EFIP. European Federation of Inland Ports Fédération Européenne des Ports Intérieurs Europäischer Verband der Binnenhäfen

Transcription

1 EFIP European Federation of Inland Ports Fédération Européenne des Ports Intérieurs Europäischer Verband der Binnenhäfen RESPONSE OF THE EUROPEAN FEDERATION OF INLAND PORTS ON THE ROADMAP TO A SINGLE EUROPEAN TRANSPORT AREA Commission s White Paper on competitive and sustainable Transport

2 The European Federation of Inland Ports (EFIP) brings together more than 200 inland ports and port authorities in 19 countries of the European Union, Moldova, Switzerland and Ukraine. The unique voice of inland ports in Europe Since 1994 EFIP is acting as the unique voice of the inland ports in Europe. EFIP highlights and promotes the role of inland ports as nodal points for intermodal transport, combining road, rail, maritime and inland waterway transport. EFIP actively follows all developments in the field of EU policy of importance to inland ports and their environment. EFIP represents the inland ports to the European institutions. EFIP is also representing the inland ports to other national and international organisations, such as the Economic Commission of the United Nations for Europe, the Central Commission for the Navigation on the Rhine and the Danube Commission. EFIP is developing and defending common positions on European policy issues of importance for inland ports and their economic and business environment. An important information network for and about inland ports EFIP is the nodal point between the inland ports and the European institutions. In that respect EFIP informs its members about any move in European transport policy of interest for inland ports. Moreover the EFIP information network can be used by its members to exchange information about relevant calls for proposals, participation in projects and can facilitate project partner search. At the same time, EFIP is informing European policy makers about what is going on in inland ports. A promoter of inland ports EFIP is promoting inland ports, their activities and their role in the national and international economy. EFIP aims at increasing the visibility of the inland ports towards the European transport, political and business environment. For more information, please contact: European Federation of Inland Ports (EFIP) Treurenberg 6, B-1000 Brussel/Bruxelles Tel: Fax: Port of Frankfurt HFM

3 The role of inland ports in a competitive and sustainable transport chain European inland ports are thé inland waterway station by excellence for getting freight on and of the waterway. Since most of European inland ports are not only linking water with road but also with railways, inland ports are facilitating the integration of inland waterway transport into the comodal transport chain. Taking into consideration the reality of economic and transport flows it is clear that a sustainable but efficient transport policy cannot be based on one mode. Freight transport users, need a market place where they can make choices, they can combine in function of the product, the destination, the client, the cost (both internal and external). European inland ports are very well placed and ready to take up this function of transport market place to implement this concept of efficient comodality. In essence, European inland ports have a triple function: Comodal hub on the European inland waterway corridors: inland ports serve as efficient transhipment nodes on the European inland waterway corridors. They are the interface between the inland waterway transport, the maritime leg and the other land modes of transport. Ideal business platform for the region: inland ports are functioning as the nodal point for the regional economy. Next to their transport and logistic function and because of this function they become an ideal location in the region for businesses and industries which want to be close to the market and the European transport corridors. - - An efficient bridge between sustainable long distance transport and the urban last mile: inland ports situated in an EU capital or major urban agglomeration make it possible to bring the urban freight by water right into (or near to) the city centre, limiting as such the road transport to the last mile. By exploiting the potential of a city inland port, the urban freight avoids the congestion barrier around the big agglomerations and limits the use of road transport to a minimum. EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 1 I

