COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 1999/62/EC on the charging of heavy goods vehicles for the use of certain infrastructures and Proposal for a Council Directive amending Directive 1999/62/EC on the charging of heavy goods vehicles for the use of certain infrastructures, as regards certain provisions on vehicle taxation

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    1_EN_impact_assessment_part2_v4.pdf

    https://www.ft.dk/samling/20171/kommissionsforslag/KOM(2017)0276/kommissionsforslag/1414093/1768891.pdf

    EN EN
    EUROPEAN
    COMMISSION
    Brussels, 31.5.2017
    SWD(2017) 180 final
    PART 2/2
    COMMISSION STAFF WORKING DOCUMENT
    IMPACT ASSESSMENT
    Accompanying the document
    Proposal for a Directive of the European Parliament and of the Council amending
    Directive 1999/62/EC on the charging of heavy goods vehicles for the use of certain
    infrastructures
    and
    Proposal for a Council Directive amending Directive 1999/62/EC on the charging of
    heavy goods vehicles for the use of certain infrastructures, as regards certain provisions
    on vehicle taxation
    {COM(2017) 275 final}
    {COM(2017) 276 final}
    {SWD(2017) 181 final}
    Europaudvalget 2017
    KOM (2017) 0276
    Offentligt
    2
    ANNEXES ..........................................................................................................................4
    1. ANNEX 1: PROCEDURAL INFORMATION CONCERNING THE
    PROCESS TO PREPARE THE IMPACT ASSESSMENT REPORT AND
    THE RELATED INITIATIVE....................................................................................4
    1.1. Organisation and timing ....................................................................................4
    1.2. Consultation of the RSB....................................................................................4
    1.3. Evidence ............................................................................................................6
    1.4. External expertise ..............................................................................................7
    2. ANNEX 2: STAKEHOLDER CONSULTATION SYNOPSIS REPORT.................8
    2.1. Consultation strategy.........................................................................................8
    2.2. Results of the open public consultation.............................................................9
    2.3. Results of the targeted consultation.................................................................12
    2.4. Results of the stakeholder seminars and conference .......................................17
    2.5. Conclusions and use of the results...................................................................18
    3. ANNEX 3. WHO IS AFFECTED BY THE INITIATIVE AND HOW...................19
    4. ANNEX 4. ANALYTICAL MODELS USED IN PREPARING THE
    IMPACT ASSESSMENT .........................................................................................22
    4.1. Description of analytical models used.............................................................22
    4.2. Baseline scenario.............................................................................................27
    4.3. Detailed description of the policy measures and assumptions used in the
    Policy Options .................................................................................................38
    5. ANNEX 5: ROAD CHARGING SYSTEMS IN THE EU .......................................54
    6. ANNEX 6: IMPORTANCE OF ROAD CHARGES IN HGV OPERATING
    COSTS IN THE EU ..................................................................................................60
    6.1. Uneven playing field in freight transport ........................................................60
    7. ANNEX 7: VIGNETTE PRICES FOR LIGHT DUTY VEHICLES .......................63
    8. ANNEX 8: ROAD ASSET CONDITION AND MAINTENANCE FUNDING .....64
    8.1. Issues with road maintenance funding in Member States ...............................64
    9. ANNEX 9: SCOPE OF AND REVENUES FROM ROAD CHARGING IN
    MEMBER STATES ..................................................................................................66
    10. ANNEX 10: LEVELS AND DIFFERENTIATION OF ROAD CHARGES...........71
    11. ANNEX 11: PRE-SELECTION OF POLICY MEASURE AND
    PACKAGING OF OPTIONS....................................................................................75
    11.1. Rationale behind retained measures ................................................................75
    11.2. Discarded policy options (measures)...............................................................82
    12. ANNEX 12: ASSESSMENT OF MEASURES AIMED IMPROVING ROAD
    QUALITY .................................................................................................................85
    12.1. Impacts on road quality ...................................................................................85
    12.2. Main economic impacts...................................................................................86
    12.3. Main environmental impacts ...........................................................................87
    3
    12.4. Main social impacts.........................................................................................87
    12.5. Comparison of options to improve road quality..............................................88
    12.6. Overall conclusion / preferred option..............................................................89
    13. ANNEX 13: IMPACT OF CONGESTION CHARGING ON LOCAL
    COMPETITIVENESS...............................................................................................90
    13.1. Approach .........................................................................................................90
    13.2. Methodology....................................................................................................91
    13.3. Model results ...................................................................................................93
    14. ANNEX 14: SME TEST ...........................................................................................94
    14.1. Consultation with SME representatives ..........................................................94
    14.2. Assessment of businesses likely to be affected ...............................................95
    14.3. Measurements of the impacts on SMEs ..........................................................96
    14.4. Assess alternative options and mitigating measures........................................98
    15. ANNEX 15: THE ROAD INITIATIVES – THE 'BIG PICTURE'...........................99
    15.1. Introduction .....................................................................................................99
    15.2. The EU road transport market .........................................................................99
    15.3. Why is there a need for action? .....................................................................100
    15.4. What are the main problems? ........................................................................101
    15.5. Options and main impacts .............................................................................101
    15.6. Expected synergies of the package................................................................103
    BIBLIOGRAPHY ...........................................................................................................104
    4
    ANNEXES
    1. ANNEX 1: PROCEDURAL INFORMATION CONCERNING THE PROCESS TO PREPARE THE
    IMPACT ASSESSMENT REPORT AND THE RELATED INITIATIVE
    1.1. Organisation and timing
    The Directorate-General for Mobility and Transport is the lead service for the preparation
    of the initiative (2016/MOVE/004) and the work on the impact assessment.
    An inter-service steering group (ISG), chaired by the Secretariat-General, was set up in
    May 2016 with the participation of the following Commission Directorates-General: Legal
    Service; Economic and Financial Affairs; Internal Market, Industry, Entrepreneurship and
    SMEs; Environment; Climate Action; Communications Networks, Content and
    Technology; Joint Research Centre; Regional and Urban Policy; Taxation and Customs
    Union; Justice and Consumers.
    Invitations were also sent to DG Competition; DG Employment, Social Affairs and
    Inclusion; DG Energy; DG Neighbourhood and Enlargement Negotiations.
    The ISG met three times between the end of May 2016 and the end of February 2017,
    discussing the inception impact assessment, the terms of reference for the external study,
    the questionnaire for the public consultation, as well as subsequent reports of the support
    study and the draft impact assessment.
    1.2. Consultation of the RSB
    The Regulatory Scrutiny Board received the draft version of the present impact assessment
    report on 1 March 2017 and following the Board meeting on 29 March 2017 issued a
    positive opinion with reservations on 31 March 2017. The Board made recommendations.
    Those were addressed in the revised IA report as follows:
    RSB recommendations Modification of the IA report
    (1) The introduction of a new objective on CO2 reduction is
    not sufficiently justified. As stated in the evaluation and the
    impact assessment, road charges are not the most cost-
    effective way of reducing CO2 emissions. In addition, the
    report does not sufficiently demonstrate the proportionality
    and complementarity with other environmental charges and
    taxes linked to the ownership and use of vehicles;
    Explanations on the proportionality
    and complementarity in relation to
    other environmental charges and
    taxes linked to the ownership and
    use of vehicles have been added in
    section 2.2.1.
    (2) The impact assessment does not treat earmarking of
    revenues of road charges in a consistent way. While
    earmarking is in principle excluded on subsidiarity
    grounds, the preferred option makes it mandatory in the
    case of congestion charges;
    Explanations on the reasons for this
    differentiation have been added in
    section 11.1.
    (3) The problem definition does not clearly describe the
    main design deficiencies of the Eurovignette Directive. It
    does not sufficiently explain the main obstacles for
    increasing Member States' uptake of road charging;
    Further explanation has been added
    to the problem definition (section
    2.2).
    (4) The report lacks a clear explanation of the reasons for
    discarding certain options (e.g. mandatory road charging,
    earmarking revenues) and for introducing new reporting
    requirements. The report does not describe the reasons for
    Explanations on the reasons for
    discarding mandatory road charging
    and generalised earmarking of
    revenues, as well as on phasing-
    5
    introducing phasing-in periods for different option elements
    and their necessary duration;
    in/out measures have been added in
    section 11.2.
    (5) The analysis does not clearly present the expected
    contribution of this initiative towards reducing CO2
    emissions, improving quality of roads or reducing air
    pollution and congestion. It does not identify whether any
    Member States are particularly affected and how;
    The contribution towards reducing
    CO2 emissions is now presented
    under section 6.2.1. The contribution
    to the necessary investment in road
    maintenance is presented in section
    6.1.6. Most affected Member States
    will be those where road quality is
    bad, as indicated in sections 2.1.2
    and 2.2.2. The contribution to reduce
    air pollution and congestion is
    described in sections 6.2.2 and 6.1.2.
    (6) Although this is a REFIT initiative, the report does not
    sufficiently develop the possibilities for simplification of
    the Directive and its implementation, and the quantification
    of the administrative burden.
    More details have been added in
    section 7.3 as well as under the
    description of options (section 5).
    The quantification of costs to
    authorities is provided in section
    6.1.4.2, while the
    administrative/compliance costs for
    users in section 6.1.5.
    Further considerations and adjustment
    recommendations
    (1) Context and problem definition
    The report should briefly describe how the Eurovignette
    Directive has worked so far and identify the main
    shortcomings in its design. It should explain the main
    obstacles for increasing Member States' uptake of road
    charging, including for light duty vehicles. The report
    should clarify why many Member States prefer time-based
    vignettes. It should better justify the need to extend the
    scope beyond HGVs.
    More explanation has been added in
    section 1.3 as well as in section 2,
    the description of the problem
    definition, and in particular the
    drivers.
    (2) Objectives
    The report should better justify the CO2 emission reduction
    objective of this initiative; given that, the report recognises
    that internalising external costs of emissions in the fuel cost
    would be a better instrument. It should demonstrate the
    consistency with other instruments contributing to the same
    objective (e.g. fuel taxes, vehicle registration taxes, CO2
    emission standards) and discuss whether there might be
    risks of duplication. The report should clarify if the
    initiative has an explicit simplification objective.
    An explanation on the consistency
    with other instruments (e.g. fuel
    taxes, vehicle registration taxes, CO2
    emission standards) has been added
    in section 2.2.1.
    (3) Options
    The report should better explain the choices made
    regarding the content of the options. For example, why is
    an option of making road charging mandatory discarded
    while at the same time proposing phasing-out time-based
    vignettes? It should explain why revenues from congestion
    charging are earmarked for investment in roads or mobility
    solutions, even though overall earmarking of revenues from
    road charging has been discarded due to subsidiarity
    concerns. The report should better justify the introduction
    Partly covered by point 2 above;
    more explanation has been added
    under the options (section 5).
    6
    of inter-urban congestion charging. It should explain why,
    in the absence of earmarking of toll revenues, Member
    States need to report on their toll revenues and expenditure
    on toll road maintenance to improve the overall quality of
    roads. In contrast, the option does not foresee reporting on
    the proposed road quality indicators, which risks limiting
    their usefulness. The report should also describe for which
    option elements phasing-in periods are foreseen and what
    would be the appropriate duration.
    Reporting does include information
    based on quality indicators – the
    description has been corrected in in
    section 5 with more detail provided
    under Annex 11 (section 11.1.).
    (4) Impacts
    The report should present what contribution is expected
    from this initiative towards reducing CO2 emissions from
    road transport, improving quality of roads or reducing air
    pollution and congestion. It should identify if any Member
    States are particularly affected and how. The report should
    describe if and to what extent an increased uptake of the
    distance-based road charging in Member States is expected
    (given that there is no obligation to introduce it). It should
    strengthen the REFIT dimension by better identifying the
    specific simplification potential. The report should also
    explain the implications of phasing-in different option
    elements over longer time.
    The contribution of the initiative to
    these goals is presented in the
    relevant subsections in chapter 6 and
    summarised in section 7.1. Changes
    in tolling revenues (6.1.4.1) as well
    as transport costs (6.1.1) are
    presented per Member State and
    particularly affected Member States
    are mentioned in the text.
    An increased uptake of distance-
    based charging is expected and the
    assumptions are introduced at the
    end of section 5 with detailed
    description in Annex 4.
    More explanation has been added
    under section 7.3 on the REFIT
    dimension and under options.
    The implications of phasing-in of
    distance-based charging (or the
    phasing out time-based schemes) are
    explained in the discussion on the
    preferred option, while detailed
    rationale for each measure are
    provided in Annex 11.
    1.3. Evidence
    The problem definition was based on previous evaluations carried out by the Commission
    as well as using external expertise (evaluation of the implementation of EU infrastructure
    charging policy since 1995, Update of the Handbook on external costs of transport1
    ),
    complemented by additional research used to update and substantiate the problems
    identified in those evaluations (see external expertise below). In particular the Handbook
    on external costs of transport was peer reviewed by a group of selected experts in the field,
    including representatives of academia.
    Regarding the current situation in road charging, evidence was based on information
    publically available on the websites of Member States/public authorities/road operators
    regarding the scope and levels of road infrastructure charges. For macro-economic trends
    1
    Ricardo-AEA et al (2014), Update of the Handbook on External Costs of Transport:
    http://ec.europa.eu/transport/themes/sustainable/studies/sustainable_en
    7
    as well as emissions, the Impact Assessment report builds on the Baseline scenario
    described in section 4. This Baseline scenario has been developed with the PRIMES-
    TREMOVE model by ICCS-E3MLab and draws on the EU Reference scenario 20162
    but
    additionally includes few policy measures adopted after its cut-off date (end of 2014) and
    some updates in the technology costs assumptions. As regards environmental data,
    European Environment Agency was used as data source.
    In addition, the Impact Assessment report relies on a previous Impact Assessment prepared
    in 2013, accompanying a proposal for Fair and efficient road pricing, which was not
    adopted in view of political opportunity reasons.
    1.4. External expertise
    As indicated above, the impact assessment work was based on previous evaluations and an
    impact assessment partly informed by external expertise.
    Following discussions with the ISG, a public tender for the impact assessment support
    study was launched in June 2016 and the consultant started working on the study in
    September 2016. Its reports (an advanced inception report including the definition of the
    problems, an intermediate report including assessment of stakeholder input, and a draft
    final report including the assessment of all major impacts) have been scrutinised by the
    ISG and commented by various services of the Commission.
    2
    ICCS-E3MLab et al. (2016), EU Reference Scenario 2016: Energy, transport and GHG emissions -
    Trends to 2050.
    8
    2. ANNEX 2: STAKEHOLDER CONSULTATION SYNOPSIS REPORT
    2.1. Consultation strategy
    Title: Impact Assessment for the revision of Directive 1999/62/EC
    Background: Directive 1999/62/EC (the "Eurovignette" Directive) provides a detailed legal
    framework for charging heavy goods vehicles (HGVs) for the use of certain roads.
    The Directive aims to eliminate distortions of competition between transport
    undertakings by achieving step-wise harmonisation of vehicle taxes and
    establishment of fair mechanisms of infrastructure charging. Following ex-post
    evaluations of the current legislative framework, the Commission has to assess the
    potential impacts of various options for a possible revision of the legislative act in
    question. The consultation of stakeholders is an integral part of the impact
    assessment process.
    Objective of the consultation
    Goal: The objective of the stakeholder consultation was to collect the views and opinions
    on the approach proposed in the Inception Impact Assessment. It was used to
    identifying gaps in the proposed intervention logic or areas requiring further
    attention.
    Scope: The consultation covered all elements of the impact assessment: problem definition
    and respective drivers/root causes, the issue of subsidiarity and the EU dimension of
    the problem, the preliminary options (policy measures). The consultation also
    allowed asking the stakeholders on their perception of the likely impacts of each
    option.
    Identification of stakeholders
    Stakeholders: Member States; Public authorities: Transport authorities/agencies in the Member
    States (CEDR)
    Industry and industry associations from the road sector:
    - infrastructure managers: ERF (association of stakeholders involved in
    construction, equipment and operation of Europe’s road network),
    - toll chargers and service providers: ASECAP (association of toll chargers), AETIS
    (association of prospective European Electronic Toll Service providers)
    - road users: IRU and UETR (associations of hauliers), FIA (association of
    motorists), CLECAT (association for forwarding, transport, logistics and customs
    services)
    - automotive industry and sectors dependent on transport: ACEA (association of the
    automotive industry), BusinessEurope, UEAPME (association of SMEs)
    Companies and associations from other modes of transport: CER (association of
    railway companies); UIRR (association of intermodal transport)
    Environmental associations: Transport&Environment
    Citizens.
    9
    Consultation methods and tools
    Methods: A combination of consultation methods were used:
    1) A standard 12-week online open public consultation was organised in between
    July and October 2016 via the website "Your Voice in Europe" on the basis of
    questionnaires.
    2) Targeted consultation with specific stakeholders and specialists took place
    throughout the IA process and involved:
    a) Thematic seminars with stakeholders and Member States
    b) A conference on the planned road initiatives on 19 April 2016. The
    conference involved specialists, stakeholder associations as well as
    representatives of Member States and Members of the EP.
    c) 21 interviews with stakeholders selected based on specific data needs
    carried out by the contractor preparing the IA support study. An interview
    guide was agreed with the Commission.
    2.2. Results of the open public consultation
    The open public consultation (OPC) ran from 8 July to 5 October, although late
    contributions were still accepted. The OPC contained two set of questions: the first aimed
    at understanding the perceptions of users addressed to the general public, and a second,
    more technical one to experts. Respondents were also given the opportunity to provide any
    further comments. Some respondents also submitted additional documents providing
    further relevant information.
    The questionnaires were based on the issues identified by the evaluation. The issues
    covered included the quality of road infrastructure, the fairness of road pricing (taxes and
    charges), the problems of congestion and CO2-emissions, as well as the scope of EU
    legislation in the field. The questionnaires and statistics are available on the consultation
    webpage:
    http://ec.europa.eu/transport/modes/road/consultations/2016-eurovignette_en
    2.2.1. Objectives of the OPC
    The main objectives of the OPC were: 1) to confirm/verify the problems identified during
    the ex post evaluation; 2) to seek the opinion of stakeholders on possible policy measures;
    and 3) to assess the expected impacts of the possible policy measures.
    2.2.2. Statistical information
    There were 135 responses to the questionnaires as well as 48 additional documents of
    which 27 were of relevance. These responses covered a variety of stakeholder groups,
    including transport undertakings and their representatives (42%), consumers/citizens and
    their representatives (14%), public authorities (13%), the construction industry (7%),
    public transport associations (4%), and tolling service/solution providers (4%).
    There was a relatively high number of coordinated responses (36, i.e. 27%), following 12
    different templates for answers, indicating that standard replies circulated by associations
    to their members and sent in high numbers.
    Responses were received from respondents residing in, or organisations based in, 20 EU
    Member States, with the majority of responses (80%) are from EU-15 Member States. The
    highest number of responses was received from Belgium (24), Germany (20), Spain (19),
    Austria (11), and Hungary (8).
    10
    2.2.3. Main findings and position on the main potential policy measures
    a. Opinions on the fairness of pricing
    The majority of respondents (72%) were of the opinion that different taxes and charge
    systems are thought to cause market distortion, therefore supporting EU harmonisation.
    Transport undertakings were strongest in agreement with this, with 82% of respondents
    indicating that they felt that this was the case. 70% agreed that the exemption of lorries
    between 3.5t and 12t in some countries can distort competition.
    Regarding light goods vehicles, there is mixed opinion over whether the fact that the
    Eurovignette Directive does not cover vans can cause market distortion within the freight
    transport industry. The majority of respondents agreed (54%) that this was the case,
    whereas 31% disagreed.
    Regarding passenger cars, 60% of the respondents (85% of consumers/citizens) felt that
    EU rules could introduce fairness for non-resident road users to some extent or fairly
    significantly.
    There was disagreement as to whether road users are paying enough based on these
    principles, with 65% of transport undertakings feeling that charges were too high, while
    52% of consumers/citizens felt that charges were too low. In the case of light vehicles,
    respondents from EU-13 Member States felt strongly (67%) that prices are too low. This is
    probably linked to the prevalence of vignette schemes in those countries.
    b. Scope of the rules and overall approach
    The survey suggested that any legislation introduced should not be focused solely on
    HGVs, but on all road vehicles including both freight and passenger transport (54%)
    based on the polluter pays (75%) and user pays (80%) principles.
    At the same time, only 51% agreed that the overall price of transport should cover all
    related externalities, with 42% were against. Consumers/citizens agreed in highest
    proportion (63%).
    Regarding the geographic scope, 34% were in favour of applying legislation to all main or
    national roads, whilst 36% felt that the legislation would be best applied to road
    infrastructure of European importance, such as motorways and national roads carrying
    significant international traffic.
    Regarding congestion, with the exception of toll service providers (strongly feeling that
    EU legislation should be applied, in order to address congestion on all of the TEN-T
    network, motorways, and interurban roads), most respondents felt that the problem should
    be dealt with by Member States and local authorities.
    Most respondents (82%) agreed that the revenues generated from taxes and charges should
    be reinvested back into the maintenance, repair and upgrade of the road network, ensuring
    transparency of the process to the public. At the same time several felt that tax revenues
    should not be used solely for the support of infrastructure, but should be used to fund other
    transport-related services, e.g. public transport.
    There was also broad agreement (74%) on the question whether the EU should make sure
    that all vignette prices are set proportionately.
    On the way to address CO2-emissions, many suggested the introduction of regulations
    covering fuel consumption and CO2-emissions for heavy duty vehicles; that CO2-emissions
    should be accounted for in fuel taxes; and that the focus should rest on taxing fuels
    appropriately.
    11
    In addition, there was some concern that by changing this Directive there would be a
    danger of 'double taxation', i.e. by another source for the same reason (e.g. annual road
    tax). The stakeholders believe that EU-wide harmonisation of the rules would be an ideal
    solution, as it would create fair competition rather than favouring companies in countries
    where taxes are lower.
    c. On the proposed solutions
    Overall the proposed changes were positively received, with the stakeholders considering
    all identified issues to be covered by the Eurovignette Directive as important.
    1) Challenge of road maintenance
    All three proposed measures received around 2/3 of approval, with monitoring and
    reporting of revenues and expenditures getting slightly higher mark (69%) than the
    introduction of rules on the liability of the keeper of the toll road, and the requirement of
    national plans on the maintenance and upgrade of roads (both 65%).
    2) Fair pricing for HGVs
    The stakeholders were proponents of phasing out vignette schemes in favour of distance-
    based charging for HGVs or all goods vehicles.
    3) Fair pricing for other vehicles
    Respondents felt the most favourable with the inclusion of light goods vehicles and
    buses/coaches was also suggested from the responses. Other options – including either
    light vehicles or buses/coaches received a lower level of approval.
    4) Possible extension of mark-ups beyond mountainous regions
    Responses were mixed: 32% felt that this provision should be extended, to use the
    revenues more flexibly, to support projects within the same corridor, or used to
    compensate for the higher costs linked to the use of an alternative infrastructure on the
    same corridor, while 29% were against. EU-15 Member States were more in favour with
    EU-13 respondents less so.
    For some, further mark-ups may result in double charging, and no further mark-ups can be
    justified. If a mark-up is used in these areas, then there needs to be transparency in its
    calculation, with its contribution clearly separated from the base charge.
    5) Measures addressing CO2-emissions
    The proposed measures for addressing CO2 emissions from HGVs were supported by the
    stakeholders. The options that were most agreed with were the measures to promote fuel
    efficient vehicles and technologies by reduced road charges for them (68% and 66%
    respectively). By contrast, the only option which suffered a more mixed response was the
    phasing out of the EURO exhaust emissions standards. Even so, in this, 44% expressed
    agreement with the measure, whilst 33% disagreed.
    The need for an adequate measuring methodology was widely accepted.
    6) Addressing congestion
    Proposals for congestion charging were met with scepticism. The greatest approval rate
    (40%) was given to 'allowing congestion charging for all vehicles', with the possibility to
    extend the application of mark-ups receiving the lowest disapproval (40%).
    It was agreed that if congestion charging is applied, it should cover all vehicles, not just
    HGVs. Some said that congestion charging may not actually have the intended effects, as
    often users do not have alternatives.
    12
    d. Additional contributions
    Fifty three additional contributions were received, of which 32 were of direct relevance.
    One third of the latter were from public authorities and nearly one quarter from transport
    undertakings.
    In the additional contributions, there was a lot of discussion of distance-based charging
    versus vignettes. Most contributions supported distance-based charging and the phasing
    out of vignettes, as the former were best able to internalise external costs in line with the
    user-pays and polluter-pays principles. Other contributions underlined the greater costs
    associated with distance-based charging, and argued that while distance-based charging
    might be appropriate for HGVs, time-based vignettes were more appropriate and cheaper
    for other types of vehicles.
    There were mixed views on the internalisation of external costs, with some additional
    contributions calling for the inclusion of external costs relating to congestion, accidents
    and CO2 emissions in addition to air pollution and noise, while others believed that
    external cost charging was not appropriate or was difficult. For congestion, views ranged
    from support for such charges to be additional, rather than revenue-neutral, to arguing that
    additional provisions for congestion charging were not necessary, as the costs of
    congestion were already internalised by users. Some public authorities called for the
    maximum charging levels to be reviewed or even directly removed to enable charging that
    actually reflects the costs of pollution; a similar view was held by a motorway operator in
    relation to congestion. There was some support for replacing the possibility to differentiate
    charges by Euro emissions class with CO2-differentiated charging, but it was noted that the
    latter was difficult in the short-term as a result of a lack of relevant information for HDVs.
    An alpine region called for mountainous areas to be allowed to implement additional tolls
    to cover the additional infrastructure and external costs imposed on these sensitive areas.
    Views on the use of revenue varied between making it mandatory for revenues to be used
    to support the development and maintenance of transport infrastructure to a more general
    belief in revenues being used to decrease external costs and promote cleaner transport
    modes. Member States, on the other hand, tended to argue that the use of revenue should
    be left to public authorities.
    There was some support for the scope of the legislation to be extended to buses and
    coaches, and even to all vehicles. Some supported the legislation being amended to require
    mandatory distance-based charging, although road users in particular did not support such
    mandatory charging. Some Member States supported the removal of the possibility of
    exempting HGVs over 3.5 tonnes and less than 12 tonnes, but did not support the extension
    of the Directive to any type of vehicle lighter than 3.5 tonnes.
    2.3. Results of the targeted consultation
    2.3.1. Interviews
    In order to obtain better insight and more detailed information, a set of targeted interviews
    have been carried out. Contributions were received from 21 different stakeholders,
    including nine Member States (four EU-15 and five EU-13), five transport companies,
    including two SMEs, four EU level representative bodies, two tolling companies and one
    national industry association. Stakeholders were asked questions on the potential policy
    options for amending the Directive.
    Most of the nine Member States supported action to incentivise the use of fuel efficient
    vehicles in general, but not all of these were convinced of the ease and value of
    implementing this through CO2-differentiated charges. The Member States that were most
    13
    supportive of CO2-based charges underlined that it needed to be applied simply and that a
    system of differentiation according to CO2 emissions needed to be phased-in carefully as
    the Euro emissions class system was phased out. Where they expressed a view, Member
    States wanted CO2-based charging to be voluntary.
    Of those Member States that expressed an opinion, one stated that a CO2-based charge
    should be revenue-neutral, while another argued that it should not, as ensuring revenue-
    neutral differentiation requires regular changes to the charges, which posed administrative
    challenges and was difficult to communicate to industry. Opinion was also divided on the
    challenges and costs of changing to a CO2-based system, as one Member State noted that
    their existing toll system could be relatively easily adapted for CO2-based charges, while
    others noted that the administrative burden was potentially the main issue, as verifying the
    appropriate CO2 emissions could be high, at least in the transition period.
    One Member State felt that there were still benefits to be gained from being able to
    differentiate charges according to Euro emissions class, which could be lost if CO2-based
    charging, for which there was still a lack of data, was introduced. Another also supported
    retaining differentiation by Euro emissions class, as this was easier to identify for a
    vehicle.
    Amongst the other stakeholders, there was generally broad support for the principal of
    CO2-based charging, but in practice some issues were identified. Two of the four EU level
    stakeholder organisations explicitly supported charging based on the results that emerge
    from VECTO, which will be used to monitor and report CO2 emissions from HDVs and for
    setting emission reduction targets for these vehicles. In spite of the fact that information
    from VECTO will not be available to be used for the purpose of charging until 2020, these
    stakeholders underlined that the current Eurovignette amendment should enable the use of
    the VECTO’s information as it becomes available, and then possibly phase out the use of
    Euro emissions classes. Other EU level stakeholders noted that the results of VECTO
    would not be accurate in practice, as the CO2 emissions of an HDV in use depended on lot
    of factors. In spite of this, one noted that a vehicle that performs well “in the laboratory”
    would also perform well on the road, so that VECTO’s results would be a good proxy for
    real-world emissions. The two EU level stakeholders that expressed an opinion stated that
    such differentiated charging should be applied to all vehicles.
    The representatives of transport companies were supportive of taking account of
    transport’s CO2 emissions. One argued that it would be better to do this through fuel taxes,
    but as this was politically difficult, an approach based on the results of VECTO would be
    appropriate. Another supported CO2-differentiated charges, as long as this was mandatory
    for all vehicles, including light duty vehicles. A third thought that reaching an agreement
    on CO2-based charges would be politically-difficult and lacked a clear rationale compared
    to internalising the external costs of CO2, so instead was in favour of the latter being
    mandatory. The transport companies underlined that the way in which differentiated-
    charging was implemented was of fundamental importance. A national industry
    association underlined that any system should be simple and sufficiently reward hauliers
    that use fuel-efficient vehicles.
    The two representatives of transport SMEs that were interviewed were both generally
    supportive of the CO2 differentiation of charges, but both underlined that it would be better
    if the same system was implemented and enforced in all Member States, otherwise there
    would be impacts on competitiveness.
    The representatives of tolling companies were less supportive of CO2-diferentiated
    charging, even though generally they supported measures to improve the environmental
    performance of transport. One was concerned that any changes to the structure of tolls
    14
    always opened up wider discussions of contracts, which potentially led to problems. They
    argued that it would contractually simpler for CO2-differentiated charges to be revenue-
    neutral, i.e. reduce charges for new vehicles while increasing charges for older vehicles,
    although it would be relatively easy to do this using an electronic charging system. They
    also noted that more charging was the obvious way of replacing fuel tax revenues, which
    were likely to decline. The other tolling company was concerned that CO2-based charging
    would have an adverse effect on its business model and that it risked complicating tolling,
    as it would be more complex than differentiating charges according to Euro emissions
    classes.
    Member States were generally not supportive of the policy options that might be
    implemented to enhance the quality of road infrastructure. With respect to existing
    tolled roads, it was underlined that in countries that have a lot of tolled roads already, such
    as Austria, Italy and Slovenia, the concessionaries already have performance indicators
    written into their contracts or agreements, which include inter alia maintaining the quality
    of their road network. In Member States that do not have extensive charging networks,
    indicators are sometimes used to monitor road quality and to prioritise investment.
    Concerns were raised that it would be difficult to agree a common set of indicators, as
    those relevant to Alpine countries would be different to those needed in relatively flat
    countries. Additionally, a standard set of EU-wide indicators could be difficult for some
    countries to achieve, as a result of a lower levels of resources. One Member State
    suggested that the Directive could include a general requirements to establish indicators,
    but leave it to Member States to decide what these should be, while another saw the value
    of common indicators, but did not want these to be imposed. Another Member State
    supported the establishment of EU performance indicators for infrastructure maintenance,
    but thought that these should not be implemented through the Eurovignette Directive.
    Subsidiarity concerns were raised in many cases, with Member States suggesting that it
    should be up to them to decide how to manage and fund their respective road networks in
    light of other priorities, and to decide on what they should report. A concern was also
    raised that the policy options proposed were more administrative in nature and so would
    introduce administrative costs without necessarily delivering better roads. Three Member
    States noted that in their countries revenues from charges were earmarked for road
    development and maintenance, and one of these suggested that such earmarking could be
    a requirement more generally.
    Other stakeholders were more supportive of action to ensure the quality of the road
    network, although many underlined that it was important to make a distinction between
    tolled and non-tolled roads. In general, it was considered that tolled roads were reasonably
    well maintained, although there was still support for a more common approach,
    particularly on the TEN-T network. Several stakeholders supported the development of a
    common set of indicators, although many also recognised the associated challenges of
    achieving this. To overcome this, an EU level trade association proposed having a common
    road quality monitoring system that could be used across the EU with a central authority.
    Some supported the use of a common set of indicators together with the development by
    Member States of national maintenance and upgrading plans. Other options proposed
    included the development of guidelines on the minimum level of maintenance, although
    the details should be left to individual countries, and a requirement to take action to
    remedy any issues identified by any indicators.
    A number of interviewees noted that distance-based charging was a potential solution to
    the problem of funding non-tolled roads, while several explicitly supported the earmarking
    of revenues from such charges for road maintenance and development.
