REGULATORY SCRUTINY BOARD OPINION Proposal for a DIRECTIVE on harmonised river information services (RIS) on inland waterways in the Community

EUROPEAN COMMISSION
Brussels, 28.9.2023
SEC(2024) 38 final
REGULATORY SCRUTINY BOARD OPINION
Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL amending Directive 2005/44/EC on harmonised river information services
(RIS) on inland waterways in the Community
{SWD(2024) 15 final}
{SWD(2024) 16 final }
Offentligt
KOM (2024) 0033 - SEK-dokument
Europaudvalget 2024
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This opinion concerns a draft impact assessment which may differ from the final version.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
regulatory-scrutiny-board@ec.europa.eu
EUROPEAN COMMISSION
REGULATORY SCRUTINY BOARD
Brussels,
RSB
Opinion
Title: Impact assessment / River Information Services
Overall opinion: POSITIVE WITH RESERVATIONS
(A) Policy context
River Information Services (RIS) stem from the RIS Directive and support traffic and
transport management in inland navigation. They also provide geographical, hydrological,
and administrative information about inland waterways and calamity abatement support.
This initiative aims to update the 2005 Directive in light of digitalisation and technological
advances. It examines options to provide an updated framework for the deployment and
use of harmonised RIS in the EU. It aims to enable improvements in the competitiveness
and safety of the sector, and its contribution towards the European Green Deal objectives.
(B) Summary of findings
The Board notes the additional information provided in advance of the meeting and
commitments to make changes to the report. However, the report still contains
significant shortcomings. The Board gives a positive opinion with reservations
because it expects the DG to rectify the following aspects:
(1) The report does not sufficiently explain the magnitude of the problem and the
urgency for the EU to act.
(2) The description of the policy options does not present clearly enough how
different options and policy measures would work in practice.
(3) The justification for various estimates used in the assessment of impacts is not
robust enough.
(C) What to improve
(1) The report should better explain the magnitude of the problems. The problem
definition should better distinguish the individual problems and their links with the
problem drivers and consequences. The analysis should demonstrate, with more evidence,
the urgency for the EU to act, reflecting the views of the most affected Member States. It
should set out the main bottlenecks that have been delaying timely implementation of the
Ref. Ares(2023)6586926 - 28/09/2023
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new standards. The report should also differentiate between problems affecting specific
Member States, regions, local authorities, private entities, or particular EU areas. It should
better elaborate whether there are particular concerns regarding safety, data protection, or
environmental and territorial concerns.
(2) The policy options section should bring out clearly the available options, presenting
genuine alternative approaches and bringing out the relevant policy choices. The
presentation of the options should better explain how the policy measures would work in
practice and which are the most important ones in ensuring the success of the initiative. It
should also explain what would be the responsibility of each actor, i.e. Member States,
regional authorities, private entities, etc. The option description and analysis should use a
simpler language, making it less technical and more accessible for the non specialist
readers.
(3) The analysis should be clearer on how different estimates were calculated, where they
come from and how robust and complete their assessment is. It should better assess the
reliability of estimates on environmental and social impacts which appear to be attributed
to increased punctuality, given that these drive the benefit-cost ratio. The report should be
more explicit as to how this initiative would increase punctuality under each option, given
that the study estimates cited as basis for the calculations were based on figures for railway
and it is unclear to which extent these can be used in the present context.
(4) The report should better explain what the initiative aims to accomplish exactly. To
achieve this, the general and specific objectives should be better structured, splitted in
order to fit with the problem drivers and expressed in SMARTer terms to ensure better
measurement and monitoring of effectiveness and ultimately success of the EU action.
The Board notes the estimated costs and benefits of the preferred option(s) in this
initiative, as summarised in the attached quantification tables.
Some more technical comments have been sent directly to the author DG.
(D) Conclusion
The DG must revise the report in accordance with the Board’s findings before
launching the interservice consultation.
If there are any changes in the choice or design of the preferred option in the final
version of the report, the DG may need to further adjust the attached quantification
tables to reflect this.
Full title Impact Assessment Report accompanying the Proposal for a
Directive of the European Parliament and the Council
amending Directive 2005/44/EC of the European Parliament
and the Council of 7 September 2005 on harmonised river
information services (RIS) on inland waterways in the
Community
Reference number PLAN/2021/11060
Submitted to RSB on 30 August 2023
Date of RSB meeting Written procedure
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ANNEX: Quantification tables extracted from the draft impact assessment report
The following tables contain information on the costs and benefits of the initiative on which
the Board has given its opinion, as presented above.
If the draft report has been revised in line with the Board’s recommendations, the content of
these tables may be different from those in the final version of the impact assessment report,
as published by the Commission.
I. Overview of Benefits (total for all provisions) – Preferred Option (PO-B)
Description Amount Comments
Direct benefits
Adjustment costs savings
for vessel operators,
expressed as present value
over 2025-2050 relative to
the baseline
EUR 72.1 million Recurrent adjustment costs savings for
vessel operators due to better quality
information and reduced efforts to collect
the necessary information to plan their
voyage.