4 A clear long term European vision on the future investments is needed The Commission s vision and goals are ambitious. EFIP welcomes the White Paper s main and ambitious vision to both support mobility ánd reduce emissions. Indeed, EFIP believes the European transport mobility should aim in the first place for a better a more efficient and more sustainable mobility. As a matter of fact a good mobility within the European Union is needed to make the internal market fully operational and beneficial to the European citizens. EFIP fully supports the White Paper s plea for clarity on the future policy frameworks and for coherence at EU level. A clear long-term European vision on the future investments to be made on European transport infrastructure in general and inland waterways in particular, which is fully supported by all Member States involved, would allow inland ports to draw up ambitious, sustainable and strong investment plans. Such a long-term strategy is also the best way to attract new investments in inland ports and in the inland waterway sector in general. By their nature, the European inland waterways cross different Member States and should be considered as natural parts of Europe s transport infrastructure. For this reason it is of paramount importance that the national policies governing the waterway transport infrastructure cherish the European inland waterway fairways that are crossing their territory. A top-down approach should avoid that planned and agreed investments or funding schemes are put into question, delayed or even reversed. EFIP welcomes very much the ambition of the Commission to look into urban transport issues and its assessment that the interface between long-distance and last-mile freight transport should be organised more efficiently. But, putting CO 2 free city logistics as a 2030-goal for the major urban centres can only gain EFIP s support if this sustainable urban transport policy is accompanied by a sustainable transport strategy for bringing the goods towards the city gates (see also page 6). By making a benchmark of having all core seaports sufficiently connected to rail and IWT (if applicable) by 2050, the Commission is giving an important signal. Optimising the sustainable hinterland links of the important seaports is a crucial factor for achieving efficient multimodal corridors linking the global market with Europe s hinterland. Such a model will allow inland ports to use their full potential as sustainable inland transport node. I P 2 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 3 I Ports of Paris

5 on distance On one important issue though, the White Paper lacks ambition: namely in its basic assumption that freight shipments over short and medium distances (below some 300 km) will to a considerable extent remain on trucks. According to Eurostat calculations put forward by the Commission in its White Paper, more than half of all goods (in terms of weight) in road transport is moved over distances below 50 km. More than ¾ of road transport is moved over distances below 150 km. This means that nowadays only 25% of all goods moved over road goes over a distance that exceeds the 150 km. This allows us to put the Commission s target of shifting 30% by 2030 (and 50% by 2050) of road freight over 300 km to other modes in the right perspective. By limiting the scope to the >300 km road transport segment, the Commission is tackling less than 25% of the road transport (in weight) and thus aiming in fact at a modal shift of less than 8% (less than 12% by 2050) of the total road freight transport. EFIP believes this goal is not at all ambitious. By focusing on the over 300 km market segment, the Commission is abandoning the idea of using alternative modes in what constitutes, even in an internal market, the gross of road freight movements: the short and medium distances. Furthermore, if we translate this goals into national transport policy, this would imply that the smaller Member States do not even have to think about a modal shift. Moreover, this long-distance road transport target ignores the current reality: It suffices to look at the fast developing links between the big seaports and the inland ports to see that hinterland links on short distances by inland waterways and rail transport are business as usual and are one of the main priorities of the big seaports in view of facing the challenge of congestion in and around seaports. This aspect will become even more important once a network of core seaports is being identified and developed. 2.1 million tonnes were shipped by inland waterway transport in 2010 between the Port of Gennevilliers (Ports of Paris) and the Port of Le Havre. The road distance between both is 200 km. More than 800,000 tonnes are transported annually by inland waterway transport between the Port of Antwerp and the Port of Brussels. The distance covered in this case is approximately 50 km. Port of Lille (France) has regular inland waterway transport connections with the following seaports at less than 300 km: Gand (80 km), Dunkerque (90 km), Zeebrugge (105 km), Anvers (135 km) and Rotterdam (220 km). Moreover inland waterway transport between inland ports on very short distances is common practice. The example of the construction company Dekempeneer in the Port of Brussels is striking. Recently, they decided to use water instead of road transport for the transport of sand over a distance of only 5 km. As a result 1000 lorries will be taken off the road annually. 46% (some 9.5 million tonnes/year) of the inland waterway traffic of the Ports of Paris is taking place within the Ile-de-France Region, on medium but also short distances. To give an example, in 2010 more than 250,000 tonnes were transported between the Ports of Grand Paroisse and Marolles-sur-Seine: a distance of 12 km. In addition, European inland port authorities are often obliging the use of inland waterway (and sometimes rail) transport and setting strict targets, regardless of the distance, when contracting port land to a third party. Finally, the Commission s assumption passes over the fact that inland ports and inland waterway transport are playing an increasing role in the urban freight logistics. In this role, ports are realising modal shifts to IWT and rail over very short distances. I P 4 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 5 I

