Opinion of the European Economic and Social Committee on the Motorways of the sea in the logistics chain (exploratory opinion)
Date: 2008-01-16
Institutions: European Economic and Social Committee
Subjects: administrative formalities, carriage of goods, combined transport, common ports policy, maritime transport, sustainable mobility, trans-European network, transport infrastructure

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Opinion of the European Economic and Social Committee on the Motorways of the sea in the logis-
tics chain (exploratory opinion)

(2008/C 151/07)

In a letter dated 4 July 2007, the Portuguese Presidency of the European Union asked the EESC, under
Article 262 of the Treaty establishing the European Community, to draw up an exploratory opinion on:

Motorways of the sea in the logistics chain (exploratory opinion)

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 18 December 2007. The rapporteur
was Mr Simons.

At its 441st plenary session, held on 16 and 17 January 2008 (meeting of 16 January 2008), the European
Economic and Social Committee adopted the following opinion unanimously.

1. Conclusions

1.1
Short sea shipping can play a key role in the further
development of co-modality and logistics chains. All transport
modes should be taken into consideration. In the context of co-
modality short sea shipping could be used mainly for longer
distances.

The EESC confirms its full support

for measures to
1.2
further develop and promote short sea shipping. However,
it
has questions and comments about the actual implementation
of these measures.

1.3
In this context, the definition of motorways of the sea
needs to be clarified. The EESC considers that this designation
cannot be given solely to new subsidised services, but should
apply to all efficient short sea shipping services. The EESC is
pleased that
the Commission has clarified the definition of
motorways of the sea in the working document on the Motor-
ways of the Sea, accompanying the Communication on the EU's
freight transport agenda of 18.10.2007, in particular that the
term also includes existing services (1).

1.4
A concentration of cargo on a limited number of selected
ports will have a negative influence on the efficient provision of
services, and this will undoubtedly lead to congestion in the
ports and their surrounding areas (2). This will not be conducive
to the sustainable development of transport.

1.5
The development of additional port capacity and the
improvement of hinterland connections by means of other
modes should be a priority in the concept of motorways of the
sea. Support measures should concentrate on these matters. This
will at the same time support the policy of co-modality.

1.6
Support measures for the motorways of the sea should
also be directed towards infrastructure, especially the expansion
of ports and their hinterland connections,
leaving in place
existing support measures for services, operational costs and
promotion.

1.7
Preventing distortion of competition is a sensitive point
that should be tackled extremely carefully because of the specific
market structure of short sea shipping. The aim must be to shift
goods that are carried by road to sea routes. The aim should not
be to switch goods that are carried by sea to another maritime
transport operator.

frequency, a delivery service that

1.8
The Commission intends to use quality standards as one
of the evaluation criteria for motorways of the sea projects.
Depending on the specific service, the following criteria could
be used:
fits in with the
the services
production process,
(according to the Commission's definition, therefore, including
the intrinsic merits of the mode), hinterland connections, effi-
cient ports and junctions, e-logistics, optimal administrative
procedures, etc.

reliability, co-modality of

the Programme for

In the Mid-Term Review of

1.9
the
Promotion of Short Sea Shipping, the Commission states that
the possibility of quality labelling will be examined for motor-
ways of the sea. As stated in the Opinion on Freight Transport
Logistics, the EESC believes that this must not generate more
red tape and unnecessary costs for the sector.

1.10
The simplification and reduction of administrative
procedures is likewise a priority for short sea shipping services.
Customs formalities for intra-European sea cargo should not be
more time-consuming than for road transport. The simplified
customs procedures should be thoroughly reorganised, with the
cargo and the transport operator being the focal points.

Other bottlenecks

1.11
in the logistics chain must be
improved. The EESC fully supports the work being done in the
context of the Commission's Freight Transport Logistics Exer-
cise.

(1) Freight transport agenda [COM(2007) 606 final]; Commission Staff

Working Document on the Motorways of the Sea of 18.10.2007.

(2) TEN/258 Opinion on A common EU ports policy, OJ C 168,

20.7.2007, pp. 57-62.

1.12
Both short sea shipping and the logistics services are
short of highly qualified workers. Greater attention should be
paid to recruitment, education and training.

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1.13
Switching goods transport from road to sea will bring
benefits for both the environment and society. A further reduc-
tion in exhaust emissions from ships should be encouraged. The
international agreements on this will be
EESC hopes that
concluded.

