Opinion of the Economic and Social Committee on the "Proposal for a Regulation of the European Parliament and of the Council on the granting of Community financial assistance to improve the environmental performance of the freight transport system" (COM(2002) 54 final — 2002/0038 (COD))
Date: 2002-07-17
Institutions: European Economic and Social Committee
Subjects: EU financial instrument, EU programme, carriage of goods, environmental impact, freight rate

7.10.2002

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The Committee noted that defects would be graded on a scale
of 1 to 3. The Committee suggests that the directive should
require the various competent authorities to exchange infor-
mation on a quarterly basis on all defects in addition to
circulating information on the most serious defects.

English language: the Committee stresses the need for
4.6.
all crews to have a fluent command of the English language in
the interests of safety. This requirement should be included in
the ICAO standards.

4.8.
Competence of the European Aviation Safety Agency
(EASA). The Committee feels that responsibility for application
of the SAFA programme should in future be taken on by the
EASA.

4.9.
Entry into force. In view of its objective, the SAFA
procedure should enter into force as soon as possible. Whilst
the
appreciating the technical complexity of
Committee therefore suggests that the proposed period of two
years for implementation of the proposal for a directive be
reduced to 12 months.

the matter,

4.7.
The exchange of information between the competent
authorities and the Commission (Article 6) should be effected
as rapidly as possible using information technologies. The
authorities’ access to databases is essential.

— In this context it should be borne in mind that a proposal
for a directive relating to this area has been in existence
since 1997, so that the Member States have had five years
to adopt the necessary measures.

Brussels, 17 July 2002.

The President

of the Economic and Social Committee

Göke FRERICHS

Opinion of the Economic and Social Committee on the ‘Proposal for a Regulation of the European
Parliament and of the Council on the granting of Community financial assistance to improve the
environmental performance of the freight transport system’

(COM(2002) 54 final — 2002/0038 (COD))

(2002/C 241/07)

On 21 February 2002, the Council decided to consult the Economic and Social Committee, under
Article 71 of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
drawing up the Committee’s work on the subject, adopted its opinion on 19 June 2002. The rapporteur
was Mr Levaux.

At its 392nd Plenary Session (meeting of 17 July 2002), the Economic and Social Committee adopted the
following opinion with 124 votes in favour and one abstention.

1.

Introduction: Presentation of the proposal
Regulation

for a

1.1.
The European Commission’s White Paper of 12 Sep-
tember 2001 entitled ‘European transport policy for 2010:
time to decide’ provides for the replacement of the PACT
programme, which came to an end on 31 December 2001, by
a new programme to promote intermodality, to be known as
the ‘Marco Polo programme’.

mission Staff Working Paper entitled ‘Results of the PACT
programme 1997-2001’; the PACT programme has also been
the subject of an external evaluation covering the period 1997-
1999.

1.2.
This new programme takes account of the lessons
drawn from the PACT programme, as set out in the Com-

The main aim of the Marco Polo programme is to
1.3.
reduce road congestion and to improve the environmental
performance of the whole transport system by shifting part of

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the increase in the volume of freight from road transport to
short-sea, rail and inland waterway transport.

1.4.
As was the case with the PACT programme, the Marco
Polo programme intends to provide financial assistance to
commercial actions in the market for freight transport services.

1.5.
Unlike the PACT programme, however, Marco Polo
will foster modal shift projects in all segments of the freight
market, and not only in combined transport, which involves
the use of roads for the initial or final part of the journey.

The Marco Polo programme will give priority to
1.6.
international, rather than national, projects and will be based
on three main approaches:

— provision of start-up support for new, non-road freight
transport services, which should be viable in the medium-
term (‘modal shift actions’);

— provision of support for launching freight services or
facilities of strategic European interest (‘catalyst actions’);
and

— stimulation of cooperative behaviour in the freight logis-

tics market (‘common learning actions’).

1.7.
The main aim of the Marco Polo programme is to help
shift freight from the roads to other modes of transport. The
amount to be shifted will be equal to the anticipated growth
in international road haulage.

2. General comments

2.1.