    15
    With respect to vignettes, Member States were split on the need for further measures to
    avoid discrimination, but there was little support for phasing out vignettes. There was
    some support for expanding the existing proportionality rules that applied to HGVs to
    other vehicles such as cars and buses, although others opposed this arguing that the focus
    of the Eurovignette Directive should remain HGVs as these were the main type of vehicles
    that travelled a lot internationally. One Member State argued that if it was considered that
    vignettes did not sufficiently cover costs, the response should not be to abolish vignettes,
    but to lift the restrictions on them as it was not currently possible to use these to cover the
    costs imposed by HGVs. Some Member States believed that there was no need for
    additional rules, as it was more a case of properly enforcing existing rules on
    proportionality, rather than creating additional legislation. Those Member States that
    already had a distance-based charging scheme in place for HGVs often did not object to
    phasing out vignettes for HGVs. Several Member States argued that, particularly for
    LDVs, the costs of implementing a distance-based charging scheme were prohibitive,
    whereas a time-based system could deliver similar results for much less in the way of
    costs, even though it was not the best way of implementing the user-pays principle. One
    Member State argued that some countries, if faced with a choice between a distance-based
    system and no charging would adopt the latter approach, and so phasing out vignettes
    could lead to less charging overall.
    With respect to distance-based charging, Member States were again divided on the need
    for additional measures to ensure a level playing field, with one questioning the logic
    behind the need for action in the first place. Some Member States that already had – or
    were planning – a distance-based charging scheme in place for HGVs supported this being
    made mandatory on the TEN-T network and extended to LCVs, but noted that this might
    be a challenge in other countries. One Member State supported the extension of the road
    charging rules to all vehicles, including cars, as this would increase acceptability amongst
    road hauliers, while another supported an extension to buses and coaches. Other Member
    States were explicitly against mandatory distance-based charging for any vehicles or even
    a common approach to such charging, arguing that vignettes were more appropriate in
    some cases (see above). It was also pointed out that in those countries with lower levels of
    traffic, revenues from distance-based charging would be less, which would further
    undermine the benefits of the scheme.
    The majority of other stakeholders were in favour of distance-based charging applying to
    all vehicles and the phasing out of vignettes, although some supported vignettes for reasons
    similar to the Member States. The arguments in favour of distance-based charging included
    that this was fairer and better applied the user- and polluter-pays principles. Many of the
    stakeholders supported mandatory distance-based charging, at least as the ultimate long-
    term goal, and noted that this needed to be phased in gradually. One stakeholder proposed
    that after HGVs, it would be most appropriate to apply distance-based charging to buses
    and coaches, followed by LCVs, as these were being used in some Member States instead
    of heavier commercial vehicles as their use is less regulated. A number of stakeholders
    noted that distance-based charging was the obvious way for Member States to maintain
    revenue levels from road transport, with the likely decline of revenues from fuel duties in
    light of the increasing electrification and improved efficiency of the new vehicle fleet.
    Many stakeholders also stressed that any increase in costs as a result of increased charges
    should be compensated for by reductions in other transport-related taxes. Those that were
    in favour of retaining the possibility of maintaining a vignette system noted that the
    increased costs for short-term users were justifiable as a result of the flexibility that the
    system provides to these users, and that the costs of introducing distance-based charging
    for cars in particular would be prohibitive. An EU trade association that supported
    16
    distance-based charging argued that in the short-term the proportionality requirements on
    vignettes should be retained; a transport company supported such rules being applied to
    all vehicles.
    Member States generally favoured more flexibility in the Directive to enable them to
    ensure an efficient transport system, rather than more prescriptive requirements. Several
    Member States argued that the current approach to external cost charging needed to be
    simplified and that restrictions on the ability to increase charges by the time of day should
    be lifted in order to give Member States more flexibility. One Member State argued that
    the maximum level of any charge should be fixed to ensure consistency between Member
    States. It was proposed that rather than the Directive setting more rules to govern charges,
    it would be simpler if Member States simply had to justify their actions. In relation to
    congestion charging, some argued that it was a very local issue so the Directive should
    provide sufficient scope to allow for appropriate local action. In relation to external cost
    charging more generally, it was noted that in countries with older vehicle fleets,
    introducing such charging could be expensive for users. A general comment was that the
    more restrictions that were imposed on charging by the Directive, the less likely it was that
    a Member State would voluntarily implement a charging scheme, in spite of its potential
    benefits.
    Views on whether the Directive should apply to all vehicles were divided, with some not
    supporting any extension to vehicles of less than 3.5 tonnes, while others supported non-
    mandatory principles being applied more generally.
    Of the other stakeholders interviewed, many transport companies supported
    congestion charging, as long as it was mandatory and applied to all vehicles, while others
    were not convinced of the need for congestion charging. A mandatory scheme was
    preferred, as it was considered that if the choice was left to Member States, they might take
    the easier option politically and only apply congestion charges to HGVs rather than to all
    vehicles. One stakeholder noted that it was important for the Directive to be seen to
    facilitate congestion charging, so this should be explicit and congestion should be included
    as one of the external costs that could be covered by user charges, although Member States
    should be left with flexibility as to how to apply the charge. The need for a common
    methodology for applying the charges allowed by the Eurovignette Directive was
    mentioned by a couple of stakeholders.
    Others opposed allowing Member States to charge for congestion, arguing that the costs of
    congestion were already internalised by hauliers in terms of increased fuel, labour and
    vehicle costs. Others believed that for inter-urban roads, the provisions of the Eurovignette
    Directive were already sufficient to enable Member States to address congestion, or that
    there would be no need for congestion charging if distance-based charging was introduced.
    Those that expressed a view on the use of revenues, argued that these should be used for
    new transport infrastructure and abatement measures. A couple of stakeholders believed
    that the decision as to whether to implement external costs charging generally, and
    congestion charging specifically, should be left to Member States and cities. Few
    stakeholders had any views on potential adverse or beneficial impacts on SMEs. The
    main observation was that anything that increased costs or complexity had the potential to
    have an adverse impact.
    17
    2.4. Results of the stakeholder seminars and conference
    In the context of the planned road transport initiatives, as described in the Commission
    Work Programme 20163
    , DG MOVE organised a series of five informal seminars during
    September and October 2015. In addition a conference was held in April 2016.
    2.4.1. Insufficient financing
    Member States were generally of the opinion that flexibility is required to spend revenues
    from road charging according to national priorities and according to national decisions.
    Others echoed that it is important to respect subsidiarity in the area of infrastructure and
    maintenance financing. Stakeholders on the other hand, and particularly road users,
    stressed that earmarking of revenues and proper maintenance is a prerequisite for
    acceptability of user charges. It was also stressed that user charges and earmarking should
    be seen in a wider context of providing users with incentives to encourage improved
    economic and environmental performance of the road transport sector.
    2.4.2. Vignettes
    Some Member States advocated phasing out vignettes and replacing these with distance-
    based tolls collected with the help of interoperable on-board units. Several other Member
    States, however, thought that the flexibility of the current Eurovignette framework should
    be maintained, at least in the short to medium term. A positive aspect of vignettes was
    considered to be its relative simplicity and low administrative costs, in particular in
    countries having low volumes of transit traffic. Views were divided as to whether the issue
    of discrimination of passenger cars should be addressed by an extension of the
    Eurovignette framework. A slight majority were in favour of including passenger cars
    while others were against in order not to increase the cost burden.
    2.4.3. Price signals
    Whilst most Member States expressed their support for the application of the user
    and polluter pays principles, only some requested measures to ensure clearer and more
    effective price signals. For instance, some Member States currently charging for external
    costs, or planning to do so, proposed to review caps currently imposed on external cost
    charges. It was also proposed by some to allow a differentiation of user charges and tolls
    based on CO2 emissions to better reflect the environmental performance of vehicles.
    Views were divided on the possibility to allow Member States to charge for congestion as
    an additional charge rather than, as presently, a variation of user charges and tolls. Whilst
    some Member States were in favour, others did not consider that a congestion charge
    would impact behaviour given that international hauliers are unable to avoid main
    congestion centres at some stage of their international journey. As a consequence, it was
    considered by some that a congestion charge may add costs and not significantly contribute
    to reducing congestion. Stakeholders confirmed that clear and consistent price signals
    were important given the highly competitive nature of the road haulage sector. It was
    noted that recent evidence (Germany was cited) has demonstrated that clear price signals
    have contributed to reducing empty running and to the use of more environmentally
    friendly trucks.
    3
    COM(2015)610 final.
    18
    2.5. Conclusions and use of the results
    There were some differences of note with respect to the responses from the different
    elements of the consultation.
    There was general support for measures to incentivise the use of fuel efficient vehicles,
    although less specific support for doing this through charges and phasing out the
    possibility of differentiating charges by a vehicle’s Euro emissions class. Some additional
    contributions and many non-Member State interviewees supported the introduction of
    CO2-based differentiation and the phasing out of differentiation by Euro emissions class,
    whereas Member State interviewees were generally less supportive of this approach. While
    doubts have been expressed regarding its short-term feasibility, there was no obvious
    opposition to the revenue-neutral differentiation of charges based on CO2 emissions.
    In relation to possible measures to ensure the quality of road infrastructure, there was a
    distinct difference between, on the one hand, the views expressed in the online public
    consultation and the views of most stakeholders interviewed, and on the other, the views of
    the Member States interviewed. The majority of respondents to the public consultation and
    other interviewed stakeholders generally supported the measures to ensure the quality of
    road infrastructure. On the other hand, Member States were generally not supportive of the
    measures, citing subsidiarity concerns, that the proposals were unnecessary as tolled roads
    were already of sufficient quality and the challenges with identifying a common set of
    indicators.
    With respect to possible measures to avoid discrimination and ensure a level playing
    field, there is again a distinct difference between the views of Member States and others.
    Respondents to the online public consultation strongly supported the application of the
    user-pays and polluter-pays principles, and for the EU to ensure that vignette prices are set
    proportionately. Many additional contributions and non-Member State interviewees
    supported the phasing out of vignettes and the introduction of distance-based charging. On
    the other hand, Member State interviewees were divided on the need for further action in
    this respect, they generally did not support the phasing out of vignettes (particularly for
    cars) and tended to support distance-based charging only if they already had such a system
    in place. Many argued – as did some other interviewees – that vignettes were more
    appropriate and cheaper for cars.
    With respect to ensuring an efficient transport system, the majority of respondents to the
    online public consultation believed that dealing with congestion should be left to Member
    States, with the most popular option for congestion charging being that it should apply to
    all vehicles. The need for any congestion charging to cover all vehicles, not just HGVs,
    was underlined by those non-Member State interviewees who supported congestion
    charging. Member State interviewees were in general in favour of more flexibility about
    implementing the measures to ensure an efficient transport system.
    The results of all the consultation activities were used in designing the policy options and
    selecting the measures. The most rejected ones were discarded after the initial screening
    and the retained measures were grouped options with increasing level of regulatory
    intervention, so that decision makers have the possibility to judge on the desired level of
    ambition. The results of the consultation are referred to throughout the various sections of
    the impact assessment.
    19
    3. ANNEX 3. WHO IS AFFECTED BY THE INITIATIVE AND HOW
    Type of stakeholder Practical implications
    Road hauliers and
    logistics companies –
    many of which SMEs
    Transport and operating costs
    Direct costs in the form of road charges may slightly increase for
    the average haulier (SME), with a possibility to make savings on
    road charge and fuel cost by using the cleanest and most efficient
    vehicles. All hauliers will benefit form of increased reliability
    and speed of deliveries from lower congestion and better road
    quality implying savings on vehicle operating cost and delay
    costs, which would offset any increase in road charge. In
    addition, hauliers will probably be compensated through reduced
    taxes (as it was the case most recently in Belgium where vehicle
    taxes were reduced to the minimum when the distance-based
    charge was introduced).
    Firms can react in different ways to the introduction of new road
    tolls, external cost charges and congestion charges: instead of
    absorbing them, SMEs are likely to pass on these costs to their
    customers; or they can reduce the impact on operating costs by
    adapting their operations to the new circumstances through route
    shift, travel time shift, frequency reduction, modal shift, or
    increased uptake of low/zero emission vehicles. Firms investing
    in low/zero emission vehicles will benefit from lower
    fuel/running costs that are expected to more than compensate for
    increased purchase prices over the lifetime of the vehicles.
    Shippers &
    consumers
    Transport costs/prices
    Shippers might be required to adapt their shipping practices to
    slightly modified transport prices (depending on the itinerary),
    but would benefit from more efficient transport operations,
    reduced delays, more predictable delivery times. This is
    especially important to firms working for sectors such as
    manufacturing and retail (where there is high reliance on just-in-
    time delivery).
    Impacts on consumer prices are expected to be negligible, even
    under cases of 100% cost pass-through.
    Private road users Cost of mobility & behaviour
    Regular users of toll roads would experience hardly any
    difference in road charge on average but, like hauliers, would
    benefit from better road conditions and reduced congestion.
    Occasional road users would benefit from fairer treatment (lower
    charges) in Member States with time-based charging.
    Those travelling regularly alone by car in rush-hour on roads with
    distance-based charging may – only in case the Member State
    decides to introduce time-differentiated charging – either be
    20
    required to change habits and/or transport mode, or would face
    higher road charges and be the main beneficiaries of reduced
    congestion in exchange. The exact level of road charge will
    depend on the specific local context; however, as an example, a
    trip with 10 km in near capacity condition (7 km on rural and 3
    km on metropolitan motorway) may be charged up to 1-2 euro –
    a price very much comparable to an equivalent trip by train or
    bus. Indeed it would be possible to mitigate even this small cost
    by carpooling.
    Depending on the itinerary, the cost of long distance travel by bus
    may slightly increase (around 1 euro per passenger on a trip
    involving 400 km of motorways), which will be considered by
    the travellers when choosing between different transport modes,
    e.g. bus or train.
    Road operators Revenues & budget
    Assuming that a significant portion of collected tolls would be
    allocated to the operator of the toll road, they would dispose of a
    stable revenue stream to maintain their road network in good/safe
    condition. This would make it possible for road operators to time
    their maintenance activities in an optimal way thereby reducing
    long-term maintenance costs.
    Monitoring & reporting
    Those operators, which have no regular road quality monitoring
    in place, would be required to implement such a scheme; they
    may need to consult other operators for the purpose of
    exchanging good practices and capacity building, and would be
    required to report on the results on a yearly basis. The costs
    associated with these obligations would be covered by toll
    revenues (the inclusion of such costs in the calculation of tolls is
    already provided for in the Directive).
    Member States'
    administrations
    Investment & budget
    Those Member States, which currently apply vignettes for HDVs
    would have to choose between two possibilities if they want to
    replace revenues forgone due to the abolishing the scheme: (1)
    introduce distance-based charging within 5 years if they intend to
    collect user charges on their roads; alternatively, (2) they may
    choose to raise the equivalent amount of revenues via other
    channels, e.g. by slightly increasing transport taxes (fuel or
    vehicle). All other Member States would also be affected by
    additional costs where they introduce new road tolls
    (voluntarily).
    1. Increasing fuel tax could be a meaningful alternative as it is
    paid in proportion of fuel burnt and in principle by all road
    users. It is very easy to implement at virtually no cost. For
    example, in the case of Luxembourg, the revenues forgone
    21
    thanks to abolishing the Eurovignette system could be
    compensated by less than 2% increase in fuel tax. However,
    increasing fuel taxes can be politically difficult in some
    countries, and many Member States are seeking alternative
    sources of revenue as vehicles become more fuel efficient
    (eroding the tax base).
    2. Road charging provides a more direct price signal to the user,
    whereas the fuel price, once paid, is already a sunk cost.
    Distance-based road charging can also be adjusted according
    to the environmental performance of vehicles, noise levels
    and time of day, thereby contributing to reducing external
    costs. Steady revenues collected from the users can ensure a
    quick payback period (generally within the same year), and
    long-term benefits in any case. Furthermore, the cost of
    operating different electronic toll schemes varies between 4.5
    and 12% of toll revenues. The cost of on-board units is on a
    downward path. 4
    For Member States choosing to introduce new road tolls, this
    result in an initial investment cost of around €150m (€82m to
    €232m, depending on the size of the county) and ongoing
    maintenance/enforcement costs of around €20m per year (€9m to
    €41m). At the same time, it is also possible to introduce
    electronic tolling at lower cost as in Hungary (below EUR 100
    million). These costs would be counterbalanced by increased
    revenues from road user charges in all cases, which would be
    greater than the ongoing costs.
    Reporting
    There may be small additional costs for implementing the
    measures regarding monitoring and reporting of investments,
    expenditures and road quality (although several Member States
    already do this), but these would be very minor, especially in
    comparison to the system costs explained above.
    Equipment
    manufacturers
    Wider application of distance-based road charging will mean
    more business opportunities for electronic toll service providers,
    while the competitiveness of OEMs will be positively affected by
    increased demand for cleaner and more efficient vehicles.
    Society at large Society and the economy would benefit from the wider
    application of proportionate distance-based road pricing (i.e. the
    polluter pays and user pays principles), since it will incentivise
    more efficient transport operations, the use of cleaner vehicles
    and ultimately result in lesser negative impact from transport,
    lower level of externalities, including reduced CO2 emissions.
    4
    Ex-post evaluation of Directive 2004/52/EC on the interoperability of electronic road toll systems in the
    Community and Commission Decision 2009/750/EC on the definition of the European Electronic Toll
    Service and its technical elements
    22
    4. ANNEX 4. ANALYTICAL MODELS USED IN PREPARING THE IMPACT ASSESSMENT
    4.1. Description of analytical models used
    A model suite has been used for the analytical work, combining the strengths of three
    different models: ASTRA, PRIMES-TREMOVE and TRUST. The model suite covers the
    entire transport system (e.g. transport activity represented at Member State level, by origin-
    destination and at link level, technologies and fuels at Member State level, air pollution
    emissions at Member State and link level and CO2 emissions at Member State level) and
    its macro-economic impacts:
     Geography: individually all EU Member States.
     Time horizon: 2005 to 2050 (5-year time steps) in PRIMES-TREMOVE. ASTRA has
    been run up to 2030 for this impact assessment.
     Transport modes covered: private road passenger (cars, powered 2 wheelers), public
    road passenger (buses and coaches), road freight (heavy goods vehicles, light
    commercial vehicles), passenger rail, freight rail, passenger aviation, freight and
    passenger inland navigation and short sea shipping. Numerous classes of vehicles and
    transport means with tracking of technology vintages.
     Regions/road types: traffic represented at country level in PRIMES-TREMOVE5
    ; by
    origin at NUTS 2 level in ASTRA and at link level by NUTS 3 region in TRUST.
     Energy: all crude oil derived fuels, biofuels, CNG, LNG, LPG, electricity and
    hydrogen (PRIMES-TREMOVE6
    and ASTRA).
     Emissions: greenhouse gas emissions and pollutants emissions (CO, NOx, PM2.5),
    and VOC (ASTRA).
     Stock of vehicles: full dynamics of stock turnover for road (more refined) and non-
    road transport means.
     Macro-economic impacts: GDP and employment (ASTRA).
    A brief description of each model is provided below, followed by an explanation of each
    model’s role in the context of this impact assessment.
    4.1.1. ASTRA model
    ASTRA (ASsessment of TRAnsport Strategies) is an integrated assessment model using a
    system dynamics approach7,8
    . It projects and evaluates the impacts of policy measures on
    GDP, employment, transport demand performance by mode for passenger and freight,
    vehicle fleet composition and transport emissions at country level for each EU Member
    State. Transport demand is generated for passenger and freight at NUTS 2 level.
    The model includes four main components: economy, transport, technology and
    environment. The macro-economic component consists of five elements: supply side,
    demand side (including an investment module), an input-output model based on 25
    5
    For trip classes distinction between urban areas (distinguished into one metropolitan and other urban
    areas) and inter-urban areas (distinguished into motorways and other roads).
    6
    PRIMES-TREMOVE additionally provides for the linkage to refuelling/recharging infrastructure by trip
    type.
    7
    Source: http://www.astra-model.eu/index.htm
    8
    Source: http://www.assist-project.eu/assist-project-en/content/deliverables.php
    23
    economic sectors, employment module and government module. In addition, two trade
    models are implemented (i.e. intra-EU trade and EU to rest-of-the-world trade). The
    transport component is represented by means of two classical 4-stage transport models,
    one for passenger and one for freight transport, including endogenous feedback on all
    stages9
    . The transport network is not explicitly represented but information on network
    capacity is considered for the different transport modes drawing on the TRUST model. The
    technology component covers the differentiation of road vehicle fleets into age classes and
    different emission standard categories10,11
    . Investments and learning curves are included in
    the simulation of the fleet development process. Efficiency improvements are also included
    for non-road modes. The environment component calculates the emissions from transport
    based on traffic flows, the information on the composition of the vehicle fleets and on
    emission factors. ASTRA quantifies the impacts on fuel consumption, CO2 emissions and
    air pollutants (NOx, PM, CO and VOC).
    ASTRA allows quantifying the impact of policies in the field of pricing (e.g. road charging
    schemes for light duty and heavy duty vehicles, railways infrastructure charges), taxation
    (e.g. energy taxation, vehicle taxation, feebates), infrastructure (e.g. TEN-T projects
    accelerated implementation, improving frequency and reliability of service), internal
    market (e.g. opening of the domestic rail passenger market, elimination of restrictions on
    cabotage, simplification of formalities for ships travelling between EU ports), efficiency
    standards (e.g. CO2 emissions standards for light duty and heavy duty vehicles, standards
    for controlling air pollution), transport planning (e.g. city logistics/urban freight
    distribution/urban consolidation centres) and research and innovation (e.g. increased
    replacement rate of inefficient and polluting vehicles, electromobility).
    ASTRA has been recently used for a study on the deployment of C-ITS in Europe12
    , for a
    study on the cost of non-completion of the TEN-T13
    and for a 2013 study on the
    Eurovignette Directive, and in a series of Horizon 2020 and FP7 research projects like:
    REFLEX, FUTRE, ASSIST, GHG-TransPoRD14
    .
    ASTRA is a private model, developed and maintained by TRT, MFIVE and Fraunhofer-
    ISI15
    . A version of ASTRA, so-called ASTRA-EC, is available to external users through a
    user interface16
    .
    9
    Even if a full origin-destination matrix is not modelled, demand is segmented according to trip purpose
    and in different distance bands to better consider the competition between alternative modes.
    10
    Road freight transport demand is segmented by different vehicle types: light commercial vehicles (below
    3.5 tonnes), medium heavy goods vehicles (from 3.5 to 12 tonnes) and large heavy goods vehicles (above
    12 tonnes) - according to different spatial domains (i.e. local, short, national, international). Assumptions
    on the composition of vehicle fleet used in each spatial domain are made to reflect the use of each vehicle
    type. The demand for new heavy goods vehicles as well as the replaced vehicles is associated with
    emission standards depending on the year of registration but the model only covers conventional diesel
    technologies. Nevertheless, the version of the model used for the IA includes also differentiation by fuel
    technology, based on the input of the PRIMES-TREMOVE model. For cars, the model differentiates the
    engine types, including e.g. hybrid, electric and fuel cells.
    11
    See Annex A of Ricardo et al. (2017) Support Study for the Impact Assessment Accompanying the
    Revision of Directive 1999/62/EC.
    12
    Source: http://ec.europa.eu/transport/sites/transport/files/2016-c-its-deployment-study-final-report.pdf
    13
    Source : http://ec.europa.eu/transport/sites/transport/files/themes/infrastructure/studies/doc/2015-06-
    fraunhofer-cost-of-non-completion-of-the-ten-t.pdf
    14
    Source: http://www.astra-model.eu/downloads-research-applications.htm
    15
    Source: http://www.astra-model.eu/index.htm
    16
    Source: http://www.assist-project.eu/assist-project-en/content/deliverables.php
    24
    4.1.2. PRIMES-TREMOVE transport model
    The PRIMES-TREMOVE transport model projects the evolution of demand for passengers
    and freight transport by transport mode and transport mean. It is essentially a dynamic
    system of multi-agent choices under several constraints, which are not necessarily binding
    simultaneously. The model consists of two main modules, the transport demand allocation
    module and the technology choice and equipment operation module. The two modules
    interact with each other and are solved simultaneously.
    The projections include details for a large number of transport means, technologies and
    fuels, including conventional and alternative types, and their penetration in various
    transport market segments for each EU Member State. They also include details about
    greenhouse gas and air pollution emissions (e.g. NOx, PM, SOx, CO), as well as impacts
    on external costs of congestion, noise and accidents.
    In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g.
    eco-driving, deployment of Intelligent Transport Systems, labelling), economic measures
    (e.g. subsidies and taxes on fuels, vehicles, emissions; ETS for transport when linked with
    PRIMES; pricing of congestion and other externalities such as air pollution, accidents and
    noise; measures supporting R&D), regulatory measures (e.g. CO2 emission performance
    standards for new passenger cars and new light commercial vehicles; EURO standards on
    road transport vehicles; technology standards for non-road transport technologies),
    infrastructure policies for alternative fuels (e.g. deployment of refuelling/recharging
    infrastructure for electricity, hydrogen, LNG, CNG). Used as a module which contributes
    to a broader PRIMES scenario, it can show how policies and trends in the field of transport
    contribute to economy wide trends in energy use and emissions. Using data disaggregated
    per Member State, it can show differentiated trends across Member States.
    PRIMES-TREMOVE has been used for the 2011 White Paper on Transport, Low Carbon
    Economy and Energy 2050 Roadmaps, the 2030 policy framework for climate and energy
    and more recently for the Effort Sharing Regulation, the review of the Energy Efficiency
    Directive, the recast of the Renewables Energy Directive and for the European strategy on
    low-emission mobility.
    The PRIMES-TREMOVE is a private model that has been developed and is maintained by
    E3MLab/ICCS of National Technical University of Athens17
    , based on, but extending
    features of the open source TREMOVE model developed by the TREMOVE18
    modelling
    community. Part of the model (e.g. the utility nested tree) was built following the
    TREMOVE model19
    . Other parts, like the component on fuel consumption and emissions,
    follow the COPERT model.
    17
    Source: http://www.e3mlab.National Technical University of Athens.gr/e3mlab/
    18
    Source: http://www.tmleuven.be/methode/tremove/home.htm
    19
    Several model enhancements were made compared to the standard TREMOVE model, as for example: for
    the number of vintages (allowing representation of the choice of second-hand cars); for the technology
    categories which include vehicle types using electricity from the grid and fuel cells. The model also
    incorporates additional fuel types, such as biofuels (when they differ from standard fossil fuel
    technologies), LPG and LNG. In addition, representation of infrastructure for refuelling and recharging
    are among the model refinements, influencing fuel choices. A major model enhancement concerns the
    inclusion of heterogeneity in the distance of stylised trips; the model considers that the trip distances
    follow a distribution function with different distances and frequencies. The inclusion of heterogeneity was
    found to be of significant influence in the choice of vehicle-fuels especially for vehicles-fuels with range
    limitations.
    25
    As module of the PRIMES energy system model, PRIMES-TREMOVE20
    has been
    successfully peer reviewed21
    , most recently in 201122
    .
    4.1.3. TRUST
    TRUST (TRansport eUropean Simulation Tool) is a European scale transport network
    model covering road, rail and maritime transport23
    . TRUST covers the whole Europe and
    its neighbouring countries and allows for the assignment of origin-destination matrices at
    NUTS 3 level (about 1600 zones) for passenger and freight demand.
    TRUST projects the average daily loads on road links split by demand segment and by
    country of origin, road traffic activity (passenger-km, tonnes-km, vehicle-km) per year by
    country (based on territoriality principle), origin-destination journey time, road
    accessibility measures by NUTS 3 region, energy consumption and emissions of NOx,
    PM, VOC, CO and CO2 by link.
    Road transport demand is modelled in TRUST by means of origin-destination matrices
    between NUTS 3 zones. Intra-NUTS 3 demand is not part of the matrices as it is not
    assigned to the network, but implicitly considered as pre-load on links. TRUST freight
    matrix includes tonnes transported by vehicles above 3.5 tonnes (i.e. heavy goods vehicles)
    and no differentiation of the matrix by heavy goods vehicle type is available. For this
    reason, the model works with an average charge (currently weighted on the composition of
    the vehicle fleet and on the charges by vehicle size and EURO classes, where applied).
    Average charges are applied to the road network as link-based tolls and are differentiated
    according to link types (e.g. motorway, roads with separate carriageways, two-lane roads)
    and at country level.
    National vignettes are applied as equivalent distance fares (i.e. the fare of the yearly
    vignette is translated into a distance-base cost as ratio between the cost of the vignette and
    the average annual travelled mileage on the charged network). The links where extra-tolls
    are levied (e.g. tunnels, mark-ups etc.) are modelled case by case. Link tolls, together with
    other variable operating costs (fuel and, for trucks, driver costs) are relevant for path
    choice during the assignment step.
    TRUST is particularly suitable for modelling road charging schemes for cars and heavy
    goods vehicles, and policies in the field of infrastructure (e.g. completion of the core and
    comprehensive TEN-T network).
    TRUST is a private model, developed and maintained by TRT24
    . It has been used for the
    2013 ex-post evaluation of transport infrastructure charging policy, for the TRACC -
    20
    The model can be run either as a stand-alone tool (e.g. for the 2011 White Paper on Transport and for the
    2016 Strategy on low-emission mobility) or fully integrated in the rest of the PRIMES energy systems
    model (e.g. for the Low Carbon Economy and Energy 2050 Roadmaps, for the 2030 policy framework for
    climate and energy, for the Effort Sharing Regulation, for the review of the Energy Efficiency Directive
    and for the recast of the Renewables Energy Directive). When coupled with PRIMES, interaction with the
    energy sector is taken into account in an iterative way.
    21
    Source: http://ec.europa.eu/clima/policies/strategies/analysis/models/docs/primes_model_2013-
    2014_en.pdf.
    22
    https://ec.europa.eu/energy/sites/ener/files/documents/sec_2011_1569_2.pdf
    23
    See Annex A of Ricardo et al. (2017) Support Study for the Impact Assessment Accompanying the
    Revision of Directive 1999/62/EC.
    24
    Source : http://www.trt.it/en/tools/trust/
    26
    TRansport ACCessibility at regional/local scale and patterns in Europe25
    and for other
    TEN-T projects focusing on e.g. improving the ports and multimodal transport links of the
    northern Adriatic26
    .
    4.1.4. ASTRA, PRIMES-TREMOVE and TRUST role in the impact
    assessment
    PRIMES-TREMOVE transport model is a building block of the modelling framework used
    for developing the EU Reference scenario 2016, and has a successful record of use in the
    Commission's transport, climate and energy policy analytical work – it is the same model
    as used for the 2011 White Paper on Transport and the 2016 European strategy on low-
    emission mobility. In this impact assessment, it has been used to define the Baseline
    scenario, having as a starting point the EU Reference scenario 2016 but additionally
    including few policy measures that have been adopted after its cut-off date (end of 2014).
    In addition, the large number of transport means, technologies and fuels, including
    conventional and alternative types, and its ability to evaluate the impact of tolls on the
    vehicle fleet renewal (i.e. trend and composition), made PRIMES-TREMOVE particularly
    suitable for assessing the impacts of modulation of infrastructure charges according to CO2
    emissions.
    TRUST model is a European scale transport network model that allows for the assignment
    of origin-destination matrices at NUTS 3 level for passenger and freight demand. As the
    transport network is not represented in either PRIMES-TREMOVE or ASTRA, TRUST
    was used for evaluating the impacts of road assignment on link-based indicators (e.g.
    traffic and NOx emissions at link level). At Member State level, the Baseline trend of road
    transport activity has been estimated on the trend of road transport demand in the ASTRA
    model, which is calibrated according to PRIMES-TREMOVE projections.
    ASTRA has been used to quantify the impacts of policy options, taking the form of
    integrated policy packages, and to provide indicators for the direct effects on the transport
    system (e.g. transport activity, energy use, air pollutant and CO2 emissions) and for the
    indirect effects of transport on the economic system (e.g. GDP, employment). The Baseline
    scenario has been calibrated on PRIMES-TREMOVE projections. For the modulation of
    the infrastructure charges according to CO2 emissions, in the first stage the PRIMES-
    TREMOVE model has been run while in the second stage PRIMES-TREMOVE results
    (i.e. the structure of the vehicle fleet by type of powertrain, euro class and age and its
    evolution; increase in road charges for vehicles with CO2 emissions above the average27
    )
    have been used in defining the integrated policy packages (i.e. policy options) in ASTRA.
    For each policy options, ASTRA provides the TRUST model with the average road charge
    by country (based on the new vehicle fleet composition) and with updated road demand
    growth rate by mode, country, Origin-Destination and spatial domain. For policy options
    25
    http://www.espon.eu/main/Menu_Projects/Menu_ESPON2013Projects/Menu_AppliedResearch/trac
    c.html
    26
    https://ec.europa.eu/inea/en/ten-t/ten-t-project-implementation-successes/improving-ports-and-
    multimodal-transport-links-northern
    27
    The increase in road charges for the part of the vehicle fleet with CO2 emissions above the average has
    been derived while respecting revenue-neutrality, i.e. while reducing charges for vehicles with lower than
    average CO2 emissions.
    27
    including congestion charging, feedback loops from TRUST to ASTRA are implemented
    to take account of the impacts on the transport network28
    .
    4.2. Baseline scenario
    4.2.1. Scenario design, consultation process and quality assurance
    The Baseline scenario used in this impact assessment builds on the EU Reference scenario
    2016 but additionally includes few policy measures adopted after its cut-off date (end of
    2014) and some updates in the technology costs assumptions.
    Building an EU Reference scenario is a regular exercise by the Commission. It is
    coordinated by DGs ENER, CLIMA and MOVE in association with the JRC, and the
    involvement of other services via a specific inter-service group.