6 Other factors than distance are far more decisive when choosing for other transport modes The transport of urban waste from the city centres to specialised waste treatment centres constitutes a good example. In the area of Lille transport of waste is done by waterways over distances of not more than 40 and 60 km. In 2010 more than 216,000 containers were transported by water (equivalent of 20,000 lorries). The Ports of Paris has developed a vast traffic in waste from the French capital to the specialised waste treatment centres outside. Big volumes of old paper are transported from Paris to Rouen (distance of some 130 km) by inland waterway transport ( tonnes/year in paper balls, tonnes/year in containers). It is thus clear that other factors than distance are far more decisive when choosing for other transport modes: type of products, volumes, transhipment facilities available, the existence of transport experts in ports, ect. For these reasons, EFIP urges the Commission to develop a policy in support of a sustainable and efficient comodal transport chain and an optimal modal split for all transport segments - short, medium and long distance - regardless of the distance. EFIP hopes that the 300 km threshold put forward by the Commission does not discourage the move towards sustainable transport solutions and does not affect the plans of seaports to develop and strengthen their sustainable hinterland links with inland ports. The Strategy and Initiatives: what needs to be done A true internal market for rail services EC Initiative 1 For inland ports there is a clear sense of urgency in achieving a single European railway network. A Single European Railway Area without barriers is the best way to guarantee an efficient use of existing railway capacity. Remaining barriers - legal, technical and political - should be lifted without further delay. Completing the interoperability of the European railway system is a real priority for EFIP. Awaiting a full European interoperable railway system, a pragmatic regime of cross acceptance of operational rules at local level is needed to enhance the railway links between neighbouring cross border ports in the short run. The last rail miles linking the rail terminal outside the port area with the port area are often characterised by old infrastructure and bad equipment. Sometimes the tracks are not electrified, which means that the link with the port area can only be made with diesel locomotives. The limited infrastructure makes the rail operations on these last miles very complicated (burdensome security rules, etc.) and restricts indirectly the access to the port area. Often rail undertakings are not willing or not able to access ports and have to rely on the unique railway undertaking bridging the rail terminal with the port area ( opérateur ferroviaire de proximité ). The lack of competition in this part of the network has an effect on the price. Very rightly, the staff working document accompanying the White Paper (see paragraph 433) states the importance of open effective and non-discriminatory access to last mile and to train formation facilities in view of stimulating the use of rail transport. EFIP pleads in that respect for an optimisation of the rail links to and from the port area in view of guaranteeing a non discriminatory access for all railway undertakings to the port area. Improving these links should be seen as an important element of completion of the TEN-T network. There is a clear sense of urgency in achieving a single European railway network Port of Strasbourg Port of Enns I P 6 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 7 I

7 Finally, EFIP backs the proposal to work towards a structural separation between infrastructure management and service provision. EFIP pleads for a complete unbundling of railway infrastructure and operations. The unbundling should thus also be legal : infrastructure managers and rail operations services cannot be housed under the same mother company or holding. Only a fully independent infrastructure manager can play its role properly. The current provisions still allow for situations where the infrastructure manager remains hostage of the rail operation branch of the incumbent railway undertaking. This could lead to infrastructure investment choices that are biased by the interests of the incumbent undertaking and could hamper an optimal organisation, use and management of rail infrastructure. EFIP however understands that the complete unbundling of rail infrastructure and operations is not cost-effective in case of a very small national railway network. In this exceptional case, and as long as the railway networks are managed on a national basis, a different approach in view of guaranteeing a fair and non-discriminatory access to the rail infrastructure and rail-related services seems to be adequate. A maritime Blue Belt and market access to ports EC Initiative 4 EFIP believes free maritime movement in and around Europe should not stop at the seaport. Inland waterway transport and ports should also be integrated in this Blue Belt concept in order to simplify and facilitate not only the maritime transport but also the further transport flow to the inland ports. The final aim should be to evolve towards a Blue Network. Stimulating short sea shipping (SSS) on the inland waterway network (coasters) is an important factor in using the full potential of waterborne transport. Therefore, the IWT network should eliminate infrastructure bottlenecks that exist for this type of vessels: the height of bridges, the dimensions of locks, the creation of dedicated berths for short sea vessels in the hinterland. Hinterland connections, including infrastructure and equipment up to the inland terminals, have to be an integral part of the so-called Motorways of the Seas. Market information about potential new SSS links should be easily made available by the short sea promotion centres. EFIP believes that a de minimis approach (in case of low turnover, not affecting the trade between member states, not distorting competition) should be maintained when reviewing the policy on transparency and state aid as well as when considering the need for concessions procedures for inland ports. EFIP acknowledges the need for transparency on ports financing and the importance of fair competition in the transport sector. The European Federation of Inland Ports believes however that the current Directive 2006/111/EC strikes a good balance between the need to guarantee a fair application of the state aid rules of the Treaty and the necessity to maintain a workable system for the public inland ports falling under these rules. A suitable framework for inland navigation EC Initiative 5 EFIP fully supports the plans of the Commission to optimise the internal market for inland waterway transport and to remove the barriers that prevent its increased use. The main barrier for the internal market for inland waterway transport remains the fact that not all EU inland waterway corridors are fully navigable. In that respect EFIP expects a lot from the review of the TEN-T policy. EFIP attaches a lot of importance to the development of a solid core network of waterways that are integrated into the EU inland transport network through a network of inland ports. EFIP believes that the European obligation to develop the core TEN-T projects is of paramount importance. This will give a boost to the development of the EU missing water links and will enhance the use of inland waterway transport in the European Union. In addition, the European inland ports plead for a gradual harmonisation of EU navigation rules. The differences in regulatory systems between river basins should be reduced to a minimum. The expertise existing in the different river Commissions and at the different institutional levels should of course be used to work towards a more harmonised system. Finally, when developing a regulatory framework for inland waterways, there is a need to cooperate closely with all countries, also the non EU countries, that are naturally linked by the European waterways. The main barrier for the internal market for inland waterway transport remains the fact that not all EU inland waterway corridors are fully navigable I P 8 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 9 I

