The European Logistics Ecosystem is undergoing substantial changes as the European Union and its Member States, as well as other non-EU countries in the region, seek to decarbonise freight transport. Legislation is of course one way to achieve this, and there has been no shortage of work here at an EU level. However, the legislative framework has been subject to close scrutiny from many different stakeholders in European Logistics.
One of the organisations which has been following these developments very closely is the International Union for Road-Rail Combined Transport (UIRR), and its President, Ralf-Charley Schultze.
To get the UIRR’s thoughts on the legislation as it stands, and how it could impact modal shift, we spoke to Schultze himself.
During the interview, Schultze highlighted several concerns, particularly regarding the proposed allowance of 44-tonne cross-border road transport within the EU.
Health of rail freight
Before getting into the nitty-gritty of the legislative framework, Schultze acknowledged that the combined transport industry has been battling with numerous challenges of late, including high traction electricity prices, wars and their economic repercussions, as well as factors mitigating the quality of rail freight.
With regards to the latter, Schultze expressed concern about the impact that disruption from infrastructure works could have on rail freight in Germany:
“It’s sad to see the rail freight situation. For 30 years or so there was no investment done on the infrastructure side in Germany, and now they want to do everything at the same time. There are 40 huge works projects coming up until 2030, and there will be prolonged line closures with each for six months or even more. In the absence of adequate diversionary routes, operating freight trains in Germany will remain extremely difficult.”
CountEmissionsEU
When it comes to the aforementioned legislation, Schultze made it clear that the UIRR likes some of the plans more than others.
“I think it’s good to have it, but we still have to work on it and I don’t think it will be until the autumn when the legislation gets through the EU legislative machine,” Schultze said regarding the CountEmissionsEU initiative, one of the components of the EU’s Greening Freight Transport Package.
Schultze also expressed concerns about the initiative’s lack of ambition, particularly regarding mandatory emissions measurements and the inclusion of small and medium-sized enterprises.
Rail infrastructure capacity management
Regarding the EU’s regulatory framework on rail infrastructure capacity management, Schultze and his UIRR colleagues are generally positive. He believes there are „a lot of good ideas in it”, and likes the aim of achieving 4% more and better quality capacity as an initial step.
Schultze nonetheless admits that better quality is also required besides additional capacity.
“We need to get rid of all these disruptions. The new Capacity Regulation will bring planning and coordination processes that minimise the disruptions based on a socio-economic and environmental cost-benefit analysis.” the UIRR President told Trans.INFO.
Speaking of capacity, Schultze also denied the notion that rail freight is pretty much full to capacity as it stands:
“Of course, I often hear there’s no capacity, but that’s why we have the Rail Infrastructure Capacity Management plan. The current capacity reserve is over 15 to 20%, and with each infrastructure project this grows further. This is the biggest leverage we have, and it’s not true that there’s not enough capacity everywhere. Look at the Eastern half of Europe there’s certainly more than enough capacity, albeit there are some bottlenecks which cannot be ignored. By making passenger trains longer the same passenger transport performance can be provided with fewer trains potentially opening up additional train paths for freight. And rolling stock is always cheaper than building new infrastructure.”
The UIRR President also noted the importance of the Trans-European Transport Network, and the allowance of 740 metre trains and the 4m corridor, which have the ability to boost rail freight and its productivity.
Weights and Dimensions Directive
One clear point of contention for Schultze and the UIRR is the Weights and Dimensions Directive. Schultze described the proposals in the directive as “extremely shocking,” arguing that the directive would likely undermine efforts to promote intermodal transport while reducing CO2 and pollutant emissions.
“If the aim is to maintain the 76% share of road transport or even to enhance it, and to have more traffic on the roads, then the proposed measures are the right ones,” Schultze complained. “Our trust now lies in the European legislative process where corrections are still possible,” he added.
Schultze’s comments contrast sharply with those made by the International Road Transport Union (IRU), which has generally given the directive the thumbs up.
“IRU welcomes the European Parliament Transport Committee’s decision to allow up to six additional tonnes for zero-emission vehicle combinations as well as the 12.5 tonne allowance on the drive axle. This compensates for load capacity losses due to the weight of zero-emission technology, such as batteries, and eases challenges for weight distribution in road passenger and goods transport,” said the organisation, in a statement concerning the vote made on February 14th.
44-tonne cross border transport
Schultze then went on to caution against allowing heavier trucks, arguing it would lead to a modal shift away from rail and thus hamper sustainability goals.
“The measures in the Weights and Dimensions Directive are good for road transport efficiency only. You can’t tell me that these measures will do anything positive for intermodal or CO2 or pollutant emissions, which is exactly what the objective of the directive is announced to be. In our analysis of these measures, it was clear they’ll achieve the opposite of what was intended. There’s a real risk of modal shift from trains to trucks. As explained in the study, there could be anything from a 16% to 21% shift to road transport,” added Schultze.
Moreover, with regards to the road transport weight limits, Schultze stressed the importance of harmonisation at an EU level.
In his view, a maximum weight limit of 40 tonnes across the EU would be better than the situation whereby individual member states are allowed to unilaterally or bilaterally decide to go up to 44 tonnes. Schultze believes such harmonisation is essential for creating a level playing field and encouraging modal shift from road to rail.
