power to act against the hauliers, but Member States need to accept some responsibility for the actions of those of their hauliers who blatantly disregard the law.The ecopoint system should, therefore, be revised to apply some form of sanction against Member States proportional to the number of ecopoints not paid by hauliers when making unauthorised transits of Austria.The majority of lorries on the road in Austria are not covered by the ecopoint system. The Commission notes with concern the absence of any statistical information concerning one category of transport that is exempt from payment of ecopoints, namely lorries with ECMT permits. The absence of such information is contrary to proper management of a permit system. The Commission would also question whether the use of ECMT permits for journeys made wholly within the EU are anachronistic, given the existence of a Single Market.Member States therefore should consider the system of ECMT permits that appears to be in need of reform, as far as intra-Community traffic is concerned.Road is not the only mode of transport for freight to transit Austria. Indeed, the river Danube provides a major inland waterway route for east-west traffic. However, it must be concluded that, whilst additional railway capacity may exist for transit through Austria it is not proving attractive - not even for Austrian hauliers who would be expected to have the greatest opportunities for business relationships with the Austrian national railways. The European Commission shall undertake a study to examine the role of the railways in transporting freight through Austria [22]. Furthermore, if additional railway capacity through Austria has been provided but is not being utilised it is for the railway operators to come up with a better rail service to attract additional customers - it is not sufficient to expect road freight to be forced onto the railways by arbitrary rules such as the 108% clause. Rather, railway operators need to take the necessary steps to improve the attractiveness of rail freight services through Austria;[22]  To be undertaken as part of the report on international rail freight to be presented by the Commission in 2001.4.2. Recommendations* The ecopoint system continues in operation until 31 December 2003;* The opportunity is taken to revise the system by removing the upper ceiling on trips per year (the "108% clause") without prejudice to the primary goal of the ecopoint system, namely a 60% reduction in emissions. This shall be done by means of a Regulation that amends Protocol No 9 accordingly.5.  ANNEX I : the history of the ecopoint systemThe ecopoint system came into existence as a direct consequence of the geographic position (and geography) of Austria and the historical development of road transport in Western Europe.Lying immediately between Italy and Germany and also on a major corridor to Eastern Europe Austria is thus susceptible to transit traffic in both north-south and east-west directions.Furthermore, the geography of Austria's alpine areas encourages north-south travel along alpine valleys whose fragile ecosystems particularly susceptible to the negative effects of transport pollution.The long-term growth in the transport of freight by road has been exacerbated in Austria by the policy of artificially low weight limits for lorries in Switzerland that has resulted in considerable additional traffic being diverted via Austria.The environmental concerns in Austria resulted in a desire for action to reverse the deteriorating environmental situation caused by transit traffic.On 2 May 1992 an Agreement between the European Economic Community and the Republic of Austria on the Transit of Goods by Road and Rail [23] was signed. Article 15 of the Agreement stated that "the Parties agreed to reduce the emissions and noise generated by heavy goods vehicles crossing Austrian territory in transit. Such a reduction shall be achieved by cutting NOx emissions" [24]. It went on to say that "total NOx emissions from heavy goods vehicles with a laden weight of 7.5 tonnes registered in one Party [i.e. either in one of the 12 Community Member States or Austria] and crossing Austria by transit shall, starting in 1992, be reduced by 60% in the twelve year period until the end of 2003".[23]  O.J. No. L373 of 21.12.1992, p. 6.