8 Multimodal transport of goods: e-freight EC Initiative 7 The creation of a single multimodal transport document and liability regime will definitely be a strong instrument to support short sea shipping in combination with rail or inland navigation. Safer shipping EC Initiative 18 EFIP supports the Commission s idea of the creation of a quality label, an EU sign and EU register certifying safe, secure and environmentally friendly inland and maritime ships manned by highly qualified professionals. This label could help inland ports in identifying quality ships. Such a label should be open to any ship meeting the criteria, not only to EU ships. Linking this EU quality label to a favourable treatment or lower port dues (as a result of their benefit for the port in terms of environmental performance, lower insurance, etc.) as suggested in the staff working document (paragraph 268) should however only take place on a voluntary basis, as part of a policy of individual ports, but should at no point be imposed. Waterwegen en Zeekanaal I P 10 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 11 I

9 An innovation and deployment strategy EC Initiative 25 The European Federation of Inland Ports encourages the development of Intelligent Transport Systems (ITS) fully. EFIP highlights the importance of the interoperability of intelligent transport systems and new technologies across the different transport modes. The harmonisation of the technological systems is the key to making intermodal transport a success and are thus, next to the hard infrastructure an important element of the TEN-T network. Moreover, inland ports believe that a modern supply chain management needs transparent information among all modes. The information that seems useful in that respect is: status of loading, actual position of vessel, expected time of arrival, etc. Getting this information in time would enhance the smooth functioning of the inland ports. It would allow inland ports to plan a slot time for the gantry crane, to plan the container check/repair and so on. The use of advanced ITS solutions implies however an investment for the barge owners and operators. For small barges (ex. Freycinet type barges) such an investment can become a problem. Besides, barge operators are often considering these ITS systems as a way to control their operations and are reluctant to share data that are commercially sensitive. As a result, a further development and use of ITS should take into account this double concern of financial implications and confidentiality. Carbon footprint calculators EC Initiative 29 EFIP fully backs the proposal to work towards common EU standards to estimate the carbon footprint of freight journeys. A lot of inland ports have already experience with measuring the carbon- and environmental footprint of transport services. They commissioned studies calculating the carbon footprint of certain journeys from and to their port, using different modes. EFIP stresses the need to develop a recognised model of calculation avoiding the proliferation of different models and the green washing of certain operations as a result of unclear calculations. It would also be a useful tool for smaller ports which do not have the means to develop their own studies and calculator. Ecocomparateur The Ports of Paris has developed on its website a tool allowing potential clients to measure the environmental gains of using combined transport (water-road) instead of 100% road transport when transporting goods between Rouen and Le Havre and the Seine Basin. The instrument also looks at the cost for the company in each case and the difference in time of transport. The calculations are made on the basis of a study made by the Agence de l Environnement et de la Maîtrise de l Energie. See: I P 12 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 13 I