“The 44 tonne cross-border rule as it is presented is not good when you have the intention to do more intermodal business, as you shouldn’t boost efficiency on the road. If you were to allow 44-tonne cross-border road transport between Belgium and France, I’m sure diesel-powered 44-tonne trucks would be working on the route for as long as they are permitted [2035]. What I hear from the market is that shippers will simply go with what offers a lower price.” Schultze told Trans.INFO.
The UIRR President continued:
“If the European Commission wants to harmonise, then do it at 40 tonnes, because the effect will be much higher – 40-tonne trucks consume less fuel. Similarly, when it comes to motorway speed limits for trucks, you can choose 130km/h, 150km/h or 100km/h. It has very clearly and scientifically been proven that a 100km/h limit delivers much less CO2 and pollutant emissions than 130km/h.”
In the opinion of Schultze, 44-tonne road transport is “not really needed” because the sectors that could utilise 44-tonne lorries, like the chemical industry, tend to do more intermodal when possible. Therefore, he believes it is counterproductive to allow companies to do the same transports via road at a lower cost. Instead, Schultze argues there should be incentives created to take more freight off the roads.
“If the competitiveness of greener transport modes is reduced, there will no longer be interest in taking cargo off the road. We’re looking for a level playing field here,” Schultze told Trans.INFO.
Giga-liners and the European Modular System
Another bone of contention here is the European Modular System (EMS), whereby so-called giga-liners may also cross borders. Schultze says that although these units are compatible with rail, they’ll only be efficient when using them on long distances.
Addressing the usage of the “Reverse Modal Shift” tag
Last week, Trans.INFO talked to Mike Sturgeon, Executive Director of the Association of European Vehicle Logistics, who was of the opinion that there “is no such thing as reverse modal shift”.
When we asked Schultze about the term itself and whether the criticism was fair, the UIRR President replied:
“I think it’s a fair argument and the word “reverse” is not the problem. If there is business which was never on the road, it’s not a reverse modal shift. However, in our study we talk about reverse modal shift precisely because there are the volumes that will go back to the road that are going by rail today. The shift itself, irrespective of whether you use the word ‘reverse’, is a scandal.”
Combined Transport Directive
Regarding the Combined Transport Directive, Schultze acknowledged some positive elements but raised issues regarding the definition of combined transport and its ambiguous implementation guidelines.
“We see it’s good to have a toolbox, a menu card with compensatory measures,” Schultze noted. „We think it’s also good that some of the driving bans don’t apply to combined transport road legs, which supports 24/7 operations.”
Schultze nonetheless noted that there are issues with the manner in which some terms are defined in the legislation. The UIRR President said that there are aspects of the current directive that are “ambiguous and lack legal certainty”. “Nobody has really defined what ‘appropriate’ actually means when you are referring to the nearest “appropriate” terminal,” Schultze told Trans.INFO.
On the plus side, Schultze likes the fact that the Combined Transport Directive takes into consideration external costs including congestion, fatalities, accidents, CO2 and pollutant emissions, road damage, and noise pollution. “They really have a very comprehensive approach, which we think is good,” said the UIRR President.
When it comes to these costs, Schultze implied that additional investments in road transport can generate huge cost burdens to society:
“We can’t forget the cost reductions that Member States should achieve through the Combined Transport Directive. Every Member State should achieve at least 10% of cost reduction. The point here is that for every million Euro that you give per year to road transport to be more under the banner of operational efficiency, society has to bear 5-times as large a burden through the related external costs.”
Elaborating on these costs, Schultze referred to the wear and tear that road networks would suffer from due to the use of heavier trucks. The UIRR President claimed that you need only look at some of the road infrastructure in countries where 44-tonne transport are permitted to get an idea of the scale of the impact.
On the flip side, Schultze also raised concerns about the values in the legislation being invalid when the new rules enter into force:
“The problem is that the revision of the Commission’s Transport Externality CE Delft Handbook, which forms the basis for the external costs, has just started., They’ve told us it will take another 24 months before the values for the new CE Delft handbook will be available. This is a real headache as the definition is based on values that won’t be valid in 2 year’s time. We have to rethink the definition. Perhaps a rule based on percentages would be a positive first step. It could be that a certain percentage of road is the maximum you can do before it cannot be considered as combined transport.”
Looking forward, what will the UIRR continue to campaign for?
Given what Schultze has said about the UIRR’s position on the aforementioned EU legislation and EU regulations, how will the organisation continue to exert its influence in this area?
Schultze told Trans.INFO that UIRR is meeting with the Commission regarding the study that was completed together with the rail freight sector, which is said to cover a number of the gaps in the Commission’s impact assessment.
The UIRR President maintains that himself and his colleagues are not “bashing road transport” when reciting empirical facts but want to see it predominantly limited to short distances in the first and last mile phases of combined transport operations. This, Schultze suggests, will bring benefits in that drivers will be able to return home at night, and the short distances will also lend themselves ideally to existing electric trucks.
“You need the right regulatory framework. It’s not about shifting 100% off the road to rail. Short distance transportation will not move to rail because it will never be economically viable. Once it gets to around 300-400 kilometres, you should think about it, and from 500 kilometres you should do it.”
Schultze stressed that in general, the Commission did make an effort to bring things together with regards to legislation. However, he also reiterated his opposition to the Weights and Dimensions Directive.
“We do see that some of the parts of our study have been taken onboard during the legislative process in the European Parliament’s transport Committee and we are happy about that. Nevertheless, the two main points of 44-tonne cross-border and the EMSs are still there. We will continue to fight against these as we don’t think it’s what society wants. It’s not the way Europe should legislate transportation,” concluded Schultze.