1. On a general level, the group welcomes the Commission’s initiatives to revitalise rail and to make intermodality more attractive to users.
2. More specifically, the group strongly welcomes the initiative to harmonise maintenance procedures of units across all transport modes. The current situation leaves it to the appreciation of individual organisations and modes to take measures in that respect. The group feels that harmonisation efforts in this field are urgently required. It therefore wishes to inform the Commission that, in the realm of the Technical Committee of INTERUNIT  (Chaired by Mr Muzio, Managing Director CEMAT), a working group has been set up to look at this issue. It also wishes to offer the Commission its expertise if it were required.
3. With regard to the creation of a new intermodal unit which could be used equally by all modes and which would progressively replace the existing fleets, the group wanted to share its views with the Commission and make the following comments:
3.1 A new family of intermodal units, versatile enough so that it could be used by all transport modes, would be successful and trigger investment from the industry only if economically viable. 3.2 Over the past years, the market has attempted to develop and launch more versatile units than the traditional swapbody. One can mention the Dutch project which aims to develop a unit with greater interoperability between road and rail. 3.3 However, although such initiatives exist, the European market has not embraced the idea of converting progressively to one type of unit only. The range of products transported by combined transport requires a range of adequate units. 3.4 One should also bear in mind that, in Europe, combined transport essentially represents an alternative to road. Over the past 15 years, road has been devising new technical solutions. To ensure and encourage the growth and development of combined transport, it is felt necessary to allow it to develop a range of technical products which respond to market expectations. 3.5 With regard to stackability, the group wanted to point out that, although stackable units present a clear advantage, they also still mean a greater tare weight. Nonetheless, it is true that specialised stackable units are beginning to appear on the market. 3.6 Finally, the group wished to suggest that the Commission could also encourage the development and harmonisation of intermodal units through promoting the concept of semi-trailers designed to be handled by grabs.