2. Introduction

2.1
The development of motorways of the sea in Europe was
earmarked in 2004 as one of the thirty priority projects within
the trans-European transport network.
the development of
Article 12a of Decision No 884/2004/EC (3), covering guidelines
for the development of a trans-European transport network, lays
down the basic elements for the motorways of
In
concrete terms, it was stated that the trans-European network of
motorways of the sea is intended to concentrate flows of freight
on sea-based logistical routes in such a way as to improve
existing maritime links or to establish new viable, regular and
frequent maritime links so as to reduce road congestion and/or
improve access to peripheral and island regions and states.
Motorways of the sea should not exclude the combined trans-
port of persons and goods, provided that freight is predomi-
nant.

the sea.

— motorway of the sea of south-west Europe (western Mediter-
ranean), connecting Spain, France, Italy and including Malta,
and linking with the motorway of the sea of south-east
Europe (6) (2010);

— the EESC, taking into account EU enlargement, points out
that motorways of the sea should also be developed in the
Black Sea itself, not excluding compatible sea river shipping
services on the Danube.

2.5
The Commission will evaluate the projects on the basis
of the criteria stated in Article 12a of the guidelines for the
trans-European transport network with the following key
points:

— Contribution to modal shift and/or cohesion: a percentage
of road freight in a given corridor should be shifted to the
motorway of the sea and should contribute to the social and
economic cohesion of the countries concerned.

— Quality aspects: the project should have clear quality stan-
dards with regard to five elements: port services, hinterland
connections, information systems and monitoring, the ship-
ping service itself, and integration into the TEN network.

2.2
TEN funds can be claimed if the costs of motorways of
the sea are concerned with facilities and infrastructure. Services
and operational costs can be supported by the Marco Polo
programme (4).

— Viability and credibility of the project: the viability both of
the service itself and of the hinterland connections must be
demonstrated. The introduction of risk capital and state
funding (national, regional, EU) must be clearly stated.

2.3
The projects of common interest of the trans-European
network of motorways of the sea must be proposed by at least
two Member States. They must consist of facilities and infra-
structure concerning at least two ports in two different Member
States. The projects proposed in general involve both the public
and private sectors on the basis of a public call for tenders orga-
nised jointly by the Member States concerned and targeting
consortia bringing together at least shipping companies and
ports.

2.4
Decision No 884/2004/EC (Annex II) lists the following
motorways of the sea as projects of common interest, identified
in accordance with Article 12a, namely:

— motorway of the Baltic Sea (linking the Baltic Sea Member
States with Member States in Central and Western Europe,
including the route through the North Sea/Baltic Sea Canal
(Kiel Canal) (2010);

— motorway of

the sea of western Europe (leading from
Portugal and Spain via the Atlantic Arc to the North Sea
and the Irish Sea) (2010);

— motorway of the sea of south-east Europe (connecting the
Adriatic Sea to the Ionian Sea and the Eastern Mediterranean
to include Cyprus) (2010) (5);

(3) Decision No 884/2004/EC of the European Parliament and of the
Council of 29 April 2004 amending Decision No 1692/96 in connec-
tion with Community guidelines for the development of the trans-
European transport network.

(4) Regulation (EC) No 1382/2003 (Marco Polo Programme) L196,
2.8.2003 and COM(2004) 478 final of 14.7.2004 (Marco Polo II).
(5) It should be pointed out that there are already short sea connections set
up by private operators, for example between Turkey and Italy and
between Italy and Spain.

— Effects on competition: distortion of competition through
state aid should be avoided. The impact of the project on
existing services and ports must therefore be examined.

2.6
The modalities for the call for project proposals for the
establishment of the motorways of the sea were laid down in a
Commission Vademecum of 28 February 2005.

In the meantime, a call for tender has been published for

2.7
the following projects for motorways of the sea:

— motorway of

the sea projects
Germany/Finland and Baltic Sea;

in the Baltic Sea area:

— motorway(s) of the sea between the Atlantic coasts of Spain

and France — Channel — North Sea;

— motorways of the sea projects in the North Sea region.

Other projects are being examined and discussed by various
special ‘task forces’.

A Mid-Term Review of the Programme for the Promo-

2.8
tion of Short Sea Shipping was published in mid-2006 (7).

2.9
In September 2007 the European Commission also
appointed Mr Luis Valente de Oliveira (Portugal) as Coordinator
for motorways of the sea.

(6) Including to the Black Sea.
(7) COM (2006) 380 final of 13.7.2006.