    For the EU Reference scenario 2016, Member States were consulted throughout the
    development process through a specific Reference scenario expert group which met three
    times during its development. Member States provided information about adopted national
    policies via a specific questionnaire, key assumptions have been discussed and in each
    modelling step, draft Member State specific results were sent for consultation. Comments
    of Member States were addressed to the extent possible, keeping in mind the need for
    overall comparability and consistency of the results.
    Quality of modelling results was assured by using state of the art modelling tools, detailed
    checks of assumptions and results by the coordinating Commission services as well as by
    the country specific comments by Member States.
    The EU Reference scenario 2016 projects EU and Member States energy, transport and
    GHG emission-related developments up to 2050, given current global and EU market
    trends and adopted EU and Member States' energy, transport, climate and related relevant
    policies. "Adopted policies" refer to those that have been cast in legislation in the EU or in
    MS (with a cut-off date end of 201429
    ). Therefore, the binding 2020 targets are assumed to
    be reached in the projection. This concerns greenhouse gas emission reduction targets as
    well as renewables targets, including renewables energy in transport. The EU Reference
    scenario 2016 provides projections, not forecasts. Unlike forecasts, projections do not
    make predictions about what the future will be. They rather indicate what would happen if
    the assumptions which underpin the projection actually occur. Still, the scenario allows for
    a consistent approach in the assessment of energy and climate trends across the EU and its
    Member States.
    The report " EU Reference Scenario 2016: Energy, transport and GHG emissions - Trends
    to 2050"30
    describes the inputs and results in detail. In addition, its main messages are
    summarised in the impact assessments accompanying the Effort Sharing Regulation31
    and
    28
    See Annex A of Ricardo et al. (2017) Support Study for the Impact Assessment Accompanying the
    Revision of Directive 1999/62/EC.
    29
    In addition, amendments to two Directives only adopted in the beginning of 2015 were also considered.
    This concerns notably the ILUC amendment to the Renewables Directive and the Market Stability
    Reserve Decision amending the ETS Directive.
    30
    ICCS-E3MLab et al. (2016), EU Reference Scenario 2016: Energy, transport and GHG emissions -
    Trends to 2050
    31
    SWD(2016) 247
    28
    the revision of the Energy Efficiency Directive32
    , and the analytical work accompanying
    the European strategy on low-emission mobility33
    .
    PRIMES-TREMOVE is one of the core models of the modelling framework used for
    developing the EU Reference scenario 2016 and has also been used for developing the
    Baseline scenario of this impact assessment. The model was calibrated on transport and
    energy data up to year 2013 from Eurostat and other sources.
    4.2.2. Main assumptions of the Baseline scenario
    The projections are based on a set of assumptions, including on population growth,
    macroeconomic and oil price developments, technology improvements, and policies.
    Macroeconomic assumptions
    The Baseline scenario uses the same macroeconomic assumptions as the EU Reference
    scenario 2016. The population projections draw on the European Population Projections
    (EUROPOP 2013) by Eurostat. The key drivers for demographic change are: higher life
    expectancy, convergence in the fertility rates across Member States in the long term, and
    inward migration. The EU28 population is expected to grow by 0.2% per year during
    2010-2030 (0.1% for 2010-2050), to 516 million in 2030 (522 million by 2050). Elderly
    people, aged 65 or more, would account for 24% of the total population by 2030 (28% by
    2050) as opposed to 18% today.
    GDP projections mirror the joint work of DG ECFIN and the Economic Policy Committee,
    presented in the 2015 Ageing Report34
    . The average EU GDP growth rate is projected to
    remain relatively low at 1.2% per year for 2010-2020, down from 1.9% per year during
    1995-2010. In the medium to long term, higher expected growth rates (1.4% per year for
    2020-2030 and 1.5% per year for 2030-2050) are taking account of the catching up
    potential of countries with relatively low GDP per capita, assuming convergence to a total
    factor productivity growth rate of 1% in the long run.
    Fossil fuel price assumptions
    Oil prices used in the Baseline scenario are the same with those of the EU Reference
    scenario 2016. Following a gradual adjustment process with reduced investments in
    upstream productive capacities by non-OPEC35
    countries, the quota discipline is assumed
    to gradually improve among OPEC members and thus the oil price is projected to reach 87
    $/barrel in 2020 (in year 2013-prices). Beyond 2020, as a result of persistent demand
    growth in non-OECD countries driven by economic growth and the increasing number of
    passenger cars, oil price would rise to 113 $/barrel by 2030 and 130 $/barrel by 2050.
    No specific sensitivities were prepared with respect to oil price developments. Still, it can
    be recalled that lower oil price assumptions tend to increase energy consumption and CO2
    emissions not covered by the ETS. The magnitude of the change would depend on the
    price elasticities and on the share of taxation, like excise duties, in consumer prices. For
    transport, the high share of excise duties in the consumer prices act as a limiting factor for
    the increase in energy consumption and CO2 emissions.
    Techno-economic assumptions
    32
    SWD(2016) 405
    33
    SWD(2016) 244
    34
    European Commission/DG ECFIN (2014), The 2015 Ageing Report: Underlying Assumptions and
    Projection Methodologies, European Economy 8/2014.
    35
    OPEC stands for Organization of Petroleum Exporting Countries.
    29
    For all transport means, except for light duty vehicles (i.e. passenger cars and light
    commercial vehicles), the Baseline scenario uses the same technology costs assumptions as
    the EU Reference scenario 2016.
    For light duty vehicles, the data for technology costs and emissions savings has been
    updated based on a recent study commissioned by DG CLIMA36
    . Battery costs for electric
    vehicles are assumed to go down to 205 euro/kWh by 2030 and 160 euro/kWh by 2050;
    further reductions in the cost of both spark ignition gasoline and compression ignition
    diesel are assumed to take place. Technology cost assumptions are based on extensive
    literature review, modelling and simulation, consultation with relevant stakeholders, and
    further assessment by the Joint Research Centre (JRC) of the European Commission.
    Specific policy assumptions
    The key policies included in the Baseline scenario, similarly to the EU Reference scenario
    2016, are37
    :
     CO2 standards for cars and vans regulations (Regulation (EC) No 443/2009, amended
    by Regulation (EU) No 333/2014 and Regulation (EU) No 510/2011, amended by
    Regulation (EU) No 253/2014); CO2 standards for cars are assumed to be 95gCO2/km
    as of 2021 and for vans 147gCO2/km as of 2020, based on the NEDC test cycle, in line
    with current legislation. No policy action to strengthen the stringency of the target is
    assumed after 2020/2021.
     The Renewable Energy Directive (Directive 2009/28/EC) and Fuel Quality Directive
    (Directive 2009/30/EC) including ILUC amendment (Directive 2015/1513/EU):
    achievement of the legally binding RES target for 2020 (10% RES in transport target)
    for each Member State, taking into account the use of flexibility mechanisms when
    relevant as well as of the cap on the amount of food or feed based biofuels (7%).
    Member States' specific renewable energy policies for the heating and cooling sector are
    also reflected where relevant.
     Directive on the deployment of alternative fuels infrastructure (Directive 2014/94/EU).
     Directive on the charging of heavy goods vehicles for the use of certain infrastructures
    (Directive 2011/76/EU amending Directive 1999/62/EC).
     Relevant national policies, for instance on the promotion of renewable energy, on fuel
    and vehicle taxation, are taken into account.
    In addition, a few policy measures adopted after the cut-off date of the EU Reference
    scenario 2016 at both EU and Member State level, have been included in the Baseline
    scenario:
     Directive on weights & dimensions (Directive 2015/719/EU);
     Directive as regards the opening of the market for domestic passenger transport services
    by rail and the governance of the railway infrastructure (Directive 2016/2370/EU);
    36
    Source: https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/technology_results_web.xlsx
    37
    For a comprehensive discussion see the Reference scenario report: “EU Reference Scenario 2016:
    Energy, transport and GHG emissions - Trends to 2050”
    30
     Directive on technical requirements for inland waterway vessels (Directive
    2016/1629/EU), part of the Naiades II package;
     Regulation establishing a framework on market access to port services and financial
    transparency of ports38
    ;
     The replacement of the New European Driving Cycle (NEDC) test cycle by the new
    Worldwide harmonized Light-vehicles Test Procedure (WLTP) has been implemented
    in the Baseline scenario, drawing on work by JRC. Estimates by JRC show a WLTP to
    NEDC CO2 emissions ratio of approximately 1.21 when comparing the sales-weighted
    fleet-wide average CO2 emissions. WLTP to NEDC conversion factors are considered
    by individual vehicle segments, representing different vehicle and technology
    categories39
    .
     For Germany, an extension of the toll network by roughly 40,000 kilometres of federal
    trunk road from 2018 onwards for all heavy goods vehicles over 7.5t.40
     For Austria, the incorporation of exhaust emissions and noise pollution in the distance
    based charges. All federal highways and motorways, totalling around 2,200 km, are
    subject to distance based charges.
     For Belgium, a distance based system replaced the former Eurovignette for heavy goods
    vehicles over 3.5t from April 2016. The system applies to all inter-urban motorways,
    main (national) roads41
    and all urban roads in Brussels.
     For Latvia, the introduction of a vignette system applied for goods vehicles below 3.5t
    on the motorways, starting with 1 January 2017. In addition, for all heavy goods
    vehicles over 3.5t the vignette rates applied on motorways for the EURO 0, EURO I,
    EURO II are increased by 10% starting with 1 January 2017.
    38
    Awaiting signature of act (Source :
    http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?reference=2013/0157(COD)&l=en)
    39
    Simulation at individual vehicle level is combined with fleet composition data, retrieved from the official
    European CO2 emissions monitoring database, and publicly available data regarding individual vehicle
    characteristics, in order to calculate vehicle CO2 emissions and fuel consumption over different
    conditions. Vehicle CO2 emissions are initially simulated over the present test protocol (NEDC) for the
    2015 passenger car fleet; the accuracy of the method is validated against officially monitored CO2 values
    and experimental data.
    40
    Currently, 15,000 kilometres of federal trunk road and motorways are subject to tolls.
    41
    E.g. http://www.viapass.be/fileadmin/viapass/documents/download/VlaanderenE.JPG
    31
    Figure 4-1: Summary of road charging systems applied by Member States in the Baseline
    Current Situation AT BE BG CY CZ DE42
    DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
    Road
    infrastructure
    charge
    Vignette
    HGV <12t
    HGV >12 t
    Buses
    Vans
    Cars
    Toll
    HGV <12t
    HGV >12 t
    Buses
    Vans
    Cars
    Phasing out vignette
    HGV
    Buses
    Vans
    Cars
    EURO Class modulation
    HGV
    Buses
    Phasing in CO2/pollutant
    modulation
    HGV
    Buses
    Vans
    Cars
    Rebates for zero emission
    vehicles
    HGV
    Buses
    Vans
    Cars
    External costs
    HGV
    Buses
    Congestion charging All
    Mark-ups
    HGV
    Buses
    Reduced circulation taxes HGV
    42
    In the Baseline only tolls for HGVs above 7.5 t apply.
    32
    4.2.3. Summary of main results of the Baseline scenario
    EU transport activity is expected to continue growing under current trends and adopted
    policies beyond 2015, albeit at a slower pace than in the past. Freight transport activity for
    inland modes is projected to increase by 36% between 2010 and 2030 (1.5% per year) and
    60% for 2010-2050 (1.2% per year). Passenger traffic growth would be slightly lower than
    for freight at 23% by 2030 (1% per year) and 42% by 2050 (0.9% per year for 2010-2050).
    The annual growth rates by mode, for passenger and freight transport, are provided in
    Figure 4-243
    .
    Road transport would maintain its dominant role within the EU. The share of road
    transport in inland freight is expected to slightly decrease at 70% by 2030 and 69% by
    2050. The activity of heavy goods vehicles expressed in tonnes kilometres is projected to
    grow by 35% between 2010 and 2030 (56% for 2010-2050) in the Baseline scenario, while
    light goods vehicles activity would go up by 27% during 2010-2030 (50% for 2010-2050).
    For passenger transport, road modal share is projected to decrease by 4 percentage points
    by 2030 and by additional 3 percentage points by 2050. Passenger cars and vans would still
    contribute 70% of passenger traffic by 2030 and about two thirds by 2050, despite growing
    at lower pace (17% for 2010-2030 and 31% during 2010-2050) relative to other modes,
    due to slowdown in car ownership increase which is close to saturation levels in many
    EU15 Member States and shifts towards rail.
    Figure 4-2: Passenger and freight transport projections (average growth rate per year)
    Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab)
    Note: For aviation, domestic and international intra-EU activity is reported, to maintain the comparability
    with reported statistics.
    Rail transport activity is projected to grow significantly faster than for road, driven in
    particular by the opening of the market for domestic passenger rail transport services and
    the effective implementation of the TEN-T guidelines, supported by the CEF funding,
    leading to the completion of the TEN-T core network by 2030 and of the comprehensive
    network by 2050. Passenger rail activity goes up by 44% between 2010 and 2030 (84% for
    2010-2050), increasing its modal share by 1 percentage point by 2030 and an additional
    percentage point by 2050. Rail freight activity grows by 51% by 2030 and 90% during
    2010-2050, resulting in 2 percentage points increase in modal share by 2030 and an
    additional percentage point by 2050.
    43
    Projections for international maritime and international extra-EU aviation are presented separately and
    not included in the total passenger and freight transport activity to preserve comparability with statistics
    for the historical period.
    -1.0%
    -0.5%
    0.0%
    0.5%
    1.0%
    1.5%
    2.0%
    2.5%
    3.0%
    Road Rail Aviation Inland
    navigation
    Passenger transport
    '95-'10 '10-'30 '30-'50
    -1.0%
    -0.5%
    0.0%
    0.5%
    1.0%
    1.5%
    2.0%
    2.5%
    3.0%
    Road Rail Inland navigation
    Freight transport
    '95-'10 '10-'30 '30-'50
    33
    Domestic and international intra-EU air transport would grow significantly (by 59% by
    2030 and 118% by 2050) and increase its share in overall transport demand (by 3
    percentage points by 2030 and by additional 2 percentage points by 2050). Overall,
    aviation activity including international extra-EU flights is projected to go up by 60% by
    2030 and 124% by 2050, saturating European skies and airports.
    Transport activity of freight inland navigation44
    also benefits from the completion of the
    TEN-T core and comprehensive network, the promotion of inland waterway transport and
    the recovery in the economic activity and would grow by 26% by 2030 (1.2% per year)
    and by 46% during 2010-2050 (0.9% per year).
    International maritime transport activity is projected to continue growing strongly with
    rising demand for oil, coal, steel and other primary resources – which would be more
    distantly sourced – increasing by 37% by 2030 and by 71% during 2010-2050.
    Transport accounts today for about one third of final energy consumption. In the context of
    growing activity, energy use in transport is projected to decrease by 5% between 2010 and
    2030 and to stabilise post-2030 (see Figure 4-3). These developments are mainly driven by
    the implementation of the Regulations setting emission performance standards for new
    light duty vehicles. Light duty vehicles are currently responsible for around 60% of total
    energy demand in transport but this share is projected to significantly decline over time, to
    53% by 2030 and 49% by 2050. Energy use in passenger cars and passenger vans is
    projected to go down by 19% during 2010-2030 (-24% for 2010-2050). Heavy goods
    vehicles are projected to increase their share in final energy demand from 2010 onwards,
    continuing the historic trend from 1995. Energy demand by heavy goods vehicles would
    grow by 14% between 2010 and 2030 (23% for 2010-2050).
    Bunker fuels for air and maritime transport are projected to increase significantly: by 17%
    by 2030 (33% for 2010-2050) and 24% by 2030 (42% for 2010-2050), respectively.
    Figure 4-3: Evolution of total final energy consumption and GHG emissions for 1995-2050
    Source: Baseline scenario, PRIMES model (ICCS-E3MLab)
    Electricity use in transport is expected to increase steadily as a result of further rail
    electrification and the uptake of alternative powertrains in road transport; its share
    increases from 1% currently to 3% in 2030 and 4% in 2050. Battery electric and plug-in
    hybrid electric vehicles are expected to see faster growth beyond 2020, in particular in the
    segment of light duty vehicles, driven by EU and national policies offering various
    44
    Inland navigation covers inland waterways and national maritime.
    0
    200
    400
    600
    800
    1,000
    1,200
    1995
    2000
    2005
    2010
    2015
    2020
    2025
    2030
    2035
    2040
    2045
    2050
    Final energy demand (Mtoe)
    Industry Residential Tertiary Transport
    0
    900
    1,800
    2,700
    3,600
    4,500
    5,400
    1995
    2000
    2005
    2010
    2015
    2020
    2025
    2030
    2035
    2040
    2045
    2050
    Total GHG emissions (Mt of CO2-eq)
    Energy industries Industry
    Residential & tertiary Transport
    Non-CO2 emissions
    34
    incentives and the decrease in battery costs. The share of battery electric and plug-in
    hybrid electric vehicles in the total light duty vehicle stock would reach about 6% by 2030
    and 15% by 2050 (with the shares of battery electric being 2% in 2030 and 6% in 2050).
    The uptake of hydrogen would be facilitated by the increased availability of refuelling
    infrastructure, but its use would remain limited in lack of additional policies beyond those
    assumed in the Baseline scenario. Fuel cells would represent about 3% of the light duty
    vehicle stock by 2050.
    LNG becomes a candidate energy carrier for road freight and waterborne transport,
    especially in the medium to long term, driven by the implementation of the Directive on
    the deployment of alternative fuels infrastructure and the revised TEN-T guidelines which
    represent important drivers for the higher penetration of alternative fuels in the transport
    mix. In the Baseline scenario, the share of LNG is projected to go up to 3% by 2030 (8%
    by 2050) for road freight and 4% by 2030 (7% by 2050) for inland navigation. LNG would
    provide about 4% of maritime bunker fuels by 2030 and 10% by 2050 – especially in the
    segment of short sea shipping.
    Biofuels uptake is driven by the legally binding target of 10% renewable energy in
    transport (Renewables Directive), as amended by the ILUC Directive, and by the
    requirement for fuel suppliers to reduce the GHG intensity of road transport fuel by 6%
    (Fuel Quality Directive). Beyond 2020, biofuel levels would remain relatively stable at
    around 6% in the Baseline scenario. The Baseline scenario does not take into account the
    recent proposal by the Commission for a recast of the Renewables Energy Directive.
    In the Baseline scenario, oil products would still represent about 90% of the EU
    transport sector needs in 2030 and 85% in 2050, despite the renewables policies and the
    deployment of alternative fuels infrastructure which support some substitution effects
    towards biofuels, electricity, hydrogen and natural gas (see Figure 4-4).
    Figure 4-4: Evolution of final energy use in transport by type of fuel
    Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab)
    The declining trend in transport emissions is expected to continue, leading to 13%
    lower emissions by 2030 compared to 2005, and 15% by 2050.45
    However, relative to 1990
    levels, emissions would still be 13% higher by 2030 and 10% by 2050, owing to the fast
    rise in the transport emissions during the 1990s. The share of transport in total GHG
    45
    Including international aviation but excluding international maritime and other transportation.
    0
    50
    100
    150
    200
    250
    300
    350
    400
    2010 2015 2020 2025 2030 2035 2040 2045 2050
    Mtoe
    Electricity & hydrogen
    Gas & biomethane
    Biofuels
    LPG
    Fuel oil
    Jet fuel
    Diesel
    Gasoline
    35
    emissions would continue increasing, going up from 23% currently (excluding
    international maritime) to 25% in 2030 and 31% in 2050, following a relatively lower
    decline of emissions from transport compared to power generation and other sectors (see
    Figure 4-3). Aviation would contribute an increasing share of transport emissions over
    time, increasing from 14% today to about 18% in 2030 and 21% in 2050. Maritime bunker
    fuel emissions are also projected to grow strongly, increasing by 22% during 2010-2030
    (38% for 2010-2050).
    CO2 emissions from road freight transport (heavy goods and light goods vehicles) are
    projected to increase by 6% between 2010 and 2030 (11% for 2010-2050) in the Baseline
    scenario. For heavy goods vehicles, the increase would be somewhat higher (10% for
    2010-2030 and 17% for 2010-2050), in lack of specific measures in place. At the same
    time, emissions from passenger cars and passenger vans are projected to decrease by 22%
    between 2010 and 2030 (32% for 2010-2050) thanks to the CO2 standards in place and the
    uptake of electromobility. CO2 emissions from buses and coaches are projected to remain
    relatively unchanged by 2030 compared to their 2010 levels, and to slightly increase post-
    2030 (3% increase for 2010-2050).
    The overall trend in transport emissions is determined by three broad components:
    transport activity levels (expressed in passenger or tonne-kilometres), the energy intensity
    of transport (defined as energy consumption per passenger or tonne-kilometre) and the
    carbon intensity of the energy used (given by the CO2 emissions divided by energy
    consumption). Following this approach, it has been evaluated how much the projected
    transport emissions will increase/decrease (in percentage terms or Mt of CO2) between
    2010 and 2030 due to transport activity growth, improvements in energy intensity and
    carbon intensity (see Figure 4-5).46,47
    Overall, CO2 emissions from passenger transport decrease by 14% (109 Mt of CO2)
    between 2010 and 2030 in the Baseline scenario. The 14% decrease in CO2 emissions from
    passenger transport is due to transport activity growth (+21%, equivalent to 165 Mt of
    CO2), improvements in energy intensity (-31%, equivalent to 246 Mt of CO2) and in
    carbon intensity (-4%, equivalent to 28 Mt of CO2). The trend for the three components
    and their contribution to emissions is different by transport mode. Efficiency gains play a
    decisive role in reducing emissions in road transport, while in aviation they would not
    offset the activity growth leading to higher fuel use and emissions. The use of less CO2
    intensive fuels contributes to a reduction of emissions for road and rail passenger transport
    with no effect on aviation by 2030.
    For freight transport, the 5% (13 Mt of CO2) increase in CO2 emissions between 2010 and
    2030 is the result of transport activity growth (+30%, equivalent to 75 Mt of CO2),
    improvements in energy intensity (-20%, equivalent to 49 Mt of CO2) and in carbon
    intensity (-5%, equivalent to 13 Mt of CO2). The efficiency gains and the uptake of
    alternative fuels for road freight transport are not sufficient to offset the effects of activity
    growth, and thus CO2 emissions go up between 2010 and 2030. The electrification in rail
    has positive effects on emissions, despite the growth in traffic volumes. For inland
    46
    The proposed method is the Montgomery decomposition. For a recent application of the method see: De
    Boer, P.M.C. (2008) Additive Structural Decomposition Analysis and Index Number Theory: An
    Empirical Application of the Montgomery Decomposition, Economic Systems Research, 20(1), pp. 97-
    109.
    47
    The decomposition analysis only takes into account the tank to wheel emissions, under the assumption
    that biofuels are carbon neutral.
    36
    navigation, efficiency gains and to some lower extent the uptake of LNG has also positive
    effects on emissions reduction.
    Figure 4-5: Decomposition of CO2 emissions in the Baseline scenario (2010-2030)
    Source: EC elaboration based on the Baseline scenario, PRIMES-TREMOVE transport model (ICCS-
    E3MLab)
    Note: The figures report the changes in CO2 emissions due to the three broad components (transport activity
    levels, energy intensity of transport and carbon intensity of the energy used) in two ways: in levels and in
    relative terms compared to 2010. The size of each column bar, read on the left axis, represents the change in
    terms of CO2 emissions compared to 2010, expressed in Mt of CO2. The percentage changes reported above
    the column bars represent relative changes in these emissions compared to their respective 2010 levels.
    Provided that CO2 levels for 2010 corresponding to each transport mode are not comparable in size, the
    -21%
    14%
    -31%
    -4%
    -29%
    31%
    -18% -42%
    17%
    51%
    -34%
    0%
    -250
    -200
    -150
    -100
    -50
    0
    50
    100
    150
    Change in CO2 emissions Activity Energy intensity CO2 intensity
    Mt
    of
    CO2
    Passengertransport
    Road Rail Aviation
    TOTAL COMPONENTS
    6%
    31%
    -20%
    -4%
    -8%
    39%
    -15% -32%
    -3%
    23%
    -17% -9%
    -60
    -40
    -20
    0
    20
    40
    60
    80
    Change in CO2 emissions Activity Energy intensity Carbon intensity
    Mt
    of
    CO2
    Freight transport
    Road Rail Inland navigation
    TOTAL COMPONENTS
    37
    percentage changes reported in the figures are not directly comparable. The figures above include only tank
    to wheel emissions.
    NOx emissions would drop by about 56% by 2030 (64% by 2050) with respect to 2010
    levels. The decline in particulate matter (PM2.5) would be less pronounced by 2030 at
    51% (65% by 2050). By 2030, over 75% of heavy goods vehicle stock is projected to be
    Euro VI in the Baseline scenario and more than 80% of the passenger cars stock is
    projected to be Euro 6. Overall, external costs related to air pollutants would decrease by
    about 56% by 2030 (65% by 2050).48
    High congestion levels are expected to seriously affect road transport in several Member
    States by 2030 in the absence of effective countervailing measures such as road pricing.
    While urban congestion will mainly depend on car ownership levels, urban sprawl and the
    availability of public transport alternatives, congestion on the inter-urban network would
    be the result of growing freight transport activity along specific corridors, in particular
    where these corridors cross urban areas with heavy local traffic (see Figure 4-6). The
    largest part of congestion will be concentrated near densely populated zones with high
    economic activity such as Belgium and the Netherlands – to a certain extent as a result of
    port and transhipment operations – and in large parts of Germany, the United Kingdom and
    northern Italy. Congestion patterns differ significantly among Member States though, since
    their hourly, daily and seasonal variation depends on local conditions.
    Figure 4-6: Congestion levels on the inter-urban network in the Baseline scenario for 2030
    Source: TRUST model
    48
    External costs are expressed in 2013 prices. They cover NOx, PM2.5 and SOx emissions.
    38
    Estimating the costs of congestion is not straightforward, because it occurs mostly during
    certain times of the day, often caused by specific bottlenecks in the network. In the
    Baseline scenario, total congestion costs for urban and inter-urban network are
    projected to increase by about 24% by 2030 and 43% by 2050, relative to 2010.
    Noise related external costs of transport would continue to increase, by about 17% during
    2010-2030 (24% for 2010-2050), driven by the rise in traffic. Thanks to policies in place,
    external costs of accidents are projected to go down by about 46% by 2030 (-42% for
    2010-2050) – but still remain high at over €100 billion in 2050. Overall, external costs49
    are projected to decrease by about 10% by 2030 and to increase post-2030; by 2050 they
    stabilise around levels observed in 2010.
    4.3. Detailed description of the policy measures and assumptions used in the
    Policy Options
    4.3.1. Policy Option 1
    PO1 builds on the Baseline scenario and additionally includes the following modelling
    assumptions (see Figure 4-7 for a summary of measures by Member State):
     Remove exemptions for HGVs below 12 tonnes: it is assumed that time-based
    charges for HGVs below 12 tonnes are introduced in Denmark, Luxembourg, the
    Netherlands, Sweden and the United Kingdom starting from 2025. The rates for HGVs
    below 12 tons are set at 65% of those already existing for HGVs above 12 tons. For
    Germany an extension of the tolling system to HGVs below 7.5 tons is assumed from
    2020 onwards.
     Promote zero-emission vehicles by allowing reduced rates: starting with 2020 it is
    assumed that zero-emission HGVs and buses are exempt from charging and zero-
    emission vans and cars benefit of a 50% reduction.50
     Extension of mark-ups beyond mountain regions: introduction of mark-ups is
    assumed on some roads in France and in Slovenia. For modelling purposes plans for
    mark-ups are mainly assumed in mountain regions; this is because they are the only
    real examples available to test the introduction of possible future schemes. These
    examples can also show the possible differences in effect on larger and smaller
    Member States.
     Reviewing of maximum values for external cost charging to better reflect external
    costs of air pollution and noise. The maximum permissible external cost charge limits
    and the external cost charges currently applied in Germany and Austria51
    are provided
    in Annex 5. For modelling purposes, in PO1 it is assumed that external costs are
    increased from 2020 onwards in Germany for HGVs and in Austria for HGVs and
    buses according to the values of the 2014 Handbook on external costs of transport52
    .
    The review implies using more proportionate values for external cost charges, i.e.
    differentiated according to vehicle weight (heavier trucks pollute more than lighter
    ones). The values do not change between policy options and are set in line with the
    2014 Handbook on external costs of transport.
    49
    External costs cover here air pollution, congestion, noise and accidents.
    50
    Reduced rates are implemented only in Member States where road charging systems are in place.
    51
    Currently these are the only Member States making use of this possibility offered by Directive 1999/62/EC
    52
    Ricardo-AEA et al (2014), Update of the Handbook on External Costs of Transport:
    http://ec.europa.eu/transport/themes/sustainable/studies/sustainable_en
    39
    Figure 4-7: Summary of policy measures introduced in PO1 relative to the Baseline
    AT BE BG CY CZ DE53
    DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
    Road
    infrastructure
    charge
    variations
    Vignette
    HGV <12t
    HGV >12 t
    Buses
    Vans
    Cars
    Toll
    HGV <12t
    HGV >12 t
    Buses
    Vans
    Cars
    Phasing out vignette
    HGV
    Buses
    Vans
    Cars
    Phasing out EURO Class
    modulation
    HGV
    Buses
    Phasing in CO2/pollutant
    modulation
    HGV
    Buses
    Vans
    Cars
    Rebates for zero emission
    vehicles
    HGV
    Buses
    Vans
    Cars
    External costs54 HGV
    Buses
    Congestion charging All
    Mark-ups
    HGV
    Buses
    Reduced circulation taxes HGV
    Note: measures included in PO1 relative to the Baseline are reported in green.
    53
    In PO1 tolls for HGVs also apply below 7.5 t.
    54
    In the context of reviewing the maximum values for external cost charging to better reflect external costs for air pollution and noise, the charges for HGVs and buses for Austria
    and for HGVs for Germany are increased in line with the values of the 2014 Handbook on external costs of transport.
    40
    4.3.2. Policy option 2
    PO2 builds on PO1 and additionally includes the following modelling assumptions:
     Phase out vignettes for HGVs above 3.5 tonnes and buses starting in 202555
    with
    the introduction of new distance based charging systems in Denmark, Lithuania,
    Luxembourg, Latvia, the Netherlands, Romania, Sweden and the United Kingdom and
    the extension of the existing ones to cover also buses in Belgium, Germany and
    Hungary. Additionally, for Bulgaria the phasing out of vignette for HGV is assumed
    starting with 202056
    . The average charges assumed for modelling purposes are
    summarised in Figure 4-8.
    Figure 4-8: Assumed average distance-base charges replacing existing vignettes (€cent/km)
    Country HGV 3.5t - 12t HGV> 12 t Buses
    BE Unchanged Unchanged 13,5
    BG 8,18 14,49 8,18
    DE 13,5 Unchanged 13,5
    DK 13,5 16,3 13,5
    HU Unchanged Unchanged 11,7
    LT 8,18 14,49 8,18
    LU 13,5 16,3 13,5
    LV 8,18 14,49 8,18
    NL 13,5 16,3 13,5
    RO 8,18 14,49 8,18
    SE 13,5 16,3 13,5
    UK 13,5 16,3 13,5
     Phase out Euro class-differentiation and more extensive use of external cost
    charging starting in 2025. The measure is simulated through the elimination of
    modulation of infrastructure charges by Euro class in all Member States where it is
    applied and the assumed introduction of external cost charging for air and noise
    pollution in those Member States, based on 2014 Handbook on external costs of
    transport57
    . More specifically, external cost charging for HGVs would be additionally
    applied in PO2 in Belgium, Bulgaria, Czech Republic, Denmark, Hungary, Lithuania,
    Latvia, Luxembourg, the Netherlands, Poland, Sweden, Slovenia and Slovakia and for
    buses in Bulgaria, Czech Republic, Lithuania, Latvia, Poland, Slovenia and Slovakia.
     Phasing in of revenue-neutral modulation of infrastructure charges according to
    CO2 emissions for HGVs above 3.5 tonnes and buses starting in 2025. The measure
    is assumed to apply in all Member States except Cyprus, Estonia, Finland and Malta
    (where no charging system is applied). The revised charges are based on the results of
    the PRIMES-TREMOVE model (ICCS-E3MLab)58
    . The assumptions used for the
    modulation of infrastructure charges according to CO2 emissions are provided in
    Figure 4-9.
    55
    Assumptions about changes in the charging systems were made in 5-year steps. The assumptions regarding
    the timing of the introduction of the measures are conservative, considering the uncertainty.
    56
    The time of the introduction of the measure has been assumed in line with the Government plans. These plans
    have not yet been adopted in law and thus they are not considered in the Baseline.
    57
    http://ec.europa.eu/transport/themes/sustainable/internalisation_en
    58
    This measure has been modelled in two steps. In the first step, the PRIMES-TREMOVE model has been run.
    In the second step, PRIMES-TREMOVE results (i.e. the structure of the vehicle fleet by type of powertrain,
    age and its evolution; the increase in road charges for vehicles with CO2 emissions above the average) have
    been used in defining the integrated policy package in ASTRA model.
