Memorandum to Czech Presidency and Ten Test - EEB

EEB Memorandum to the Czech EU Presidencyand robust. One of the key conclusions from the IMPACT study undertaken forthe European Commission, which underpins the upcoming proposal, is that‘scientists have done their job (...) general figures (within reliable bandwidths) areready for policy use.’We regret that the Commission’s proposals are not sufficient to enable MemberStates to reorganise road freight transport in the most sustainable and futureorientedway. Only if road users are encouraged to take real costs into accountvia a price signal will they react in a way which minimises the costs to society,public health and the environment, whilst maximising transport efficiency (byoptimised use of capacity of infrastructure and cleaner vehicles).The Directive should encourage Member States to internalise the costs of climatechange (GHG emissions) caused by lorries, in order to fully take into account thepolluter pays principle as outlined in the Treaty. Whilst recognising that thesecosts could also be effectively addressed through fuel taxation, it is inappropriatefor the EU to prohibit Member States from having the choice of internalising theclimate costs of road transport (as is currently the case).The Commission has reneged on the long-held ambition to allow Member Statesto internalise the accident costs caused by lorries. This is incomprehensible froma scientific perspective and also marks a u-turn from the 2003 proposal (COM2003/448) for the previous review of the Directive, which proposed including amethodology to internalise accident costs in road charges. The scientificevidence has become more robust in the last five years and the severity ofaccidents involving trucks across Europe undoubtedly merits new policy impetus.The IMPACT handbook clearly shows that a substantial portion of accident costsis not internalised through insurance premiums or other risk anticipationconsiderations. For example, the costs of emergency services and the temporaryclosure and clean-up of motorways are currently paid out of the general budgetrather than by road users. Exclusion of accident costs will rule out an importantopportunity to improve road safety.Time-based vignettes have no place in a ‘smart charging’ framework, yet theyare currently used in 11 EU Member States. In contrast to distance-basedcharges, fixed charges per day, per month or per year do not encouragetransport efficiency or help to meet environmental targets. In fact, time-basedvignettes give a perverse incentive to drive more during a given time period. Withthe falling technical implementation costs of distance-based charging systems,the time has come to consider a mandatory transition from vignettes to distancebasedtolls. Experiences with existing smart km-charging systems in Austria,Germany and Switzerland confirm that these schemes contribute to efficiencyand competitiveness within the transport sector, as the price signal from kmpricingresults in improved use of vehicle and infrastructure capacities, a fastertransition to cleaner vehicles and no negative economic impact.17