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ETF Preliminary Comments on the Consultation Document on Logistics for Promoting Freight Intermodality

31 March 2006

The existing potential for growth in transport, including in terms of employment, justifies a strategic approach and for that reason we support this exercise. However, the fact that the Commission announces its intention to only address transport logistics, without involving terminals and hubs which include distribution centres, limits already the “strategy” concept and in the ETF view this should be reviewed. In fact, in addition to the general approach proposed by the Commission, there is a need to look into transport in the European Union with a sustainable vision, which necessarily implies an important regulatory role for the European Union and the Member States. Market has proved not to be able (and willing) to voluntarily progress towards sustainability. The ETF is ready to make its contribution to that important objective and for that reason is planning to engage in a serious debate on “a trade union vision on sustainable transport” to which it will invite the Commission, the Member States and other stakeholders to contribute.

The Commission announces its intention to develop intermodality, namely, through further integration of road, inland waterways, rail, Short Sea Shipping and deep-sea shipping for the transport of freight in Europe towards fulfilling the objectives of the Lisbon agenda and the White paper. The ETF agrees that some framework conditions have to be established at the European level. However, the ETF would like to draw the attention of the Commission to the fact that the Lisbon agenda is not just about prosperity and competitiveness but also about employment and social cohesion (“more and better jobs”) and the respect for the environment. The promotion of intermodality and the Communication to be adopted in June 2006 should also consider those aspects at the same footing.

Additionally, the Commission should promote research on the strategies of the “big players” in the supply, transport and logistics chain .Who are they? Which sub-sectors they develop, as for example, the courier-and express deliveries (DPWN, UPS, Fedex, TNT) , the contract logistics companies (used to be for example EXEL) , the car logistics (for example ANSA)?

The analysis of their strategies will also give an answer to the question ‘which logistics solutions and tools do they develop to promote intermodal integration in freight’, because this can be the cheapest as well as the safest way to carry freight from door-to-door and just-in time

If PROTRANS analysed the role of third party logistics providers and their impact on transport, it would be interesting to do the same for the fourth party logistics providers.

The ETF shares the Commission’s view that improving the infrastructure system should not just mean the construction of logistics terminals which might then become intermodal distribution centres “out of the blue”, but rather mean, according to the national/regional context, improving existing infrastructure as for example, inland ports, and constructing there, logistics terminals. The airports and ports where different transport modes may come together are privileged sites to provide space for the construction of warehousing and intermodal distribution centres. The TEN-T and the structural funds might provide the space and improve the infrastructure and interoperability of inland navigation or airport or seaport and rail. We are less convinced of the fact that public money should be provided to build distribution centres.

However, European public money might be used to promote better coordination and interoperability between short-sea service, ports, airports, hinterland connections and hinterland operations and in general for targeted co-ordination of all policies and developments to promote the most efficient intermodality for freight transport.

The ETF supports the Commission’s idea to create a group of focal points, bringing together representatives of respective national administrations, as well as a continuous dialogue between the European Commission, the focal points, relevant industries (service providers and customers) .The ETF takes the assumption that the involvement of European social partners representing the different transport modes involved in the logistics sector is implied in the idea to create a “neutral brainstorming platform for intermodal logistics”.

Much has been said and written on possible ways to eliminate bottlenecks in the transport chain. The ETF agrees in principle with the Commission’s proposal concerning common technical standards for intermodal loading units, with the use of electronic messages to simplify and speed up customs procedures, with a one-stop shopping where all customs and other formalities are carried out. However the Commission is certainly aware of the resistance from many actors to the introduction of new, European standards. A key priority at this level is harmonisation and in particular that of bureaucratic procedures, papers, customs, etc.

With respect to the Motorways of the Seas, the ETF is of the view that instead of identifying individual ports, the concept should rather be applicable to all ports areas and vessels complying with a series of criteria and standards.

The ETF would very much welcome a higher involvement of the European Commission in the coordination of the policies and developments to boost intermodality. However, that role can not be limited to regulating and creating the conditions for more intermodality, but as well for better intermodality in the interest of the Community, which is not necessarily the same as that of the actors in the transport industry.

On the other hand, the ETF has serious doubts about the efficiency of a certificate of an intermodal logistics quality in transport. Nevertheless, if there should be one, it ought to include the respect of social legislation, including trade union rights. The ETF considers priority should be given to the coordination of policies and measures which improve the connections and interoperability between the different freight transport modes. The ETF would not support measures or a policy that would promote or favour big integrators which already dominate the market and more particularly if this would be done with public funding.

On training and skills as well as competences in logistics, the ETF draws the attention of the Commission to the IRU-ETF Joint recommendations on the development on training and employment in logistics adopted in November 2005. All Member-states, under the umbrella of the Commission, should develop statistics on employment in logistics and lifelong training should be provided to workers in the sector, according to national practices.

The ETF is also surprised that the Commission does not mention the NOVALOG study on innovation and competences in logistics and which was financed by the Leonardo programme. This study is the basis for the social partners’ joint recommendations. Those recommendations constitute a solid argument to involve social partners in the promotion of intermodality and its logistics requirements.

For more information, please consult the website of DG Energy and Transport: http://www.europa.eu.int/comm/transport/logistics/consultations/index_en.htm

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