Stakeholders' questionnaire Page 1

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1 the EC Railway interoperability 1 Bottlenecks Rail 2 Bottlenecks Rail EC should accelerate the common standard programme launched in 2006 to overcome the current lack of interoperability: - uniforming high speed and conventional rail system's Technical Specification for Interoperability (TSI). Dedicated freight rail tracks - allowing rolling stock used in one Member State to run accross all other national networks; common rules for licensing. - identifying common rules among for Railway Undertakings's safety management systems. Railway interoperability EC should finance projects to overcome lack of interoperability on key corridors (e.g. voltage system, clearance gauge, maximum train length); 50% co-finance was announced, but the overall budget dedicated to interoperability is too small. ETCS is a key issue. Railway capacity Positive "+++" Positive "++" Positive "+" Positive "++" Positive "+" Infrastructure Positive "++" Positive "+" Positive "+" Positive "++" Positive "+" Should the maximum train length be increased, the impact on logistic costs would be even bigger 3 Bottlenecks Rail EC should give actual implementation to Directive 2001/14/EC "on the allocation of railway infrastructure capacity [...]" Freight paths have to be allocated in a transparent and non-discriminatory way with respect to passenger paths in all Member States. Railway capacity Positive "++" Positive "++" Positive "+" Positive "++" Positive "+" freight paths shoudl be given to authorised applicants 4 Bottlenecks Rail EC should harmonise train regulation rules along the key frieght corridors and give higher priority to freight on these corridors. Faster introduction of ETCS on freight corridors can increase capacity by 30%. Positive "++" Positive "+" Positive "+" Positive "+" Positive "+" 5 Bottlenecks Rail Railway capacity EC should implement freight-oriented networks, especially on key corridors. Infrastructure Positive "++" Positive "+" Positive "+" Positive "+" Positive "+" Although rail freight-oriented corridors would be welcome, it is a long-term solution. In the shortmedium term, full implementation and enforcement of the first and second railways packages is necessary 6 Bottlenecks Lack of connections capacity / lack of connections (all modes) EU should finance investments for intermodality development (e.g. Improve direct links between main corridors and logistics nodes, including through financing, address for structural funds and EC's initiative programmes) Infrastructure Neutral Positive "+" Neutral Neutral Neutral Money is needed to finance infrastructure, not uncertain and unspecified "links": research shoudl be financed, services must be economically viable. 7 Bottlenecks 8 Bottlenecks Encourage integration of networks with urban areas, including through financing. EU should finance infrastructure (e.g. freight hubs and related links, parking areas) to improve goods distribution efficiency in urban areas. Lack of integration of air and rail freight Promote for air/rail interoperability for freight Bottlenecks survey 9 Bottlenecks All areas To institutionalise the dialogue with logistics actors and provide for annual reporting on follow-up to the bottlenecks identified. Infrastructure Neutral Neutral Neutral Neutral Neutral too vague, best left to business Equipment Neutral Neutral Neutral Neutral Neutral Positive "++" Positive "+" Positive "+" Positive "+" Positive "+" dedicated projects elaborate their interfaces autonomously The impact of such action will depend on the efficiency in resolving bottlenecks Bottlenecks Rail Impossibility for logistics service providers to ask for rail slots Enable logistics service providers to become 'authorised applicants' Positive "++" Positive "+++" Positive "++" Positive "++" Positive "++" The first and second railways packages have not yet produced their effects and service quality is still not up to customers' expectations. Allowing logistics service providers to become 'authorised applicants' would surely foster competition and thus drive up service quality Bottlenecks Rail No uniform implementation of EU legislation on rail freight liberalisation EC should monitor such implementation and enforcement and discipline Member States lagging behind Positive "++" Positive "++" Positive "++" Positive "++" Positive "++" The effects of a unfirom level of full and fair competition in rail freight in the EU would be very ppositive. Indeed, figures show that service quality has risen in those countries where competition is fully in place 10 Lack of an intermodal liability regime Simpler and uniform liability framework for to be introduced by a Multimodal Convention Procedures Neutral Neutral Negative "--" Neutral Negative "-" A EU-only liability regime would only add costs (insurance) - a convetion is beign developed by UNCITRAL, several regimes would just add more complication. 11 Cost of administrative compliance Simplification and rationalisation of customs legislation, systems and procedures CLECAT would need further details on measure senvisaged to refine its assesment. This said, Customs and administrative procedures is generally positive. 12 Simplification and rationalisation of customs legislation, systems and procedures Promote a Single Window (or One-stop Shop) to all Customs Authorities. Procedures Positive "++" Positive "++" Positive "+" Positive "+++" Positive "++" This work is currently undertaken within the modernisation of the Community Customs Code. Ideally, Single Window concept should also embrace all import and export related procedures and formalities but this is a very longterm work. 13 Road Efficient use of road infrastructure Review current vehicle size and weight restrictions Positive "+++" Positive "+++" Positive "+++" Negative "-" Positive "+++" Besides cost advantages and obvious consequences on congestion, emissions of greenhouse gases could be curbed Stakeholders' questionnaire Page 1

