Here is a selection of our position papers or interventions:
At the end of its Parliamentary term and in election time the European Parliament has adopted the proposals on bus and coach passenger rights in first reading and introduced an unfeasible and impractical framework for passenger rights.
While EPTO welcomes initiatives to improve the attractiveness of bus and coach services, and recognise the value of creating comparable regimes for passengers throughout the travel chain, EPTO has strong reservations about the adopted proposal.
Commenting on the outcome the president of EPTO Michel Quidort said 'We feel disappointed about the outcome as the Commission's proposals were written with long-distance coach services in mind; local and regional bus services have very different characteristics. In particular, we believe that the proposal has not considered the specific needs of local and regional public transport.'
Secretary General Jan Möllmann adds ‘Most worrying is that some of the Commission's proposals are impractical for bus services - especially as they have not been considered in the EC's Impact Assessment. Especially the inclusion of buses in the proposed Regulation (but not other local transport modes) is illogical'.
New liabilities for matters that are outside the control of operators would make it difficult to secure appropriate insurance. Without insurance, services to the public could not continue.
The very good safety record of buses and coaches has shown in the past that action is not necessary to increase the financial and legal burden on bus operators and their passengers. Urban transport networks often offer travel options involving different modes (including regular bus, metro and light rail services).
EPTO believes that local transport services require a Regulation of this nature and are optimistic that the Council and the member states will help to develop a wise, realistic and feasible solution.
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Parliament votes on impractical framework for passenger rights
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The objective of the initiative has been the creation of new strategic framework for EU actions 2009-2014.
In its Green Paper on Urban Transport the Commission had asked for comments and answers to 25 dedicated questions deriving from 5 policy fields being:
The internalisation of external costs had been for discussion for many years. In August 2007 the European commission had launched a consultation on the internalisation of external costs caused by transport in general. In January 2008 the Commission published a handbook on the estimation of external cost in the transport sector.
The approach of the Commission focuses on the following factors causing external costs: 1) Congestion 2) Accidents 3) Noise 4) Air pollution 5) Climate Change.
From the point of view of Arriva and EPTO a modal shift from private car to public transport, and therefore an increased efficiency of public transport could be expected from internalisation of external costs of transport:
When judging the external costs of public transport and when allocating the funds coming from taxation and other measures related to the internalisation of external costs.
EPTO has asked the European Commission to follow the chosen way to internalise external cost but to take into account also the benefits of certain transport modes as public transport, e.g. social inclusion. Additionally EPTO has also asked the commission to take into account that on the one hand one important cost external factor, the land use, still is missing and that on the other hand the reference figure for comparisons and calculation of external cost should always be basing on values as passenger km or seat km.
The approach presented so far has still some more open points
The Community Guidelines on State Aid for Railway Undertakings were adopted by the Commission on 30 April 2008. The aim to provide guidance on the compatibility of Member State aids to railway undertakings with the EC Treaty.
EPTO welcomes the publishing of the new guidelines and especially the requirements for Member States to pay particular attention to competition, the situation of new market actors and the well-functioning of the railway market when proposing to grant state aids.
Download EPTO Stateaid Railways PDF document »
In December 2007 the Commission has adopted the directive on the promotion of clean and energy efficient road transport vehicles.
EPTO has commented on this guideline:
EPTO has written to the Commission and asked about the interpretation on the rules concerning the transition period for the implementation of the public service regulation, PSR.
The Commission confirms that contracts terminating during the transition period have to be put to competitive tendering when they finish. The transition period cannot be used to postpone the implementation of the Regulation until 2019 (end of the transition period) by awarding contracts without consideration to what is specified by the Regulation.
EPTO has replied to the COM study »
EPTO has taken position on the further passenger railway market opening. Key points are:
A selection of position papers or interventions of members and partners:
Federatie Mobiliteit Nederland (FMN), Claim about Den Haag »