10 One should also aim at using sustainable modes of transport for bringing the goods as close as possible towards European cities A Strategy for near- zero-emission urban logistics 2030 EC Initiative 33 EFIP welcomes very much the ambition of the Commission to address the issue of urban freight logistics and is very pleased that the Commission recognises the important role inland ports can play in that respect. For inland ports, greening the last urban mile, through the use of low emission vehicles and innovative solutions for distributing the goods into the city, is only one part of the strategy. One should also aim at using sustainable modes of transport (inland waterway transport, rail and short sea shipping) for bringing the goods as close as possible towards European cities. Inland ports can help in making the last mile transport as efficient and limited as possible by bringing the goods in a sustainable way into the towns, from where they can be distributed to their final destination. Inland ports can also function as a real gate to waterborne and rail transport for goods leaving the town. Using rail, inland waterways and short sea shipping to bring the goods from a medium or long distance in or near to the city centres implies however space for transhipment and logistics near the river, around the rail terminals. During the last decades, towns have rediscovered the attractiveness of the riverside and river banks have become the dream location for real estate and housing projects, leisure activities and other non river related use. The space along the waterways has often lost its specific logistic function and the inland city ports are often getting squeezed. As a result, inland ports risk to lose their capacity of responding in an adequate way to the growing supply and distribution needs of towns. EFIP strongly believes the logistic assets of an inland port in a town should be revalorised. Moreover, the different functions of the riverbanks should be rebalanced. If needed, some space along the waterway should be safeguarded for logistical purposes or other river-related uses. Finally municipal and regional authorities should involve the port authorities when preparing urban mobility plans. European inland ports fully back the approach to bring together amongst others aspects of land planning, rail and river access when defining a strategy for near zero-emission logistics. For bringing the goods as close as possible towards European cities I P 14 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 15 I Port of Brussels

11 Inland ports are playing and are ready to play a crucial role in the TEN-T network as high quality intermodal connecting points A core network of strategic European infrastructure A European mobility Network EC Initiative 34 The European Federation of Inland Ports welcomes the review of the TEN-T policy and gives it full support to the rationale of this review. For inland ports, modernising the network, boosting its genuine integration into the internal market, better linking East and West, decarbonising, integrating the nodes (inland and seaports, urban nodes) are the right priorities. EFIP considers the attention that is given to inland ports in the TEN-T review as a recognition of the crucial role inland ports are playing and are ready to play as high quality intermodal connecting points:»» in the integration of transport modes»» in facilitating co-modal operations»» by enhancing the links between national networks, in particular in cross-border sections of the TEN-T network, that are often transport no-man s-land»» through their hinterland hub function to and from the big seaports»» as sustainable transport node (access and exit gate, logistic hub) between the long distance transport and the urban last mile. For inland ports, the EU obligation to go forward with a project that is part of the Core Network is fundamental for the future TEN-T policy. Indeed, this obligation will help to overcome the local difficulties EU projects with an important added value are often facing. Finally, EFIP stresses the importance of aligning the Cohesion fund allocation with the TEN-T priorities, avoiding as such that the Cohesion fund in the field of transport would feed other transport priorities than the ones proposed and supported by this TEN-T review. Multimodal freight corridors for sustainable transport networks EC Initiative 35 EFIP supports the development of multimodal freight corridor structures within the TEN-T core network. As intermodal connecting points, the European inland ports can enhance the development of these corridors and enhance their integration and access to the overall transport network. EFIP acknowledges the wish of the European Commission to support multimodal transport and to stimulate the integration of inland waterways into the transport system. The European inland ports hope however that this wish will be reflected in the concrete transport and infrastructure policy. As stated in the staff working document (paragraph 432), the lack of knowledge of potential transport options is one of the obstacles to the development of multimodal transport. The lack of knowledge and expertise on intermodal transport solutions mistakenly feeds the image of intermodal transport as a complex and costly solution. It is therefore important that shippers and businesses are making their way to intermodal transport solutions including inland waterway transport. This implies that the companies can count on experts (in-house or external) setting up a competitive, sustainable and reliable transport chain for their company/client. Port of Bratislava SPaP Bratislava Port of Krems I P 16 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 17 I