Administrative costs
savings for vessel operators,
expressed as present value
over 2025-2050 relative to
the baseline
EUR 28.5 million Recurrent administrative costs savings for
vessel operators, due to reducing the need
for re-registering cargo information and
reporting cargo information to ports. These
administrative costs savings are driven by
the exchange of cargo-related information
through the eFTI mechanism, the exchange
of information through the RIS COMEX
platform, the new standards and technical
specifications for the exchange of
information with IWT ports and legal clarity
for personal data.
Adjustment costs savings
for RIS software services
providers, expressed as
present value over 2025-
2050 relative to the baseline
EUR 8.1 million Recurrent adjustment costs savings for RIS
software services providers due to improved
access to better quality information, which
will reduce the costs of their software
applications.
Administrative costs
savings for national public
authorities, expressed as
present value over 2025-
2050 relative to the baseline
EUR 30.6 million Recurrent administrative costs savings for
national public authorities through
electronic processing of cargo information
(instead of paper cargo reports) and the
phase out of national platforms that would
be gradually replaced by RIS COMEXT.
Indirect benefits
Reduction in external costs
of CO2 emissions, expressed
as present value over 2025-
2050 relative to the baseline
EUR 48.6 million Indirect benefit to society at large, due to the
tonnes of CO2 emissions saved, enabled by
the higher use of IWT and the shift away
from road transport. The reduction in the
external costs of CO2 emissions is estimated
at EUR 48.6 million, expressed as present
value over the 2025-2050 horizon relative to
the baseline.
Reduction in external costs
of noise emissions,
expressed as present value
over 2025-2050 relative to
the baseline
EUR 36.6 million Indirect benefit to society at large, enabled
by the higher use of IWT and the shift away
from road transport. The reduction in the
external costs of noise emissions is
estimated at EUR 36.6 million, expressed as
present value over the 2025-2050 horizon
relative to the baseline.
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I. Overview of Benefits (total for all provisions) – Preferred Option (PO-B)
Description Amount Comments
Reduction in external costs
of habitats, expressed as
present value over 2025-
2050 relative to the baseline
EUR 36.2 million Indirect benefit to society at large, enabled
by the higher use of IWT and the shift away
from road transport. The reduction in the
external costs of habitats is estimated at
EUR 36.2 million, expressed as present
value over the 2025-2050 horizon relative to
the baseline.
Reduction in external costs
of road congestion,
expressed as present value
over 2025-2050 relative to
the baseline
EUR 86.8 million Indirect benefit to society at large, enabled
by the higher use of IWT and the shift away
from road transport. The reduction in the
external costs of road congestion is
estimated at EUR 86.8 million, expressed as
present value over the 2025-2050 horizon
relative to the baseline.
Reduction in external costs
of road accidents (fatalities
and injuries), expressed as
present value over 2025-
2050 relative to the baseline
EUR 115.8 million Indirect benefit to society at large, due to the
lives saved and injuries avoided, enabled by
the higher use of IWT and the shift away
from road transport and thus a reduction in
the road freight transport activity relative to
the baseline. The reduction in the external
costs of road accidents is estimated at EUR
115.8 million, expressed as present value
over the 2025-2050 horizon relative to the
baseline.
Administrative cost savings related to the ‘one in, one out’ approach*
Administrative costs
savings for vessel operators,
average per year relative to
the baseline
EUR 1.6 million on average per year Recurrent administrative costs savings for
vessel operators, due to reducing the need
for re-registering cargo information and
reporting cargo information to ports. They
are estimated at EUR 1.6 million per year on
average relative to the baseline, and they are
driven by: the exchange of cargo-related
information through the eFTI mechanism
(EUR 0.6 million), the exchange of
information through the RIS COMEX
platform (EUR 0.2 million), the new
standards and technical specifications for the
exchange of information with IWT ports
(EUR 0.5 million) and legal clarity for
personal data (EUR 0.3 million).
II. Overview of costs – Preferred option (PO-B)
Citizens/Consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurrent
Direct adjustment costs,
expressed as present value
over 2025-2050 relative to the
baseline
- - - -
For national
public
administrations:
EUR 18.3
million
-
Direct administrative costs,
expressed as present value
over 2025-2050 relative to the
baseline
- - - - -
For national
public
administrations:
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II. Overview of costs – Preferred option (PO-B)
EUR 75.3
million
Direct regulatory fees and
charges
- - - - - -
Direct enforcement costs - - - - - -
Indirect costs - - - - - -
Costs related to the ‘one in, one out’ approach
Total
Direct adjustment
costs
- - - -
Indirect
adjustment costs
- - - -
Administrative
costs (for
offsetting)
- - - -
Electronically signed on 28/09/2023 19:59 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121