2 the EC Lack of clarity for the performance of raod cabotage operations Liberalise and/or provide clear definition of road cabotage (an in particular 'temporary character'), CLECAT maintains its position that cabotage should be free and unrestricted within the entire EU. This being said, the lack of an EU definition combined with the differences in national regulatory regimes on cabotage is a source of difficulties and legal uncertainties in road cabotage. There is therefore a need for clarification through an EU definition of road cabotage (and in particular its temporary character) and common rules on checks and controls. Lack of centralised information system on driving bans for heavy goods vehicles Set up an EU information system on driving bans for heavy goods vehicles Positive "++" Positive "++" Positive "+" Positive "++" Positive "++" Since a full EU harminisation of driving bans for HGV seems impossible, an EU information system would at least provide an extremely useful tool for logistics service providers for planning purposes. Stakeholders' questionnaire Page 2

3 the EC 14 Dimension containers so that they are equally suited for carriage by water, rail and road. Adopt an industry standard for an intermodal loading unit. Equipment Neutral Neutral Negative "-" Neutral Neutral CLECAT is not in favour of a brand new EU. being global, loading should be set internationally by ISO. In addition, we feel that 45' container can fulfill such intermodal prupose. Lack of legal certainty as regards international movement of 45' PW containers Review Directive 96/53 Equipment Positive "++" Positive "+++" Positive "+++" Positive "+++" Positive "++" Following EC interpretation of Directive 96/53, MS may allow 45' containers for national after 31 December Although such interpretation is to be welcome as a means to foster intermodal, only a revision of Directive 96/53 could provide legal certainty for international movement of 45' containers all over the Union. 15 training Lack of common in skill certification Promoting a Common European Competence Framework (identifying specific skills associated to different professional levels) Positive "++" Positive "+++" Positive "+" Positive "++" Positive "+" CLECAT acknowledges that proper logistics training is lacking. As a result, the industry has decided to build its own tuition schemes. Something could be done at EU level but CLECAT strongly suggests the involvement of the industry and promotes the professional drawn by FIATA, the worldwide freight-forwarding organisation ( that has a permanent training system managed and distributed in the world through its Advisory Body on Vocational Training. FIATA ABVT could play an important role in developing on the basis of its permanent training system, which has proved successful for a number of years Lack of adequate skills 16 training 17 training Reccomendation on a EU common training scheme to develop new courses to improve workers' operational capacities Evolving demands on skills of workers in the logistics. Promote training in the logistics professions and provide recognition of acquired competences, in the framework of actions in support of lifelong development of competencies and qualifications lack of common in traning in logistics training training promote common standard in concjunction with FIATA & CLECAT 18 Security risks generated by or affecting freight Develop European which comply with existing legislation and international conventions and international and facilitate secure interconnectivity in the logistic chain. A certain level of compatibility between the various security legislation and (aviation, Customs, maritime) could be achieved and would be desirable. 19 Service quality Lack of a quality label for logistics Promoting a unique certification through a "building blocks" mechanism (awarded on the basis of both ISO and CEN certifications in quality management, environmental management and security of the supply chain) Neutral Neutral Negative "--" Neutral Negative "--" The EU logistics has achieved an excellent level of service without any legislative framework or quality labels. The added value of an EU quality label is therefore doubtful. In addition many logistics companies are ISO certified. The creation of an EU quality label would not only put our companies at a competitive disadvantage compared to world competitors, it would also entail high costs that many SMEs could just not face. Securing the credibility of "green" labels for freight 20 Service quality Setting minimum applicable to "green" labels, including for verification. Service quality Service quality Positive "+" Positive "+" Neutral Negative "-" Positive "+" CLECAT agrees that setting an EU 'green label' based on minimum would be useful and positive to the image of freight. Stakeholders' questionnaire Page 3