12 Smart pricing and taxation EC Initiative 39 As regards the internalisation of external costs of transport, the Commission is proposing a policy in two phases. In a second phase ( ), the Commission wants to internalise the costs of local pollution and noise in ports. EFIP believes that calculating the correct price of externalities of all modes of transport and taking these externalities into account in the transport costs will help transport users in finding transport alternatives that are best both for the economy and the environment. This will benefit the use of environmentally friendly modes of transport, in particular waterborne transport and rail. To inland ports, it must however be clear that the internalisation of external costs should only be used to make transport modes more comparable for the user, not as an instrument to increase the overall cost of transport and to feed the national budgets. Moreover, the internalisation should only relate to the external costs and has to be distinguished very clearly from the infrastructure costs. But, the European inland ports see no point in and no way of extending the internalisation of external costs to the ports as such. Inland ports have a transhipment function but are at the same time a cluster of industrial and logistic businesses of all kind. Each of these installations and industries are subject to different environmental legislation and taxes. The internalisation of external costs (local pollution and noise) in ports would thus mean that the ports would have to bear once again for the external costs of the industries in the ports, costs that are often already borne by the individual businesses through their sectoral legislation and tax regimes. This would lead to a double taxation. Another option would be to isolate the external costs that are strictly linked to the transhipment and transport activities in and around the port in view of their internalisation. This as well does not seem to be a feasible option since the transport and industrial/business activities are fully interrelated. EFIP therefore opposes the White Paper s proposal to internalise the costs of local pollution of the ports. EFIP notes that the staff working document is more moderate on this point and takes into account the specificity of ports. Port of Frankfurt HFM I P 18 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 19 I

13 The main European inland waterways do not stop at the EU borders Transport in the world: the external dimension EC Initiative 40 EFIP strongly believes that the EU transport policy has to be developed and implemented in close cooperation with third countries, in particular with the EU neighbouring countries. The main European inland waterways do not stop at the EU borders. The inland ports therefore plead for a great involvement of all riparian countries when developing a policy affecting these waterways. The development of the Danube Strategy, involving all riparian countries, can serve as example in that respect. Even to a larger extent, EFIP believes that the European transport priorities put forward in this White Paper should be integrated in the transport programmes with third countries. These priorities should be the main focus of transport aid programmes in third countries. EFIP Secretariat Director Isabelle Ryckbost isabelle.ryckbost@inlandports.be Assistant Ombeline d Hollander ombeline.dhollander@inlandports.be EFIP Members EFIP s President Roland Hoerner (Germany) EFIP s Vice Presidents Willy Robijns (Belgium) Bernard Pacory (France) Carmen Costache (Romania) Rainier Reekmans (Belgium) EFIP s members Austria Interessengemeinschaft Öffentlicher Donauhäfen in Österreich (IGÖD) Belgium Port autonome de Liège Port autonome de Namur Port de Bruxelles Haven van Gent Waterwegen en zeekanaal nv Bulgaria Port complex ruse j.s. co. Czech Republic Port of Krems I P 20 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport Cesko-Saske privasty S.R.O. (Port of ) EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 21 I

14 France Association Francaise des Ports Interieurs (AFPI) Germany Bundesverband Öffentlicher Binnenhäfen (BÖB) Greece Ellhnikh etaireia logistics Hungary Paksport Italy Unione Navigazione Interna Italiana (UNII) Provincia di Mantova - port of Valdaro Luxemburg Port de Mertert Moldova Giurgiulesti international free port Netherlands Nederlandse Vereniging van Binnenhavens (NVB) Portugal Instituto portuario e dos transportes maritimos - delegação Douro Romania Administration of river ports on the Danube National company maritime Danube ports administration Galati Union of Romanian inland ports Slovakia Ports of Bratislava and Komarno Spain Puerto de Sevilla Sweden Mälarhamnar AB (Ports of Köping & Västerås) Vänerhamn ab Switzerland Schweizerische rheinhäfen Ukraine Port Ochakov co. Ltd. Danube shipping management service (DSMS) EFIP s observer member Egypt National river ports management company Port of Passau Bayernhafen Gruppe Port of Enns I P 22 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport EFIP s response to the Commission s White Paper on competitive and sustainable Transport I P 23 I

15 I P 24 I EFIP s response to the Commission s White Paper on competitive and sustainable Transport Port of Switzerland

16 EFIP European Federation of Inland Ports (EFIP) Tel: Fax: Treurenberg 6 B-1000 Brussel/Bruxelles info@inlandports.be