Lessons drawn from the PACT programme 1997-2001

2.1.1.
The ESC has noted with interest the studies com-
missioned by the European Commission which were intended
to draw lessons from the PACT programme before it came to
an end on 31 December 2001.

The ESC notes that, although the abovementioned
2.1.2.
studies made it possible to draw on the experience gained
with the PACT programme when planning the Marco Polo
programme, there is no continuity between the two pro-
grammes. Actions launched under the PACT programme were
concluded at the start of 2002, without it being possible at
that time to foresee when new actions under the Marco
Polo programme could be presented, examined, adopted and
funded. As the Marco Polo programme is due to come into
force on 1 January 2003 (see Article 12 of the Regulation), the
first actions cannot be launched at the very best until sometime
in 2003. The ESC has, however, noted that the Commission

has made provision in its own budget for ‘mini invitations to
tender’ in the course of 2002 covering a total of EUR 2 million.
The ESC welcomes this solution but would point out that,
given the modest funding, it will regrettably not be possible to
ensure continuity between the two programmes.

2.1.3.
The ESC notes that the budgetary allocation initially
foreseen for the PACT programme was EUR 35 million over a
period of five years. This sum was likely to be used up by the
beginning of 2002, since, as the Commission points out, EUR
30 million had already been committed by 30 September
2001.

2.1.4.
The Commission indicates that it has been possible,
with the above-mentioned EUR 30 million and an average rate
of aid of 25 %, to fund actions totalling EUR 120 million.

2.1.5.
The ESC notes that the total amount of aid requested
was EUR 203 million, which, on the basis of an average rate
of aid of 25 %, would cover actions costing a total of EUR
812 million. The ESC wonders about the discrepancy between
the funding requested and the funding granted; this would
seem to indicate that the initial budgetary allocation for the
PACT programme was inadequate.

In Chapter 1 of

2.1.6.
the Explanatory Memorandum
(‘Lessons from the PACT programme 1997-2001’) the Com-
mission states in points 8 and 9 (‘Quantitative results’) that of
the 65 actions which were closed on 30 September 2001,
51 % were considered to be fully successful, 22 % were
regarded as partially successful and 27 % were deemed
unsuccessful. This therefore means that only one action in two
produced fully satisfactory results. The remaining actions made
it possible to pinpoint a number of weaknesses in the logistics
chain. Steps should therefore be taken to ensure that the Marco
Polo programme provides better results.

2.2.

External evaluation of the PACT programme 1997-2001

The ESC welcomes the fact that an independent
2.2.1.
external evaluation has been made of the PACT programme
for the period 1997-2000.

2.2.2.
The ESC does, however, wish to point out that this
evaluation covers the first half of the programme but does not
indicate the number of closed actions actually covered. (The
Executive Summary of the Independent Evaluation of the
PACT Programme in Annex I also fails to make this point
clear.)

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2.2.3.
The ESC does, however, assume that, bearing in mind
the delays in bringing the programme on stream in 1997 and
the 65 closed actions recorded on 30 September 2001, the
external evaluation was able to take account of a maximum of
30 or so actions of which, according to the Commission, an
average of one in two was fully pertinent.

2.2.4.
Under these circumstances, the ESC believes that
once it is possible to make a definitive appraisal of the whole
of the PACT programme, there should be a review of the
conclusions drawn from this external evaluation — which are
very important for the approach to be adopted in the Marco
Polo programme.

2.2.5.
Subject to this proviso, the ESC welcomes the fact
that the recommendations made at the end of the external
evaluation have been taken into account in the preparation of
the Marco Polo programme.

The recommendation that the funding of feasibility
2.2.6.
studies as precursors to operational projects be stopped seems
reasonable in view of the ESC.

The ESC believes that giving priority to financial aid
2.2.7.
for concrete actions in the form of, inter alia, start-up support
does, indeed, represent a more effective approach.

2.3. Current market developments and needs

2.3.1.
presented by the Commission.

The ESC has taken note with interest of the analysis

2.3.2.
The ESC is pleased to note that, when considering
the non-road transport modes which are to ease road freight
congestion, the proposal for a Regulation setting up the
Marco Polo programme attaches the same importance to rail
transport, short-sea shipping and inland waterways. In this
context,
the ESC points to the statistics quoted by the
Commission in its report of 2 May 2002 (1) on the application
over the 1996-1999 period of Council Directive 92/106/EEC
of 7 December 1992 on the establishment of common rules
for certain types of combined transport of goods between
Member States.