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2.10
In October 2007 the European Commission published
a working document on the Motorways of the Sea as part of
the EU's freight transport agenda (8).

Commission has clarified the definition of motorways of the sea
in the working document of 18.10. 07 accompanying the
Communication on the EU's freight transport agenda of the
in particular that the term also includes existing
same date,
services (11).

3. General comments

3.1
The EESC has consistently supported measures aimed at
developing short sea shipping on account of its considerable
potential and as a good alternative to other, less environment-
friendly modes of transport, thereby helping to reduce road
congestion, accidents and noise and air pollution (9). Further-
more, short sea shipping fits in well into the framework of co-
modality and the logistics chain and offers the opportunity to
provide access to the islands and peripheral regions.

3.2
The motorways of the sea initiative therefore deserves
the fullest support. Nevertheless, as stated in the opinion
referred to in footnote 9, the notion of motorways of the sea
still raises some further questions and comments which will be
discussed here.

4. The concept of motorways of the sea

the sea.

There is

justifiable confusion about

the concept of
4.1
motorways of
In practice, there are already at this
moment many efficient quality short sea shipping services
which provide good multimodal services and thereby reduce
road transport congestion and offer services to island and
peripheral regions.

4.2
As was stated in the Mid-Term Review of the Programme
for the Promotion of Short Sea Shipping, this is the mode of
transport better placed to keep up with the rapid growth of
road transport (10). Between 1995 and 2004, the tonne-mile
performance of short sea shipping in the EU grew by 32 % as
against 35 % for road transport. The share of short sea shipping
in the EU-25 is 39 % as opposed to 44 % for road transport. In
the EU-15, the share of short sea shipping was 42 % compared
to 44 % for road transport.

in many cases,

This good performance by short sea shipping is to a
4.3
large extent based on high levels of investment by shipowners
in ships and,
logistics systems,
improvements in efficiency and the sale of logistical services,
the work of the National Short Sea Shipping Focal Points on the
bottlenecks, the practical work of the coastal shipping promo-
tion centres, and cooperation between the industry and the
European Institutions.

in intermodal

The intention is not to undermine this success story by
4.4
not regarding existing services based on initiatives by the private
sector as motorways of the sea and to keep this designation
exclusively for subsidised services. The EESC is pleased that the

(8) See footnote 1.
(9) TEN/268 Short Sea Shipping- Mid-term Review, 25 April 2007, OJ C

168, 20.7.2007, p. 68.

(10) Commission Communication COM(2006) 380 final of 13.7.2006.

5. Selection of ports

5.1
There is a fundamental difference between a motorway
for road transport and a motorway for sea transport. Transport
by lorry via a motorway connects two points in as straight a
line as possible. In the case of sea transport, however, in practice
cargo originating from or destined for a broad hinterland is
transported via a number of different competing ports. The
most competitive and efficient ports for a particular trade will
then be included in the various sailing schedules of shipping
companies.

The concentration of cargo on a limited number of
5.2
selected ports will, however, have a negative influence on the
efficient provision of services (12), and will undoubtedly lead to
congestion in the ports and their surrounding areas. This does
not help the sustainable development of transport.

5.3
Furthermore, the inclusion of certain ports in the motor-
ways of the sea and the exclusion of others of similar size
would also result in a distortion of competition between ports.
The choice of ports must be left open in such a way that the
others too, by constantly improving their efficiency, are able to
develop into motorway of the sea ports.

6. Co-modality

Short sea shipping can play a key role in the further
6.1
development of co-modality t, especially for longer distances. As
stated in the Opinion on Freight Transport Logistics,
the
Committee considers that all transport modes have to be taken
into consideration (13). Ports have a fundamental role in this as
multimodal hubs. Various projects are being developed in this
regard (14).

Bottlenecks in the logistics chain must be improved. The
6.2
Commission is already carrying out a study of bottlenecks in
freight logistics, which covers administrative as well as infra-
structure and operational bottlenecks.

6.3
Both short sea shipping and the logistics services are
short of highly qualified workers. The EESC reiterates the recom-
mendation made in the Opinion on Freight Transport Logistics
that more attention needs to be paid to recruitment education
and training.

(11) Commission Communication on the EU's freight transport agenda of
18.10.2007; Staff Working Document on the Motorways of the Sea.
(12) TEN/258 Opinion on A common EU ports policy, OJ C 168,

20.07.2007, pp. 57-62.