4 the EC 21 Price and service level transparency of the freight logistics market Promote the establishment of an open and interoperable environment for logistics transactions (emarketplace) Neutral Neutral Neutral Neutral Neutral Fully transparent prices are one of the main characteristics of planned economies. Market economy being however in place in the EU, CLECAT is unsure what kind of objectives the European Commission is after. Market offers hundreds of solutions that are efficient and cost effective. why wastig public money on objectives that offered on the market already? 22 End-to-end freight planning and monitoring. Promoting harmonization of information systems for traffic and infrastructure management. Infrastructure Positive "+" Positive "++" Neutral Positive "+" Neutral Many logistics companies have heavily invested in such technology as part of the service they offer to their clients. Although the idea in itself is attractive, CLECAT feels it may be difficult to ask companies who have successfully invested in the development of ICT solutions for their relations with their clients, to change their systems to new. 23 Tracking goods across modes Develop solutions in order to provide an integrated view on the movement of freight across modes, including through research funding. Equipment Positive "+" Positive "++" Neutral Positive "+" Neutral See item Multitude of freight-accompanying documentation Develop a waybill Procedures Negative "---" Negative "---" Negative "---" Negative "---" Negative "---" Why adding another 27 different bills to the existing multitude? The chances of a harmonised EU bill are small, to impose the standard on the rest of the world the chances are ZERO. 25 Systems integration Direct financing to projects & research activities aiming at spreading ICT/ITS devices at lower costs Equipment Positive "++" Positive "+++" Positive "+" Positive "++" Positive "+" Stakeholders' questionnaire Page 4

5 the EC 26 All areas Emerging requirements to track and trace dangerous goods or livestock in near real time Establish a standard solution for the registration and storage of payload-related data and how to link this to vehicle or container movement Negative "---" Negative "---" Negative "---" Negative "---" Negative "---" Action line is incomprehensible. What is the result of linking payload related data to vehicle movements? Lack of standard information exhange system -administration Enhance standardisation of communication systems for the fulfilment of administrative formalities and procedures Positive "+" Positive "+" Positive "++" Positive "++" Positive "++" Use signle window concept 27 Statistical data Lack of data EC to set up a Programme to establish an EU Freight Data Framework, involving potential data providers. Procedures Negative "---" Negative "---" Negative "---" Negative "---" Negative "---" This is too vague for CLECAT to give an opinion. In addition, the object of this item seems very close to that of item Statistical data Lack of adequate statistics on logistics operations, in particular intermodal freight carriages. Voluntary contributions from industry on freight, storage and transhipment. CLECAT is involved in an EC project on the collection of intermodal statistics 29 Statistical data Absence of information about employment-related aspects of the logistics industry Analyse social aspects of the logistics in depth Negative "---" Negative "---" Negative "---" Negative "---" Negative "---" Not a task for EU institutions 30 Statistical data Obtaining access to information on mode alternatives for the carriage of freight Support the creation of promotion centres Negative "-" Negative "-" Negative "-" Negative "-" Negative "---" The knowledge of available and logistics solutions is within logistics service providers' expertise. It is also part of their expertise to propose the solution that best matches their clients needs in terms of cost, quality, efficiency and reliability. CLECAT therefore doubts there is a lack of knowledge of solutions within the logistics and therefore any need to create promotion centres. Activity of promotion centres might invade private companies commercial space, thus creating unfair competition. Statistical data Statistical data Stakeholders' questionnaire Page 5

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