[24]  NOx is a collective term for all the oxides of nitrogen.Thus an overall limit on total NOx emissions was calculated for the year 1991 and this is reduced on a linear basis by a total of 60% until the end of 2003.As a safeguard to ensure that technical progress in the development of cleaner engines did not make the ecopoint system ineffective the Agreement also laid down a quantitative limit of 108% of the journeys made in 1991. If this limit was exceeded then the number of ecopoints made available the following year would be revised downward by a formula, laid down in the Agreement.The distribution of ecopoints amongst the Member States was laid down in Council Regulation (EEC) No. 3637/92 [25]. Not only did this Regulation fix the proportion of each year's ecopoints that every country would get, it also created a "Community Reserve", whereby each Member States puts 3.34% of their national ecopoint allocation into a reserve which is then used to alleviate shortages.[25]  O.J. No. L373 of 21.12.1992, p. 1.In 1993 during preliminary meetings on accession Austria confirmed that they wished the ecopoint system to continue in its entirety after their accession into the European Union. Therefore, as part of the accession negotiations, the ecopoint system was added to the Treaty of Accession as Protocol No. 9 as a derogation from the workings of a Single Market. This was adopted unanimously by the EU Member States and came into force on 1 January 1995. Simultaneously the ecopoint system was revised (by means of Regulation 3298/94) to include Sweden and Finland for the first time and to take into account the revised status of Austria as a Member State - in particular, its obligations to contribute to- and possibility to benefit from- the Community Reserve of ecopoints.Since the accession of Austria, Sweden and Finland Regulation 3298/94 has been amended three times, by Commission Regulation (EC) No. 1524/96 [26], Commission Regulation (EC) No. 609/2000 [27] and Council Regulation 2012/2000 [28].[26]  O.J. No. L190 of 31.07.1996, p. 13.[27]  O.J. No. L73 of 22.03.2000, p.9[28]  O.J. No. L241 of 26.09.2000, p.186. ANNEX II : the operation of the ecopoint systemThe ecopoint system operates by means of annually producing a number of ecopoints which is equivalent to the number of trips made in the base year (of 1991) multiplied by the NOx target average for the year in question. Originally the ecopoints only took the form of adhesive paper stamps but from 1 January 1998 a telematics-based electronic ecopoint system was introduced to facilitate the operation of the system within the framework of the abolition of border controls at the inner borders of Austria.The ecopoint system works by requiring each heavy goods vehicle to "pay" a number of ecopoints for each transit journey through Austria, where one ecopoint corresponds to the emission of 1 gram of NOx per kilowatt hour(kWh) of a lorry. Thus, for example, a lorry with an emission level of 8 grams NOx /kWh would have to use 8 ecopoints to make a single transit journey across Austrian territory.For lorries built on or after 1 October 1990 the information on the lorry's emissions level is known from the type-approval documentation (issued when the lorry is manufactured). It is for each Member State, usually in co-operation with lorry manufacturers or importers, to then issue a lorry with a "Conformity of Production" (COP) Document which states the NOx value and ecopoint liability. For lorries built before October 1990 (for which no recognised type-approval information on the lorry's emissions exists) or when a lorry has not been issued with a COP document (or when the driver does not present a COP document at the border) a "default" of 16 ecopoints must be paid for a transit journey. The possibility exists to get a new COP document for a lorry that receives a replacement engine that produces fewer NOx emissions than the original.The proportional distribution of ecopoints between the Member States is fixed. The distribution key (including the establishment of a Community Reserve) was laid down in Regulation 3637/92 and can be seen in Table 1a of Annex IV. This was subsequently amended (due to enlargement) by Regulation 3298/94 and due to be revised again (see footnote 6). Table 1b shows the revised distribution key.In addition to the mandatory 3.34% contribution of ecopoints each Member State makes into the Community Reserve each country is also obliged to return ecopoints that would be unused to the Community Reserve for redistribution as a solidarity measure to help countries with ecopoint shortages. The Commission formally holds the Community Reserve of ecopoints and distributes it subject to the approval of a Management Committee.Ecopoints are valid for 13 months, from 1 January to 31 January of the following year. This ensures that hauliers making round-trips at the end of the year can do so without the need for two different sets of ecopoints. Apart from this one-month overlap unused ecopoints may not be carried over from one year to the next. In the paper ecopoint system the year is printed on the ecopoint