    41
    Figure 4-9: Assumptions used for the modulation of infrastructure charges according to CO2
    emissions for HGVs and buses/coaches
    Environmental performance Euro 0-VI New low CO2-emission vehicles59
    Heavy goods vehicles between 3.5 tonnes
    and 7.5 tonnes plus buses/coaches
    Charge above average rate
    Assume 25% reduction in charges versus
    Euro 0-VI
    Heavy goods vehicles above 7.5 tonnes
    Charge above average rate
    Assume 25% reduction in charges versus
    Euro 0-VI
     Rebates for all zero emission vehicles are assumed starting with 2020 in almost all
    MSs (except Cyprus, Estonia, Finland and Malta where no charging system is
    applied). Rebates imply the full exemption from tolls for zero emission HGV and
    buses and 50% reduction for zero emission vans and passenger cars. Exemptions for
    HGV below 12 tonnes are phased in from 2025 onwards in Denmark, Lithuania,
    Luxembourg, Latvia, the Netherlands, Romania, Sweden and the United Kingdom,
    and from 2020 onwards for BG60
    .
     Reduction of circulation taxes for HGV above 12 tonnes and below 12 tonnes,
    according to Figure 4-10, where a 50% reduction is assumed for distance-based
    systems already in place and exemptions for new distance-based systems.
    Figure 4-10: Implementation of reduced circulation taxes
    Country HGVs > 12 tonnes and HGVs < 12 tonnes
    AT 2020 (50% reduction)
    BE 2020 (50% reduction)
    BG 2020 (Exemption)
    CY -
    CZ 2020 (50% reduction)
    DE 2020 (50% reduction)
    DK 2025 (Exemption)
    EL 2020 (50% reduction)
    ES 2020 (50% reduction)
    FR 2020 (50% reduction)
    HR 2020 (50% reduction)
    HU 2020 (50% reduction)
    IE 2020 (50% reduction)
    IT 2020 (50% reduction)
    LT 2025 (Exemption)
    LU 2025 (Exemption)
    LV 2025 (Exemption)
    MT -
    NL 2025 (Exemption)
    PL 2020 (50% reduction)
    PT 2020 (50% reduction)
    RO 2025 (Exemption)
    SE 2025 (Exemption)
    SI 2020 (50% reduction)
    SK 2020 (50% reduction)
    UK 2025 (Exemption)
    Figure 4-11 below provides a summary of the measures included in PO2, by Member State.
    59
    'Low emission' vehicles are defined as below the average (VECTO baseline).
    60
    Differences in the timing of introduction are linked to the introduction of distance-based systems in these
    Member States.
    42
    Figure 4-11: Summary of policy measures introduced in PO2 relative to the Baseline
    AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
    Road
    infrastructure
    charge
    variations
    Vignette
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Toll
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Phasing out vignette
    HGV
    Buses
    Vans
    Cars
    Phasing out EURO Class
    modulation
    HGV
    Buses
    Phasing in CO2/pollutant
    modulation
    HGV
    Buses
    Vans
    Cars
    Rebates for zero emission
    vehicles
    HGV
    Buses
    Vans
    Cars
    External costs
    HGV
    Buses
    Congestion charging All
    Mark-ups
    HGV
    Buses
    Reduced circulation taxes HGV
    Note: measures included in PO1 and PO2 are reported in green; additional measures included in PO2 are reported in blue.
    43
    4.3.3. Policy option 2 – sensitivity case (PO2s)
    PO2s (sensitivity case) builds on PO2 but additionally includes the following modelling
    assumptions:
     Phase-in of distance-based charges for all HGVs and buses in Estonia and Finland
    starting with 2025.
     Phase-in of revenue-neutral modulation of infrastructure charges according to CO2
    emissions for HGVs above 3.5 tonnes and buses starting with 2025 for Estonia and
    Finland. Similarly to PO2, the revised charges are based on the results of the
    PRIMES-TREMOVE model (ICCS-E3MLab).
     Rebates for all zero emission vehicles starting with 2025 in Estonia and Finland.
     Exemption of circulation taxes for HGVs from 2025 onwards in Estonia and Finland.
    Figure 4-12 below provides a summary of the measures included in PO2s, by Member State.
    44
    Figure 4-12: Summary of policy measures introduced in PO2s (sensitivity case) relative to the Baseline
    AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
    Road
    infrastructure
    charge
    variations
    Vignette
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Toll
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Phasing out vignette
    HGV
    Buses
    Vans
    Cars
    Phasing out EURO Class
    modulation
    HGV
    Buses
    Phasing in CO2/pollutant
    modulation
    HGV
    Buses
    Vans
    Cars
    Rebates for zero emission
    vehicles
    HGV
    Buses
    Vans
    Cars
    External costs
    HGV
    Buses
    Congestion charging All
    Mark-ups
    HGV
    Buses
    Reduced circulation taxes HGV
    Note: measures included in PO1 and PO2 are reported in green; measures included in PO2 and PO2s are reported in blue; additional measures included in PO2s are reported in light blue.
    45
    4.3.4. Policy option 3a
    PO3a builds on PO2 and additionally includes the following modelling assumptions:
     Phase in genuine congestion charging in distance-based environment for all
    vehicles, i.e. in Greece, Spain, France, Croatia, Ireland, Italy, Poland and Portugal61
    from 2025.
    The modelling of congestion charging required the identification of potential congested
    links where charges should be phased in. The identification of the most congested links is
    made on the basis of the TRUST model’s output of road traffic assignment in 2030,
    assuming a load/capacity ratio of 0.5 computed on daily traffic as representative of
    congestion during peak time (Figure 4-13).
    Figure 4-13: Congested links in TRUST 2030 network (Daily load/capacity ratio >= 0.5)
    61
    These are the Member States currently applying distance-based charging for all vehicle categories,
    therefore the only ones that can make use of the instrument.
    46
    Source: TRUST model
    The level of additional charges is based on the specific country values for traffic conditions
    close to road capacity available from the 2014 Handbook on external costs of transport62
    ,
    detailed by road type (motorways and main roads) and vehicle type.
    The daily average charges are expressed in 2015 prices. To translate peak charges into
    average daily charges the share of cars and HDV traffic in the peak periods (from 7:00 to
    11:00 and from 16:00 to 20:00) has been used, considering the available set of real traffic
    data for motorways and main roads in EU countries.
    The average daily congestion charges modelled in PO3a are summarised in Figure 4-14.
    Figure 4-14: Average daily efficient marginal congestion costs, € per vkm
    Car Rigid truck Articulated truck Bus
    Country Motorway
    Main
    Roads Motorway
    Main
    Roads Motorway
    Main
    Roads Motorway
    Main
    Roads
    EL 0,074 0,093 0,108 0,163 0,165 0,249 0,142 0,215
    ES 0,082 0,104 0,121 0,182 0,184 0,278 0,159 0,24
    FR 0,089 0,112 0,13 0,196 0,198 0,3 0,171 0,258
    HR 0,049 0,062 0,072 0,108 0,109 0,165 0,094 0,142
    IE 0,105 0,132 0,154 0,232 0,235 0,354 0,202 0,305
    IT 0,083 0,105 0,122 0,184 0,186 0,28 0,16 0,242
    PL 0,052 0,065 0,076 0,114 0,115 0,174 0,099 0,15
    PT 0,066 0,083 0,096 0,146 0,147 0,222 0,127 0,191
    Additional assumptions on maximum congestion charges are made considering the specific
    length of the congested links in the TRUST model network. Given the strategic level of the
    network implemented in European models such as TRUST, links are generally
    characterized by a certain length (e.g. 20–30 km) and the increase of charges due to
    congestion should consider only a portion of the link to reflect the real situation where, if
    congestion occurs, it is generally localised a on shorter portion of the links. In this respect,
    a threshold of 10 kilometres is imposed.
    A feedback of the results obtained from TRUST into the ASTRA model (as an exogenous
    input) allowed for ASTRA indicators to include the impact of congestion charging.
    Specifically, TRUST provided the share of traffic (by vehicle type) travelling on links
    subject to congestion charging with respect to the total traffic on tolled road network in
    each NUTS I zone of a country. These shares were used to calculate the average value of
    congestion charge (applied on top of the infrastructure charge) at the NUTS I level, which
    was introduced in ASTRA as an input to calculate travel costs, affecting modal split and
    revenues from road charging.
    Figure 4-15 below provides a summary of the measures assessed in in PO3a, by Member
    State.
    62
    http://ec.europa.eu/transport/themes/sustainable/internalisation_en
    47
    Figure 4-15: Summary of policy measures introduced in PO3a relative to the Baseline
    AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
    Road
    infrastructure
    charge
    variations
    Vignette
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Toll
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Phasing out vignette
    HGV
    Buses
    Vans
    Cars
    Phasing out EURO Class
    modulation
    HGV
    Buses
    Phasing in CO2/pollutant
    modulation
    HGV
    Buses
    Vans
    Cars
    Rebates for zero emission
    vehicles
    HGV
    Buses
    Vans
    Cars
    External costs
    HGV
    Buses
    Congestion charging All
    Mark-ups
    HGV
    Buses
    Reduced circulation taxes HGV
    Note: measures included in PO1, PO2 and PO3a are reported in green; measures included in PO2 and PO3a are reported in blue; measures additionally included in PO3a are provided in purple.
    48
    4.3.5. Policy option 3b
    PO3b also builds on PO2 and additionally includes the following modelling assumptions:
     Genuine congestion charging in distance-based environment for all vehicles,
    i.e. in Greece, Spain, France, Croatia, Ireland, Italy, Poland and Portugal from
    2025. Assumptions concerning congestion charges are the same as in PO3a (see
    section 4.3.4).
     Phasing in the modulation of infrastructure charges according to
    CO2/pollutant emission for vans and passenger cars by 2025 as shown in Figure
    4-16. The revised charges are based on the results of the PRIMES-TREMOVE
    model (ICCS-E3MLab)63
    .
    Figure 4-16: Assumptions used for the modulation of infrastructure charges
    according to CO2/pollutant emissions for vans and passenger cars
    Environmental
    performance
    Conformity factor
    above 2.1
    Maximum 168 mg NOx
    and maximum 95 gCO2/km for
    passenger cars (147 gCO2/km for
    vans) in 2020
    Maximum 80 mg NOx and
    maximum 95 gCO2/km for
    passenger cars (147
    gCO2/km for vans) from
    2021
    Charge per km Above average rate
    -15% versus
    highest rate
    -30% versus
    highest rate
    Figure 4-17 below provides a summary of the measures implemented in PO3b by Member
    State.
    63
    This measure has been modelled in two steps. In the first step, the PRIMES-TREMOVE model has been
    run. In the second step, PRIMES-TREMOVE results (i.e. the structure of the vehicle fleet by type of
    powertrain, age and its evolution; the increase in road charges for vehicles with CO2 emissions above the
    average) have been used in defining the integrated policy package in ASTRA model.
    49
    Figure 4-17: Summary of policy measures introduced in PO3b relative to the Baseline
    AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
    Road
    infrastructure
    charge
    variations
    Vignette
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Toll
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Phasing out vignette
    HGV
    Buses
    Vans
    Cars
    Phasing out EURO Class
    modulation
    HGV
    Buses
    Phasing in CO2/pollutant
    modulation
    HGV
    Buses
    Vans
    Cars
    Rebates for zero emission
    vehicles
    HGV
    Buses
    Vans
    Cars
    External costs
    HGV
    Buses
    Congestion charging All
    Mark-ups
    HGV
    Buses
    Reduced circulation taxes HGV
    Note: measures included in PO1, PO2, PO3a and PO3b are reported in green; measures included in PO2, PO3a and PO3b are reported in blue; measures included in PO3a and PO3b are provided in
    purple; measures additionally included in PO3b are reported in orange.
    50
    4.3.6. Policy option 4
    PO4 builds on PO3b and additionally includes the following modelling assumptions:
     Mandatory external cost charging for air pollution and noise for HGVs and buses on
    the TEN-T network in all countries where road charging is applied.
     Phase out vignettes for vans by 2025 and phase-in of distance-based charging for
    these vehicles in Austria, Bulgaria, Czech Republic, Hungary, Lithuania, Latvia,
    Romania, Slovenia and Slovakia.
     Phasing out of vignettes for passenger cars and phase-in of distance based
    charges for passenger cars in Austria, Bulgaria, Czech Republic, Hungary, Romania,
    Slovenia and Slovakia.
     Extension of genuine congestion charging also to Austria, Bulgaria, Czech
    Republic, Hungary, Romania, Slovenia and Slovakia. The assumptions used for the
    average daily congestion charges in PO4, based on the 2014 Handbook on external
    costs of transport values, are summarised in Figure 4-18.
     Exemption from circulation taxes for vans in Austria, Bulgaria, Czech Republic,
    Hungary, Latvia, Lithuania, Romania, Slovenia and Slovakia from 2025 onwards.
    Assume a 50% reduction for vans for the distance-based systems already in place in
    Greece, Spain, France, Croatia, Ireland, Italy, Poland and Portugal from 2020
    onwards.
    Figure 4-18: Average daily efficient marginal congestion costs, € per vkm
    Car Rigid truck Articulated truck Bus
    Country Motorway
    Main
    Roads Motorway
    Main
    Roads Motorway
    Main
    Roads Motorway
    Main
    Roads
    AT 0,104 0,131 0,152 0,23 0,232 0,351 0,2 0,302
    BG 0,036 0,046 0,053 0,080 0,081 0,122 0,070 0,105
    CZ 0,066 0,083 0,096 0,145 0,146 0,221 0,126 0,19
    EL 0,074 0,093 0,108 0,163 0,165 0,249 0,142 0,215
    ES 0,082 0,104 0,121 0,182 0,184 0,278 0,159 0,24
    FR 0,089 0,112 0,13 0,196 0,198 0,3 0,171 0,258
    HR 0,049 0,062 0,072 0,108 0,109 0,165 0,094 0,142
    HU 0,053 0,067 0,078 0,118 0,119 0,18 0,103 0,155
    IE 0,105 0,132 0,154 0,232 0,235 0,354 0,202 0,305
    IT 0,083 0,105 0,122 0,184 0,186 0,28 0,16 0,242
    PL 0,052 0,065 0,076 0,114 0,115 0,174 0,099 0,15
    PT 0,066 0,083 0,096 0,146 0,147 0,222 0,127 0,191
    RO 0,039 0,049 0,056 0,085 0,086 0,130 0,074 0,112
    SI 0,07 0,088 0,102 0,154 0,156 0,236 0,135 0,203
    SK 0,06 0,076 0,088 0,134 0,135 0,204 0,116 0,176
    Source: TRT elaborations based on 2014 Handbook on external costs of transport
    Figure 4-19 below provides a summary of the measures included in PO4, by Member State.
    51
    Figure 4-19: Summary of policy measures introduced in PO4 relative to the Baseline
    AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
    Road
    infrastructure
    charge
    variations
    Vignette
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Toll
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Phasing out vignette
    HGV
    Buses
    Vans
    Cars
    Phasing out EURO Class
    modulation
    HGV
    Buses
    Phasing in CO2/pollutant
    modulation
    HGV
    Buses
    Vans
    Cars
    Rebates for zero emission
    vehicles
    HGV
    Buses
    Vans
    Cars
    External costs
    HGV
    Buses
    Congestion charging All
    Mark-ups
    HGV
    Buses
    Reduced circulation taxes
    HGV
    Vans
    Note: measures included in PO1, PO2, PO3a, PO3b and PO4 are reported in green; measures included in PO2, PO3a, PO3b and PO4 are reported in blue; measures included in PO3a, PO3b and PO4 are
    provided in purple; measures included in PO3b and PO4 are reported in orange; measures additionally included in PO4 are reported in red.
    52
    4.3.7. Policy option 4 – sensitivity case (PO4s)
    PO4s builds on PO4 but additionally includes the following modelling assumptions:
     Phase-in of distance-based charges for vans and passenger cars in Belgium, Germany,
    Luxembourg and Netherlands from 2025 onwards.
     Phase-in of modulation of infrastructure charges according to CO2/air pollutant
    emissions for vans and passenger cars starting with 2025 in Belgium, Germany,
    Luxembourg and Netherlands.
     Rebates for all zero emission vans and passenger cars starting with 2025 in Belgium,
    Germany, Luxembourg and Netherlands.
     Extension of genuine congestion charging also to Belgium, Germany, Luxembourg
    and Netherlands.
     Exemption from circulation taxes for vans in Belgium, Germany, Luxembourg and
    Netherlands from 2025 onwards.
    53
    Figure 4-20: Summary of policy measures introduced in PO4s (sensitivity case) relative to the Baseline
    AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK
    Road
    infrastructure
    charge
    variations
    Vignette
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Toll
    HGV <12t
    HGV >12t
    Buses
    Vans
    Cars
    Phasing out vignette
    HGV
    Buses
    Vans
    Cars
    Phasing out EURO Class
    modulation
    HGV
    Buses
    Phasing in CO2/pollutant
    modulation
    HGV
    Buses
    Vans
    Cars
    Rebates for zero emission
    vehicles
    HGV
    Buses
    Vans
    Cars
    External costs
    HGV
    Buses
    Congestion charging All
    Mark-ups
    HGV
    Buses
    Reduced circulation taxes HGV
    Vans
    Note: measures included in PO1, PO2, PO3a, PO3b, PO4 and PO4s are reported in green; measures included in PO2, PO3a, PO3b, PO4 and PO4s are reported in blue; measures included in PO3a,
    PO3b, PO4 and PO4s are provided in purple; measures included in PO3b, PO4 and PO4s are reported in orange; measures included in PO4 and PO4s are reported in red; measures additionally included
    in PO4s are reported in light red.
    54
    5. ANNEX 5: ROAD CHARGING SYSTEMS IN THE EU
    Figure 5-1: Heavy goods vehicles
    55
    Figure 5-2: Light goods vehicles
    56
    Figure 5-3: Buses and coaches
    57
    Figure 5-4: Passenger cars
    58
    Figure 5-5: HGV external cost charges, covering air pollution costs per kilometre from
    1st
    October 2015, Germany
    Emission category Toll rate [cents],
    Costs for air pollution
    Euro VI 0
    EEV 1, Euro V 2.1
    Euro IV, Euro III + with particulate reduction class 2 3.2
    Euro III, Euro II + with particulate reduction class 1 6.3
    Euro II 7.3
    Euro I, Euro 0 8.3
    Source: (Toll Collect, 2016). These charges are independent of the number of axles of the vehicle
    and the type of road (BMJV, 2015).
    Figure 5-6: HGV external cost charges, covering air pollution costs per kilometre from
    1st
    January 2017, Austria
    Emission category Toll rate [cents],
    Costs for air pollution
    2 axles
    Toll rate [cents],
    Costs for air pollution
    3 axles
    Toll rate [cents],
    Costs for air pollution
    4+ axles
    Euro VI --- --- ---
    EEV, Euro V 1.37 1.92 2.19
    Euro IV 2.00 2.80 3.20
    Euro 0 - III 4.00 5.60 6.40
    Source: (BMVIT, 2016b), Interview input from BMVIT
    Figure 5-7: HGV external cost charges, covering noise costs per kilometre from 1st
    January 2017, Austria
    Time Toll rate [cents],
    Costs for noise
    2 axles
    Toll rate [cents],
    Costs for noise
    3 axles
    Toll rate [cents],
    Costs for noise
    4+ axles
    Day 0.07 0.16 0.20
    Night 0.11 0.25 0.32
    Source: (BMVIT, 2016b), Interview input from BMVIT
    59
    Figure 5-8: Maximum chargeable air pollution cost according to Directive 1999/62/EC
    cent/vehicle.kilometre Suburban roads
    (including motorways)
    Interurban roads
    (including motorways)
    EURO 0 16,9 12,7
    EURO I 11,7 8,5
    EURO II 9,6 7,4
    EURO III 7,4 6,4
    EURO IV 4,3 3,2
    EURO V
    after 31 December 2013
    0 0
    3,2 2,2
    EURO VI
    after 31 December 2017
    0 0
    2,2 1,1
    Less polluting than EURO
    VI
    0 0
    Updated on 1.06.2016
    Figure 5-9: Maximum chargeable noise cost according to Directive 1999/62/EC
    cent/vehicle.kilometre Day Night
    Suburban roads
    (including motorways)
    1,17 2,12
    Interurban roads
    (including motorways)
    0,22 0,32
    Updated on 1.06.2016
    60
    6. ANNEX 6: IMPORTANCE OF ROAD CHARGES IN HGV OPERATING COSTS IN THE EU
    A wide variety of different road charging systems exist in the EU and only a share of
    vehicles are charged (section 2.2.3). Charging schemes differ not only in the technology
    they use64
    but also in terms of pricing (section 2.2.5), which provide contradictory incentives
    to the user. While differentiated distance-based charging encourages the most efficient
    transport choice for a given trip, time-based vignettes and vehicle taxes represent sunk costs
    to the user, and thus do not incentivise travelling shorter distances. As such, vignette systems
    are convenient for the heaviest road users, while at the same time may discriminate against
    the occasional user. Vignettes and circulation taxes are by nature very similar instruments,
    which is a potential concern when Member States replace taxes by vignettes, as this can lead
    to compensating national users and discrimination against foreign users. The result is an
    uneven playing field in freight transport.
    6.1. Uneven playing field in freight transport
    The initial aim of the Eurovignette Directive was to eliminate distortion of competition in the
    road haulage market through a harmonisation of levy systems and the establishment of fair
    mechanisms for charging infrastructure costs to hauliers.65
    However, as demonstrated by the
    evaluations referred to in section 1.3, in spite of the framework provided by the Directive, the
    patchwork of charging systems (see Annex 5) are causing an uneven playing field. In
    addition, contradictory price signals stemming from the use of different systems, in particular
    time-based schemes, cannot ensure truly proportionate pricing.
    Another source of inconsistency in road pricing is the diverging level of annual vehicle taxes
    across Europe. While Directive 1999/62/EC sets minimum levels for HGV taxes, there is no
    upper limit, which can result in differences of over 250% between neighbouring countries66
    .
    Where annual circulation taxes are meant to be a contribution to the maintenance of the
    national/local road network, Member States might be reluctant to implement road charging on
    the top of the taxes or will want to compensate their haulage sector. This can be problematic
    in the case of introducing a vignette scheme working as an extension of the tax to foreign
    operators; and raise concerns of discrimination especially in case of one-to-one compensation
    of nationals (see e.g. the case of the heavy vehicle fee introduced by the UK).
    As a result of these variations, road charging and vehicle taxes make up a very different share
    of operating costs of a HGV in different Member States, as shown in Figure 6-1: Taxes,
    charges and tolls per standard haul, [Euro per trip]. Differences in road charges to be paid can
    be over 20 or even 40 euro per trip between neighbouring Member States67
    . Previous
    evaluation showed that the share of road user charges compared to total HGV operating costs
    can vary between 1% and 15% between counties applying vignettes and those using distance-
    based tolls (Figure 6-2). The majority of stakeholders, in particular transport undertakings
    64
    I.e. satellite positioning (GNSS) or microwave communication (DSRC)
    65
    Recital 1 of Directive 1999/62/EC
    66
    Report in accordance with Article 11 (4) of Directive 1999/62/EC, Inventory of measures to internalise
    external costs, Summary of measures that internalise or reduce transport externalities, SWD(2013) 269 final:
    https://ec.europa.eu/transport/sites/transport/files/themes/sustainable/doc/swd%282013%29269.pdf
    67
    E.g. between Belgium and the Netherlands, which can lead to distortions and traffic diversion between
    Belgian and Dutch ports
    61
    (82%) felt that different taxes and charge systems cause market distortion, therefore
    supporting EU harmonisation.
    Figure 6-1: Taxes, charges and tolls per standard haul, [Euro per trip]68
    Source: COWI (2016), Assessment of Infrastructure Costs Calculation, Tolls Calculation and
    Variation for Heavy Goods Vehicles in Member States
    68
    assuming a standard haul of 400 km
    62
    Figure 6-2: Share of road user charges compared to total HGV operating costs69
    Source: Ricardo-AEA et al., Evaluation of the implementation and effects of EU infrastructure charging policy
    since 1995, 2013. Bayliss (red) Report of the High Level Group on the development of the EU road haulage
    market, 2012.
    69
    Note that Belgium and Hungary have introduced network-wide distance-based tolling for HGVs in 2016 and
    2013 respectively, which would bring these Member States closer to Germany and Austria, in the lower part
    of the figure. This also results greater differences in road charges to be paid between neighbouring Member
    States (Belgium/Netherlands and Hungary/Romania), which can lead to distortions and traffic diversion, e.g.
    between the ports of Belgian and Dutch ports.
    1%
    1%
    1%
    1%
    2%
    5%
    7%
    8%
    11%
    15%
    Belgium
    Hungary
    Netherlands
    Romania
    Sweden
    Spain
    Italy
    France
    Germany
    Austria
    Vignettes
    Concessions
    Tolls
    (networ
    k-wide)
    63
    7. ANNEX 7: VIGNETTE PRICES FOR LIGHT DUTY VEHICLES
    Figure 7-1: Vignette prices for light duty vehicles across Member States, 2017
    Member State Vignette prices [€] Ratio of average daily
    price between shortest
    term and longest term
    vignette
    Shortest term vignettes
    (number of days)
    Annual vignette
    (number of days)
    Passenger cars
    Austria 8.9 (10) 86.4 (365) 3.76
    Bulgaria 8 (7) 50 (365) 8.34
    Czech Republic 11.5 (10) 55.5 (365) 7.54
    Germany (planned) From 2.5 to 20 From 0 to 130 3.65 to 7.3*
    Hungary 9.5 (10) 138 (365) 2.53
    Romania 3 (7) 28 (365) 5.59
    Slovakia 10 (10) 50 (365) 7.30
    Slovenia 15 (7) 110 (365) 7.11
    Vans
    Austria 8.9 (10) 86.4 (365) 3.76
    Bulgaria 8 (7) 50 (365) 8.34
    Czech Republic 11.5 (10) 55.5 (365) 7.54
    Hungary 19 (10) 138 (365) 5.05
    Latvia 6 (1) 300 (365) 7.3**
    Latvia 14 (7) 300 (365) 2.43**
    Lithuania 6 (1) 304 (365) 7.20**
    Lithuania 14 (7) 304 (365) 2.40**
    Romania 6 (7) 96 (365) 3.26
    Slovakia 9 (10) 47 (365) 7.30
    Slovenia 30 (7) 220 (365) 7.11
    * Proposal not yet adopted. In the case of the cleanest vehicles, even though the weekly
    vignette would only cost €2.50, the ratio could be even higher
    ** Ratio of the daily/weekly vignette price (in line with the relative price set in the Directive)
    Source: own development based on analysis of data collected for the impact assessment
    support study
    For vans (vehicles up to 3.5 tonnes), the picture is slightly different, with 4 Member States
    applying the same rates as for cars, some applying higher vignette prices than for cars, while
    Hungary for instance apply double rates for vans compared to cars in the case of weekly and
    monthly vignettes only and uses the same rate for the yearly vignette. This makes the relative
    price of short term vignettes for vans much less proportionate than for cars. Only Latvia and
    Lithuania apply the ratios set in the Eurovignette Directive for heavy goods vehicles.
    64
    8. ANNEX 8: ROAD ASSET CONDITION AND MAINTENANCE FUNDING
    Figure 8-1 emphasises the point that ‘optimal’ road condition does not mean ‘as new’ but
    rather an acceptable condition that avoids costly replacement at a later date. Road surfaces
    that remain untreated can deteriorate at a faster rate, with the cost of repairs rising
    disproportionately – deferring preventative maintenance can therefore lead to substantial
    increases in repair/rehabilitation costs (European Parliament, 2014). If road condition
    deteriorates to the point that reconstruction is needed, the costs can be three to four times
    more than if timely maintenance had been adequately funded70
    .
    Figure 8-1 Asset Condition Model
    Source: NAO, UK (2014)
    8.1. Issues with road maintenance funding in Member States
    Examples of maintenance backlogs are reported in several Member States – all of which
    currently have reports of overall good road quality:
     Germany: the German Institute for Economic Research (DIW) reports a past investment
    shortfall of almost €4 billion for the maintenance of the transport infrastructure.
    Assuming that at least this investment is required in order to maintain the transport
    70
    https://www.piarc.org/ressources/publications/8/24531,2016R07EN-Gestion-Patrimoine-Routier-Road-Assets-
    Management-World-Road-Association-Mondiale-Route.pdf
    65
    infrastructure in coming years, and if the cumulative result of years of neglect is also
    taken into account, the additional annual investment requirement should be at least €6.5
    billion (Kunert & Link, 2013)
     UK: a figure of €9.6 billion for clearing the maintenance backlog in local road network
    alone (it tends to be the local road network that has been sacrificed to preserve the
    strategic network). An estimated of 13 years is needed to clear the maintenance backlog
    (HMT, UK Treasury, 2015).
     Ireland: the National Road Authority has highlighted that maintenance works are most
    effective when carried out on a continuous basis. The Department for Transport, Leisure
    and Sport quantify this as an annual cost of €1.6 billion up to 2020, the current forecasted
    expenditure will lead to a shortfall of over €260 million in road investment. (DTTAS,
    2014) (CE Delft, 2016).
     Netherlands the annual expenditure should be around €600 to €700 million. In the period
    1995-2005, the actual expenditures were generally below the steady state level
    expenditures, implying an underinvestment in road maintenance. Conversely, in the
    period 2005-2010, expenditures were significantly above steady state levels, which
    suggest a recovering of overdue maintenance of national roads (CE Delft, 2016).
    Another indication suggesting that the state of road infrastructure is a problem for Member
    States is that each year more of them realise that there is a gap in their budget for financing its
    maintenance (let alone development). As an example, following recommendations from the
    World Bank, Bulgaria plans to replace its time-based road charging scheme (bringing just
    over €100M/year altogether from heavy and light vehicles) with a distance-based system for
    HGVs, covering the entire network of roads.71
    But road maintenance is not only a challenge in Eastern Europe. Belgium replaced its time-
    based charging scheme (the Eurovignette72
    ) with a distance-based road charging system using
    satellite technology for HGVs above 3.5 tonnes on its main road network in April 2016.
    Germany is about to expand its distance-based tolling system applied to HGVs to all national
    roads (in 2018), and intends to introduce a vignette system for light vehicles, to increase the
    inflow of revenues that could be spend on infrastructure maintenance.
    At the same time, motorists associations (FIA) and road transport operators represented by the
    IRU are arguing that road users already contribute more to national budgets (through taxes
    and charges) than what is effectively spent on road infrastructure73, 74
    . The issue is that tax
    revenues are generally allocated to the general budget even if those from fuel tax correspond
    on average to infrastructure costs (1.3% of GDP).
    71
    According to the Ministry of Regional Development and Public Works, road maintenance in Bulgaria has
    been severely underfunded for decades. The Bulgarian Road Infrastructure Agency estimates that the annual
    allocation of about €100M is less than half of the needed budget. It has also been recognized that the vignette
    system is not flexible enough and is not fair to users – the lion's share of revenues have come from private
    vehicles that cause little to no damage to the roads, while revenues from HGVs, which are the main cause of
    damage to the pavement, forms a small share.
    72
    The Eurovignette is a road user charge for HGVs with a gross vehicle weight of minimum 12 tonnes that
    continues to be applied by Denmark, Luxemburg, the Netherlands and Sweden:
    https://www.eurovignettes.eu/portal/
    73
    http://www.fiaregion1.com/en/fia_region_1/news/european-motorists-deserve-a-betterdeal.htm
    74
    https://previouswww.iru.org/en_policy_co2_response_transporttax
    66
    9. ANNEX 9: SCOPE OF AND REVENUES FROM ROAD CHARGING IN MEMBER STATES
    Figure 9-1: Scope of infrastructure charging systems for HGV network – Share of main
    network that is being tolled
    Member State Total motorway
    length (km)
    Share of motorway that is charged for HGVs*
    Time OR distance-
    based
    of which Distance-
    based (i.e. tolls)
    Austria 2,185 100% 100%
    Belgium 1,763 100% 100%
    Bulgaria 734 100% 0%
    Croatia 1,290 100% 100%
    Cyprus 257 0% 0%
    Czech Republic 3,404 42% 42%
    Denmark 1,216 100% 0%
    Estonia 140 0% 0%
    Finland 810 0% 0%
    France 11,560 79% 79%
    Germany 12,949 100% 100%
    Greece 1,558 100% 100%
    Hungary 1,180 100% 100%
    Ireland 897 39% 39%
    Italy 6,751 89% 89%
    Latvia 1,674 90% 0%
    Lithuania 1,948 87% 0%
    Luxembourg 152 100% 0%
    Malta 163 0% 0%
    Netherlands 2,678 100% 1%
    Poland 1,552 100% 100%
    Portugal 3,065 96% 96%
    Romania 683 100% 0%
    Slovenia 1,499 40% 40%
    Slovakia 1,943 100% 100%
    Spain 14,981 23% 23%
    Sweden 2,088 100% 1%
    United Kingdom 3,760 100% 1%
    Total 82,880 76% 58%
    Notes: * some Member States may apply exemptions (e.g. for HGVs below 12t) or base their
    system on vehicle characteristics other than weight (e.g. number of axles or vehicle height).
    Source: Impact assessment support study
    67
    Figure 9-2: Revenues from road charging and their use
    Member
    State
    Part of the
    charged
    network(1)
    Annual Toll
    revenue /
    M€, 2014
    Use of revenue
    HDV LD
    V
    Austria 1 1235 449 Reinvested in construction, operation and safety of
    highly advanced road network.