The 2 870 billion tonne-kilometres (tkm) of freight transported
in total
in 1998 are broken down as follows according to
transport mode:

— road transport:

— maritime transport:

— rail transport:
— inland waterway transport:

— pipelines:

1 255

1 167

241
121

87

Over the 1996-1999 period, the rail and inland waterway legs
of combined transport operations represented 26.5 % of road
transport operations by themselves over distances of more
than 500 kilometres.

The ESC shares the Commission’s standpoint with
2.3.3.
regard to air transport; this form of transport will not make a
substantial contribution to reducing congestion in road freight
transport in Europe. Air transport is, however, a mode which
can be justified for certain types of freight, for intercontinental
transport operations and for long-haul European transport
operations, the number of which will increase with the EU
enlargement.

The ESC takes the view that, in order to broaden the
2.3.4.
range of services provided, it would be appropriate not to fully
exclude air transport
from the Marco Polo programmes.
Provision should therefore be made, subject to conditions to
be defined by the Commission, for the possibility of funding
actions with a view to including air transport, in a subsidiary
capacity,
in the scope of the Marco Polo programme; one
example of such actions could be the installation of intermodal
handling facilities.

In an earlier opinion (2), the ESC pointed out in
2.3.5.
points 3.2 and 3.3 that road transport accounted for 74.7 %
of the European Union’s freight market and that rail transport,
inland waterways and pipelines accounted for 13.4 %, 6.8 %
and 5.1 % respectively. The ESC further pointed out in
point 3.4 of this opinion that: ‘taken together, rail, pipelines
and inland waterways currently carry a quarter of goods traffic
and have reserve capacity that could be expanded if they were
made to compliment each other better’.

The ESC is surprised that the Commission fails to
2.3.6.
mention the transport of products by pipeline; pipeline
transport does, however, make a significant contribution
to intermodal transport since, depending on the countries
concerned, it can carry up to three-quarters of the freight
carried by inland waterway transport.

2.3.7.
The ESC therefore takes the view that under the
Marco Polo programme it should also be possible to finance
actions for transferring freight from road transport to pipelines.

On the subject of intermodal road and short sea
2.3.8.
shipping transport, the ESC supports the Commission’s call
for the management and marketing of this form of transport
to be simplified through the development of one-stop shops
and, more generally, the establishment of ‘freight integrators’,
a new profession specialising in integrated goods transport
using all available modes.

( 1) COM(2002) 215.

(2) Opinion on the future of the trans-European inland waterway

network — OJ C 80, 3.4.2002.

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2.3.9. With a view to improving the image of short sea
shipping — in particular container shipping — and promoting
its use, it is undoubtedly necessary to publicise this mode, as
the Commission is advocating.

In the ESC’s view, more does, however, need to be
2.3.10.
done. The Commission should ask the Member States to
encourage central and regional administrations to make it their
standard policy to promote short sea shipping, rail and inland
waterway transport, whenever possible. The example set
by these public administrations would have an important
‘snowball effect’ on investment in materials and equipment for
alternative modes of transport and on the future choices of
private transport enterprises.

2.3.11.
Turning to rail transport, the Commission rightly
highlights once again the lack of interoperability in terms
of equipment, infrastructure, communications systems and
operational rules, which is standing in the way of a genuine
single market for rail transport.

2.3.12.
The ESC supports all the measures taken by the
Commission to harmonise conditions of access to rail infra-
structure in the EU and, on a general level, all measures which
permit optimal use of existing equipment.

2.3.13.
The ESC regrets, however, that the Commission
fails to point out on this occasion that the Member States and
regions concerned will have to grant very substantial funding
without delay in order to adapt, modernise and add to existing
rail infrastructure, such as infrastructure linking up to maritime
transport and inland waterway transport; it is only by optimis-
ing such infrastructure that it will be possible to meet the
challenges which it currently has to face. The Member States
and the regions concerned must, therefore, do more than voice
their good intentions; they need to jointly provide the funding
required to achieve their goals.