stamps in order to give them a finite life. In the electronic system the programme refuses to use ecopoints after their expiry date. [29][29]  As a result of the one-month carryover period ecopoint statistics do not always reconcile. For example it is possible for more ecopoints to be used in a particular year than were issued, simply because a large number of ecopoints from the previous year were used in January.Until April 1998 the ecopoint system was totally a paper-based system. Since 1 April 1998 the system has been primarily electronic telematics-based but with some paper ecopoints.6.1.1. The paper ecopoint system up to April 1998In the paper system ecopoints are affixed to a standardised triplicate form known as the ecocard. Until April 1998 the completed ecocard would then be presented to the control authorities upon entering Austria, along with the COP document of the lorry (to justify the number of ecopoints used). The control authorities would then stamp the ecocard and keep one copy of the ecocard (with the affixed ecopoints). The driver would have the stamped ecocard as proof of payment of ecopoints and would surrender a second copy to the control authorities when exiting Austria (and keeping the third copy of the ecocard for the haulier's records).6.1.2. The electronic ecopoint systemA major problem for continuation of the ecopoint system after Austria's accession to the EU was the fact that the paper ecopoint system required systematic border controls to collect and stamp the ecocards. Yet such controls would not be permissible in a Europe without frontiers.As a condition of allowing the ecopoint system to continue after accession Austria therefore agreed to construct an electronic telematics-based ecopoint system that would be able to function without the need for lorries to stop at the frontier. This system came into operation on 1 April 1998, to coincide with Austria's abolition of internal border controls.When creating the electronic ecopoint system there were several possible ways of designing its operation. Consultation showed that it was the wish of the Member States that the system be designed so as to minimise the cost of equipment that hauliers would have to install in their lorries.Thus lorries wishing to use electronic ecopoints are fitted with a rather simple and unsophisticated electronic tag (or 'ecotag'). This tag uniquely identifies the lorry and is programmed with the details of the lorry's COP document (and thus the number of ecopoints needed per trip).The ecotag is affixed to the windscreen of the lorry (enabling it to be read by microwave beacons located either at the side of the road or overhead). When entering Austria the driver must then push a button on the ecotag to inform the system if the journey is one where ecopoints shall be paid, or not. The beacons can read the ecotag of a lorry without the need for it to stop or even slow down.The ecotag itself does not contain information as to whether the lorry has the prerequisite number of ecopoints to make a transit journey. Rather this information is stored in the central computer of the ecopoint system. It is thus for the haulier to ensure that their "account" (in the computer) has sufficient ecopoints to permit an ecopoint journey. If this in not the case the ecotag may be electronically marked ('flagged') to enable the control authorities to see that the lorry is travelling on Austrian territory without ecopoints. This makes the lorry more likely to be controlled but, of course, the driver will have the possibility to demonstrate why he/she is travelling without ecopoints (for example making a bilateral journey or an ecopoint-exempt transit journey). This method of operation is a direct consequence of the design restriction on the ecotags to make them as inexpensive as possible.Over 95% of the EU ecopoints are in electronic format (in 2000 the precise figure was 95.24%). Not only does the electronic ecopoint system make management of ecopoints easier it also results in extremely detailed and up-to-date statistics on the use of those ecopoints [30].