    Austria 2 155
    Belgium 1 650 N/A The Flemish minister for mobility has stated that toll will
    be earmarked for investment in road infrastructure. The
    rest of the income will go to the general budget and can
    be spent on whatever the Flemish government so
    choose. The Wallonia region has not published any
    plans on how they are to spend the money raised from
    the toll but it is assumed to be reinvested into road
    infrastructure due to how the road management is
    structured there.
    Bulgaria 2 102 The vignette revenues are entered in the budget of the
    country and are allocated to the operation, current
    maintenance, repair and reconstruction works, but are
    not meant for new construction works.
    Croatia 1 317 Toll collection revenues are used to finance, build,
    maintain, operate and improve the motorways.
    Czech
    Republic
    1 360 All revenues from highway and motorway tolls are
    received by the State Infrastructure Fund, which also
    collects revenue from the road tax, consumer tax on
    hydrocarbon fuels, and the transfer of assets from the
    National Property Fund (privatisation). Revenues are
    used to finance:
    - Construction, modernisation, of roads, motorways,
    railways and inland waterways.
    - Repair and maintenance of roads, motorways and
    railways
    - Safety accessibility to persons with restricted
    movement and orientation
    - Construction and maintenance of cycling paths.
    Denmark 2 559 Finance the upgrade of Danish hinterland connections.
    Toll revenues received from bridges are used to finance
    the operation and maintenance, as well as repay loans
    incurred during the construction period.
    France 1 9390 Toll revenues are the main financers of the
    transportations infrastructures. Tolling revenues are
    collected on the oldest sections in order to finance the
    most recent ones.
    68
    Member
    State
    Part of the
    charged
    network(1)
    Annual Toll
    revenue /
    M€, 2014
    Use of revenue
    Germany 1 4370 The Bundesfernstraßenmautgesetz (BFStrMG) states
    that the Federal Government may use the income from
    the toll to cover the costs of operating and monitoring
    the toll system and for the administration costs of the
    Federal Traffic Infrastructure Finance Company (VIFG).
    In addition, up to EUR 450 million are used to
    implement Federal programmes aimed at securing jobs
    and qualifications and at promoting environment-
    friendliness and safety as regards haulage firms
    operating on toll routes.
    There are three programmes: to encourage the
    purchase of low-emission HGVs, to promote basic and
    further training, qualification and employment in haulage
    firms with HGVs, and to promote safety and the
    environment in haulage firms with HGVs.
    The remaining toll income will, apart from an annual
    amount of EUR 150 million, be added to the transport
    budget and used in its entirety for the sole purpose of
    improving the infrastructure of the Federal trunk roads.
    Greece 1 495 Until 2007 the toll system was run by TEO, which is
    owned by the Government. The revenue was used to
    finance, maintain and operate the network. Since then,
    a concession system has been introduced for the
    majority of tolled roads. Toll charges are used to finance
    part of the construction, as well as maintenance and
    improvement of the highways. Their profits are subject
    to VAT, which goes to the general budget.
    Hungary 1 678 The utilisation of the increased revenue due to the
    introduction of the HU-GO system is determined by the
    requirement system of the EU: it can only be used in the
    public road and traffic sector. Hu-Go states that the toll
    revenue will ensure financial means for developing,
    maintaining and operating the road network.
    Ireland 2 217 Major new road developments in Ireland are funded
    through Public Private Partnerships. Therefore, the toll
    revenues go both to the private companies who
    invested in the road as well as the public sector. There
    is no mention on how the toll revenues that go to the
    public sector are distributed.
    Italy 1 5454 There are no specific funds directed toward financing
    national highway infrastructure in Italy, which is funded
    by the general revenue. Highway revenue is generated
    by taxes and tolls, but this revenue is not tied to
    highway construction. A percentage of revenue
    generated by tolls goes to the National Autonomous
    Roads Corporation (Azienda Nazionale Autonoma delle
    Strade, ANAS) for monitoring highways under
    69
    Member
    State
    Part of the
    charged
    network(1)
    Annual Toll
    revenue /
    M€, 2014
    Use of revenue
    concession.
    Latvia 1 N/A N/A Maintenance and development of roads.
    Lithuania 1 43 N/A Financing of the road construction and maintenance, as
    well as Development Programme of the Republic of
    Lithuania.
    Luxem-
    bourg
    1 3 N/A Luxembourg applies the principle of
    the unity of the budget. Revenue feeds into general
    taxation budget. Therefore, no revenue may be provided
    with an "earmarking".
    Netherlands 2 28 The Netherlands funds state highways through a
    national Infrastructure Fund, which is fed by express
    lane fees and regular tolls. Provinces, municipalities,
    and district water boards may also set tolls on motor
    vehicles passing through certain tollgates on state-
    managed roads. Additionally, the government applies
    one-time and recurrent taxes on registered motor
    vehicles, and levies fuel taxes and a general VAT of
    21%. Whether or not these taxes are applied to road
    construction and maintenance is unclear.
    Poland 2 209 on A2
    and A4
    Poland stopped using the vignette system on 1st July
    2011, and replaced it with a toll. The revenue is directly
    transferred to the National Road Fund and reinvested to
    the road network.
    Poland 2 284 N/A
    Portugal 1 915 (for 19
    toll domains)
    The revenue from tolls is directly assigned to a legally
    independent entity in charge of financing, building,
    maintaining, and operating the infrastructure. Profits are
    also subjected to company taxes and VAT and therefore
    contribute to the national budget.
    Romania 1 N/A N/A Toll revenues are allocated directly to NCMNR. In
    addition, NCMNR (Road Administration) collects
    charges for overloaded vehicles. The total direct
    income, however, is too low in relation to the full cost of
    road maintenance for the national road network. Thus,
    NCMNR is reliant on the State budget, IFIs and/or
    commercial loans in order to fund the shortfall.
    Slovenia 2 350 Motorways are operated by DARS, a company that is
    100% owned by the State. The revenues are used to
    finance motorway management and maintenance,
    construction of new motorways and repayment of loans.
    Slovakia 1 185 119
    .6
    Construction and maintenance of roads.
    Spain 2 1709 Concessionaires are responsible for financing, building,
    maintaining, and operating the infrastructure for Spanish
    toll motorways. Their profits are subject to VAT, which
    goes to the general budget.
    70
    Member
    State
    Part of the
    charged
    network(1)
    Annual Toll
    revenue /
    M€, 2014
    Use of revenue
    Sweden 1 N/A N/A Concerning bridges between Sweden/Denmark and
    Sweden/ Norway, the fees are meant to cover the cost
    of building and maintaining the infrastructure. At
    Öresundsbron, Sweden and Denmark divide the toll
    revenues 50/50. At Svinesundsförbindelsen, Sweden
    collects tolls from vehicles entering Norway.
    United
    Kingdom
    1 49.28 N/A The revenue raised from the HGV levy goes into
    general government funds.
    United
    Kingdom
    2 102 Any revenue generated from tolls goes to the highway
    authority and must be used for the road network or
    related transportation measures.
    1
    1= network-wide (or large parts), 2=specific parts of the network (e.g. specific bridges, tunnels etc.)
    71
    10. ANNEX 10: LEVELS AND DIFFERENTIATION OF ROAD CHARGES
    Figure 10-1: Average user charge per km on toll roads across EU Member States
    (freight transport)
    Member
    State
    Charging system and average charge per
    vehicle category in Cent/Km
    HGV > 12t Charge
    /tolled
    km
    HGV < 12t Charge
    / tolled
    km
    Vans < 3.5t Charge/
    tolled
    km
    Austria Distance-
    based
    46.7 Distance-based 32 Time-based -
    Slovenia Distance-
    based
    27 Distance-based 21.4 Time-based 2.3
    France Distance-
    based
    26.5 Distance-based 21.5 Distance-based 13
    Spain Distance-
    based
    22.4 Distance-based 20.8 Distance-based 11.7
    Ireland Distance-
    based
    20 Distance-based 18 Distance-based 12.2
    Croatia Distance-
    based
    20 Distance-based 16 Distance-based 11
    Hungary Distance-
    based
    19 Distance-based 11.7 Time-based 2.5
    Portugal Distance-
    based
    18.5 Distance-based 15 Distance-based 13
    Belgium Distance-
    based
    18.4 Distance-based 12.5 N/A 0
    Czech
    Republic
    Distance-
    based
    18.2 Distance-based 11.5 Time-based 1.3
    Slovakia Distance-
    based
    17.7 Distance-based 7.7 Time-based 1.3
    Germany Distance
    Based
    16.2 Distance-based
    (only above 7.5t)
    3.5 N/A 0
    Italy Distance-
    based
    13.2 Distance-based 10 Distance-based 7
    Greece Distance-
    based
    11.1 Distance-based 9.2 Distance-based 3.4
    Poland Distance-
    based
    10.6 Distance-based 7.8 Distance-based 10
    Romania Time-based 3.3 Time-based 1.1 Time-based 3.1
    Sweden Time-based * 3 N/A 0 N/A 0
    Denmark Time-based * 2.8 N/A 0 N/A 0
    Latvia Time-based 2.4 Time-based 1.5 Time-based75
    -
    Luxem-
    bourg
    Time-based * 2.3 N/A 0 N/A 0
    Lithuania Time-based 2.2 Time-based 1.6 Time-based -
    Bulgaria Time-based 2 Time-based 1.2 Time-based 2.1
    Netherlands Time-based * 1.9 N/A 0 N/A 0
    75
    Since 1 January 2017 for vehicles with a total permissible weight of more than 3 tonnes
    72
    United
    Kingdom
    Time-based 76
    1.3 N/A 0 N/A 0
    Cyprus No charging 0 No charging 0 No charging 0
    Estonia No charging 0 No charging 0 No charging 0
    Finland No charging 0 No charging 0 No charging 0
    Malta No charging 0 No charging 0 No charging 0
    Figure 10-2: Comparison of EURO emission groups across EU Member States (where
    applied)77
    .
    COUNTRY
    EURO
    0
    EURO
    I
    EURO
    II
    EURO
    III
    EURO
    IV
    EURO
    V
    EEV EURO
    VI
    Time-based
    Denmark, Luxemburg,
    Netherlands, Sweden
    Group1 Group2 Group3
    Bulgaria Group1 Group2
    Lithuania Group1 Group2
    Distance-based
    Austria Group1 Group2 Group3 Group4
    Germany Group1 Group 2 Group3 Group4
    Poland Group1 Group 2 Group3 Group4
    Czech Republic Group1 Group 2 Group3
    Slovakia Group1 Group 2 Group3
    Slovenia Group1 Group 2 Group3
    France/Italy
    Frejus tunnel
    Not
    allowed
    Group1 Group2
    France/Italy
    Mont Blanc tunnel
    Not allowed Group1
    Source: Ricardo-AEA et al., Evaluation of the implementation and effects of EU infrastructure charging policy
    since 1995, 2013
    76
    HGV Levy is applied to 11 vehicle categories depending on the weight (always > 12 t) and the number of
    axles. For most UK-registered HGVs, vehicle excise duty (VED) was reduced by the same amount as the
    levy, and is conveniently paid alongside VED to keep administrative costs to a minimum. As with VED the
    levy can be paid either annually or six-monthly. The tax disc will display the total duty paid (combined
    vehicle tax and levy). Vehicles registered abroad must make levy payments before entering the UK. The
    levy can be paid by day, week, month or year and discounts are available for longer levy periods.
    77
    Existing concession contracts are exempted from this requirement until the contract is renewed (article 7g (1)
    of Directive 1999/62/EC, as amended).
    73
    Figure 10-3: Differentiation by EURO class for vehicles >12t.
    Member
    state
    Date of toll
    introduction
    Date of first
    differentiation
    by Euro class
    Dates valid Vehicles
    Saving compared to Euro I
    Euro
    II
    Euro
    III
    Euro
    IV
    Euro
    V
    Euro
    VI
    Germany 2005 2005 >12t 15% 15% 30% 30% n/a
    2006-2008 >12t 0 17% 17% 30% n/a
    Czech
    Republic
    2007 2007-2010 >12t 0 17% 17% 30% n/a
    2012 >3.5t 0 21% 21% 50% 50%
    Austria 2004 2010 2010 >3.5t 0 0 13% 13% 18%
    Poland 2011 2011 0 13% 30% 50% 50%
    Slovakia 2010 2010 0
    2012
    (highways)
    >12t 0 5% 30% 30% 30%
    2012 (1st
    class roads)
    >12t 0 7% 7% 7% 7%
    2012
    (highways)
    3.5-12t 0 8% 11% 11% 11%
    2012 (1st
    class roads)
    3.5-12t 0 10% 10% 10% 10%
    Source: Ricardo-AEA et al., Evaluation of the implementation and effects of EU infrastructure charging policy
    since 1995, 2013
    74
    Figure 10-4: Maximum charge differentiation according to Euro class for vehicles in the
    same category
    Source: Ricardo-AEA et al., Evaluation of the implementation and effects of EU infrastructure charging policy
    since 1995, 2013
    Figure 10-5: Maximum differentiation according to time of travel for vehicles >3.5t in
    the same category78
    Source: Ricardo-AEA et al., Evaluation of the implementation and effects of EU infrastructure charging policy
    since 1995, 2013
    78
    It should also be noted that in most countries the differentiation is only applicable on selected routes, whereas
    Czech Republic and Slovenia apply them on the network. In addition, Austria and Slovenia apply higher
    charges at night to control noise emissions, whereas the other Member States apply higher charges during
    peak hours to control congestion.
    75
    11. ANNEX 11: PRE-SELECTION OF POLICY MEASURE AND PACKAGING OF OPTIONS
    The packaging of measures is done in a way to ensure that all options address the identified
    problem, at least to some extent. The minimal solution to each problem is PO1. Some of the
    measures can address more than one problem.
    11.1. Rationale behind retained measures
    To contribute to the goals of low-emission mobility:
    - Promoting zero-emission vehicles through allowing reduced toll rates (for both HDVs
    and LDVs): this is a measure, which is very easy to implement while providing a direct
    price signal to users; it does not require emission values to be measured and is
    technology neutral. Since the total cost of ownership of a zero-emission HDV is still 2
    to 3 times that of a conventional diesel, even complete exemption from charges could be
    justified for these vehicles. The situation is different for LDVs, where the total cost of
    ownership is already very close (see section 4.2.10 of the impact assessment support
    study) and even a more limited reduction of road charges could provide incentives for
    the uptake of clean vehicles.
    - Mandatory differentiation of infrastructure charges according to CO2 emissions for
    HDVs (HGVs + buses/coaches) from 2020: Once vehicle certification data on CO2
    emissions becomes available for new vehicles79
    , it will be possible to differentiate
    charges between the more and less fuel-efficient trucks. Distinction could be made
    between i) Euro 0-VI vehicles, ii) low-CO2 (new or retrofitted) vehicles. Since the
    certification data will only be available in the future, the precise method for
    differentiating charges would be defined by the Commission in a delegated act. In order
    to provide a coherent price signal and have noticeable impact, Member States would be
    required to differentiate tolls accordingly. Differentiation between Euro 0-VI and new
    low-emission vehicles should be simple (in any case much simpler than the current
    differentiation according to Euro classes applied by Member States) remain revenue-
    neutral, in recognition of the fact that the cost of CO2 emissions are in practice
    internalised through fuel taxation (even if excise duties are not necessarily collected
    with this goal in mind). A possible way in which such modulation could take place is
    described in Annex 4 (Figure 4-9).
    - Mandatory differentiation of tolls and user charges (i.e. both distance- and time-based)
    for LDVs (Vans and passenger cars) from 2020: Distinction would be made into 3 or 4
    emission classes based on WLTP80
    according to CO2 and pollutant emissions,
    complemented by RDE tests for NOX. In order to provide a coherent price signal and
    have noticeable impact, Member States would be required to differentiate tolls
    accordingly.
    Compared to LDVs with a gasoline engine, diesel LDVs generally have lower
    emissions of CO2 but higher emissions of air pollutants. Therefore, incentivising only
    79
    VECTO – Vehicle Energy consumption Calculation Tool developed by DG CLIMA and the JRC – will be
    ready to provide this information for HGVs above 7.5 t as from 2019.
    80
    World harmonised Light vehicle Test Procedure
    76
    the most fuel-efficient LDVs without taking account of pollutant emissions would
    promote diesel driven vehicles entailing higher emissions of air pollutants and also
    exacerbate the problem of diesel/gasoline imbalance.
    Differentiation of road charges for LDVs could be based on the forthcoming UNECE
    World harmonized Light vehicle Test Procedures (WLTP) complemented by on-road
    tests, which are better reflecting real driving emissions (RDE81
    ) and allowing better
    comparison between petrol and diesel cars. A possible way of such modulation of
    charges is described in Annex 4, section 4.3.5.
    To contribute to adequate road quality
    - Monitoring and reporting of toll revenues and expenditures on maintenance/operation
    of roads will ensure transparency and raise the awareness of Member States' authorities
    of potential financing gaps. As an extension of current reporting requirements on tolls
    (every four years, including information on the levels and variation of charges, revenues
    from charges and any action related to their use recommended by the Directive),
    Member States would be required to publish annual reports in a more systematic way,
    including information on
     total revenues from road charging (also for time-based systems) as well as
    congestion charging;
     the use of revenues;
     the state of roads based on objective indicators (to be harmonised in a subsequent
    step, cf. measure below): and
     the level of congestion on the tolled network.
    The measure received the support of over 2/3 of the respondents to the public
    consultation. Because of the administrative implications, Member States are generally
    less supportive. It has nevertheless maintained as an alternative to the provision of
    earmarking of toll revenues in general, which is even less supported by Member States,
    and to improve the current – insufficient reporting practices. It is also worth noting that
    Regulation No 1108/70 already requires Member States to report on infrastructure
    spending but this is not coherently practiced by them (see also section 12.2.3 in Annex
    12).
    - Introduction of common quality indicators will ensure that the manager of a toll road
    will maintain the given road section in sufficiently good/safe condition. Such indicators
    are already used by most Member States. However, the information is not strictly
    81
    For their approval, new models of vehicles are currently subject to laboratory tests of their emissions.
    However, analysis has shown that light vehicles produced in line with existing Euro standards generate
    substantially higher emissions on the road than in laboratory conditions. This problem was detected in
    particular in relation to emissions of diesel vehicles of the pollutant substance nitrogen-oxides (NOx). That is
    why new procedures to measure emissions in real driving conditions are needed. Until at least 2021, so called
    conformity factors will be applied to allow manufacturers adapt to RDE tests. See e.g.
    http://www.consilium.europa.eu/en/press/press-releases/2016/02/12-vehicle-emissions-in-real-driving-
    conditions-2nd-package/
    77
    comparable since different methodologies are used. A harmonised definition based on
    current national practices in monitoring road characteristics could be adopted by the
    Commission through an implementing act.
    To ensure that road pricing treats occasional / non-resident motorists fairly:
    - Removing the possibility to exempt HGVs above 12 tonnes after a period of 5 years will
    ensure that all HGVs are subject to proportionate treatment thereby contributing to
    levelling the playing field in road freight transport. Currently these vehicles are
    exempted from road charging in the Member States applying the so called 'Eurovignette'
    (Denmark, Luxembourg, the Netherlands and Sweden) and in the UK, while Estonia
    also intended to introduce its upcoming charging scheme only to vehicles above 12
    tonnes. Germany applies tolls to vehicles above 7.5 tonnes. The stakeholder
    consultation indicated general support to this measure and finally Estonia has also
    decided to charge vehicles between 3.5 and 12 tonnes. Germany has also such plans.
    - Inclusion of buses and coaches designed to carry at least 16 passengers (with a
    maximum weight above 3.5 tonnes) in the scope of the Directive and applying the same
    principles as to HGVs: these vehicles cause similar damage to the infrastructure and the
    environment as HGVs (a number of Member States already apply similar if not the
    same charges for all HDVs). These buses are typically used for long distance services,
    and regular interurban services could be further liberalised by revising Regulation (EU)
    1073/2009. Since long-distance coach services compete with rail transport, it appears
    justified that they also pay for the use of the infrastructure and for environmental
    damage in a coherent way across the EU. The measure was also explicitly supported by
    some stakeholders saying that coaches should be the next vehicle category to be covered
    by common rules (to be followed by light goods vehicles and passenger cars). As in the
    case of extension of rules to HGVs below 12 tonnes, this measure would affect the four
    'Eurovignette' countries, the UK, Germany, and Estonia, after having introduced
    charging for HGVs (cf. Figure 5-3 in Annex 5).
    - Introducing non-discrimination and proportionality requirements for light vehicles: the
    goal is to ensure non-discriminatory pricing for short-term vignettes – mainly purchased
    by occasional users thus most often by foreign nationals – by clarifying the rules on
    proportionality in the case of light vehicles, taking account of different use pattern of
    private vehicles82
    , and the rules concerning the possible compensation of nationals.
    Since short-term vignettes are mainly purchased by holidaymakers and the price of a
    daily vignette would have to be very low even to the point of generating a higher
    administrative cost than revenue brought, it would seem justified to require the
    provision of at least two different type of short-term vignettes: monthly (valid for 1 or 2
    months) vignettes, 10-day vignettes instead of weekly vignettes (one week vignettes
    often oblige holidaymakers to buy two vignettes to cover the inbound and outbound
    trip). Most Member States already offer 10-day vignettes, while 4-day vignettes (if
    82
    Private vehicles, if used regularly, are used on shorter distances than HGVs; at the same time, when they use
    the motorway network less frequently, the average length of the trip increases. This, and the fact
    administrative costs are proportionately higher in the case of light vehicles justifies somewhat higher relative
    price for the short-term vignettes in the case of these vehicles, compared to HGVs (for which the Directive
    currently limits the prices of short-term vignettes: the monthly rate at 10%, the weekly rate at 5%, and the
    daily rate at 2% of the annual rate – these correspond to price ratios of 1.2, 2.6 and 7.3 respectively).
    78
    available) could offer a proportionate and thus fair price for very limited use of toll
    roads.
    Based on a dedicated study83
    using survey data from the UK, the only Member State
    having relevant data, the following vignette types and price ratios would be considered
    proportionate:
     Two-month vignette: max. 25-30% of that of the annual vignette (ratio of up to
    1.8);
     Monthly vignette: max. 15-18% of that of the annual vignette (ratio of up to 2.2);
     10-day vignette: max. 7-8% of that of the annual vignette (ratio of up to 2.9);
     4-day vignette is max 4-6% of that of the annual vignette (ratio of up to 5.5).
    The percentages are derived from the assumed quantity of trips that the holder of
    vignette type makes and the average km per trip, according to the assumptions of the
    Booz&Co. study, that is:
     The longer the vignette duration, the less frequently the motorist uses it (by time);
    and
     The more frequent the usage, the shorter the trip (by distance).
    Figure 11-1: Average trip and distance assumptions
    Source: Booz&Co. (2012).
    To reflect their more intensive use of the roads, vans and minibuses could be charged at
    a higher rate than private cars.
    83
    Booz&Co. (2012). Study on Impacts of Application of the Vignette Systems to Private Vehicles.
    http://ec.europa.eu/transport/sites/transport/files/modes/road/studies/doc/2012-02-03-impacts-application-
    vignette-private-vehicles.pdf
    79
    The measure would primarily affect those Member States, which operate time-based
    vignette systems to charge passenger cars (cf. Figure 5-4 in Annex 5), and received
    overwhelming support from consumers/citizens, while some Member States are
    reluctant about it.
    - Phasing out vignettes for HDVs (HGVs + buses/coaches) after 5 years (by 2023) – only
    distance based charging would be allowed for these vehicles. Member States would
    remain free to decide whether or not to introduce road charging on their territory and on
    which roads. However, once they decide to do so, the method of distance-based tolling
    would be obligatory on the roads which are charged. A 5-year implementation period
    would give Member States ample time to implement distance-based tolls. The common
    argument of Member States saying that systems costs of distance-based tolls are
    prohibitive would be addressed by the parallel revision of the EETS legislation, which
    would lead to lower system costs84
    . The measure would affect the nine Member States
    currently operating vignette systems for HGVs and 12 applying vignettes or no charging
    to buses/coaches (cf. Figure 5-1 and Figure 5-3 in Annex 5). While some Member
    States that currently apply vignette schemes are not in favour, the majority of
    stakeholders agree that this is a necessary next step in the harmonisation of charges.
    - Removing minimum levels of vehicle circulation taxes for HGVs above 12 tonnes
    (Chapter II of the Directive) would allow Member States reduction or complete
    abolishing of the tax in case of the application of distance-based charging on TEN-T
    network. Those Member States which are introducing new systems are interested in
    being able to compensate the haulage sector through the reduction of vehicle taxes, as
    the parallel application of an annual vehicle tax and road charging can be perceived as
    double taxation. Many stakeholders also stressed that any increase in costs as a result of
    increased charges should be compensated for by reductions in other transport-related
    taxes.
    - Phasing out vignettes for vans – only distance based charging would be allowed for
    these vehicles: since light goods vehicles (vans) are more and more engaged in
    international transport85
    and compete with HGVs, it can be argued that these vehicles
    should also be required to pay tolls according to the actual use of the roads (instead of
    the relatively cheap time-based charges). This would further the creation of a level-
    playing field in freight transport. The measure would affect nine Member States
    currently applying vignettes for these vehicles (cf. Figure 5-2 in Annex 5). While road
    transport operators and environmental organisations are in favour of the measure,
    Member States are less inclined to agree with it. It would nevertheless be a logical
    future step in the application of the polluter pays and user pays principles.
    84
    It is possible already now for Member States to implement distance-based solutions that are not prohibitively
    costly. For example the Hungarian system introduced in 2013 allows the use of third party devices, including
    existing fleet management equipment, as on-board units (OBUs) necessary for keeping track of the
    kilometres covered by the vehicle
    85
    See e.g. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/514912/road-use-statistics.pdf
    or the results of the consultations carried out in the framework of the impact assessment on the revision of Regulation
    (EC) No 1071/2009 and Regulation (EC) No 1072/2009, where stakeholders representing the EU road haulage industry
    (IRU) and national level (France, Germany, and Denmark) referred to an increasing presence of foreign registered LCVs
    in hire-and-reward traffic
    80
    - Phasing out time-based vignettes for cars: distance-based pricing is the most
    proportionate way to charge user for the costs of road use. It can be modulated
    according to the environmental performance of vehicles as well as location and the time
    of travel, and minimises the possibility of discrimination on the basis of travel
    frequency (discounts may still be offered by toll chargers on a commercial basis). The
    measure would affect the seven Member States currently applying vignettes for
    passenger cars, plus Germany, which plans to introduce such a system (cf. Figure 5-4 in
    Annex 5). As for vans, there is a distinct difference in stakeholder views concerning this
    measure. However, a number of Member States would be against it as the measure
    affects private cars, which makes it much more sensitive. It should be part of a medium-
    term strategy (as already put forward in the 2011 White Paper), but in the short run, it
    should be treated with care.
    To contribute to reduction of air pollution and congestion:
    - Simplification of the requirements for external cost charging: merging the charging of
    noise costs (which are very low on their own) with the cost of air pollution and the
    waiver of the notification requirement, in case the values set in the Directive are
    applied, will make it significantly easier for Member States to apply external cost
    charging. The revised Directive could offer a set of reference values for external cost
    charges to be applied to different HGV and bus/coach categories depending on their
    weight or number of axles. These values would better reflect the actual amount of
    external costs generated by heavy duty vehicles and Member States would not need to
    make any calculation unless they intend to apply higher charges than the new reference
    values.
    - Extending the possibility to use mark-ups beyond mountain regions (up to 15% on top
    of average infrastructure charge, and up to 25% in case of cross-border sections) to
    contribute to the financing of removing bottlenecks on the TEN-T network, while
    keeping the condition of acute congestion or significant environment damage generated
    by vehicles. The measure would apply to HGVs and buses/coaches.
    Member States would not be allowed to apply a mark-up on roads on which a
    congestion charge is already applied. Mark-ups could be used for example where no
    genuine congestion charging is possible (e.g. because cars are not subject to distance-
    based charging).
    - Phasing out differentiation of infrastructure charges for HGVs according to Euro
    emission classes (simplification) – with external cost charging remaining optional. The
    removal of a redundant measure could incentivise Member States to make use of the
    other, now simplified, possibility of using external cost charging to protect their local
    environment from pollution caused by older vehicles. In any case, differentiation
    according to Euro emission class is losing its relevance and effectiveness over time as
    the vehicle fleet is replaced and without a Euro VII standard in sight. The share of Euro
    VI vehicles on German toll roads increase by about 16% each year and stands already at
    47% overall and 51% among vehicles registered in Germany, representing a
    replacement rate of just over 6 years. Thus, the share of Euro 0-IV is barely 6% and
    decreasing every year. The tendency is similar in other countries operating network-
    wide distance-based tolls; e.g. in Hungary the share of toll paid by Euro VI trucks
    81
    increased from 12 to 21% between 2015 and 2016, with the share of Euro V standing at
    50%. The pace of the change is at least partly due to the fact that Hungary does not
    differentiate between Euro III, IV, V and VI, which also explains that the share of tolls
    paid by Euro II-III trucks was still 20% in 2016 (but dropped from 28% in 2015). These
    trends, together with the fact that Member States with long-term concession contracts
    have been exempted from this differentiation indicate that in just a couple of years the
    measure will have no impact, apart from hindering genuine external cost charging.
    - Allowing genuine congestion charging on top of the infrastructure charge on congested
    parts of the network, for all vehicles (LDVs + HDVs): such a congestion charge, should
    Member States decide to implement it, would apply to all vehicles (LDVs and HDVs),
    which is the fairest way to charge as they are all contributing to congestion. Congestion
    charging is only possible in a distance-based scheme. Therefore, where private cars are
    not subject to tolls (when they either use the roads freely or are subject to a vignette
    scheme), genuine congestion charging cannot be applied.
    It would be up to the Member State to choose whether to make use of this possibility or
    not. The Directive could require the revenues generated by congestion charging to be
    invested in the maintenance/development of the road in question or alternative
    solutions. This could raise the level of acceptability of an extra charge.
    While Member States generally want to keep the decision on the use of toll revenues for
    themselves; however, they did agree to the requirement of allocating revenues from
    specific additional charges to transport in the case of mark-ups (plus external cost
    charges if applied in combination). Since congestion charging would also only cover
    limited stretches of the network only at specific hours of the day or days of the year, the
    collected amounts would be limited compared to overall toll revenues. The measure
    might have therefore better chances of success than the obligation of generalised
    earmarking.
    In the case of congestion charging many fear that this would become an additional
    burden on those who are already stuck in congestion. Allocating the revenues to projects
    addressing the problem can improve acceptability as it could render the charge
    progressive. As described in the impact assessment support study, whether congestion
    pricing has progressive or regressive effects depend on the design of the system and on
    initial travel patterns – and most crucially, on the use of revenues86
    .
    Member States are likely to face opposition to introduction of congestion charges if the
    scheme is perceived to be inequitable. The revenues can be used to counteract any
    regressive impact, which is a key factor in the acceptability of the systems – hence it is
    likely that any new congestion charge introduced under the policy options will be
    (perceived as) equitable, otherwise they will be rejected by the public.87
    86
    Ricardo et al. (2017), Support Study for the Impact Assessment Accompanying the Revision of Directive
    1999/62/EC.
    87
    Ibid.
    82
    - Making external cost charging mandatory on the tolled TEN-T network for all heavy-
    duty vehicles: with the phasing out of differentiation according to Euro class, it can be
    argued that the pollutant emissions of vehicles would have to be factored in the road
    charge if Member States are still to incentivise (not only more efficient) but also cleaner
    HDVs. In practice, where HDVs are charged, the toll would have to include an external
    cost charge. Member States would still have the possibility to charge only a percentage
    of the reference values to be provided in the Directive.
    11.2. Discarded policy options (measures)
    Some of the specific measures of a full internalisation scenario were considered during the
    public consultation but have not been retained:
     Making distance-based charging mandatory on the TEN-T network for HGVs / all
    goods vehicles – not retained due to extensive implementation costs (at least in the short
    term) and proportionality considerations. Road charging is a very sensitive issue for
    Member States, especially when it comes to passenger cars. While this would probably be
    the most effective solution to the identified problems, it is not achievable at this stage. In
    addition, in sparsely populated areas it may not be the most efficient solution (due to the
    relative importance of costs compared to traffic volumes).
    The consultation results clearly indicate negative sentiments about such a restrictive
    measure among those Member States which have no distance-based charging in place.
    Even other stakeholders, which are in favour of such a measure to be applied on the TEN-
    T network as the ultimate long-term goal, indicated that this needed to be phased in
    gradually.
    For heavy goods vehicles, all Member States (except Estonia, Finland, Cyprus and Malta)
    already have charges in place (either tolls or vignettes). The impact of mandatory charging
    would therefore be limited, while creating strong political opposition. Considering that
    most countries have charging in place, it would be more effective to require Member
    States to abandon time-based charging and apply tolls.
     Inclusion of the external costs of accidents not already covered by insurance schemes
    (supported by the European Parliament) – not retained because accident costs are best
    internalised through pay-as-you-drive insurances and taxes thereon; road charging would
    not be the fairest and could only be the second best instrument. The consultation did not
    show practically any support for including accident; on the contrary, a number of
    respondents mentioned insurance schemes as a better instrument.