Turning to inland waterway transport, the ESC is
2.3.14.
pleased to note that this form of transport plays a full role in
the Marco Polo programme.

2.3.15.
In its recent own-initiative opinion referred to
above (1), the ESC drew the attention of the Council and the
European Parliament to the need to enhance the utilisation
capacity of inland waterway transport, as part of intermodal
transport, by removing bottlenecks, as in the case of rail
transport.

( 1) See footnote 1.

2.3.16.
The ESC also suggests that the Commission pro-
mote the development of a multimodal transport by com-
missioning, for users, a ‘European Guide’ to all multi-modal
platforms. This guide could indicate the characteristics of the
various platforms, including maritime ports, inland waterway
ports and a number of airports. The document on multimodal
platforms in the individual Member States, which has been
provided by the Commission and which is appended to this
opinion, represents a first step towards drawing up a ‘skeleton’
list of these facilities, on the basis of which the proposed
European Guide could be drawn up.

2.4. The Marco Polo programme

The Commission draws attention to the fact that, if
2.4.1.
no action is taken, road freight transport in the EU will increase
by approx. 50 % by 2010. This represents an additional
60 billion tkm. Cross-border road transport between EU
Member States, alone, will double by 2020, i.e. there will be
an estimated increase of 12 billion tkm per year. The socio-
economic cost of the additional 12 billion tkm on roads has
been estimated at more than EUR 3 billion per year. It is
revealing to compare this figure with the EUR 23 million
annual budget for the Marco Polo programme.

In its White Paper of 12 September 2001 entitled
2.4.2.
‘European transport policy for 2010:
time to decide’ the
Commission set out 60 measures — including the Marco Polo
programme — for tackling the increase in transport volume.
The aim for 2010 is that the traffic share between the various
transport modes should be maintained at its 1998 level.

The ESC notes

the Commission is more
that
2.4.3.
ambitious in its proposal for a Regulation than in its White
Paper, since under the Marco Polo programme the Commission
hopes to maintain road freight at its current level and to have
the additional 12 billion tkm absorbed by other modes of
transport.

The ESC has already pointed out on a number of
2.4.4.
occasions that it fully supports the approach adopted by the
Commission. It does, however, note that the deadline of 2010
is becoming increasingly difficult to respect since it is barely
eight years away.

2.4.5.
The ESC therefore proposes that the Commission
draw up a timetable for the various measures to be taken by
all the parties involved with a view to achieving the goals and
respecting the deadlines set. Regular monitoring of the action

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taken, including the publication of an annual report, should
make it possible to identify any delays and their causes and
make up for lost time.

Should this not happen, the ESC believes that, in the
2.4.6.
absence of realistic deadlines, motivation is likely to flag.
That would be particularly detrimental, bearing in mind the
important issues at stake.

2.4.7.
The ESC is pleased to note that the Commission
points out that the Marco Polo programme will apply to all
segments of the freight market and that combined transport
will not be the only option taken into account.

2.4.8.
If the goals set are to be achieved, the ESC thinks that
all possible resources will have to be mobilised and nothing
ruled out.

2.4.9.
For this reason, the ESC fears that there may be some
confusion as to the Commission’s intentions since in points 44
the Explanatory Memorandum
and 45 of Chapter 3 of
(‘Delimitation to other support initiatives’) it makes a number
of apparently contradictory statements on the funding of
infrastructure. It is, in the ESC’s view, vital to ensure that
intentions and resources are in line with each other; to that
end, point 44 should be amended so that projects requiring
the establishment of ancillary infrastructure may be funded
under the Marco Polo programme provided that such infra-
structure promotes the transfer of traffic from the roads to
other modes. The ESC proposes that Regulation (EC) 2236/95
be amended with regard to the granting of Community
financial aid in the field of support networks for modal shifts
so that the aid for ancillary facilities is set at a higher rate than
the 20 % stipulated for transport TEN infrastructure projects.

