Grid of comments by the Groupe UIC du Transport Combiné
1.- General comments
- The CTG welcomes the initiative of an action plan supporting the organisers of intermodal freight transport.
- The organisation of door - to - door freight transport by combining different modes of transport to build high quality, efficient and sustainable intermodal transport solutions is at the essence of the past and present efforts of the intermodal community.
- This reflects the need for integrating the intermodal chain and for approaching the intermodal transport as an autonomous transport mode.
- The CTG does not feel however that setting up integrating organisations whose drivers would not be, first and foremost, market forces like demand, added value to the customer, competition, profit and shareholders value, would constitute a viable, lasting and in the end, helpful proposition.
- In the view of the CTG, this reality stemming from the market puts the neutrality requirement in doubt from the start, however desirable and indispensable the goal of integrating the intermodal chain.
- A lot of intermodal operators do already fulfil an integrating role, that could be further expanded. However, the parlous, or at least fragile financial status of most of the intermodal operators reflects the difficulty of this particular business in the present market conditions.
- Likewise, it does not look realistic nor useful to want to create and develop new and independent information systems, instead of seeking interfaces in order to use the existing ones in a more integrated and user friendly way.
- Nevertheless, the CTG is in full agreement with the need of working on the four courses of action proposed by the Commission, and is pleased at the perspective of developing joint proposals and common actions in this regard with the Commission and the other partners in the intermodal chain, like the shippers, the intermodal operators and the transporters and the transport organisers.
- Especially, the actions regarding the improvement of knowledge, awareness and understanding of intermodal transport, and the actions aimed at fostering the commitment and co-operation of transport users are of utmost importance in the eyes of the CTG.
- In that regard, of special importance to the CTG are the conditions of co-operation between the Railway Undertakings, on the one hand, and between Railway Infrastructure Managers, on the other hand.
2.- Comments on specific questions
- Does the paper correctly assess the problems and potential for intermodal transport ?
Problems and potential seem to have been correctly assessed. But any solution that discards the market motivations of any integrator and the role already played in that regard by the existing intermodal operators, does not look viable to the CTG.
- Is the emphasis on improving management of the chain by "freight integrators" shared?
The CTG shares the emphasis on improving management of the chain. However, for the CTG, this improvement should best be left to the actors of the chain and must be driven by market forces and not by regulation. But the Commission can assist in this evolution by helping in the different areas of action.
- Are the solutions proposed suitable ? What additional ones should be considered?
See the statements in the General Comments and in the answers to specific questions 1 and 2. We would also refer REFER Infrastructure Manager from Portugal to the CGT position paper on the harmonisation of intermodal loading units. SQAS for Intermodal transport must be urgently developed. User friendly interfaces between the existing tracking and tracing systems must be encouraged and developed. CTG is working on a pilot and demonstration project in this domain. The railway infrastructure capacity reserves through 2010-2015 are being reviewed by the CTG, in order to establish how the Intermodal community will be able to cope with a growing business on a constrained infrastructure.
- What significant action could the European Union take in order to improve intermodal liability regimes ? What could be the benefits of such actions ?
Actions in this domain could be left to the bodies currently dealing with the issue (such as the United Nations).
- How can the widespread use of information and communication technologies be stimulated?
Support for pilot projects through the continuation and extension of research programmes. Public fora where experiences are shared.
- What incentives could further stimulate the use of intermodal transport ?
Urgent joint work on improvement of knowledge, awareness and understanding. Likewise, on the fostering of commitment and co-operation, extension of Marco Polo programme. Examen Review and extension of the various European and national legislations and regulations regarding Intermodal transport, including subventions, Special treatment of Intermodal transport regarding infrastructure charges.