[30]  As a comparative example under the paper system no accurate statistics were available for transit journeys made by Portuguese and Spanish lorries. This was because on the handwritten ecocards the origin country of the lorry was sometimes illegible and thus P and D, and E and I were misread.6.1.3. The paper ecopoint system since April 1998Before the partial abolition of Austrian border controls the frontier authorities cancelled all ecopoints and simultaneously collected a copy of the ecocard.Today this approach still applies for lorries making transit journeys via Austria's external border. For lorries transiting via Austria's internal borders ecopoints must be self-cancelled by the driver in machines located at all major Austrian frontier points. The ecocards are then controlled by means of random checks of lorries when on Austrian territory.It was agreed (and laid down in Regulation 1524/96) that the overwhelming majority of transit journeys should use electronic ecopoints but that a small quantity of ecopoints could remain in paper format. This pragmatic approach was to enable lorries that make occasional transit journeys through Austria to avoid having to buy and install ecotags. The quantity of ecopoints that may be in paper format is limited to 0.6% of the annual EU total per Member State, which approximates to some 9000 trips per Member State.In practice this means that eight Member States, whose ecopoint allocations are based on less than 9000 trips per year may have their entire ecopoint allocation in paper format [31], whilst seven Member States must take the majority of their ecopoints in electronic form [32].[31]  The eight Member States who can have ecopoints wholly in paper format are:[32]  The seven Member States who must take a majority of their ecopoints in electronic ecopoints are:Since April 1998 the major transit route through Austria (between Italy and Germany) does not involve passing an external border. In the absence of systematic controls a large percentage of used paper ecopoints were never collected. As a consequence statistics for ecopoint use for those eight Member States that use only paper ecopoints are so low as to be meaningless (and have been denoted with the abbreviation "n/k" - for "not known" - in the statistical tables of Annex IV). However, given that paper ecopoints now account for less than 5 percent of the total EU ecopoint allocation this is not a significant distortion of the statistics for EU-15 as a whole.7. ANNEX III: pollution in Austria's alpine regionsTransalpine freight transport, particularly freight transport by road has experienced an undiminished growth in the last twenty years. The modal split of road freight transport is still growing despite measures taken in the Alpine Region to improve rail infrastructure. Since lorries are responsible for a significant share in emissions from road transport, growth in road freight transport means that NOx and CO2 emissions from lorries are off-setting reductions in emissions achieved by passenger transport.Among all the major transalpine routes, the most freight travels via the Brenner valley (fig. 1a). On the Brenner route a substantial growth of the road freight transport has been seen in the past decades.figure 1a: Distribution of transalpine freight transport on the different routes in 1998&gt;REFERENCE TO A GRAPHIC&gt;&gt;REFERENCE TO A GRAPHIC&gt;Source: UVED/GVF (1999)figure 1a: Development of transit freight transport on the Brenner from 1960 to 1999&gt;REFERENCE TO A GRAPHIC&gt;Source: BMVIT (2000); Molitor et al. (1997); UVED/GVF (1999)Ambient air qualityRoad traffic is responsible for about 80% of the nitrogen oxide emission in Tirol. Road freight transport contributes to a substantial share to the nitrogen oxide emission.In 1999 the nitrogen oxide concentration experienced a growth compared to 1998. The average annual nitrogen oxide concentration exceeds on nearly all measurement points in Tirol the new EU air quality standards of 0,030 mg/m3 (sum of NO and NO2) for the protection of vegetation. The EU air quality standards for the protection of human health (0,040 mg/m3) is exceeded near the motorways (A13 Gärberbach, A12 Vomp) and in urban areas (Innsbruck, Hall im Tirol).figure 2a: Average annual NO2 concentration, A12 motorway Kufstein - Innsbruck&gt;REFERENCE TO A GRAPHIC&gt;Source: Amt der Tiroler Landesregierung /Scheiring (2000)Measuring stations in the Brenner valley (at Plon) and in the Inn valley (at Vomp) located next to the A13 and A12 motorways respectively give detailed information on the levels of pollution caused by lorries. Tables 9 to 13 in Annex IV show the data for NOx emissions. Similar data on other emissions are collected.Tables 9 and 11 show the average NOx emissions according to vehicle type. This clearly shows that lorries are major producers of NOx. However, it is interesting to note that since lorries have become progressively cleaner than buses. Indeed, since 1998 the average NOx production per lorry is now actually lower than that of buses and is expected to remain so.The differences between tables 9 and 11 clearly show that the effects of pollution from lorries and buses is much greater in the narrow and hilly V-shaped Brenner valley than in the broad and flat-bottomed U-shaped Inn valley. (In contrast cars and motorcycles produce more