The ESC recognises that,

2.4.10.
in the field of freight
transport at EU level, priority should be given to actions
involving several states. Difficulties in ensuring the continuity
and smooth flow of transport are encountered at the interfaces
between Member States’ systems and infrastructure. There are,
however, also isolated bottlenecks within Member States which
need to be removed as well. The ESC therefore requests that
the Marco Polo programme be able to finance support
measures within a Member State if such measures speed up
international traffic, especially on busy routes.

considerable flexibility advocated elsewhere by the Com-
mission in the management of this programme. The ESC
accepts that the viability of new regular maritime, rail and
inland waterway services may be linked to the load factor in
respect of the equipment used. For spatial planning reasons, it
is not, however, possible to judge how long such new services
may continue to be loss-making; what is required, above all, is
to stimulate the local market.

The ESC would also point out that the success of
2.4.12.
road transport can be attributed, inter alia, to three features
peculiar to road transport: speed, maintenance of deadlines
(reliability), and door-to-door service.

2.4.13.
These three features, taken together, have made it
possible to promote the development of the management
concept of ‘zero stockholding’. This concept now needs to be
called into question in favour of a concept which is more in
line with the modes of transport to be developed and which
could be called ‘stock in circulation’ management.

2.4.14.
The logistical possibilities now available make it
possible to ensure regular deliveries for users and to guarantee
that reasonable deadlines are met whilst, at the same time,
removing the abusive constraints imposed by the need for
urgency which characterises present-day management.

Catalyst actions:

2.4.15.
the ESC supports the Com-
mission’s desire to ‘attack core problems of running an
efficient transport chain’
(see point 55 of the Explanatory
Memorandum). The ESC does, however, note that all the
examples quoted by the Commission in point 58 of Chapter 3
of the Explanatory Memorandum require major investment.
This is the case, for example, with regard to:

— non-stop railway services, without changes of

loco-
motives, on railway networks which have yet to be
harmonised;

— the provision of inland waterway services between the
North Sea and the Black Sea; this would require a
continuous network of wide-gauge waterways;

— the introduction of high-speed goods trains; this would
require the availability of suitable equipment and net-
works, which do not exist at the present time;

2.4.11.
Start-up aid (modal shift actions): the ESC is sur-
limits set by the Commission in
prised at the empirical
point 50 of Chapter 3 of the Explanatory Memorandum (start-
these limits contrast with the
up aid for new services);

— the establishment of high-traffic density ‘motorways of
the sea’; this would make it necessary to redevelop
the ports situated on these ‘motorways’, including the
immediate land-side accesses.

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2.4.16.
Common learning actions: The ESC supports the
policy advocated by the Commission under which transport
enterprises using different modes are to be encouraged to
network in order to create synergies, which promote efficiency.

The Commission rightly stresses the importance of
2.4.17.
providing support for the dissemination of the results obtained
as this is a way of stimulating the replication of good ideas.
The experience — albeit too short — of the PACT programme
did, however, demonstrate the lack of replication, for a number
of specific reasons. The ESC takes the view that, as the concept
of sustainable development becomes more widespread, it may
reasonably be expected that there will a rapid change in
behavioural patterns, thereby making it possible to benefit to
the full from the common learning actions.

2.4.18.
The Committee endorses the approach adopted by
the Commission and recommends that, when actions are being
selected for assistance under the Marco Polo programme,
special attention be paid to their replication potential.

2.5.

External consultation

The Commission points out that it engaged in wide-
2.5.1.
ranging prior consultation before drawing up the proposal for
a Regulation.

2.5.2.
The ESC welcomes the attention paid by the Com-
mission to hearing the views of the parties concerned before
presenting its proposals. It does, however, regret the fact that
it was involved in this consultation process only at a late stage.

2.5.3.
The ESC therefore has to draw up its opinion within
a short deadline, without being able to have at its full disposal
the information gathered during the consultation phase.

3. Specific comments on the proposal for a Regulation

setting up the Marco Polo programme

3.1. Article 1 — Subject matter

3.1.1.
The ESC notes that the budget allocated to the Marco
Polo programme is EUR 23 million per year, which represents
a total of EUR 115 million over the programme’s five years.