     Mandatory application of genuine congestion charging on congested parts of the
    network in peak hours for HGVs / all vehicles – not retained due to extensive costs as it
    would require setting up tolling systems to cover the relevant parts of the network to
    facilitate such charging, and imposing it on Member States would raise subsidiarity
    considerations. The consultation did not show support for this measure, even among those
    who generally supported congestion charging, instead saying that the decision should be
    left with Member States.
    83
    The option of full internalisation would also mean that Member States would have to apply
    generalised distance-based charging for passenger cars. Even though with the evolution of
    intelligent transport solutions (in-car and roadside) pay as you drive schemes will no doubt
    gain relevance, making it mandatory at this stage would face strong opposition. The use of
    such systems has to be made easier and more attractive to the user first on a voluntary basis to
    raise public acceptance.
    Other considered and discarded measures:
     Awarding discounts for the use of specific fuel-saving equipment, such as low-
    resistance tyres of aerodynamic devices in order to incentivise more efficient operations
    (also applicable to the existing vehicle fleet) – not retained due to difficulties in
    monitoring and enforcement – the presence of the given equipment would have to be
    tracked via the on-board unit of the vehicle either automatically or with manual
    intervention from the driver.
     Promotion of specific low carbon fuel technologies – not retained because it would
    require complex calculations of specific emissions attributed to the different technologies
    to ensure a technology neutral approach. Over time, this will be possible with the use of
    the VECTO tool (PO2), while the promotion of zero emission vehicles does not require
    such a methodology and is foreseen already in PO1.
     Introduction of rules on the liability of the keeper of a toll road to maintain the given
    road section in sufficiently good/safe condition. Even though the measure received
    almost as much support from respondents to the on-line public consultation as the
    monitoring and reporting requirements, it would effectively introduce a legal obligation to
    ensure that the objective of achieving fair road quality is met. The option has been
    discarded as it was considered not to respect subsidiarity requirements. Stakeholders that
    were interviewed did not support attempting to improve road maintenance by way of rules
    relating to the potential liabilities. They suggested that liability issues are best dealt with at
    Member State level and that setting out some general indicators focused on minimum
    standards at EU level was more appropriate.
     Making it possible to apply genuine congestion charging (i.e. on top of infrastructure
    charges) on congested parts of the network in peak hours for HGVs only – not
    retained because this solution would unfairly treat freight transport and would not be the
    most effective since about 80% of road congestion can be attributed to light vehicles.
     Mandatory earmarking (ring-fencing) of revenues from road charging – as indicated
    in Figure 9-2 in Annex 9, Member States already allocate at least part of the revenues
    from road charging to transport (in some cases specifically to road maintenance).
    However, they want to keep the decision on the use of revenues from road charging in
    general at their own discretion. The measure has already been proposed but was rejected
    by Member States and based on the consultation results, even though road users would
    welcome such a provision, the majority of Member States would still reject it. It is
    therefore not currently achievable.
     Requiring Member States to prepare national plans on the maintenance and
    upgrade of their road networks (as an alternative to mandatory earmarking, which has
    already been proposed twice by the Commission but which failed for reason of
    subsidiarity) – not retained due to proportionality considerations; discarded in favour of a
    84
    similar reporting measure that would be less burdensome on Member States (i.e. the
    option to monitor and report toll revenues and expenditures).
    85
    12. ANNEX 12: ASSESSMENT OF MEASURES AIMED IMPROVING ROAD QUALITY
    The two retained measures following the first screening of options are A) Monitoring and
    reporting by Member States through regular infrastructure reports, and B) Introduction of
    quality indicators for tolled roads. The measures were analysed individually and in
    combination, and can be applied together with any of the policy options identified in section
    5. The main impacts are described below while a full assessment can be found in the impact
    assessment support study.
    12.1. Impacts on road quality
    The main intended impact of both measures A and B is to improve road quality. This is the
    key impact as all other impacts will depend on the extent to which road quality may change as
    a result of applying any of the two measures.
    Measure A – monitoring and reporting on revenues and expenditures – works through (1)
    greater transparency allowing increased public awareness of the costs of road maintenance
    and acceptance of road tolls, the uptake of such schemes and thus potentially increased
    revenues. Reporting will improve understanding and help Member States (2) identify
    financing gaps before the problem exacerbates and ensure that the necessary resources are in
    effect allocated to maintenance.
    (1) Previous experience following the introduction of road pricing in various countries show
    that transparency about the use of revenues increases the public acceptability of charging
    systems, especially when revenues are ring-fenced and reinvested in the transport system.
    At the same time, allocating revenues to the general budget is least well received by
    users88
    . This is also confirmed by the result of the public consultation where 82% of
    stakeholders agreed that the revenues generated from taxes and charges should be
    reinvested into the maintenance, repair and upgrade of the road network, ensuring
    transparency of the process to the public.
    (2) Identifying any maintenance gap sooner will help improve road quality in Member States
    where the lack of information is the underlying issue. This appears to be the case in a
    number of Member States (BE, CY, DK, DE, GR, HU, MT, PT and RO) (European
    Parliament (2014)).
    Overall, measure A is likely to have a positive effect on road quality by creating enabling
    conditions that improve public acceptance and contribute to better understanding of potential
    expenditure issues. At the same time, it is also likely that the measure on its own will not be
    adequate to ensure good road quality in all Member States and so it should be implemented as
    part of a wider package of measures.
    Measure B – the introduction of a set of common quality indicators – on the other hand
    would contribute to setting minimum standards at EU level. Road infrastructure represents the
    largest assets in most countries and there are different well-established national
    approaches/indicators to assess road quality. Even where Member States apply similar
    88
    Cf. various studies referred to in the detailed annex of the Impact assessment support study, including CEDR
    86
    techniques, data is often compiled and reported differently, even though the principles and
    core information needs are the same.
    Measure B would introduce tools that can improve the effectiveness of road quality
    monitoring in Member States, which do not have well established procedure. The measures is
    likely to have a positive impact by improving the quality and comparability of information on
    road condition.
    12.2. Main economic impacts
    12.2.1. Transport costs
    To the extent that measures A and B can improve road quality, they are expected to have
    indirect positive impact on reducing the vehicle operating costs described in section 2.1.2.
    According to World Bank studies, every dollar saved on road maintenance increases vehicle
    operating costs by 2 to 3 dollars. Overall, although it is not possible to estimate the direct
    effect of measures A or B on road quality, it is likely that greater improvements in road
    quality will result in greater benefits. Hence, it is expected that the impact of both measures
    together would be stronger due their potentially greater combined impact.
    12.2.2. Impacts on SMEs
    Any road transport undertaking would benefit from reduced operational costs, with micro
    enterprises being relatively more positively impacted than large companies due to their
    smaller turnover. Since 90% of the road haulage sector is composed of enterprises with fewer
    than 10 employees89
    , most of them would feel the difference in their daily running costs. A
    UK study, estimated the savings linked to vehicle operations at EUR 16.000 per year. It is
    not by accident that the representatives of such undertakings are most vocal when it comes to
    supporting the earmarking of revenues to road maintenance (as opposed to cross-financing of
    other modes of transport).
    12.2.3. Administrative costs
    According to a regulation from 197090
    , Member States have to report road infrastructure
    spending, so measure A is not expected to generate any additional costs. In effect, that
    regulation has extremely cumbersome reporting requirements, which may result in its repeal,
    while measure A would just require a very limited and focussed set of figures, thereby
    resulting in a reduced level of administrative burden to Member States compared to the
    status quo.
    Measure B may require additional equipment and time to monitor e.g. road surface, which in
    the case of sophisticated systems could entail high costs; however, recent technological
    development has significantly reduced the cost of measurement (Forslöf & Jones, 2015).
    Overall, for measure B, it is expected that Member States that already practice advanced
    89
    Eurostat. (2017). Goods road transport enterprises, by number of employees. road_ec_entemp
    90
    Regulation (EEC) No 1108/70 of the Council of 4 June 1970 introducing an accounting system for
    expenditure on infrastructure in respect of transport by rail, road and inland waterway
    87
    techniques will incur little or no additional costs, whereas there may be costs associated with
    equipment and staff time for countries that need to adopt new approaches.
    At the same time, it is possible to offset any additional administrative/operational costs with
    benefits from improved road maintenance. It is expected that improved monitoring data would
    allow Member States to better control contracting works for maintenance, leading to cost
    savings in the longer run. As indicated in the problem definition, preventive maintenace helps
    to reduce long-run costs (see also Annex 8: Road asset condition). Both measures could
    contribute to helping Member States more effectively identify and address maintenance gaps,
    and hence it can be expected that they will reduce maintenance costs in the longer term,
    thereby offsetting any additional administrative costs.
    12.2.4. Macroeconomic environment
    As indicated in section 2.1.2, improvements in road quality have positive impacts on the
    wider economy. First order effects include direct employment in construction and materials
    supplying industries, while second order effects occur in the production sector in response to
    the demand for additional inputs required by construction materials supplying industries.
    According to the studies referred to earlier, the value of these first and second round of effects
    for investments in transport infrastructure have a total multiplier effect of around €2.4 (range
    from €2.2 to 2.8) for each €1 invested.
    12.2.5. Competitiveness of EU economy
    Investments in improving the quality of roads are likely to have an overall positive impact on
    economic performance due to increased connectivity, accessibility and connections for
    international trade (European Commission, 2011). Connectivity is a key criterion in decisions
    related to the localisation of a new business or factory. Better road quality is associated with
    competitiveness improvements due to the lower operational costs for road users and better
    connections, which will improve the efficiency of transport and contribute to a more
    competitive economy.
    12.3. Main environmental impacts
    The impacts on climate change, air pollution and noise (issues identified in the problem
    definition, section 2) would be positive in the case of both policy measures to the extent to
    which they can influence increased investment in road maintenance and thus improve the
    quality of roads. The impact assessment support study (Annex C) has further details on the
    related literature.
    12.4. Main social impacts
    12.4.1. Safety (risk of accidents)
    Similarly to the case of environmental impacts, as described in the problem definition and
    noted under the analysis of congestion, poor road condition can increase accident rates. To the
    extent that the policy measures encourage better planning of road maintenance and higher
    road quality, they could be expected to decrease the risk of accidents.
    88
    12.4.2. Equal treatment of EU citizens
    Measure A would have a positive effect on equal treatment because it aims to ensure that
    there is transparency both with the setting of toll levels and the use of revenues. The former
    could improve the acceptance of some charges and would help to protect user rights by
    enabling them to scrutinise the rationale. Clearly stating the components of such charges
    could facilitate a wider debate about what such charges should or should not cover and enable
    user groups, or others, to apply political pressure where this was appropriate to change the
    way in which charges are estimated.
    Measure B would also benefit equal treatment of EU citizens, by ensuring that approaches to
    monitoring road quality are similarly implemented across Europe, and helping to harmonise
    the divergent practices seen today.
    12.5. Comparison of options to improve road quality
    12.5.1. Effectiveness
    With regard to the goal of ensuring adequate road quality, the main policy packages,
    including measures to increase the uptake of road tolls, which can generate additional
    revenues, would be more effective if combined with specific measures targeting road quality.
    Since monitoring road quality and reporting on toll revenues and expenditures are not
    mutually exclusive but are rather complementary, the most effective option is to use these
    measures in concert.
    12.5.2. Efficiency (cost-effectiveness)
    In the case of Measure A, the requirements call for reporting of information that is already
    collected by Member States. Hence the additional costs are low. At the same time, the
    obligations to act on the available information are also limited. This option can therefore be
    seen as creating enabling conditions that can smooth the way for better road quality through
    providing more information/transparency, without any guarantee of this outcome.
    Conversely, Measure B would require greater changes for at least some Member States in the
    form of changes to monitoring practices and/or equipment. This is more administratively
    intensive and will likely involve some amount of additional cost for implementation,
    especially if expensive equipment is needed. The cost can be mitigated through use of
    innovative measurement approaches. The introduction of best practice indicators under
    Measure B may also help to improve contracting of maintenance works. Measure B can help
    to identify problems of road quality as part of an overall asset management system, whereas
    Measure A can help to improve information flows that could identify maintenance
    expenditure gaps. Both measures could therefore contribute to cost savings due to
    preventative maintenance.
    12.5.3. Coherence
    The findings of the impact assessment support study suggest that if Measure A was
    introduced, it would be useful to further support the ongoing actions being taken at the
    89
    international level by the OECD/ITF to increase standardisation of definitions, thereby
    ensuring coherence with existing initiatives.
    12.6. Overall conclusion / preferred option
    On the basis of the analysis, it is clear that combining measures A and B is preferred, and it is
    recommended to introduce them in concert with the preferred main policy package.
    90
    13. ANNEX 13: IMPACT OF CONGESTION CHARGING ON LOCAL COMPETITIVENESS
    91
    13.1. Approach
    Congestion charging can have broad economic impacts on the profile and competitiveness of
    the region in which it takes place. Transport infrastructure plays a key role in the location of
    economic activity and individuals, in the efficient operation of the economy and in shaping
    the fabric of cities and towns. Altering the cost of using one part of the system can have
    knock-on effects on the geographical distribution of economic activities and their
    competitiveness by changing the area’s comparative advantage as a place to live, do business
    and visit. There are opposite effects at play: on the one hand the charge can make an area
    more costly and less attractive to some businesses; on the other, the improved traffic
    conditions boost its competitiveness. These drivers are likely to affect different businesses
    differently and could result in shifts in the mix of economic activities in some areas.
    An extensive search of the literature has not provided information on the economic effects of
    local charges. At the same, time dealing with this issue using the same modelling tools used
    for the analysis of the packages of options would be extremely complex, full of arbitrary
    assumptions and would therefore not yield any meaningful results. Thus, a simplified
    approach has been developed to analyse the regional impacts of congestion charges.
    The approach presented here is based on the relationship between accessibility and
    local/regional impacts. This relationship is explored in the literature, although in theoretical
    terms rather than providing empirical quantifications (also because disentangling the effect of
    accessibility to other local drivers is complex). However, at least one model exists which use
    accessibility changes to derive regional economic impact (Spiekermann and Wegener, 2006).
    A congestion charge increases travel cost on some roads -> given the higher cost, some traffic
    is diverted to other roads or modes -> given the lower traffic speed is improved on charged
    roads -> the generalised cost to travel is therefore modified because of higher cost but lower
    travel time -> a different generalised cost means a different accessibility -> a different
    accessibility has an impact on the regional economy.
    In order to capture the range of possible impacts of congestion charging on regional
    economies, several types of regions need to be considered:
    a) Regions that are considered to be “attractive” (i.e. in this case productive) areas.
    b) Regions that experience various levels of congestion.
    c) The effect of a congestion charge on demand depends on many local factors. For
    instance, the impact of the charge on traffic is heavily dependent on the overall level
    of congestion on the network, the available alternatives to charged corridors and so
    on. It is however impossible to consider local conditions at the required level of detail
    for the analysis. Instead, some parameters can be used to reflect the elasticity of
    demand and test what happens if different levels of elasticity are assumed.
    91
    Source: Ricardo et al. (2017), Support Study for the Impact Assessment Accompanying the Revision of
    Directive 1999/62/EC.
    91
    Therefore, the approach uses an estimation based on parametric assumptions for some sample
    regions. Given the importance of local conditions in determining the results, the quantitative
    outcome of the approach is provided as range of values for the potential effect. It is also
    accompanied by notes to highlight the elements that should be considered on a case by case
    basis to assess whether the impact would be likely to fall closer to the lower or the higher
    threshold.
    13.2. Methodology
    The methodology to model regional economic impacts involved the following steps:
    a) For each region a potential accessibility indicator is calculated with reference to the
    NUTS3 regions within a distance of 300 km. It is assumed that beyond this threshold
    the effect on local economy is negligible. A potential accessibility indicator is
    calculated as:
    PAi = Σj (GDPj * exp(-0.075* Generalised Costij))
    Generalised cost is defined as the monetary cost plus the monetary equivalent of travel
    time92
    .
    b) A congestion charge is assumed to be applied on paths connecting Origin-Destination
    pairs where, according to the modelled speed, some congestion occurs93
    . The
    application of the charge has two effects. First, it increases the travel cost on the O/D
    pair. Second, it improve speed on the O/D pair by reducing some of the traffic flow.
    Both these two effects depend on local conditions (see section 3 below). This defines
    range that encompasses the potential for a low and a high impact.
    c) By considering combinations of the low and high impact on travel cost and the low
    and high impact on travel speed, four scenarios are defined (low effect on cost and low
    effect on speed, high effect on cost and low effect on speed, etc.). For each scenario
    the accessibility indicator is recalculated.
    d) From the data reported in Spiekermann and Wegener (2006), the elasticity of regional
    GDP to a change of accessibility is estimated to be 0.25 (i.e. a percentage point
    improvement of the accessibility94
    gives rise to a 0.25% increment of regional GDP).
    e) The elasticity is applied to the accessibility change in each scenario with respect to the
    reference case. Four different values are obtained from which minimum and maximum
    effect can be identified.
    92
    A value of travel time of 15 Euros/hour has been used to compute the generalized travel cost. Value of travel
    time depends on local conditions. Representative values for road transport in European countries (Victoria
    Transport Policy Institute, 2010) range from 4 Euros/hour for non-working trips to 6 Euros/hour for
    commuting trips, 21 Euros/hour for business trips to 45 Euros/hour for trucks. The chosen value of 15
    Euros/hour is representative of all types of traffic (passenger and freight) taking into account that congestion
    charge should be applied in peak time where commuting trips are a large share of car trips.
    93
    Speeds are drawn from the TRUST model. It should be noted that the approach is based on the identification
    of origin-destination pairs where speed is below ideal free-flow speed. It is unimportant to detect exactly on
    which links congestion occurs.
    94
    In the study used to estimate the elasticity, the accessibility indicator is a potential one, so the methodology is
    consistent. Furthermore, data related to the impact of a road charging scenario has been considered.
    92
    As discussed above, the approach is a parametric one, adopting a low and high threshold for
    the assumed impact of congestion charging on travel cost and travel speed. In order to
    understand if in a specific region one should expect lower or higher elasticities, there are
    several elements to be considered as discussed in Figure 13-1.
    Figure 13-1: Main factors affecting elasticity of travel demand
    Impact of congestion charge on travel cost Impact of congestion charge on travel time
    The size of the charge. The larger the charge
    applied, the greater the increase in travel cost.
    Availability of alternative routes. When some links are charged, spill over
    effect on other links can occur. This is more likely when different options
    are available. If alternative routes are lacking either because the
    infrastructures are poor or because the whole network is congested (as it
    often is the case around metropolitan areas), the elasticity of demand will
    be lower. It should be also considered that if one road is congested and
    other roads on the same corridor are not, most likely the level of service
    (i.e. speed) on the alternative routes is anyway lower than on the most used
    link (otherwise as soon as congestion arises some vehicles would switch on
    alternative road). Therefore even when alternatives exist and some traffic is
    diverted onto them, the overall effect on average speed of trips is hardly
    large.
    The length of the charged network. The
    relevant travel cost is for origin-destination
    pairs. If a congestion charge is applied to
    some links, the travel cost will be affected
    more when these links represent a larger
    portion of the overall trip distance. Even large
    charges will not affect the total cost very
    much if they are only applied on a small
    number of short road stretches.
    The localisation of the charged links. The availability of alternatives can
    depend on the position of congested links. Often congested links are close
    to large attractors (e.g. a metropolitan area, an industrial zone) where many
    trip are destined to. In this situation it is hard to find alternative routes. In
    some cases interurban corridors become congested because traffic related to
    several different O/D pairs sharing part of their route converge to the same
    infrastructure. This second case is generally more favourable to find
    alternatives.
    The initial travel cost. The same charge level
    can have a different impact depending on the
    initial cost. Especially making reference to
    perceived costs, a given charge will raise car
    travel cost more than truck travel cost.
    Availability of alternative modes. Another reaction to road charging can be
    mode shift. This is more likely when good alternative services (e.g. rail
    connections) exist along the corridor.
    The length of the charged network. As already mentioned for travel cost, if
    travel time is referred to the whole trip, the effect of a congestion charge
    depends on the share of route charged. If the policy is applied to only a
    minor part of the route, even in case demand reacts significantly, the overall
    effect on the average travel speed for the trip will be small.
    Flexibility of departure time. If a congestion charge is applied only in peak
    hours, travellers who can move their departure time before or after the
    charged period can avoid paying the charge (and at the same time traffic in
    peak time is reduced). The larger the share of demand with a flexible travel
    time and the larger the effect on travel speed.
    Average income. Demand of higher income groups is usually less elastic
    than lower income groups’. If the congestion charge is based on an
    estimation of marginal cost of congestion and, in turn, such an estimation is
    based on some demand curve, the average level of income will be reflected
    in the level of the charge (as the demand curve will be more or less steep).
    However if an average value e.g. by country is applied in region with
    significantly different levels of income the response of demand can be
    diverse.
    93
    13.3. Model results
    The results summarised in Figure 13-2 were obtained, assuming elasticities within a
    reasonable range as defined above.
    Figure 13-2: Impact of congestion charge on regional economies –results
    Zone
    Type
    Region
    Effect on regional
    GDP
    1
    A region located at medium distance from a large economic pole and with a few
    congestion spots along its connections
    (e.g. Essex CC (UK))
    Min -0.6% Max
    0.5%
    2
    A region located in the middle of a large productive area where congestion is significant
    especially on short/medium distance
    (e.g. Milan (IT))
    Min -0.7% Max
    0.4%
    3
    A region which is the main economic pole in a large area where congestion is significant
    (e.g. Warsaw (PL))
    Min -0.5% Max
    1.0%
    4
    A region located in an area where GDP is evenly distributed congestion is limited to some
    spots
    (e.g. Oporto (PT))
    Min -0.3% Max
    0.3%
    5
    A region located at medium/long distance from main economic poles and in an area with
    widespread congestion
    (e.g. Harz (DE))
    Min -1.1% Max
    0.7%
    6
    A region located at medium/long distance from an economic pole and with some
    congestion along its connections
    (e.g. Maine et Loire (FR))
    Min -0.3% Max
    0.2%
    The main findings from the calculations are:
     The effect of congestion charges on regional economies are expected to be limited.
    This seems reasonable, since congestion charge should be limited in space and time.
    Furthermore, even if the charge can improve travel speed it will also increase travel
    cost, so the impact on accessibility is not necessarily positive in all circumstances.
     The effects are larger where the effect on speed is assumed to be bigger and the effect
    on cost is assumed to be smaller.
     The effect is larger where there is more congestion (even if in more congested areas,
    demand has probably fewer alternatives and so the more optimistic scenario based on
    higher elasticity of speed is unlikely).
     The impact is different across regions not only because of different levels of
    congestion, but also because congestion is “located” at diverse distances from the
    economic poles. Where charged (i.e. more congested) links are those connections to
    the main economic poles, the impact on the economy is larger. Again this is not
    surprising. One message behind this result is that if congestion exists on a corridor
    because of poor infrastructure (i.e. even if surrounding regions do not generate much
    traffic, demand is forced to use the only road available) a congestion charge is not
    effective.
    In summary, the main purpose of congestion charging can be the internalisation of congestion
    cost or to disincentive drivers to use congested roads and improve the level of service.
    Congestion charges can have indirect effects including those on local economies; however
    these indirect effects are probably not large and do not represent a major factor that will
    determine the overall success of the charge.
    94
    14. ANNEX 14: SME TEST
    95
    14.1. Consultation with SME representatives
    Consultation with SMEs took place throughout the following processes:
     The open public consultation (12 weeks from 8th
    July 2016) gave SMEs the
    opportunity to respond directly to the questionnaire:
    o Seven SMEs in the road haulage sector (from Spain, Austria, Hungary, Poland
    and Portugal) responded to the consultation.
    o Representatives of SMEs (UETR and UEAPME) responded to the public
    consultation via answers to the survey or through submission of a position
    paper.
     Interviews were carried out with two SMEs, who requested to be remain anonymous.
    The questions covered potential impacts on SMEs of different policy measures.
     Interviews with all stakeholders included questions that invited interviewees to think
    specifically about the potential impacts on SMEs and whether they might be
    disproportionate.
    As can be seen above, direct feedback from SMEs via the survey and interviews was limited
    and so their responses cannot be considered representative. Where we were able to speak
    directly with two individual SMEs in the interviews, their responses were broadly supportive
    of the changes in terms of reducing the environmental impact of goods vehicles and
    congestion, as well as re-investing revenues into road infrastructure. The position of
    UEAPME was to support the proportional pricing of vignettes and phasing out of vignettes
    for HGVs (with optional distance-based charging). They did not support the inclusion of
    freight vehicles in congestion charges given that cars are the primary cause of congestion. Nor
    did they support the inclusion of CO2 emissions in the Eurovignette Directive since CO2
    emissions are generally internalised through fuel taxation and thus this type of charging (if
    applied on top of existing charges) could lead to double taxation.
    More generally, all interviewed stakeholders were invited to provide their perspective on
    possible impacts on SMEs; however most did not have an opinion or did not respond to this
    question. Of the few responses received, one hauliers association (PL) believed that SMEs
    would find the policy measures more challenging, as these firms had fewer resources to invest
    in cleaner vehicles, new equipment or pay higher road charges. An interviewee from an EU-
    15 national authority highlighted the costs of investing in new equipment - such as on-board
    systems- would have a disproportionate impact on SMEs, particularly for occasional road
    users. Conversely, another EU-15 National ministry (who requested to remain anonymous)
    responded that they did not foresee any particular costs burdens for SMEs.
    95
    Source: Ricardo et al. (2017), Support Study for the Impact Assessment Accompanying the Revision of
    Directive 1999/62/EC.
    95
    14.2. Assessment of businesses likely to be affected
    SMEs play a significant role in the road haulage industry. The market structure is
    characterised by having a small number of large, pan-European logistic companies providing
    complex services at the top, which dominate the largest contracts but subcontract a significant
    proportion of their work to SMEs (AECOM, 2014). This is illustrated in the data from
    Eurostat on company size (Figure 14-1). For the countries where data is available, SMEs with
    less than 50 employees represent 97-100% of all road haulier enterprises in 2012 (the latest
    year for which data are available). The vast majority (80-97%) are micro-SMEs, i.e.
    companies with fewer than 10 employees. At the EU level, 90% of enterprises in the sector
    have fewer than 10 employees and account for close to 30% of turnover (including self-
    employed) (Eurostat, 2017).
    Figure 14-1; Size of enterprises in the Haulage Industry in 2012
    Source: (Eurostat, 2017) - Adapted from road_ec_entemp
    The haulage industry is highly competitive and operators are forced to operate on low profit
    margins (AECOM, 2014). Cost pressures for logistics providers mean that many heavily rely
    on subcontracting less profitable operations to smaller enterprises and owner-operators
    (AECOM, 2014). This presents a risk that additional road charges could push some players
    out of the market, especially among smaller firms that tend to compete mainly on price
    (WTO, 2010). The risk of such impacts is examined further below.
    0% 20% 40% 60% 80% 100%
    Estonia
    Italy
    Cyprus
    Latvia
    Hungary
    Austria
    Poland
    Slovenia
    Slovakia
    Finland
    Norway
    From 1 to 5 employees From 6 to 9 employees From 10 to 19 employees
    From 20 to 49 employees 50+ employees
    96
    14.3. Measurements of the impacts on SMEs
    The proposed policy measures will likely lead to increases in the costs of transport. SMEs
    may be disproportionately affected by these increases, since a large firm may be better able to
    absorb increased costs of road pricing compared to a smaller firm (Mahendra, 2010). As
    shown in the modelling results, small increases in the cost of transport are foreseen for all
    options due to the introduction of new road tolls in certain Member States and the greater use
    of external cost charges (and to a lesser extent, mark-ups in mountainous regions).
    The capacity to offset additional costs from road user charging may differ depending on the
    size and competitive position of firms. It could be argued that SMEs may have lower capacity
    to optimise their operations, and hence would be most affected by road charges. Evidence
    from Germany and Switzerland suggests that road hauliers were able to offset higher road
    charges through reducing empty runs or increasing loading factors (BMT Transport Solutions,
    2006); (CEDR, 2009). SMEs with smaller vehicles and fleets, or a lower density customer
    network, could lack the scale needed to enhance efficiency according to these mechanisms. A
    qualitative study of the effect of the UK HGV levy on Irish hauliers also suggested that the
    costs would be borne by industry, due to their “low bargaining power to push the road
    charge on to freight forwarders and exporters” (Vega & Eversa, 2016). In addition, extending
    the Directive to HGVs <12 tonnes could potentially have a greater impact on SMEs since,
    according to one interviewed stakeholder (UK authority), SMEs typically operate smaller
    vehicles.
    That said, it is generally assumed that 100% of cost increases due to road tolls are passed
    through, consistent with experience in several European countries. For instance, in Germany,
    Austria and Switzerland, the cost increases after introduction of tolls were passed to
    customers (BMT Transport Solutions, 2006); (Ruehl et al, 2015). Although these studies did
    not specify whether the results applied specifically to SMEs, since the haulage industry is
    made up almost entirely of SMEs it seems reasonable to assume that the outcome of passing
    through most (if not all) of the additional costs is representative. As such, it is expected that
    increased transport costs in PO1-4 will not have significant disproportionate impacts on
    SMEs.
    Introducing congestion charging will also likely impact SMEs, since they have lower
    flexibility in their operations (as described above). SMEs with operations based primarily in
    affected areas (e.g. that often travel through congested road networks), or that have fewer
    resources available to be flexible in the timing of operations (e.g. from a shift to off-peak
    operations) would be disproportionally affected by increased charges. In particular, small
    firms may have no choice but to drive in peak hours because they have to maximise utilisation
    of their vehicles (Mahendra, 2010).
    Interview feedback from a pan-European logistics company was that congestion charging is
    particularly challenging for trucks, as deliveries are often dependent on the demand of
    customers. This is demonstrated by the introduction of the congestion charge in London,
    where the number of goods vehicles remained almost unchanged, indicating that hauliers did
    not change behaviour in order to avoid the charges (CEDR, 2009). In their position paper,
    UEAPME noted that transport companies are already motivated to avoid congestion and
    97
    driving in peak times would be because they have no alternative choices, and suggested that
    freight vehicles should be exempted from congestion charges.
    At the same time, the same firms would likely benefit from lower congestion, which would
    result in time savings and an effective increase in the catchment area for the business. If the
    congestion charge is effective, it will improve the reliability and speed of deliveries along the
    supply chain. Given the limited real-world experience with inter-urban congestion charging,
    it is difficult to say what the net impacts would be – however, evaluations of the London
    congestion charge found no discernible impact on businesses (TfL, 2008), suggesting that
    more limited, targeted interurban congestion charging foreseen in the policy options would
    not have significant impacts (positive or negative).
    Finally, the proposed measures to promote zero-emission vehicles (included in PO1-4)
    through allowing lower road user charges could have different impacts on SMEs compared
    to larger firms. In general, the impact on firms from this measure is expected to be positive,
    since the lower per-km road charges will contribute to lower running costs overall (in addition
    to other fiscal incentives, such as tax breaks and lower prices for alternative fuels). Over time,
    these lower running costs should more than outweigh the additional purchase costs of zero-
    emission light vehicles compared to a diesel equivalent (EEA, 2016b); (Energy Saving Trust,
    2017). Taking subsidies into account, the total cost of ownership of a commercially-owned
    electric van is lower than a conventionally-fuelled van in most Member States – with larger
    savings if annual mileage is higher (Schimeczek et al, 2015).
    SMEs in particular may face more difficulties in making the upfront investment for the more
    expensive vehicle. For example, Nissan e-NV200 electric van is 47% more expensive to
    purchase and lease compared to its diesel equivalent, the NV200 (Low Carbon Vehicle
    Partnership, 2016). For HDVs the differences in purchase costs compared to conventional
    vehicles is even larger, with retail costs of electric trucks being between 170% and 280%
    higher than a conventional equivalent (CE Delft, 2013).
    If SMEs are less able to purchase or lease zero-emission vehicles, they will initially benefit
    less from the measure compared to a larger firm – both in terms of have less potential to
    access the lower rates for road user charges, as well as the co-benefits of owning zero
    emission vehicles in the form of lower fuel costs etc. There are, however, two reasons that
    the impact may not be a concern in the longer term:
     Firstly, the difference in investment costs between zero-emission vehicles and
    conventional vehicles is largely due to the powertrain costs (i.e. the battery). It is
    widely predicted that the cost of batteries will decrease significantly between 2015 and
    2030 (Wolfram & Lutsey, 2016) - meaning that upfront investment will be less of an
    issue than today.
     Secondly, SMEs typically buy their vehicles on the second-hand market (BCA, 2012).
    If the measure stimulates additional first-hand purchases of zero-emission vehicles,
    these will eventually reach the second-hand market and SMEs will benefit from
    having access to zero-emission vehicles that they would otherwise not have been able
    to purchase.
    98
    14.4. Assess alternative options and mitigating measures
    The analysis shows that the initiative might result in a slight disproportionate increase in costs
    for SMEs, but this is generally found to be small and likely to be passed on to customers.
    Experience from existing HGV road user charges (a sector primarily made up of SMEs) in
    countries such as Germany, Switzerland and Austria found that increases in costs were
    generally small and passed on to customers (Ruehl et al, 2015). Impacts from interurban
    congestion charging are expected to be limited. Consequently, there is no indication of a need
    for SME-specific measures in order to ensure compliance with the proportionality principle.