NOx per vehicle in the Inn valley).Tables 10 and 12 give the relative values of NOx production per vehicle type, with 2000 as the base year. Both tables show the massive improvements in car emissions that have been achieved over 20 years. However, lorries are forecasted to have the greatest improvement over the next ten years. It is interesting to note that motorcycles are actually producing more pollution per vehicle in comparison with 1980 and that this trend is expected to continue.Tables 11 and 13 show the total NOx emissions measured in the Brenner and Inn valleys. It can be seen that total levels of NOx emissions peaked in the 1980s and are generally declining, though only gradually.The statistics identify from 1991 the total NOx emissions in both valleys specifically produced by lorries transiting through Austria. Both show no decline in total NOx emissions from ecopoints traffic. Indeed, in the Inn valley the proportion of NOx emissions created by transit traffic is expected to gradually increase to 40% by the end of the decade, whereas in the Brenner valley transit traffic accounts for two-thirds of all NOx emissions.It is clear from these tables to see the concerns over the levels of pollution directly resulting from transit traffic, especially in the Brenner valley.The effects of pollution are seen in the plant life of the Tirolean valleys. According to a biennial survey [33] the general health of trees in 1999 had deteriorated since the study in 1997. Whilst pollution from transit traffic cannot be solely blamed for this it is a contributory factor.[33]  Report "Zustand der Tiroler Wälder" by the Regional Government of Tirol, 1999. Available on the internet at www.tirol.gv.at/wald/waldzustandbericht.htmlThe annual nutrient deposition (nitrogen) in Tirol reaches levels of up to 30 kg/ha, which is in long term considered as critical for conifers and some three times higher than recommended limits. The consequence is a destabilisation of the eco system. A growing share of the forest and the protective forest is damaged. This is also shown in a decline in healthy lichens which are an excellent indicator of excessive levels of SO2 and NO2.The air quality standards for ozone (O3) for the protection of vegetation were exceeded in Tirol in 1999 from 160 to 220 days (according to measuring station) in the valleys and practically during the entire year in the mountains.Noise levelsNoise levels in the Brenner valley far exceed environmental quality standards. In order to illustrate the situation a section of the Brenner valley at Matrei is analysed in depth (fig. 4a). During night a large area of the settlements is subjected to noise levels in excess of 50 dB(A) either through road traffic or through rail traffic. It is obvious that road traffic is responsible for a larger share of the noise levels than rail, because of the relative traffic levels.figure 3a: Matrei am Brenner, area affected by noise levels above 50 dB(A)&gt;REFERENCE TO A GRAPHIC&gt;Noise affects people physiologically and psychologically: at noise levels above 50 dB most people are moderately annoyed, noise above 65 dB are detrimental to health (TERM).8.  ANNEX IV : Statistical TablesDistribution of ecopoints 1991 - 2003Table 1a: Original distribution key of ecopoints for EU-12 and EU-15Table 1b: Revised distribution key of ecopoints for EU-15 incorporating the cut in ecopoints 2000-2003Transit journeys made through Austria 1993-1999Table 2a: Number of Transit Trips through Austria, by Member State 1993-1999Table 2b: Unauthorised Transit Journeys through Austria 1998-2000Table 3: Average number of ecopoints used per trip, by Member State 1993-2000Table 4: Ecopoint use by Member State, 1993-1999Environmental profile of lorries transiting AustriaTable 5a: Ecopoints used per lorry, 1993-1999Table 5b: Lorries transiting Austria 1993-1999, according to European StandardsTable 6: Traffic flows on main transit corridors through Austria, 1997 and 1999Rail Freight transiting AustriaTable 7a: Total freight transiting Austria 1991-1999Table 7b: Major origins/destinations of rail freight transiting Austria 1991-1999Table 8: Additional rail freight capacity in AustriaNOx levels in Alpine Valleys from road trafficTable 9: Average NOx emissions per vehicle in the Brenner valley, 1980-2010Table 10: Average NOx emissions per vehicle in the Inn valley, 1980-2010Table 11: Relative NOx emissions per vehicle in the Brenner valley, 1980-2010Table 12: Relative NOx emissions per vehicle in the Inn valley, 1980-2010Table 13: Total NOx emissions from vehicles in the Brenner valley, 1980-2010Table 14: Total NOx emissions from vehicles in the Inn valley, 1980-2010Table 15: Total NOx emissions from transport in Austria