The main elements that the Commission should be taking into account
when setting a vision for the Future of Transport
1. The current economic context, the uncertainty of how recession will develop over
the years and its impact on transport
2. The close link between transport and economy should be further put forward
3. Policy must be based on a cross-modal understanding of the whole transport
system rather than on a modal approach
4. Fleet renewal is key for bringing pollutant emissions close to zero
5. An integrated approach is needed for reducing CO2 emissions, including a fiscal
policy that does not lead to market fragmentation
6. Further infrastructure investments can no longer be delayed
7. Good statistics are indispensable for a sound transport policy
8. A better impact assessment has to be the basis for future initiatives as part of the
better regulation agenda

ACEA, the European Automotive Manufacturers Association, very much welcomes that the Commission starts preparing the vision for the future of transport now that the ten
year period of the 2001 White Paper on Transport Policy setting the transport guidelines is coming to an end. ACEA looks forward to the publication by the Commission of a
Communication on the Future of Transport in June 2009 and hereby submits to the Commission its contribution to the debate.

Commission’s consultation procedure
According to the Commission, the content of the June 2009 Communication would be made by various contributions coming from (a) the TRANSvisions 2050 Study (not yet
released), (b) an evaluation study analyzing the performance of the Transport Policy in
reaching the objectives of the 2001 White Paper and its 2006 mid-term review (not yet released), (c) a report on the drivers of transport activity (the Focus Groups’ Report) and (d) the stakeholders’ comments.

However, ACEA regrets that the only background, written document currently available(March 2009) is the Focus Groups’ Report on the Future of Transport of 20
February 2009. Whereas the report has the merit of summarizing a number of transportrelated
important topics, it is a mere compilation of more or less accurate facts (for ACEA detailed comments on the Report, see attachment). We believe that reflecting on
the Future of European Transport deserves a much more scientific approach.

Ideally, stakeholders should have been given the possibility to comment on the TRANSvisions 2050 Study, which was supposed to develop, by using a scientific
methodology, a set of long-term scenarios for transport and mobility in Europe.

Moreover, stakeholders would have appreciated having access to the Commission’s evaluation study analyzing the performance of the Common Transport Policy in reaching
the objectives laid down in the 2001 Transport White Paper and its 2006 mid-term review.

Despite the very few discussion material that has been made available by the Commission, ACEA is putting forward general comments on the Future of Transport Policy, and looks forward to a more informed consultation procedure before the publication of a new White Paper on Transport Policy in 2010.

The main elements that the Commission should be taking into account when setting a vision for the Future of Transport
1. The current economic context, the uncertainty of how recession will develop over the years and its impact on transport

We are facing an unprecedented crisis that is twofold in nature: financial (a drastically limited access to credit) and economic (a dramatic drop in demand). Two months into the year 2009, the European market of new registrations of passenger cars is down 22.6% compared to January-February 2008 and European registrations of new commercial
vehicles contracted by 37.2%, reflecting a significant drop in demand for all four categories: -37.4% for vans, -40.5% for heavy trucks, -38.4% for trucks and -17.4% for
buses and coaches. The crisis had not been anticipated and nobody knows exactly how long it will last and which will be its actual impact on the economy and on transport in
particular. But there is no doubt that it will have one and that the initial EU expectations of a GDP growth close to 2% per year are no longer valid.

2. The close link between transport and economy should be further put forward

Transport must be seen a part of the European sustainable growth and competitiveness.
The 2006 mid-term review of the Transport Policy White Paper of 2001 showed a more positive approach to transport issues in general than in the past, but did not fully
recognized the importance of road transport, which fulfils and will be fulfilling such an overwhelming majority of the transport needs of companies and individuals in
Europe. The Commission should base its policy on a much more positive approach to road transport.

Moreover, the Commission must help improving the image of the transport sector in general and road in particular by highlighting the benefits it brings to the society and
its direct link to GDP indicators. All efforts should be made to avoid burdening the sector with additional taxes and charges.

3. Policy must be based on a cross-modal understanding of the whole

transport system rather than on a modal approach
A general Commission’s perception seems to be that all modes of transport compete with each other; the fact is that some modes are in competition for transport of certain
commodities but in general modes are complementary. One way of identifying which modes are in competition and which are complementary is to look at the value of the
goods that are transported by the different modes. Existing analysis of transport within EU demonstrate that the value of the goods is the main criteria for the selection of the mode to be used.

Despite the introduction of the principle of co-modality in the mid-term review of the Transport Policy White Paper of 2001, there is still a continuous reference to “modal
shift” in EU documents and initiatives. The wrong belief that some modes are by default better from an environmental point of view than others is at the origin of such a “modal shift” approach.

In freight transport, the reality is different and to a great extent it depends on the utilization of its maximum capacity, which depends on the volume and the weight of
transported goods, the need for loading and unloading, the density of its network, source of energy, energy need loaded compared with unloaded and specific needs with respect to the commodity to be transported.
Regarding the transport of passengers, Individual and collective transport offer different services and therefore fulfil different needs. They are not, as to often assumed, communicating vessels. Public transport plays without any doubt a crucial supportive role, mainly on mainstream routes. Its role can be enhanced if its service is further adapted to the needs of its users (comfort, flexibility, modal integration, etc.). A forced

modal shift policy based on traffic restrictions and increased costs for individual transport will lead to a high loss of welfare without the expected benefits for mobility and quality of life.