    99
    15. ANNEX 15: THE ROAD INITIATIVES – THE 'BIG PICTURE'
    15.1. Introduction
    The Road Initiatives, which are all REFIT Initiatives, are fully inscribed in the overall
    priorities of the Juncker Commission notably under the 'A deeper and fairer Internal Market'
    and the 'Climate and Energy Union'.
    The Communications from the Commission on 'Upgrading the Single Market: more
    opportunities for people and business' and on 'A Framework Strategy for a Resilient Energy
    Union with a Forward-Looking Climate Change Policy' explicitly refer to the Road
    Initiatives.
    The table below presents the link between the Juncker priorities, the Impact Assessments
    prepared for the Road Initiatives and the related legislative acts.
    Priorities IAs Legislation
    A deeper and
    fairer Internal
    Market
    Hired vehicles Directive 2006/1
    Access to the haulage market and to
    the Profession
    Regulation 1071/2009 & 1072/2009
    Social aspects: Driving/rest time,
    working time and enforcement
    measures (tachograph), Posting of
    workers and enforcement measures
    Regulation 561/2006 and Regulation
    165/2014
    Directive 96/71, Directive 2014/67,
    Directive 2002/15 and Directive 2006/22
    Access to the market of buses and
    coaches
    Regulation 1073/2009
    Climate and
    Energy Union Eurovignette Directive 1999/62
    European Electronic Toll Service
    (EETS)
    Directive 2004/52
    Commission decision 2009/750
    Moreover, the transport strategy of the Commission as laid down in the White Paper
    "Roadmap to a Single European Transport Area - Towards a competitive and resource
    efficient transport system" adopted on 28 March 2011, included references to the road
    initiatives96
    .
    15.2. The EU road transport market
    Road transport is the most prominent mode of transport. In 2014, almost three quarters (72%)
    of all inland freight transport activities in the EU were by road. On the passenger side, the
    relative importance of road as mode of transport is even greater: on land, road accounts for
    more than 90% of all passenger-kilometres: 83% for passenger cars and almost 9% for buses
    and coaches.
    Almost half of the 10.6 million people employed in the transport and storage sector in the EU
    are active in carrying goods or passengers by road. Road freight transport services for hire and
    reward employs around 3 million people, while the road passenger transport sector (buses,
    coaches and taxis) adds another 2 million employed persons (a third of which are taxi
    drivers). This corresponds to more than 2.2% of total employment in the economy and does
    96
    More specifically in the Annex under points 6, 11 and 39
    100
    not include own account transport which in road freight transport alone provides employment
    for 500,000 to 1 million additional people.
    There are about 600,000 companies in the EU whose main business is the provision of road
    freight transport services for hire and reward. Every year, they generate a total turnover of
    roughly €300 billion, around a third of which is value added by the sector (the rest being spent
    on goods and services from other sectors of the economy). The provision of road freight
    transport services for hire and reward is hence an important economic sector in its own right,
    generating almost 1% of GDP.
    In road passenger transport, there are about 50,000 (mostly) bus and coach operators (of
    which 12,000 provide urban and suburban services, (some including tram and underground))
    and around 290,000 taxi companies in the EU. Together, they generate a turnover of €110
    billion. Without taxis, total turnover of the sector is around €90 billion per year, of which
    some €50 billion is value added.
    15.3. Why is there a need for action?
    Road transport is for a large part international (around 34%97
    ) and this share is increasing,
    which explains the need for a common EU legal framework to ensure efficient, fair and
    sustainable road transport. The framework covers the following aspects:
     Internal market rules governing access for operators to the markets of freight and
    passengers
     Social rules on driving/rest time and working time to ensure road safety and respect of
    working conditions and fair competition
     Rules implementing the user and polluter pays principles in the context of road charging
     Digital technologies to enable interoperable tolling services in the EU and to enforcement
    EU rules (e.g. the tachograph)
    It is clear that current rules are no longer fit for purpose. Member States are increasingly
    adopting own national rules to fight "social dumping" while acknowledging that their actions
    have adverse effects on the internal market. Moreover, public consultations have shown a
    strong support for EU action to solve current issues in road transport. For example:
     Severe competition in the road transport sector has led many operators to establish in low-
    wage countries without necessarily having any business activity in these countries. There is
    a lack a clear criteria and enforcement mechanisms to ensure that such establishment
    practises are genuine, and that there is a level playing for operators.
     Measures on Posting of Workers implemented in 4 Member States (DE, FR, AT and IT)
    are all different and obviously from other Member States which have not implemented any
    measure to implement the minimum wage to road transport on their territory. Stakeholders
    ask for a common set of (simplified) enforcement rules.
    97
    Statistical Pocketbook 2016, EU Transport in figures
    101
     CO2 emissions from road transport represent a large share of total emission and the share
    is set to rise in the absence of common action (at EU 28 level), which is needed to
    contribute substantially to the commitment under the Paris Agreement and to the 2030
    goals.
     Due to the increasingly more and more hyper-mobile nature of the sector, there is a need
    for common and enforceable rules for workers. All workers should benefit from the same
    level of protection in all Member States to avoid social dumping and unfair competition
    between hauliers. This is currently not the case.
    15.4. What are the main problems?
    The Internal market for road transport is not complete. It is our assessment that the current
    situation does not allow to exploit the full potential of transport services
     e.g. current rules on bus/coach services or the rules on hired vehicles are still very
    restrictive. Some Member States have decided to unilaterally open their market, which
    has led to a fragmentation of the EU internal market.
    Many rules are unclear, therefore leading to different level of implementation by Member
    States and problems of enforcement:
     e.g. on cabotage where all stakeholders agree that current rules are unenforceable
    There are allegations of 'social dumping' and unfair competition in the road transport sector.
    This has led to a division between East and West in Europe. As a consequence, several
    Member States have decided to take national measures, which might jeopardize the unity of
    the EU market for road transport:
     E.g. minimum wage rules in DE, FR, IT and AT coupled with disproportionate
    administrative requirements ; prohibition of drivers taking the weekly rest in the cabin
    of vehicles in FR and BE
    Environmentally, we have made good progress on reducing pollutants from Heavy Good
    Vehicles but our legal framework currently does not address the issue of climate change
    (CO2). At the same time, the infrastructure quality is degrading in the EU despite that fact that
    user charges and tolls are levied on most TEN-T and motorways.
    Electronic tolling systems in the EU are, despite the primary objective of the EU legislation of
    "one contract/one on-board unit/one invoice" for the users, far being interoperable. More
    generally, the benefits of digitalisation are still under-exploited in road transport, in particular
    to improve control of EU legislation (e.g. many Member States do not currently the use of
    electronic waybills).
    15.5. Options and main impacts
    To achieve these objectives, all IAs will consider a range of different options, which
    ultimately should improve the efficiency, fairness and sustainability of road transport.
    102
    The IA on Hired Vehicles will assess options aiming at removing outdated restrictions on the
    use of hired goods vehicles and thus at opening up new possibilities for operators and
    leasing/hiring companies alike. More flexibility for the hiring of vehicles should lead to more
    efficient operations, higher productivity and less negative environmental impacts as fleet
    renewal will be promoted.
    The IA on Access to the haulage market and to the Profession will study various options to
    ensure effective and consistent monitoring and enforcement of the existing rules in Member
    States and to ensure coherent interpretation and application of the rules. Three broad groups
    of potential measures will be assessed, namely measures liable to improve enforcement,
    measures ensuring simplification and clarification of current rules and measures reinforcing
    the cooperation between Member States.
    The IA on Access to the market of buses and coaches will assess options aiming at improving
    the performance of coach and bus services vis-a-vis other transport modes, especially private
    car and further developing the internal market for coach and bus services. This should lead to
    a reduction of the adverse environmental and climate effects connected with mobility. Various
    policy options will be considered for creating more uniform business conditions and also a
    level playing field for access to terminals.
    The IA on Social aspects of road transport will study options aiming at ensuring the
    effectiveness of the original system put in place and therefore contributing to the original
    policy objectives, i.e.: (1) to ensure a level playing field for drivers and operators, (2) to
    improve and harmonise working conditions and (3) to improve the road safety level. An
    additional objective, in the context of the implementation and enforcement of the provisions
    on posting of workers, is to ensure the right balance between the freedom to provide cross-
    border transport services and the protection of the rights of highly mobile road transport
    workers. In this perspective, three broad groups of measures will be analysed: 1.
    Simplification, update and clarification of existing rules, 2. More efficient enforcement and
    cooperation between Member States and 3. Improved working conditions of drivers and fair
    competition between operators.
    The IA on the Eurovignette will assess options to promote financially and environmentally
    sustainable and socially equitable (road) transport through wider application of the 'user pays'
    and 'polluter pays' principles. A number of different measures and their variants aiming at
    correcting price signals in freight and passenger transport will be considered in order to
    address the issues identified. The policy options range from minimum adjustments to the
    Directive required for improving its coherence and addressing all policy objectives, through
    the promotion of low carbon (fuel efficient) vehicles and the phasing out of time-based
    charging schemes (vignettes) for trucks to the optimisation of tolls for all vehicles.
    The IA on EETS (European Electronic Tolling Service) will study options aiming at reducing
    the cost and the burden linked to the collection of the electronic tolls in the EU – for the users
    and for the society at large. It will equally seek to improve the framework conditions for the
    faster and more widely provision of an interoperable European Electronic Toll Service.
    Different policy options will be considered, including a non-legislative approach (facilitating
    exchange of best practice, co-financing EETS-related projects) and a legislative review.
    103
    These policy options and their impacts will be presented and assessed in detail in the
    respective IAs.
    15.6. Expected synergies of the package
    The different initiatives constitute a coherent set of measures which will jointly contribute to
    an efficient, environmentally and socially sustainable road transport sector. It is expected that
    the impacts will be more than the addition of the impacts of each initiative, meaning that the
    initiatives are complementary. Some examples of such synergies are provided below.
     Current restrictions on cabotage are unclear and therefore lead to illegal cabotage. These
    illegal activities are closely linked with the fact that transport operators established in low-
    wage countries exert unfair competition via 'social dumping' and not respecting the rights
    of workers, who often are staying in their trucks abroad for longer periods. This illustrates
    the clear link connection between compliance of internal market rules and social/fair
    competition aspects of road transport, which are all addressed by the road initiatives and
    which cannot be dealt with separately.
     When assessing the laws applying a national minimum wage to road transport, Member
    States explained the Commission that one of the reasons for adopting these national
    measures is to fight the phenomenon of fake establishments and “letter box” companies in
    low-wage countries. Tackling the issue of posting of workers in road transport goes
    therefore hand in hand with the issue establishment of road hauliers transport operators,
    which again illustrates the link connection between internal market and social aspects of
    road transport.
     Promoting interoperability of electronic tolls systems will lead to lowering the
    implementation costs of such systems by Member States. We can expect that this will
    incentivise Member States to put in place distance-based tolls, which better reflect the user
    and polluter pays principles use of infrastructure. This shows the close link between the
    Eurovignette and EETS initiatives.
     Seeking to improve the performance of coach and bus services vis-a-vis other transport
    modes will inevitably lead discussion on a level playing between road and rail services.
    Current EU legislation provides that rail users shall pay for the use of infrastructure, while
    it is not currently the case for buses and coaches which are outside the scope of the
    Eurovignette directive. The inclusion of buses and coaches in the Eurovignette initiative to
    ensure that they pay a fair price for using the road infrastructure is therefore essential and
    will ensure endure overall coherence.
     The initiatives on hired vehicles is in particular related to the initiatives on the access to the
    market and to the profession, all having the aim of establishing clear and common rules for
    a well-functioning and efficient Internal Market for road haulage: some of them by
    ensuring a good functioning of the market of transport services, others by ensuring the best
    use of the fleet of vehicles.
    104
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    WTO. (2010). Road freight transport services.
    

    1_EN_impact_assessment_part1_v3.pdf

    https://www.ft.dk/samling/20171/kommissionsforslag/KOM(2017)0276/kommissionsforslag/1414093/1768890.pdf

    EN EN
    EUROPEAN
    COMMISSION
    Brussels, 31.5.2017
    SWD(2017) 180 final
    PART 1/2
    COMMISSION STAFF WORKING DOCUMENT
    IMPACT ASSESSMENT
    Accompanying the document
    Proposal for a Directive of the European Parliament and of the Council amending
    Directive 1999/62/EC on the charging of heavy goods vehicles for the use of certain
    infrastructures
    and
    Proposal for a Council Directive amending Directive 1999/62/EC on the charging of
    heavy goods vehicles for the use of certain infrastructures, as regards certain provisions
    on vehicle taxation
    {COM(2017) 275 final}
    {COM(2017) 276 final}
    {SWD(2017) 181 final}
    Europaudvalget 2017
    KOM (2017) 0276
    Offentligt
    i
    GLOSSARY.....................................................................................................................VII
    1. INTRODUCTION....................................................................................................... 1
    1.1. Policy context.................................................................................................... 1
    1.2. Legal context..................................................................................................... 2
    1.3. Evaluation of the implementation ..................................................................... 3
    2. WHAT IS THE PROBLEM AND WHY IS IT A PROBLEM?................................. 3
    2.1. What is the nature of the problem? What is the size of the problem?............... 5
    2.1.1. P1: Insufficient contribution of road transport to overall CO2
    emission reduction............................................................................... 5
    2.1.2. P2: Degrading quality of road infrastructure....................................... 6
    2.1.3. P3: Discrimination of occasional / non-resident road users and
    unfair distribution of costs via road charging...................................... 8
    2.1.4. P4: High levels of air pollution, noise and congestion...................... 10
    2.2. What are the main drivers?.............................................................................. 11
    2.2.1. D1. Insufficient uptake of vehicles with low CO2 emission............. 11
    2.2.2. D2. Insufficient investment in road maintenance.............................. 13
    2.2.3. D3. Insufficient uptake and sub-optimal application of road
    charging............................................................................................. 14
    2.2.4. D4. No rules on price proportionality of vignettes for passenger
    cars and vans ..................................................................................... 15
    2.2.5. D5. Lack of clear price signals on pollution and congestion ............ 16
    2.3. Who is affected by the problem? What is the EU dimension of the
    problem?.......................................................................................................... 18
    2.4. How is the problem likely to develop without action?.................................... 19
    2.4.1. Insufficient decrease in CO2 emissions from road transport............. 19
    2.4.2. Degrading quality of road infrastructure with negative economic,
    social and environmental impacts ..................................................... 19
    2.4.3. Potential discrimination against occasional/non-resident users and
    unfair distribution of costs via road charging.................................... 20
    2.4.4. Negative environmental and socioeconomic impacts of road
    transport............................................................................................. 22
    3. WHY SHOULD THE EU ACT? .............................................................................. 22
    3.1. The EU's right to act........................................................................................ 22
    3.2. Subsidiarity check ........................................................................................... 23
    3.3. EU added value ............................................................................................... 24
    4. OBJECTIVES ........................................................................................................... 25
    ii
    5. POLICY OPTIONS................................................................................................... 26
    5.1. Baseline (no additional EU action) ................................................................. 26
    5.2. Discarded policy measures.............................................................................. 26
    5.3. Policy option 1: minimum adjustments with rules for vehicles (including
    for passenger cars) (PO1)................................................................................ 27
    5.4. Policy option 2: rules for all vehicles and progressing on the 'polluter pays'
    and 'user pays' principles for HDVs (PO2) ..................................................... 29
    5.5. Policy option 3: reducing CO2 and other externalities from all vehicles
    (PO3) – with two variants (3a and 3b) ............................................................ 30
    5.6. Policy option 4: optimisation of tolls for all vehicles (PO4)........................... 31
    5.7. Overview of measures and objectives............................................................. 31
    6. ANALYSIS OF IMPACTS....................................................................................... 33
    6.1. Economic impacts ........................................................................................... 33
    6.1.1. Transport costs .................................................................................. 33
    6.1.2. Congestion cost ................................................................................. 37
    6.1.3. Impact on SMEs................................................................................ 38
    6.1.4. Member States budgets ..................................................................... 39
    6.1.5. Compliance costs to road users ......................................................... 42
    6.1.6. Road quality ...................................................................................... 43
    6.1.7. Regional distribution of impacts ....................................................... 44
    6.1.8. Macroeconomic environment............................................................ 45
    6.1.9. Competitiveness of the EU economy................................................ 47
    6.1.10. Functioning of the internal market.................................................... 47
    6.1.11. Impact on third countries................................................................... 48
    6.2. Environmental impacts.................................................................................... 48
    6.2.1. CO2 emissions ................................................................................... 48
    6.2.2. Air quality.......................................................................................... 49
    6.2.3. Noise.................................................................................................. 50
    6.2.4. Land use ............................................................................................ 51
    6.3. Social impacts ................................................................................................. 51
    6.3.1. Impacts on employment .................................................................... 51
    6.3.2. Public health...................................................................................... 52
    6.3.3. Social inclusion and distributional impacts....................................... 53
    6.3.4. Equal treatment of citizens................................................................ 54
    7. HOW DO THE OPTIONS COMPARE?.................................................................. 55
    iii
    7.1. Key economic, social and environmental impacts.......................................... 55
    7.2. Effectiveness ................................................................................................... 57
    7.3. Efficiency ........................................................................................................ 58
    7.4. Coherence........................................................................................................ 59
    7.5. Proportionality................................................................................................. 60
    7.6. Preferred option............................................................................................... 60
    7.7. Effectiveness in achieving the objective to reduce regulatory burden
    (REFIT objective)............................................................................................ 61
    8. MONITORING AND EVALUATION .................................................................... 62
    8.1. Indicators......................................................................................................... 62
    8.2. Operational objectives..................................................................................... 63
    iv
    GLOSSARY
    Buses and
    coaches
    Larger buses which are suited or intended to carry more than 16 passengers
    (having a permissible laden weight above 3.5 tonnes)
    CO2 Carbon dioxide
    DSRC Dedicated Short Range Communication, used in electronic tolling for remote
    communication between the on-board units (OBU) and the roadside
    equipment and/or mobile enforcement devices
    EETS European Electronic Toll Service: the possibility for road users to pay all
    electronic road tolls in the EU with one single OBU, one contract and one
    invoice. The EETS is mandated by Directive 2004/52/EC and defined in
    Decision 2009/750/EC.
    Euro
    emission
    classes
    Emission standards regulating the exhaust emissions of vehicles
    Euro 6 Euro 6 emission standards for LDV as regards air pollutants, which are set
    out in Commission Regulation (EC) No 692/2008
    Euro VI Euro VI emission standard for HDV as regards air pollutants, which are set
    out in Regulation (EC) 595/2009
    GHG Greenhouse gases
    GNSS Global Navigation Satellite System: satellite system that is used to pinpoint
    the geographic location of a user's receiver anywhere in the world.
    HDV Heavy-Duty Vehicle, i.e. trucks or lorries, coaches and buses (vehicles with
    a permissible laden weight above 3.5 tonnes)
    HGV Heavy Goods Vehicle, i.e. trucks or lorries (freight vehicles with a
    permissible laden weight above 3.5 tonnes)
    LDV Light-Duty Vehicle, i.e. cars, minibuses and vans (vehicles with a
    permissible laden weight up to 3.5 tonnes, including minibuses carrying up
    to 16 passengers)
    NOX Nitrogen oxides (nitric oxide (NO) and nitrogen dioxide (NO2)
    PM Particulate matter
    Polluter pays
    principle
    Principle stipulating that the one who produces pollution should bear the full
    social cost (including environmental costs and other external costs) of
    managing the pollution. The principle is enshrined in Article 191(2) of the
    Treaty on the Functioning of the European Union, as one of the principles
    underpinning the EU’s environmental policy.
    User pays
    principle
    Aims at recovery of infrastructure costs. This is consistent with the elements
    of a fair and efficient pricing system for transport, where prices paid reflect
    the real costs of the journeys.
    TEN-T Trans-European Transport Network as defined in the TEN-T guidelines1
    1
    Regulation (EU) No 1315/2013 of the European Parliament and of the Council of 11 December 2013 on
    Union guidelines for the development of the trans-European transport network
    v
    VECTO Vehicle Energy consumption Calculation Tool
    ZEV Zero-emission vehicles: vehicles with no exhaust emissions
    1
    1. INTRODUCTION
    1.1. Policy context
    The promotion of sustainable transport is a key element of the common transport policy.
    The 2011 White Paper on transport2
    calls for moving towards full application of the
    ‘polluter pays’ and ‘user pays’ principles in order to ensure more sustainable transport and
    infrastructure financing. As part of a wider strategy to provide effective incentives to users
    in all transport modes through pricing, the 2011 White Paper suggested further actions to
    promote and harmonise road charging.
    However, the current legislation on road charging has proven unfit for purpose, in two
    areas (in addition to the need for simplification and clarification): 1) The current scope of
    the legislation, including only heavy goods vehicles (HGVs), contains no provisions for
    passenger cars, vans and buses. These vehicles account for a significant amount of total
    transport volumes and impose an important strain on the environment and on the
    infrastructure. Due to their exclusion, these vehicles also do not benefit from any rules
    guaranteeing non-discriminatory road charging. 2) The current scope of externalities,
    addressing air pollution and noise, disregards CO2, a growing problem in the road transport
    sector. While other instruments (e.g. CO2 emission standards) are better placed for
    delivering significant CO2 emissions reductions in the road transport sector, road pricing
    could provide a useful complementary contribution by incentivising the renewal of the
    vehicle fleet.
    In line with the Paris Climate Agreement and increasing awareness of the magnitude and
    negative impacts of air pollution generated by transport, the European Strategy for Low-
    Emission Mobility adopted in 2016 framed the initiatives planned by the Commission in
    the coming years and mapped the areas in which options were explored: i) increasing the
    efficiency of the transport system; ii) scaling up the use of low-emission alternative energy
    sources; iii) moving towards zero-emission vehicles. It also showed how initiatives in
    related fields are linked and how synergies can be achieved3
    .
    To support the transition towards zero-emission vehicles, the Low-Emission Mobility
    Strategy acknowledged that incentives on both the supply- and demand-side are needed.
    On the supply-side, it foresees the revision of the CO2 emission Regulations for new cars
    and vans and a proposal on a monitoring and reporting system for CO2 emissions from
    heavy duty vehicles with a view of setting fuel efficiency standards. The revision of public
    procurement rules (revision of the Clean Vehicle Directive) and incentives via road
    charges to support the uptake and use of vehicles adhering to cleaner standards4
    would
    provide complementary contributions on the demand side. Thus, the Strategy indicated that
    “the Commission will revise the Directive on the charging for lorries to enable charging
    also on the basis of carbon dioxide differentiation, and extend some of its principles to
    buses and coaches as well as passenger cars and vans”.
    2
    COM(2011) 144 final: Roadmap to a Single European Transport Area – Towards a competitive and
    resource efficient transport system
    3
    COM(2016) 501 final: A European Strategy for Low-Emission Mobility
    4
    The availability of VECTO and the monitoring and certification at EU level are enabling factors to allow
    for CO2 differentiation in charging.
    2
    The Strategy further showed that fair and efficient pricing in road transport and other
    related initiatives, notably on the revision of the legislation on interoperable electronic
    tolling services and of the rules governing the internal market for road haulage and bus and
    coach services (see Annex 15), would contribute to the EU's approach to low-emission
    mobility by increasing the efficiency of the transport system.
    Following the Action Plan5
    rolled out in the Low-Emission Mobility Strategy, the initiative
    is part of a larger package of proposals to be adopted by the Commission in 2017. It is a
    REFIT6
    initiative linked to the Commission's effort to create an Energy Union through the
    moderation of energy demand, by making road transport more efficient. It is also relevant
    for the internal market through its aim of 'getting prices right', a prominent objective of the
    2011 White Paper on transport, and thus levelling the playing field when it comes to
    payment for the use of road infrastructure by transport operators.
    1.2. Legal context
    Directive 1999/62/EC7
    (the "Eurovignette" Directive) provides a detailed legal framework
    for charging heavy goods vehicles (HGVs) for the use of certain roads. The Directive aims
    to eliminate distortions of competition between transport undertakings by achieving step-
    by-step harmonisation of vehicle taxes and establishment of fair mechanisms for
    infrastructure charging. Thus the Directive has a double legal base, notably Article 71(1)
    and Article 93 of the Treaty establishing the European Community (Article 91(1) and
    Article 113 TFEU). It sets minimum levels of vehicle taxes for HGVs and provides for the
    way infrastructure charges should be set, including differentiation according to
    environmental performance (i.e. pollutant emissions reflected in Euro emission classes).
    Taking account of CO2 emissions is currently not possible. The scope of the network to
    which the Directive applies is the TEN-T plus motorways.
    The Directive does not oblige Member States to introduce user charges for HGVs, but
    specifies that if infrastructure charges are applied, they should be related to the cost of
    constructing, operating and developing infrastructure. Since 2006 (Directive 2006/38/EC),
    differentiation of infrastructure charges according to Euro class has been mandatory8
    with
    the possibility of greater variation of tolls and the inclusion of vehicles with a permissible
    laden weight above 3.5 tonnes9
    .
    The last amendment of the Directive (Directive 2011/76/EU) introduced the possibility for
    Member States to apply external cost charges related to traffic-based air pollution and
    noise. With the aim to attenuate congestion, it also adjusted the possibility to differentiate
    tolls according to time or type of the day or season.
    The Communication on the application of national road infrastructure charges levied on
    light private vehicles10
    clarified how the Treaty provisions on non-discrimination and the
    5
    COM(2016) 501 final, Annex 1: Action plan for low-emission mobility.
    6
    Regulatory Fitness and Performance Programme
    7
    Directive 1999/62/EC of the European Parliament and of the Council of 17 June 1999 on the charging of
    heavy goods vehicles for the use of certain infrastructures, OJ L 187, 20.7.1999, p. 42–50.
    8
    This only applies to distance-based schemes with the possibility to exempt long-term concession
    contracts.
    9
    With a possibility for exempting vehicles between 3.5 and 12 tonnes.
    10
    COM(2012)199 final
    3
    principle of proportionality apply to car vignettes, but provided only recommendations.
    And as already stated, there is no legal framework for passenger cars, vans or for buses.
    1.3. Evaluation of the implementation
    The Commission published its evaluation of Directive 1999/62/EC in 201311
    . An
    'Evaluation of the implementation and effects of EU infrastructure charging policy since
    1995' was published in January 201412
    . The evaluation identified various problems linked
    to road charging of heavy goods vehicles under the current legislative framework. While
    24 Member States have implemented some form of road charging and there has been a
    tendency to move towards network-wide distance-based tolling at least in Central Europe,
    there are persistent inconsistencies in the implementation of the current legislation.
    The evaluation found a wide variety of ways to vary charges according to Euro class,
    whereas a third of the Member States do not apply such variation at all13
    . This creates
    inconsistent price signals to users. Revenues from time-based charges (vignettes) are very
    low and do not meet the financial needs of infrastructure investment. Very few Member
    States have introduced time-varying charges to deal with congestion. These issues are
    linked to the provisions of the Directive:
    • Time-based charges allowed by the Directive are ineffective in covering
    infrastructure costs, incentivising cleaner, more efficient operations or reducing
    congestion;
    • The application of external cost charging is too complex, while Euro class variation
    is mandatory (with exemptions) and not well defined.
    • Variation of charges to fight congestion: the revenue-neutrality requirement is too
    cumbersome and the variation could be seen as unfair if only applied to HGVs
    while all users contribute to congestion.
    A natural limitation of the evaluation was that it could only focus on the current scope of
    the Directive, while the input from stakeholders has pointed at other relevant issues. There
    is broad consensus on the need to reduce CO2 emissions from road transport. While
    emission standards are the most effective measure in this respect, they only address new
    vehicles and their impact over time will depend on the speed of the renewal of the fleet.
    Measures such as the modulation of road charges according to CO2 emissions can make a
    useful complementary contribution by directly incentivising the renewal of the fleet; they
    can provide direct price incentives to road users at every single trip and apply to the entire
    fleet (i.e. new and old vehicles). In addition, as evidenced by the public consultation, road
    users would like road pricing to be non-discriminatory also in the case of passenger cars,
    which are outside the scope of the current legislation.
    2. WHAT IS THE PROBLEM AND WHY IS IT A PROBLEM?
    An efficient and reliable transport system is essential for the smooth functioning of the
    internal market and is a key sector of the economy. While road transport plays the most
    11
    Ex-post evaluation of Directive 1999/62/EC, as amended, on the charging of heavy goods vehicles for the
    use of certain infrastructures, SWD(2013) 1 final
    12
    http://ec.europa.eu/smart-regulation/evaluation/search/download.do?documentId=10296156
    13
    Cf. Annex 10
    4
    important role in the inland transport system, it is a source of a number of socio-economic
    and environmental challenges (e.g. climate change, air pollution, noise, congestion). Road
    pricing can play a key role in incentivising cleaner, more efficient operations, and its
    coherent design is crucial to ensuring a level playing field among hauliers.
    Figure 2-1 gives an overview of the problems and their drivers that have been identified on
    the basis of the ex-post evaluation, the impact assessment support study14
    and the feedback
    from stakeholders.
    The problems and drivers, which will be explained in detail in chapter 2, are partly related
    to the vehicles currently in scope of the legislation, i.e. HGVs above 3.5 tonnes, which are
    part of P1, P2 and P4. Other vehicles, currently outside the scope of the current legislation
    (e.g. cars and vans), are specifically included in P3 but are also part of P1, P2 and P4.
    Figure 2-1: Problem tree
    14
    Ricardo et al. (2017), Support Study for the Impact Assessment Accompanying the Revision of Directive
    1999/62/EC. Note that evidence gathered by that study is referred to in academic format (endnotes) in this
    report.
    5
    2.1. What is the nature of the problem? What is the size of the problem?
    2.1.1. P1: Insufficient contribution of road transport to overall CO2 emission
    reduction
    The Energy Union and the Energy and Climate Policy Framework for 2030 establish
    ambitious EU commitments to further reduce greenhouse gas emissions (by at least 40%
    by 2030 compared to 1990). Transport will need to contribute towards the 40% greenhouse
    gas emissions reduction target for 2030 and in particular to the 30% emissions reduction
    effort set for the non-Emission Trading Scheme sectors15
    . In this context, the analytical
    work underpinning the European Strategy for Low-Emission Mobility showed cost-
    effective emissions reductions of 18-19% for transport by 2030 relative to 200516
    . For road
    transport, this translates into a cut of about 206-221 million tonnes of CO2 by 2030 relative
    to 200517
    .
    Transport was responsible for 23%18
    of EU greenhouse gas emissions in 2014 and road
    transport accounted for 73% of these. Figure 2-2 shows that CO2 emissions from road
    transport in 2014 were still 17% higher than in 1990, despite the decrease observed
    between 2007 and 2013.
    Approximately 25% of CO2 emissions from road transport in the EU are caused by HGVs
    and buses (EEA, 2016). Improvements in energy efficiency for HGVs together with a
    decrease in road freight transport activity have led to a decrease of around 12% in CO2
    emissions between 2007 and 2012. However, the reductions have stalled since then and
    emissions levels in 2014 for HGVs and buses were still 13% higher relative to 1990. CO2
    emissions from light duty trucks have grown even faster than those of HGVs. Despite
    some reductions in recent years, in 2014 emissions from light duty trucks were still 56%
    above their 1990 levels and contributed about 12% of road transport CO2 emissions. The
    highest share of road transport CO2 emissions originates from passenger cars i.e. over 60%
    (EEA, 2016). Despite improvements in energy efficiency, driven by the CO2 standards in
    place, CO2 emissions from passenger cars in 2014 were still 13% higher than their 1990
    levels.
    15
    i.e. transport, buildings, agriculture, small industry and waste
    16
    This outcome is in line with the 2011 White Paper which established a milestone of 20% emissions
    reduction by 2030 relative to 2008 levels, equivalent to 19% emissions reduction compared to 2005
    levels, and with the 2050 decarbonisation objectives.
    17
    SWD(2016) 244 final
    18
    This share does not cover the emissions from international shipping, which are not part of the 2020 and
    2030 climate and energy targets.
    6
    Figure 2-2: CO2 emissions from road transport (1990-2014)
    0
    100
    200
    300
    400
    500
    600
    700
    800
    900
    1,000
    1990
    1991
    1992
    1993
    1994
    1995
    1996
    1997
    1998
    1999
    2000
    2001
    2002
    2003
    2004
    2005
    2006
    2007
    2008
    2009
    2010
    2011
    2012
    2013
    2014
    CO2
    emissions
    (Mt)
    Cars Light duty trucks
    Heavy duty trucks and buses Road transportation - Total
    Source: EEA (GHG data viewer), 2016
    Under current trends and adopted policies, road freight activity (measured in tonne-km) is
    projected to increase by about 35% between 2010 and 2030 (56% for 2010-2050). CO2
    emissions from road freight transport would increase by 6% by 2030 compared to 2010
    (11% for 2010-2050)19
    . At the same time, emissions from passenger cars and vans are
    projected to decrease by 22% between 2010 and 2030 (32% for 2010-2050) thanks to the
    CO2 standards in place and the uptake of electro-mobility.
    Overall, the declining trend in total transport emissions is expected to continue under
    current trends and adopted policies, leading to 13% lower emissions by 2030 compared to
    2005 (15% by 2050). This is however not in line with the cost-effective emissions
    reduction of 18-19% that the transport sector would need to contribute towards achieving
    the 2030 climate and energy targets.
    The problem is widely recognised not only by the scientific community and environmental
    organisations, but also by Member States as well as the automotive industry20
    .
