ECSA representing the shipping industry from the EU and Norway refers to the Commission Communication on “A sustainable future for transport: towards an integrated, technology-lead and user friendly system. The Communication is a follow up to the 2001 White Paper on Transport Policy that was updated in 2006. It covers a reflection process involving stakeholders and transport experts. It prepares a new White Paper on transport policy for the next decennium that will be issued in 2010. ECSA participated in the Focus Groups and in the high level stakeholders’ conference that preceded the publication of the Communication.    

Having duly studied the Communication ECSA appreciates that the Commission has recognised that transport is an essential component of the European economy. The EU being a main global trading entity this is of course also valid for the global economy and trade.    

The Communication also recognises that a liberal trading environment i.e. market opening had led to more efficiency. This is valid for intra EU transport as well as for global transport services. Particularly in periods of economic crisis tendencies to introduce protectionist measures should be resisted by all means. For intra EU services enforcement of existing market opening legislation e.g. for the rail sector is essential.      

ECSA is surprised that reference is made to the decoupling of transport growth to GDP growth that was mentioned in the original 2001 White Paper and withdrawn with the review in 2006. The shipping industry wishes to reiterate that such a policy of delinking growth in transport from growth in trade is unrealistic and is conflicting with the Lisbon strategy. It would seriously hamper the competitive position of European industry and trade.   

 Safety and Security    

 As mentioned in the Communication the EU has for the maritime sector one of the most advanced regulatory frameworks for safety and pollution prevention (lastly with the Maritime Safety Package III). This legislation must now be applied and controlled. The European Maritime Safety Agency (EMSA) can play an important role in this respect.   

 With reference to piracy ECSA commends the work done by EU-NAVFOR. However, it is clear that the piracy situation is fragile and that ongoing efforts are essential.       

The Environment     

The environment and particularly air emissions are high on the agenda in all circles including in the shipping sector. In this field the inherent environmental characteristics of shipping should also not be overlooked. Indeed, in the context of the mass effect and the distance involved as well as the ongoing modernisation of ships towards more energy efficiency, shipping is one of the best performers on emissions particularly on carbon. Targeted research should further improve this performance.

   The International Maritime Organisation (IMO) delivered drastic reductions on Sulphur (SOX) in the context of MARPOL Annex VI in October 2008. On carbon emissions all eyes are now on the UN Conference taking place in Copenhagen in December 2009. Whilst technical measures are in process to further reduce carbon emissions of shipping most public attention is going to Market-Based Instruments (MBIs). Following detailed analysis ECSA has not expressed a firm preference for any specific MBI. However it has been made clear that shipping as a global business needs a global solution. The natural vehicle being the IMO. It should also not be overlooked that the industry has over the years done quite some efforts to reduce fuel consumption/CO2.       

Co-modality – Nodal Points – Infrastructure    

Within the policy of co-modality shipping services play a key role as logistic operators. This is not only so for over sea long distance services but also for short sea services. The promotion of short sea services within the context of co-modality should be further enhanced by using and combing the most appropriate transport modes on al fronts: efficiency, environmental friendliness, and other external costs such as accident, congestion and noise. The modal shift is a logical consequence of such an approach.    

Nodal points for shipping ports and port services need an ongoing adaptation to changes and a further improvement of efficiency. In this context an application of the principles brought forward in the Commission Communication of October 2006 on a European port policy is overdue.  

Though traffics have gone down with the present economic crisis an extension of port capacity and hinterland connections is a basic factor to make the policy of co-modality reality. The TEN-T should include such projects. In this respect it should be acknowledged that access to ports and basic infrastructure for hinterland connections are public good.  

The Human Factor

The competitive edge of the European economy and trade often lies with the quality of the people involved. Education to high quality levels and specialisation coupled with flexibility are essential for the European transport sector.

 For a global industry such as shipping services a global level playing field for its seafarers should be enhanced through the ratification of the Maritime Labour Convention of the ILO.      

The Competitivety of the European Transport sector    

The communication stresses that Europe is a world leader in many fields of transport. Enhancing this leadership is a key factor in preserving the overall competitiveness of the EU economy and will also provide an opportunity for the transport industry to serve new and expanding markets.        

Maritime services are de facto operating on the global market and faced with global competition. Through the efficiency of their services European operators are world leaders in shipping services and logistics. This position should be maintained and further enhanced. Therefore an appropriate operational framework creating a level playing field with global competitors is key.