Directive 92/106 should be the legislation governing transport by more than one mode 03/12/14

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The industry associations of intermodal and combined transport, as well as inland navigation and railways continue to endorse the modal-shift targets of the 2011 EU Transport White Paper. These should remain the guiding principles for EU freight transport policymaking, including new legislative proposals, which should all be assessed as to their contribution towards achieving these aims.

The Directive 92/106 concerning the establishment of common rules for certain types of combined transport of goods between Member States is one of the oldest pieces of European transport legislation still in effect today. Therefore the initiative by the European Commission DG MOVE for a public consultation related to the Directive1 was welcomed by the sector.

Transport-chains optimized to the criteria of simultaneous economic and ecological sustainability are rarely unimodal. Quite on the contrary, they are based on the collaboration of rail, inland waterway and short sea shipping, which mostly rely on first and last mile road transport. The collaboration of different modes of transport and of several different actors including those responsible for transhipment between the modes, makes intermodal/combined transport appear more complex compared to pure road transport. Nevertheless the exceptional socio-economic performance of these multimodal transport-chains, such as greater resource efficiency, less congestion and pollution, lower emissions, fewer accidents, etc, make these forms of freight transport a good choice for both consignors and the society at large, also worthy of note for the European legislator.Support for intermodal/combined transport is a horizontal challenge, which touches on a number of European policies beyond the scope of the Combined Transport Directive 92/106. The undersigning associations emphasize the horizontal approach needed when addressing these transport-chains which rely on several modes of transport and transhipment points in between:

  • Infrastructure: the new TEN-T Guidelines rightly follows a multimodal approach. This needs to be reflected in the concrete corridor work-plans. The Connecting Europe Facility can also play an important role in providing funding for transshipment infrastructure and equipment, thus enhancing the productivity of this activity.
  • ICT solutions: Logistics chains that cover more than one mode require smart coordination across modes. This can be facilitated through simplified administrative and customs procedures (i.e. initiatives in the area of e-freight). EU support should be available for ICT and other solutions that allow better planning, coordination and bundling of cargo flows.
  • Level playing field across modes: the internalization of external costs across modes, full and fair proliferation of the user-pays and polluter-pays principles in every Member State.
  • Support of intermodal/combined transport: also on a Member State level; whereby Member States should be required to draft long-term roadmaps identifying their strategies to develop sustainable freight transport, and intermodal/combined transport in particular.

The current benefits defined in the Directive 92/106 are seen as very useful, contributing materially to the development of intermodal/combined transport-chains experienced over the past decades. This is why decision-makers should avoid the dispersion of defining terminology and other rules pertaining to transport by more than one mode of transport (combined, intermodal, multimodal) in other unrelated pieces of legislation. Directive 92/106 already provides a framework for European intermodal/combined transport, which could be further enhanced if the Commission would opt for its thorough revision.

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