3.1.2.
This amount is significantly higher than the EUR
35 million allocated to the PACT programme but much less

than the sum announced in the White Paper of 12 September
2001 entitled ‘European Transport Policy for 2010: time to
decide’; the White Paper envisaged a budget of EUR 120 million
for the Marco Polo programme over a period of just four years,
which represents EUR 30 million per year rather than EUR
23 million.

3.1.3.
In Chapter 6 the Explanatory Memorandum to the
proposal for a Regulation, the Commission points out that ‘[it]
is confident that a yearly budget of EUR 23 million should be
able to help shift an aggregate of 12 billion tkm of freight per
year ...’. The ESC is not convinced that this initiative, by itself,
will be sufficient to achieve this annual transfer target. The
ESC urges the Commission to point out in the preamble to the
Marco Polo programme Regulation that it is calling upon the
EU and the Member States to take the following additional
measures:

— to act without delay to strengthen inspections and
increase penalties in the event of infringements of labour
laws, so as to establish fair competition between the
various transport modes;

— to finance modal transfer infrastructure (e.g. terminals

and access infrastructure) from public funds;

— to demand that operators commit themselves to provid-
ing, on an ongoing basis, services of general
interest
created with assistance from the Marco Polo programme
or equivalent national programmes; financial assistance
should be provided, where necessary, to offset the cost of
meeting this demand.

The ESC would, however, reiterate that the Com-
3.1.4.
mission’s calculations are in part based on the findings of the
external evaluation of the PACT programme, the limitations
of which were highlighted in point 2.2 above.

(Chapter 6, Article 1,

3.1.5.
Furthermore, the ESC is surprised that, immediately
after having set a budget of EUR 23 million per year for the
Marco Polo programme which ‘should be able to help shift an
aggregate of 12 billion of tkm of freight per year during the
lifetime of the programme’
fourth
paragraph of the Explanatory Memorandum), the Commission
is
makes the following statement:
not attained, a quantified objective for the instrument will
substantially increase the possibilities for monitoring the
performance of the programme, and is thus,
in any case,
positive’. The fact that the Commission envisages the possi-
bility of the goal not being attained is not likely to enhance the
credibility of the instrument. The ESC therefore proposes that
this final sentence be deleted.

‘but even if

this goal

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3.2. Article 2: Definitions

two or more undertakings, established in at least two different
Member States ...’ would not apply in the exceptional cases
referred to in point 3.3.2.

3.2.1.
The ESC notes that action files are to be submitted
by a group (‘consortium’) comprising at least two enterprises
established in different states.

3.5. Article 5: Modal shift actions

3.2.2.
The ESC urges the Commission to stipulate that the
enterprises making up a consortium must not belong to the
same group and one of the enterprises must not be a subsidiary
of the other. It proposes that indent (f) ‘consortium’ of Article 2
Definitions be amended accordingly to read as follows: ‘‘con-
sortium’, means any formal or informal arrangement by which
at least two undertakings, which do not form part of the same
group and one of which is not a subsidiary of the other,
execute together and share the risk concerning, an action.’

3.5.1.
The ESC notes that modal shift actions shall ‘not lead
to unacceptable distortions of competition’ (Article 5(1)(c))
and may receive financial assistance ‘limited to a maximum of
30 % of all expenditure necessary to achieve the objectives [of
the actions]’. The ESC considers that the minimum subsidy
threshold per modal shift action, set at EUR 1 million, should
be reduced to EUR 500 000, in order to make it possible to
finance innovatory actions costing in the region of EUR
1,6 million.

3.3. Article 3: Scope

3.6. Article 6: Catalyst actions

3.3.1.
The ESC has already pointed out that the rules
stipulated in this Article are, in its view, too restrictive, insofar
as in their current form, they require the actions to involve
concrete measures linking the respective territories of the
states concerned.

The ESC does, however take the view that there may
3.3.2.
well be localised actions which affect one single territory —
and therefore one state only — but whose impact would
benefit all users of the relevant modes of transport passing
through the said territory. To quote an example, the develop-
ment of multimodal platforms should be eligible for consider-
ation under the Marco Polo programme since, even though
they are situated in a single territory, they may be used by
any international
the
transport enterprise,
enterprise’s territory of origin.

irrespective of

3.3.3.
The ESC urges the Commission to amend Article 3
of the Regulation in order to extend the range of actions
eligible for consideration under the Marco Polo programme by
making provision for justified exceptions to the rule whereby
actions have to involve the territory of at least two states.