(13) TEN/262 Opinion on Freight Transport Logistics in Europe, OJ C 168,

20.7.2007, p. 63.

(14) Co-modality project on BGV-HSC high-speed vessels and the fast

motorways of the sea (www.bgv.eu).

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7. Investment in ports and hinterland connections

The problems concerning the current congestion in
7.1
many European ports are now well known. This underlines the
need for more ports in the same league to be eligible for further
development as ports for short sea shipping.

7.2
The development and expansion of ports and hinterland
connections is made more difficult and often significantly
delayed and/or prevented by restrictions and interpretations of
In this
existing legislation and environmental requirements.
context, delays of between two and 11 years were cited in the
ESPO Annual Report 2006/2007 (15).

8.3
It is therefore not possible when analysing the market
concerned to concentrate on one specific port; rather the entire
cargo market has to be considered in order to prevent the shift
of cargo from one short sea shipping service or port to another.

8.4
As stated in 2.5, third bullet point, applicants for a new
project for a motorway of the sea must demonstrate the viability
and credibility of the project; here too monitoring should take
place to ensure that a distortion of competition is avoided.

Transparency in the allocation of aid for projects is there-
8.5
fore essential. An immediate correction should likewise be made
whenever
that cargoes artificially shift between
it appears
coastal shipping operators or ports.

7.3
As was repeatedly stated by the industry in the consulta-
tion round regarding a new EU ports policy and the Green
Paper on A Future Maritime Policy for the Union, this problem
urgently requires proper attention (16). The EESC notes that the
Commission does give proper attention to this issue in its
Communication on a European ports policy of 18.10.2007 (17).

8.6
Support for motorways of the sea is intended to result in
a transition from transport by road to transport by sea. The
ECO bonus as proposed in Italy (20), whereby carriers receive
subsidies if they take up this idea, is a good example of well-
directed aid without distortion of competition.

7.4
It is therefore also clear that support measures for the
motorways of the sea should also focus in this context on infra-
structure and in particular on the expansion of ports and hinter-
land connections. This approach also fully conforms with the
concept of co-modality as proposed by the Commission in the
Mid-term review of the White Paper on EU transport policy (18)
and in the Commission Communication on Freight Transport
Logistics (19).

This does not, of course, alter the fact

that existing
7.5
support measures for services, operational costs, and publicity
must continue to be available.

8. Distortion of competition

8.1
As mentioned in 2.5, last bullet point, the Commission
itself states that state aid may not distort competition with
existing services. The impact of the subsidised motorway of the
sea should be closely examined, taking account among other
things of the general interest, to ascertain whether competition
distortion is likely to occur.

This, however, is not easy. Short sea services serve the
8.2
hinterland of the ports which they call at. As noted in 5.1, this
hinterland can cover a fairly large area that can also be served
by other ports.

(15) OJ C 168, 20.7.2007, pp. 57-62, ESPO Annual Report 2006/2007 —

ITMMA/University of Antwerp.

(16) Green Paper Towards a future Maritime Policy for the Union COM

(2006) 275 final of 7.6.2006.

(17) Commission Communication on a

18.10.2007.

European Ports

Policy,

(18) Keep Europe Moving — sustainable mobility for our continent, COM

(2006)314 final of 22.6.2006.

(19) Freight Logistics in Europe — key to sustainable mobility, COM(2006)

336 final of 28.6.2006.

9. Quality standards

As stated in 2.5, the Commission will use quality stan-
9.1
dards as one of the evaluation criteria for motorways of the sea
projects. Depending on the specific services,
the following
criteria could be used: frequency, a delivery service that fits in
the
with the production process, reliability, co-modality of
services (according to the Commission's definition, therefore,
including the intrinsic merits of the mode), hinterland connec-
tions, efficient ports and junctions, e-logistics, optimal adminis-
trative procedures, etc.

the Programme for

In the Mid-Term Review of

9.2
the
Promotion of Short Sea Shipping (21), the Commission states
that the possibility of quality labelling will be examined for
motorways of the sea. As stated in the Opinion on Freight
Transport Logistics,
this must not
generate more red tape and unnecessary costs for the sector (22).

the EESC believes that

10. Administrative procedures

10.1
Both in the above-mentioned Green Paper on a Future
Maritime Policy for the Union and in the Mid-term review of
the White Paper on sustainable transport,
the Commission
refers to a ‘common European maritime space’, i.e. a European
maritime space without frontiers. The intention is clearly to
simplify the administrative procedures for short sea shipping so
that they would be in line with those for road transport.