We firmly believe that the Commission has to avoid addressing transport policy on the basis of “modes of transport” but on the basis of “efficient transport”. Contrary to a wide spread belief that goes back to the 2001 White Paper, modal shift is suitable
from an environmental point of view in some very specific cases, but it is neither possible nor suitable in the majority of the traffic flows. It is not acceptable that the European Transport policy is based on the assumption that some modes of transport would be, by definition, more environmental friendly than others and should therefore be given preeminence over the others.

The Commission must encourage the transport sector being more innovative with the tools that it already has today. It has to promote that transport providers, and rail transport providers in particular, further incorporate in their business culture the principle of “customer service provider” instead of the one of “modal operator”. In road transport, an EU wide application of the “modular concept” that was introduced in 1996 is likely one of the the most cost-effective ways to address all the different concerns, including CO2 emissions, congestion and co-modality. It might now be opportune to seriously explore this modular concept for Europe, leaving aside some national interests that may risk harming the general interest of the whole EU.

4. Fleet renewal is key for bringing pollutant emissions close to zero

Pollutant emissions from road transport have been drastically reduced in the recent years and further progress will be obtained thanks to the new vehicles’ compliance with the upcoming Euro emission standards.
One car in the 1970s produced as many pollutant elements as 100 cars today. Compared to 1992 standards, EURO VI emission levels will reduce NOx and PM emissions of
commercial vehicles by 95% and 97% respectively.

With the beneficial effect of fleet renewal, the issue of air quality will lose importance over the years. Actions promoting the renewal of the existing fleet should be part of any future policy aiming at providing a sustainable transport system.

5. An integrated approach for reducing CO2 emissions, including a fiscal

policy that does not lead to market fragmentation
The greatest environmental issue for road transport remains the reduction in CO2 emissions. Great progress has already been made –partly offset by an increase of the
traffic flows- and will continue to be made, mainly driven by competition and market demand. The increased diversity of fuels and power trains is also changing the situation.
CO2 emissions from new passenger cars have been reduced by 14% since 1994. CO2 for a typical European 40t-truck has been reduced by 20% over the last 20 years Besides
technology, it will be imperative to address all the ways for reducing CO2 through driver/consumer behaviour and infrastructure, the so-called “Integrated Approach”.

(a) driver/consumer behaviour
as important as technology is consumer behaviour, such as the choice of the vehicle, which has a strong link to affordability, eco driving and fleet renewal. Fiscal policy has an important role to play in indicating behaviour to consumers. The current fragmented
approach across Europe is indeed ineffective.
(b) infrastructure
improved road infrastructure also offers significant potential for reducing CO2 by enhancing journey efficiency. Changes in fuel distribution infrastructure need to be supported where there is the potential to reduce CO2 emissions.
(c) vehicle technology
There will be an increased diversity of fuels and power trains in the market as innovations are made by energy suppliers and vehicle manufacturers to reduce CO2. The
European automotive industry is developing and investing in many technologies at the same time. It is impossible to say today which technology will prove to be the most
viable. Most likely, the future will see a number of technological combinations entering the market, perhaps tailored for different usage, driving locations or circumstances and consumer preference.
Alternative fuels can significantly help reducing CO2 emissions from vehicles.
Manufacturers have developed and adjusted engines for different kinds of alternative fuels. But now these alternative fuels will have to be developed and made available on a much larger scale and for this, action from fuel companies and public authorities is
needed.

6. Further infrastructure investments can no longer be delayed

Europe’s transport infrastructure, especially its road network, is falling behind what is required for a modern economy. This is mainly due to lack of investment. This has
contributed to bottlenecks and increased congestion and CO2 emissions. Spending on road infrastructure has fallen to dangerously low levels and this is one trend that must
be reversed, especially against the background of a further ageing road infrastructure and the need for increased maintenance. Europe should be funding key transport projects that will not only modernise Europe’s infrastructure, but will also help reducing negative
environmental impacts and will create millions of jobs by developing existing, new and smarter infrastructure, especially road. Europe should not be lagging behind other leading economies: it needs more Community funding for key transport projects. This is particularly so in view of the huge contribution that transport, and road in particular, has made and will still be making to the tax revenue of the Member States.

7. Good statistics are indispensable for a sound transport policy

Future policy must be developed on the basis of appropriate, comparable and reliable data, both on passenger and goods transport at EU level, in particular:

- on congestion;
- on purpose, origin and destination of passenger transport;
- on goods' weight, type of commodity and value by mode.

8. A better impact assessment has to be the basis for future initiatives as part of
the better regulation agenda

The full impact of future legislation in the transport sector must be properly assessed
during policy formulation within the Commission and before implementation as part of
the better regulation agenda. Legislation that has not been properly impact assessed can
have a detrimental and often unforeseen impact that can work against the competitiveness
of Europe and the thrust of EU legislation.

About ACEA
The ACEA members are BMW Group, DAF Trucks, Daimler, FIAT Group, Ford of
Europe, General Motors Europe, Jaguar Land Rover, MAN Nutzfahrzeuge, Porsche, PSA
Peugeot Citroën, Renault, Scania, Toyota Motor Europe, Volkswagen and Volvo.