The ESC calls for the amendment of Article 6(1)(g)
3.6.1.
of the proposal in order to include actions on all EU transport
networks and not just actions involving goods transported on
the trans-European networks.

3.6.2.
The ESC notes that catalyst actions may receive
financial assistance ‘limited to a maximum of 35 % of all
expenditure necessary to achieve the objectives of [the actions]’
(Article 6(3)). Expenditure on ancillary measures related to
infrastructure works are also to be reimbursable at the same
rate. The ESC considers that the minimum subsidy threshold
per catalyst action, set at EUR 3 million, should be reduced to
EUR 1,5 million in order to make it possible to provide
financial assistance in respect of innovatory actions costing
approximately EUR 4,3 million.

3.7. Article 7: Common learning actions

The ESC notes that the ceiling on Community
3.7.1.
financial assistance for common learning actions is to be 50 %
of all the necessary expenditure. It considers that the minimum
subsidy threshold per common learning action,
set at
EUR 500 000, should be reduced to EUR 250 000 in order to
make it possible to provide financial assistance for innovatory
actions costing EUR 500 000.

3.4. Article 4: Eligible applicants

3.4.1.
The ESC endorses Article 4, subject to account being
taken to the observation above with regard to the composition
of a consortium. The ESC does, however, point out that the
requirement for projects to be submitted by ‘a consortium of

Article 9: Submission of projects;

Article 10: Selection of projects

3.8. Article 8: Detailed rules;

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3.8.1.

The ESC endorses Articles 8, 9 and 10.

3.11. Article 14: Evaluation

3.9. Article 11: Committee

3.9.1.
The ESC notes that the Commission points out in
Chapter 6, Article 11 of the Explanatory Memorandum that
an advisory committee is to be set up but that,
in the
Commission’s view, there is no need to set up a management
committee in view of the modest budget allocated to the
Marco Polo programme.

The ESC is surprised at the Commission’s line of
3.9.2.
reasoning, which takes account only of the budgetary aspects
of the project but fails to underscore the importance of the
goals set, given the impact of the likely increase in road
haulage.

3.11.1.
The ESC notes that the Commission is to present,
by 31 December 2006 at the latest, an assessment report on
the results of the Marco Polo programme, which comes to an
end on 31 December 2007. The ESC highlights the lack of
continuity, which it deplored earlier, between the PACT and
the Marco Polo programmes.

3.11.2.
The ESC points out that, by setting the 31 December
2006 deadline for the presentation of an assessment report on
the results of the Marco Polo programme, the Commission
runs the risk of encountering the same difficulties as it
encountered with the PACT programme, namely that the
assessment would be based on a small number of closed
actions and that too little time would be left to prepare a new
programme for achieving the objectives by 2010.

3.9.3. Without wishing to call into question the rules which
have been adopted, the ESC calls for a management committee
to be given responsibility for carrying out a special monitoring
of the implementation of the Marco Polo programme.

3.11.3.
The ESC does, at all events, take the view that by
2006 or 2007 there will no longer be any point in introducing
a new programme of the same type as PACT or Marco Polo
since it will already be clear by then whether the targets for
2010 will be achieved.

3.9.4.
As indicated in points 2.4.5 and 2.4.6 above, the
ESC calls for the establishment of a timetable for identifying
the parties involved in the actions and monitoring the
commitments entered into which will shift the growth in road
freight between now and 2010 to other modes.

3.11.4.
The Commission should, in the ESC’s view, make
provision for extending the Marco Polo programme by two or
three years (to 2008, 2009, or 2010) if additional actions are
proposed in the light of the on-going external monitoring of
the actions set in train, rather than a partial assessment.

3.10. Article 12: Budget; and

Article 13: Set-aside for accompanying measures and
programme evaluation

4. Conclusions

3.10.1.
informed appraisal of
115 million for the Marco Polo programme.