(20) Aiuto di Stato N 496/2003 — Italia.
(21) Mid-term review of the programme for the promotion of short sea

shipping COM(2006) 380 final of 13.7.2006.
(22) TEN/262 Opinion on Freight Transport Logistics.

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10.2
The EESC has taken up a position with regard to a
common EU maritime space both in its opinion on the above-
mentioned Green Paper and in its opinion on a common EU
ports policy (23):

‘The EESC understands that the concept of 'a common Euro-
pean maritime space', or a European maritime space
without frontiers, refers only to a virtual maritime space in
which there will be a simplification of administrative and
customs formalities for intra-EU maritime services giving
them a similar regime to transport by lorry, train or inland
waterway within the internal market. If this is indeed what
the Commission means and it
is expressed clearly and
unequivocally, the concept can be supported by the EESC,
provided that in international waters (high seas) it respects
the UNCLOS and IMO Conventions including the 'freedom
of navigation' and the 'right of innocent passage' within the
Exclusive Economic Zone (EEZ)’.

10.3
The simplification of customs procedures has been
repeatedly requested by the Maritime Industries Forum (MIF)
and the national contact points for the promotion of short sea
shipping. In this connection, as early as 2002 the Commission
published an advisory document with a view to encouraging the
use of a simplified customs procedure for short sea ship-
ping (24).

10.4
The implementation of this guide has not, however,
solved all problems. The key problems are that it is necessary to
obtain the status of regular service (authorised regular shipping
service) which is directly linked to both the vessel and the ship-
ping company concerned (transport operator). If another vessel
has to be laid on, this has to be reported. If a vessel with intra-
EU cargo calls at a non-EU port during its voyage, the simplified
procedure for all intra-EU cargo is cancelled (infected vessel).

10.5
A solution would be to base this simplified procedure
on the shipping company concerned (transport operator) and
on the cargo. Intra-EU goods/cargo could then in all circum-
stances use a simplified procedure which should be the same as
for road transport.

10.6 Multimodal
liability needs to be looked into. This is
being discussed by UNCITRAL. The EESC recommends an early
agreement.

Brussels, 16 January 2008.

10.7
put sea transport at a disadvantage as against land transport.

The EESC points out that security measures must not

11. The environment

Shipping is still

11.1
the most environmentally friendly
means of transport. With the exception of sulphur (SOx), ship-
ping's performance in terms of emissions per tonne-kilometre
or mile is better than other modes of transport. Nevertheless,
measures should be taken to constantly improve this position.
In this context, there is an ongoing process in the IMO (Interna-
tional Maritime Organisation) to revise the relevant Annex VI of
the MARPOL Convention. This procedure deserves the fullest
support in order to find a global solution.

11.2
Attention will be paid at the IMO talks to a possible
extension of SECAS (25) whereby a lower limit for emissions
would be applied. Short sea shipping is particularly vulnerable
here given that short sea shipping operates de facto in coastal
regions with frequent sailings. Particular attention must conse-
quently be paid to avoid throwing out the baby (the promotion
of short sea shipping) with the bathwater.

too,

shipping is

In the case of carbon (CO2) per tonne-kilometre or mile
11.3
Independent
emissions
sources (26) estimate that shipping accounts overall
for only
1.75 to 2 % of global greenhouse gases. Measures are also being
examined in this area with a view to steadily improving ship-
ping's environmental performance.

fairly well placed.

11.4
The EESC recommends research and development as
well as financial support for the reduction of shipping emis-
sions, including improved fuel quality.

However,

11.5
in addition to the question of emissions,
attention should also be given to the monitoring of pollution of
the maritime environment caused by increased coastal shipping.

The main purpose of the motorways of the sea is to
11.6
shift transport from the road to the sea. This will have both a
positive effect on the environment and direct consequences for
society concerning such matters as congestion, noise pollution
and road accidents. This should be borne in mind, without
losing sight of the fact that continuous progress is needed on
emissions from ships.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

(23) Opinion on A common EU ports policy, OJ C 168, 20.7.2007, pp. 57-
62; Opinion on a future Maritime Policy for the Union, OJ C 168,
20.7.2007, pp. 50-56.

(24) Commission staff working paper — Guide to Customs Procedures for

Short Sea Shipping SEC(2002) 632 of 29.5.2002.

(25) Sulphur Emission Control Areas.
(26) Stern Review on the economics of climate change, UK, October 2006.