The ESC pointed out earlier that it cannot make an
the proposed funding of EUR

3.10.2.
The ESC notes that the Commission itself considers
that ‘the funding amounts proposed here are relatively limited
in comparison to the overall Community budget (ca. 0,04 %)
...’ (see Chapter 6, Article 11 of the Explanatory Memorandum).

3.10.3.
For this reason the ESC considers that the Com-
mission should make provision for the possibility of proposing
an increase in the budget during the lifetime of the programme
in order
funding for any actions
additional to those currently planned by the Commission.

to provide additional

The ESC generally endorses the proposal for the Marco
4.1.
Polo programme;
this programme will extend the PACT
programme, whilst offering a broader range of options. It will
also help to transfer a significant part of the growth in cross-
border road freight between Member States by 2010 to other
modes.

The ESC does not, however, believe that the Marco
4.2.
Polo programme, by itself, will make it possible to achieve the
annual modal shift targets set by the Commission. It proposes
the following ten highly specific additional incentives:

— Tighter inspections and more severe penalties in the event

of labour law infringements.

The ESC is pleased to note that a number of
3.10.4.
operations could also be co-financed by other EU funds such
as the ERDF, Interreg and Phare.

— Public financing of modal transport infrastructure, such

as terminals and access facilities.

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— Requiring operators to pledge to provide new ongoing
services of general interest in order to secure modal shifts;
failure to do this will mean that customers will not
change their habits.

— Procedures should be set out forthwith for extending the
Marco Polo programme by two or three years in order to
ensure that it continues to operate up to 2010 (there is a
need to avoid the hiatus which occurred between the
PACT and the Marco Polo programmes).

— The greatest possible benefit should be drawn from
the experience gained from the PACT programme by
concluding the external evaluation of the programme;
the positive effects of the PACT programme have not so
far been fully evaluated.

— A timetable should be established for the measures
implementing the actions set out in the Marco Polo
programme.

— A management committee should be given the task of
monitoring actions on an on-going basis with a view to
making the necessary mid-term adjustments to the Marco
Polo programme.

— Provision should be made for including in the projects
eligible for support under the Marco Polo programme
actions involving air and pipeline transport in a secondary
capacity, provided that other modes are involved also.

— Financial aid should be approved for projects involving
actions taking place in just one Member State, provided
that the impact of such projects will benefit all users of
international shipments passing through the Member
State in question.

— A European Guide, covering all multimodal platforms in
the EU, describing their respective characteristics and
laying down minimum standards, should be drawn up
for the benefit of all users.

4.3. While recognising that the stakes for the environment
are particularly high, the ESC takes the view that they need to

Brussels, 17 July 2002.

be reconciled with the increased demand for transport which
will be generated in the coming decades by economic develop-
ment and the enlargement of the EU.

The only way to reconcile these demands is to adopt a global
policy which would change certain economic practices and
transport
include firm commitments for the building of
infrastructure.

4.3.1.
In the light of the practice of ‘zero stockholding’
which is resulting in ever shorter delivery deadlines and placing
non-road transport at a disadvantage, the ESC proposes that
the Commission considers a switch to ‘stock in circulation’
which would permit delivery deadlines more in tune with real
needs.

4.3.2.
In conclusion, the ESC draws attention to the fact
that, bearing in mind that implementation of a common
transport policy to address the abovementioned demand was
envisaged in the Treaty of Rome, more decisive measures need
to be taken in the short and long term with a view to avoiding
congestion, whilst not jeopardising EU competitiveness and
the environment in the EU. Decision-makers need to reflect on
the following figures:

— In the period up to 2020 traffic will double, this will
represent an extra 12 billion tkm per year, which will
involve an estimated annual socio-economic cost of EUR
3 billion (compared with the modest annual budget of
EUR 23 million allocated to the Marco Polo programme.

— According to a recent study, in order to meet the demand
for both goods transport and passenger transport by
2030, the enlarged EU will have to make investments
totalling EUR 550 billion — or EUR 18 billion per year if
it is to continue to have a competitive, environmentally-
sound infrastructure network; new forms of financing
projects will therefore have to found before the review of
the TENs is carried out in 2004.

The President

of the Economic and Social Committee

Göke FRERICHS