    2.1.2. P2: Degrading quality of road infrastructure
    While road maintenance is primarily a national or local competence, high quality
    infrastructure is essential for the efficient and sustainable functioning of the internal market
    as well as for road safety.
    The impact assessment support study21
    found that it is difficult to compare the quality of
    road infrastructure between Member States due to a lack of consistency in monitoring and
    reporting practices. However, available national reports indicate that there are concerns
    19
    See Annex 4 for a description of developments under current trends and adopted policies (Baseline
    scenario).
    20
    http://www.acea.be/industry-topics/tag/category/co2-emissions
    21
    Ricardo et al. (2017), Support Study for the Impact Assessment Accompanying the Revision of Directive
    1999/62/EC
    7
    over poor road quality in 13 out of 22 Member States for which national reports were
    available (59%).22
    Reports of poor road quality (even if not strongly correlated) tend to be
    associated with Member States where there is no charging, or where vignette systems are
    in place (e.g. Bulgaria, Belgium – which only introduced distance-based charging in 2016
    –, the Baltic countries, Romania and non-toll roads in Spain).
    It seems that the state of the existing road infrastructure is degrading in many Member
    States because of inadequate maintenance of the road network (section 2.2.2). Public
    spending on road infrastructure maintenance has decreased in the EU by about 30% (or
    40% in relation to GDP) between 2006 and 201323
    and stood at around 0.5% of GDP in
    201324
    . This leads to various negative economic, social and environmental impacts
    including:
    • Increased vehicle operating costs and emissions. The World Bank estimated that
    necessary maintenance work, when it is not performed, generates costs to road users
    which are the double or triple of the cost of the road works, had they been done.25
    A
    study commissioned by the European Parliament26
    refers to estimates at national level
    showing higher vehicle operation costs and emissions.27
    • Increased journey times. As the condition of carriageways deteriorates, vehicles
    travel more slowly and journey times increase. In Germany, severe deterioration of the
    bridge on the A1 motorway over the Rhine forced the authorities to temporarily close it
    for HGV traffic. It is estimated that this costs each haulage company active in the
    region on average EUR 17,000 per day in delays and detours.28
    • Accidents. Poor condition of the road surface (low friction, deteriorated evenness)
    increases the risk of accidents (e.g. because road users take evasive action to avoid
    potholes or other hazards).29
    For example, an investigation of over 600 truck accidents
    in seven European countries (France, Germany, Hungary, Italy, the Netherlands,
    Slovenia and Spain) found that accidents linked to infrastructure conditions represented
    22
    However, the information is not strictly comparable between Member States due to the different
    methodologies and reporting techniques employed.
    23
    Data extracted on 22 Jan 2017 from OECD.Stat,
    https://stats.oecd.org/Index.aspx?DataSetCode=ITF_INV-MTN_DATA#
    24
    http://www.cedelft.eu/publicatie/road_taxation_and_spending_in_the_eu/1899
    25
    World Bank, A review of institutional arrangements for road asset management, 2010.
    26
    European Parliament. (2014). EU Road Surfaces: Economic and Safety Impact of the Lack of Regular
    Road Maintenance.
    http://www.europarl.europa.eu/thinktank/en/document.html?reference=IPOL_STU(2014)529059
    27
    In Spain, additional vehicle operating costs due to “moderately deficient road surfaces” have been
    estimated for light duty vehicles (34% increase in fuel consumption, 185% higher maintenance costs and
    66% reduction in tyre lifetimes) and for heavy duty vehicles (12% increase in fuel consumption, 129%
    higher maintenance costs and 10% reduction in tyre lifetimes). In Lithuania, a national study indicated
    that: reconstruction of each kilometre of rural roads 300 thousands litres of fuel saved and 700 tCO2
    avoided. In Poland, the additional operating cost per km has been estimated for vehicles travelling at 60
    km/h as €0.004/km for passenger cars and €0.02km for heavy goods vehicles without trailers. A survey of
    SMEs in the UK found negative impacts in terms of time wasted, higher vehicle operating costs and fuel
    consumption, estimated at £13,600 per year (equivalent to €16,300).
    28
    Rheinische Post Online, IHK fordert Masterplan für die Sanierung der A1-Rheinbrücke, 28.01.2013.
    29
    https://ec.europa.eu/transport/road_safety/specialist/knowledge/road/managing_safety_of_roads_through_t
    heir_whole_life/road_and_pavement_maintenance_en
    8
    5.1% of total accidents. Over 10% of these accidents happened on highways (ETAC,
    2007).
    • Noise. Aged (rougher) surfaces generate more traffic noise.30
    After an initial settling-in
    period, road surfaces generally generate more road traffic noise as they age. Asphalt
    pavement noise increases about 3 dBA (this is a doubling of sound power) after six to
    seven years of usage and in later years of usage it can increase up to 4 dBA (European
    Parliament, 2014).
    • Wider economy. The economic effects can be estimated in terms of e.g. impacts on
    journey times, productivity, external costs and asset value of roads. For example,
    ADAC (2011) claims that the worsening condition of roads in Germany causes
    macroeconomic impacts of 4% of German GDP, in the form of increased accidents,
    vehicle wear and tear and delays due to hampered traffic flow. Other calculations for
    Lithuania indicate net benefits of €2.20 to €2.80 for every Euro invested in road
    rehabilitation, maintenance and reconstruction (European Parliament, 2014).
    These negative impacts have largely been confirmed by the perceptions of the respondents
    to the public consultation, a summary of which can be found in Annex 2, and in particular
    by professional organisations and associations that seemed to attach particular importance
    to the quality of roads (e.g. UEAPME).
    2.1.3. P3: Discrimination of occasional / non-resident road users and unfair
    distribution of costs via road charging
    Because the current legislation only covers heavy duty vehicles (HDV), all other vehicles –
    passenger cars, vans and buses – are left unaddressed without even the most basic
    provisions related to non-discrimination against foreign users, despite the significant
    amount of traffic by these vehicles.
    Distance-based road charging is by definition proportional to the use, reflecting much
    better the external costs, and therefore inherently non-discriminatory; time-based vignettes
    (and/or vehicle taxes) are less proportional. Given that annual vignettes and circulation
    taxes are very similar instruments by nature, there is a risk of discrimination of foreign
    users when Member States compensate national users while introducing vignettes.
    Moreover, unless prices of time-based vignettes are proportional, foreign/occasional users
    (typically buying short-term vignettes) may end up paying relatively more than national
    users (typically buying annual vignette). One example of such vignette schemes is the
    Slovenian one. Although it was made more proportionate following infringement
    proceedings, it is still considered by users to be disproportionately costly at €15 (the price
    of a weekly vignette) for a single trip (ITC, 2013).
    A good indication of how relative vignette prices are perceived by the users is the share of
    annual vignettes in sales as shown in Table 2-3. In those countries where the price of the
    yearly vignette is relatively low compared to that of short-term vignettes (or where
    subsidies are in place for commuters, as in Austria) the take-up of annual vignettes is
    significantly higher.
    30
    Ricardo-AEA, Accompanying study to a previous impact assessment performed in 2013.
    9
    Table 2-3: Uptake of annual passes for passenger cars and estimated proportion of
    foreign car journeys for selected vignette countries
    Country
    Take-up of annual pass by
    car owners
    Estimated proportion of foreign car
    journeys on main routes
    Austria 70% 26%
    Czech Republic 45% 33%
    Hungary 7% 19%
    Slovenia 87% 39%
    Slovakia 49% 27%
    Source: (ITC, 2013)
    Discrimination was also raised as one of the main arguments against Germany's plan to
    introduce a vignette system for passenger cars. On grounds of potential discrimination
    against drivers from other Member States, the Commission launched an infringement
    procedure in 2015.31
    Following adjustments to the initial plans, a political understanding
    was reached between the Commission and Germany on 1 December 2016. The case was
    formally closed on 17 May following the adoption by German of an amended law taking
    into account the Commission's legal concerns32
    . At the same time a number of other
    Member States are joining forces to argue against the introduction of the system, which,
    according to them, remains discriminatory, despite the amendments to the German laws.
    The second part of the problem is related to the fact that buses, coaches, cars and vans,
    which are out of the scope of the Directive, do not provide sufficient contributions via road
    charges, even though these vehicles account for a significant share of transport activity and
    are responsible for a large part of the impact on wear and tear of infrastructure (and other
    external costs). As a consequence, the division of sharing the burden of external costs
    among the road users is not fair and not proportionate to the actual use of infrastructure.
    This situation is not only financially unsustainable, but also not fair to HGV users.
    The fragmented coverage of various categories of vehicles with road charging also makes
    some of the measures addressing other transport externalities ineffective: e.g. congestion
    charging is only justifiable if it covers all vehicles. In addition, it also raises some concerns
    about fair competition between transport modes and means. Exclusion of buses and
    coaches from paying for the use of infrastructure is considered as an advantage over rail
    passenger transport which has to pay for the use of infrastructure. Similarly, favourable
    treatment of vans leads to increasing use of them over trucks.
    31
    On 8 June 2015 a law was passed to introduce a road charging scheme for cars. In parallel a law was
    introduced ensuring that vehicles registered in Germany benefit from a deduction of the road charge from
    their annual vehicle tax bill. This 1:1 deduction of the vehicle tax from the road charge would lead to a de
    facto exemption from the charge, exclusively for cars registered in Germany. The Commission believed
    that this arrangement would discriminate against drivers from other Member States for two reasons. First,
    because German users would not effectively pay the road charge, as their vehicle tax bill would be
    reduced by the exact amount of the road charge. And second, because the price of short-term toll passes,
    which are typically bought by foreign drivers, would be disproportionally high for certain vehicles.
    Despite numerous exchanges with the German authorities since November 2014 to discuss how to render
    the German scheme compatible with EU law, the Commission's fundamental concerns remained
    unaddressed. Therefore, it launched an infringement procedure against Germany in June 2015 and the
    case was referred to the Court of Justice of the EU on 29 September 2016. http://europa.eu/rapid/press-
    release_IP-16-4221_en.htm
    32
    http://europa.eu/rapid/press-release_MEMO-17-1280_en.htm
    10
    2.1.4. P4: High levels of air pollution, noise and congestion
    External costs from road transport are a major issue. Passenger cars are at the source of
    about 2/3 of all external costs (including costs of climate change, air pollution, noise,
    accidents and other negative impacts) generated by road transport, or about 1.8-2.4% of
    GDP33
    .
    According to more recent estimates, the specific issue of air pollution from road transport
    costs up to 2% of GDP to society34
    , representing half of the aggregate cost of air pollution.
    This appears to be supported by the findings from on-road tests carried out on heavy-duty
    and light-duty vehicles, suggesting that NOX emissions from diesel cars are higher on
    average than those from heavy duty vehicles.35
    . The impact of this is felt especially in
    major urban areas across Europe36
    , but it cannot be neglected on inter-urban routes.
    According to the EEA, the total number of premature death attributable to air pollution in
    the EU was around 500.000 in 201337
    , with emissions from road transport being a main
    contributor. In addition, more than 100 million EU citizens are exposed to noise levels
    dangerous for their health, and this is mainly due to road transport38
    .
    With growing demand for transport, also congestion is an increasingly significant issue,
    which has only been sporadically addressed by Member States. Road traffic is typically
    concentrated in specific hours and/or periods of the year. These traffic peaks result in
    considerable economic, social and environmental costs, which according to various
    scientific estimations amount to 1-2% of EU GDP39
    i.e. EUR 146-293 billion per year, 2/3
    of which is attributable to passenger cars. According to (Fermi & Fiorello, 2016), only the
    cost of delays from congestion accounted for 140 billion €/year or 1% of GDP in 2015,
    with 20-30% of this attributed to interurban traffic. However, congestion not only results in
    delays40
    but also in a waste of fuel – thus worsening the EU's already high oil dependence
    – and additional CO2 and air pollutant emissions. Ultimately, it leads to loss of
    competitiveness.
    33
    CE Delft, Infras, Fraunhofer ISI - External Costs of Transport in Europe, Update Study for 2008, Delft,
    CE Delft, November 2011: http://www.cedelft.eu/publicatie/external_costs_of_transport_in_europe/1258
    34
    OECD (2014), The Cost of Air Pollution: Health Impacts of Road Transport, OECD Publishing.
    http://www.oecd.org/env/the-cost-of-air-pollution-9789264210448-en.htm.
    35
    http://www.theicct.org/nox-europe-hdv-ldv-comparison-jan2017
    36
    See e.g. http://www.irceline.be/en/air-quality/measurements/nitrogen-dioxide/history for Belgium
    37
    http://www.eea.europa.eu/highlights/stronger-measures-needed/table-10-1-premature-deaths
    38
    COM/2017/0151 final, Report from the Commission to the European Parliament and the Council on the
    implementation of the Environmental Noise Directive in accordance with Article 11 of Directive
    2002/49/EC
    39
    Numerous sources, including: CE Delft, INFRAS, Frauenhofer ISI, External Costs of Transport in
    Europe, Delft, November 2011. Christidis, Ibanez Rivas, Measuring road congestion, JRC Technical
    Notes, 2012; Fermi, F., & Fiorello, D. (2016). Study on Urban Mobility – Assessing and improving the
    accessibility of urban areas - Task 2 Report – Estimation of European Urban Road Congestion Costs.
    40
    Victoria Transport Policy Institute, Transportation Cost and Benefit Analysis II – Congestion Costs:
    http://www.vtpi.org/tca/tca0505.pdf
    11
    2.2. What are the main drivers?
    2.2.1. D1. Insufficient uptake of vehicles with low CO2 emission
    CO2 emissions from road transport can be expressed as a function of (1) transport activity41
    and (2) specific CO2 emissions42
    . Correct price signals can drive transport operators
    towards more efficient use of the fleet through improving loading factors, fewer empty
    runs and the use of low- and zero-emission vehicles. Similarly, for passenger cars the right
    price signals can lead to the use of more efficient vehicles. With a view to accelerating the
    technological shift needed to achieve an ambitious long-term reduction in road transport
    emissions, zero- and low-emission vehicles would need to gain significant market share by
    2030. Incentives on both the supply- and demand-side will be needed to support the
    transition towards low- and zero-emission vehicles, as advocated by the European Strategy
    for Low-Emission Mobility adopted in 2016.
    CO2 standards are in place for light commercial vehicles since 2011 and for passenger cars
    since 2009 and have proven to be effective in reducing specific CO2 emissions43
    . However,
    CO2 emissions from trucks will only be monitored44
    and certified as of the end of the
    present decade with mandatory limits being considered as a possible future measure. In
    addition, CO2 standards only address new vehicles and their impact over time depends on
    the speed of the renewal of the fleet.
    Other existing environmental charges and taxes either target the purchase of new (i.e.
    registrations taxes) or the ownership of vehicles (i.e. annual circulation taxes) and can
    influence consumer choice when buying a new or used vehicle, but are not linked to the
    actual use of the vehicle and do not provide sufficient incentives for the renewal of the
    vehicle fleet. While the external costs of CO2 emissions are best internalised through fuel
    taxation, existing fuel taxes do not necessarily reflect the carbon content of different fuels.
    The cost of fuel is taken into account by hauliers45
    but does not provide direct incentives
    for the renewal of the car fleet as once the driver has filled the tank it becomes a sunk cost.
    As shown in Figure 2-4 (below, to the left), while the average specific CO2 emissions of
    HDV operations have improved over the last two decades, this has not been sufficient to
    offset the increase in demand for road freight transport resulting in higher total emissions
    from HDVs by 2014 relative to 199546
    . While the automotive industry emphasises the
    significant progress made in fuel efficiency of HGVs over the last few decades, it
    acknowledges that there is substantial potential for further reducing the CO2 emissions (in
    the range of 27 to 62% by 2030 and 2050 respectively) from HGVs thanks to technological
    innovations, such as in diesel engine technology, the use of alternative fuels, improvements
    41
    Expressed in tonne-kilometres for road freight transport and in passenger-kilometres for passenger cars.
    42
    Defined in terms of gCO2/tonne-kilometre for road freight and in terms of gCO2/passenger-kilometre for
    passenger cars.
    43
    Evaluation of Regulations 443/2009 and 510/2011 on CO2 emissions from light-duty vehicles (report by
    Ricardo-AEA for the European Commission,
    https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/evaluation_ldv_co2_regs_en.pdf)
    44
    http://ec.europa.eu/smart-regulation/roadmaps/docs/2015_clima_018_iaa_heavy_duty_vehicles_en.pdf
    45
    Fuel costs represent around a third of the costs of operation and their minimization is among the
    objectives of the HGV fleet operators.
    46
    Data on the split of CO2 emissions from HDVs between HGVs and buses is not available with EEA.
    12
    in the transmission and drive-train systems, hybrid drive technologies or the reduction of
    rolling- and air resistance47
    .
    Similarly, for passenger cars Figure 2-4 (below, to the right) shows that total emissions by
    2014 were higher relative to 1995, despite significant progress brought about the CO2
    standards (see Figure 2-4 right).
    Figure 2-4: Road transport indicators, 1995 to 2014 (1995=100) – road freight
    transport (left), passengers cars (right)
    60.0
    70.0
    80.0
    90.0
    100.0
    110.0
    120.0
    130.0
    140.0
    150.0
    160.0
    1995
    1996
    1997
    1998
    1999
    2000
    2001
    2002
    2003
    2004
    2005
    2006
    2007
    2008
    2009
    2010
    2011
    2012
    2013
    2014
    1995=100
    CO2 emissions - HDVs Road freight transport activity Specific CO2 emissions
    60.0
    70.0
    80.0
    90.0
    100.0
    110.0
    120.0
    130.0
    1995
    1996
    1997
    1998
    1999
    2000
    2001
    2002
    2003
    2004
    2005
    2006
    2007
    2008
    2009
    2010
    2011
    2012
    2013
    2014
    1995=100
    CO2 emissions - cars Passenger cars activity Specific CO2 emissions
    Notes: Absolute values for CO2 emissions in kilotonnes; road freight transport activity in tonne-km and passenger cars
    transport activity in passenger-km; specific CO2 emissions for road freight in grams/tonne-km and specific CO2 emissions
    for passenger cars in grams/passenger-km; Source: EEA emission data and Eurostat
    Differentiation of road charges according to CO2 emissions could provide a direct price
    signal to hauliers as well as private motorists at every single trip, while applying to the
    entire fleet (i.e. new and old vehicles), and thus accelerate the renewal of the fleet and the
    uptake of low- and zero-emission vehicles. In this respect, differentiated (distance-based)
    road charges can complement the registration tax by reflecting the actual use in a
    proportionate manner (unlike an annual vehicle tax).
    At the same time, the Eurovignette Directive encourages “the use of road-friendly and less
    polluting vehicles […] through differentiation of taxes or charges”48
    ; however, such
    differentiation is only allowed either according to the Euro emission class49
    or time, but not
    according to the CO2 emissions of vehicles.
    47
    See e.g. VDA, Association of German Automotive Industry, Driven by ideas - Commercial Vehicles
    2016: https://www.vda.de/en/services/Publications/driven-by-ideas---commercial-vehicles-2016.html or
    IRU Commercial Vehicle of the Future: A roadmap towards fully sustainable truck operations – still to be
    published
    48
    Recital 7of Directive 1999/62/EC
    49
    Which has helped reduce pollutant emissions from HGVs in a few Member States but is applied
    inconsistently across the EU because of exceptions and is becoming obsolete by 2020, as described in
    Annex 11 (section 11.1)
    13
    2.2.2. D2. Insufficient investment in road maintenance
    As already mentioned in section 2.1.2, public spending on road infrastructure maintenance
    has decreased in the EU by about 30% (or 40% in relation to GDP) between 2006 and
    201350
    and stood at around 0.5% of GDP in 201351
    . For comparison, the motorway
    network expanded by 25% only in the last decades52
    and infrastructure costs represent
    around 1.3% of GDP. At the same time, revenues from infrastructure charges represent less
    than €30 billion or just 16% of total road infrastructure costs, i.e. costs of construction and
    wear and tear. The insufficient funding of the maintenance of infrastructure can be partly
    attributed to the fact that Member States do not fully use the potential of distance-based
    road charges for financing road maintenance (cf. section 2.2.3).
    In Member States where the roads are recognised as poor, there can be little doubt that
    there is a need for increased road maintenance. These investment needs are captured in the
    concept of a “maintenance backlog”, which aims to quantify the amount of maintenance
    and rehabilitation that should have been completed in order to maintain roads in a good
    condition but has been deferred.53
    Examples of maintenance backlogs of several billions of
    euros are reported in several Member States (with an additional annual investment
    requirement of at least €6.5 billion in Germany, €260 million in Ireland, and €600-700
    million in the Netherlands and the UK) – all of which currently have reports of overall
    good road quality. These are described in Annex 8 (section 8.1).
    At times of budget cuts, deferring maintenance and investment in the road sector is a
    relatively quick way to reduce public spending and this has been pursued by a number of
    EU countries. For example, case studies on Italy, Spain and the UK revealed significant
    falls in maintenance expenditure that were reportedly due to budgetary pressures and the
    need to reduce government spending overall54
    (European Parliament, 2014). Such
    reductions will lead to increased maintenance needs in the future, since deferring required
    maintenance is not usually cost-effective in the long run. Figure 8-1 (Annex 8) shows road
    deterioration over time and the effect of maintenance in restoring road conditions and
    prolonging asset lifetimes.
    While reduced maintenance funding brings short term savings for the infrastructure owner,
    in the longer term it results in overall losses for society. A study for Scotland showed that
    reducing road maintenance funding by 40% over 10 years would entail an overall social
    loss of €370 million despite apparent savings on maintenance works.55
    50
    Data extracted on 22 Jan 2017 from OECD.Stat,
    https://stats.oecd.org/Index.aspx?DataSetCode=ITF_INV-MTN_DATA#
    51
    http://www.cedelft.eu/publicatie/road_taxation_and_spending_in_the_eu/1899
    52
    European Commission, Statistical Pocketbook 2016: https://ec.europa.eu/transport/facts-
    fundings/statistics/pocketbook-2016_en
    53
    Ricardo et al. (2017), Support Study for the Impact Assessment Accompanying the Revision of Directive
    1999/62/EC
    54
    The Italian operator of national roads, ANAS, reported a reduction in the expenditure on road
    maintenance both in routine and structural budgets, respectively of 16% and 43% in the 2008 to 2012
    period. In the UK, funding reduced by 30% between 2011 and 2015 for the Highways Agency. In Spain,
    national government allocation for maintenance and operational expenditures reduced from €1,257m in
    2009 to €926m in 2012.
    55
    Transport Scotland, Economic, Environmental and Social Impacts of Changes in Maintenance Spend on
    the Scottish Trunk Road Network, 2012.
    14
    2.2.2.1. The role of the current legislation
    Since Member States generally oppose obligations to "earmark" revenues from road
    charging, even though this opposition is not uniform56
    , the Eurovignette Directive, merely
    encourages the reinvestment of toll revenues in the transport sector (Article 9). This
    encouragement has not been followed by Member States in a systematic and
    comprehensive manner.
    In addition, current reporting requirements of the Directive do not ensure adequate follow-
    up of the use of revenues. According to Article 11, only Member States levying tolls have
    to report on toll rates and revenues raised from infrastructure and external cost charging,
    while making it possible to exclude systems that have not been changed since 2008. The
    reports are only due every 4 years.
    2.2.3. D3. Insufficient uptake and sub-optimal application of road charging
    While revenues from generalised distance-based charging could cover in a sustainable
    manner all maintenance needs of the road network, only 14 Member States apply distance-
    based charges to HGVs57
    , and only eight to passenger cars. Furthermore, where in place
    they are typically not applied to the full network, and only apply to a subset of vehicle
    types. Overall, just over half of the Member States apply some sort of charging for all
    vehicle types.
    As shown in Table 9-1 in Annex 9, only a small share of the road network and only certain
    vehicle categories are subject to road charges. Nb. the table refers to motorways only,
    while in many countries other roads are not tolled at all.
    Without clear European rules, Member States apply different charging schemes to
    buses/coaches, passenger cars and vans without fully respecting the "user pays" principle
    (see maps in Annex 5). While, due to their similar weights and axle loads, buses and
    coaches cause similar damage to the infrastructure as HGVs, only 16 out of the 24 Member
    States having road charging in place apply similar charges to them. In the case of
    passenger cars, only 8 Member States apply distance-based charges, in most cases only on
    a limited part of the network.
    There are a number of obstacles to increasing Member States uptake of (distance-based)
    road charging:
    (1) Existing vehicle taxation, which is already considered by users as a payment for the
    use of infrastructure.
    (2) Excessive notification requirements, especially in the case of external cost
    charging.
    (3) Initial investment costs, which have decreased over time but are still significant.
    56
    Cf. responses to the stakeholder consultation indicate that those Member States, which already allocate
    road charging revenues to infrastructure maintenance acknowledge the benefits of systematic earmarking
    (Annex 2, section 2.3.1).
    57
    See the map of road charging systems in the EU for an overview in Annex 5; even there, the recovery rate
    of the cost of maintenance is not uniform, see e.g. Annex 10.
    15
    Points (2) and (3) are also reasons why some Member States prefer vignette systems.
    Another reasoning that tends to come up (e.g. in the case of Estonian plans) is that the
    management of a time-based system is simple (as a vehicle tax) but also applies to foreign
    users.
    2.2.3.1. The role of the current legislation
    The Eurovignette Directives leaves large room for interpretation of road charging
    methods. It is up to the Member States to decide whether or not they want to implement
    road charging, on which part of their road network, and to what extent they want to recover
    the costs of infrastructure. Besides, the Directive allows the exemption from road charges
    of vehicles between 3.5 and 12 tonnes, which is practiced by the four Eurovignette
    countries58
    as well as the UK, while Germany applies tolls only to vehicles above 7.5
    tonnes. These exemptions are also reflected in Table 10-1 in Annex 10. At the same time,
    the Directive sets minimum amounts for annual circulation taxes for HGVs above 12
    tonnes. Member States would legitimately want to compensate their hauliers by decreasing
    the burden through the reduction of the vehicle tax if a more appropriate means to pay for
    the use of infrastructure and external costs – distance-based charging – is introduced. Due
    to the fact that only HGVs are included in the scope of the current legislation, the
    application of charges to buses, coaches, vans and passenger cars is left to Members States'
    discretion. The outcome is that road charging in most Member States is primarily focused
    on HGVs and does not reflect the 'user pays' and 'polluter pays' principles for all road
    users.
    Besides, the Directive requires distance-based systems to be notified to the Commission,
    which is seen as cumbersome by some Member States; while capping the prices of
    vignettes at a low level. This results in a number of Member States applying or considering
    introducing time-based charging systems59
    , which have significantly lower revenue raising
    potential60
    than distance-based systems (the difference can be as large as 1:20, see e.g.
    Table 10-1 in Annex 10), leading to less funding available for the maintenance of road
    infrastructure.
    2.2.4. D4. No rules on price proportionality of vignettes for passenger cars
    and vans
    While there are clear rules on vignette prices for HGVs, they do not exist for passenger
    cars and vans. As a consequence, the ratio between the average daily price of short-term
    (weekly or 10-days) vignettes and yearly vignettes varies between 2.5 (in Hungary) and 8.3
    (Bulgaria)61
    as indicated in Table 2-5. This is considered disproportionate and
    discriminatory to foreigners by many stakeholders, with a large majority of
    58
    Denmark, Luxemburg, The Netherlands and Sweden
    59
    Currently 8 Member States apply vignettes for HGVs and Estonia has decided to do so too, cf. maps in
    Annex 5
    60
    This is confirmed by the public consultation with some Member States advocating for increasing the caps
    on time-based charging to be able to cover costs, as well as by the figures presented in Table 9-2 in
    Annex 9
    61
    The average daily price is calculated on the basis of the price of the vignette divided by its duration of
    validity.
    16
    consumers/citizens responding to the public consultation indicating that EU rules could
    introduce fairness for non-resident road users (cf. Annex 2).
    Table 2-5: Vignette prices for light duty vehicles across Member States, 2017
    Member State Vignette prices [€] Ratio of average daily
    price between shortest
    term and longest term
    vignette
    Shortest term vignettes
    (number of days)
    Annual vignette
    (number of days)
    Passenger cars
    Austria 8.9 (10) 86.4 (365) 3.76
    Bulgaria 8 (7) 50 (365) 8.34
    Czech Republic 11.5 (10) 55.5 (365) 7.54
    Germany (planned) From 2.5 to 20 From 0 to 130 3.65 to 7.3
    Hungary 9.5 (10) 138 (365) 2.53
    Romania 3 (7) 28 (365) 5.59
    Slovakia 10 (10) 50 (365) 7.30
    Slovenia 15 (7) 110 (365) 7.11
    In an opinion on the previous Austrian vignette scheme,62
    the Commission indicated that in
    order for it to be proportionate, the ratio between the average daily price of short-term
    vignettes and long-term vignettes should not be higher than 5.63
    Today, only Austria and
    Hungary would meet this criterion. It is worth noting that currently only one vignette
    system applies the recommendation of the Communication of 201264
    , by setting
    proportionate vignette prices as defined in a dedicated study65
    .
    2.2.5. D5. Lack of clear price signals on pollution and congestion
    Efficient use of the transport system is largely dependent on effective price incentives
    provided to users via road charges. This in turn drives the amount of external costs from
    road transport, including air pollution and congestion.
    Distance-based road charges, when properly reflecting vehicle characteristics, the time and
    the place of infrastructure use, are the most efficient tool to foster sustainable transport
    behaviour. However, the efficiency will depend on the consistency and transparency of the
    price signals received by users. Hauliers as well as private car and van owners may
    accelerate the purchase of cleaner and more efficient vehicles (as described in section
    2.2.1) if they can save on tolls on itineraries they use66
    . Similarly, road charges could also
    direct users on the optimal time of driving provided that user charges consistently reflect
    the negative impacts of congestion.
    62
    K(96) 2166 of 30 July 1996
    63
    While the opinion was issued in 1996, the technology of vignettes for passenger cars and the structure of
    other costs (distribution, etc.) did not change much (in fact the introduction of electronic vignettes even
    decreases the cost per vignette), meaning that the opinion can still be applied today.
    64
    COM(2012)199 final; i.e. by being in line with at least the benchmarks adapted to the different usage
    pattern of private vehicles (with weekly- and monthly-vignette prices respectively equal to 7% and 11%
    of the annual-vignette price in Hungary)
    65
    Booz & Co. (2012). Study on Impacts of Application of the Vignette Systems to Private Vehicles.
    According to the study the proportionate price for weekly and monthly vignettes would be 7.5% and
    15.4% of the annual rate, respectively: http://ec.europa.eu/transport/modes/road/studies/doc/2012-02-03-
    impacts-application-vignette-private-vehicles.pdf
    66
    See e.g. http://www.fliegl-fahrzeugbau.de/fliegls-twin-programm/150/4812/4990/
    17
    An overview of road charges per km by freight vehicle category is provided in Annex 10
    (Table 10-1). For passenger cars, the situation is similar to what is indicated in Table 10-1
    for light goods vehicles, but charges are somewhat lower in all Member States.
    Interestingly, a majority of respondents to the consultation from EU-13 Member States felt
    strongly that road charges paid by light vehicles are too low. This is probably linked to the
    prevalence of vignette schemes in those countries.
    With regards to air pollution, for HGVs, the incomplete application of the polluter pays
    principle is linked to two main issues: a) the use of time-based charges (and/or vehicle
    taxes) instead of distance-based; and b) the lack of uptake of external cost charging:
    a) The use of time-based user charges (vignettes)
    Road user charges in the form of time-based vignettes, which are allowed by the
    current legislation, are not directly linked to the use of infrastructure and to the
    generation of externalities. Therefore, cost of air pollution and noise can only be
    adequately reflected in transport prices on the sections of the main road network where
    distance-based charges apply. This share of motorways subject to distance-based
    charges for HGVs is estimated to be around 58% of motorways and expressways (see
    Table 9-1 in Annex 9). Except for those Member States which apply network-wide
    tolls (see map in Annex 5), this share is even lower for national roads and for other
    vehicle categories, including passenger cars.
    b) Lack of uptake of external cost charges
    Tolls currently in place do not make full use of the options provided by the
    Eurovignette Directive to account for the external costs of air pollution and noise.
    While about two thirds of the Member States apply a differentiation for HGVs by Euro
    standard67
    , a differentiation by time of day to protect sensitive areas from noise is only
    applied in Austria and Slovenia. Similarly, the possibility to charge for the external
    cost of air pollution has only been used by Germany and Austria. This may be due to
    the Directive providing for two overlapping instruments to reflect the environmental
    performance of HGVs (see below).
    For passenger cars and vans, which contribute to a significant amount of air pollution,
    Member States generally provide no incentives. This can partly be explained by the fact
    that these vehicles are outside the scope of the current legislation.
    With regard to congestion, marginal cost pricing is the most efficient tool for reducing
    congestion. It provides economic incentives to users to opt for alternatives to single
    occupancy peak-hour car transport such as car sharing, collective (public) transport or off-
    peak travel. Despite the consensus on its positive impact on social welfare, congestion
    pricing is not widely applied on the interurban network. Of the 17 Member States that
    apply road charging to all vehicles, only a few have put in place some sort of time-of-day
    charge differentiation to control congestion (see Figure 10-2 in Annex 10). The existing
    real-world examples have proved to be effective. In the Czech Republic, increasing the
    charge by 25-50% during peak periods has resulted in a 15% decrease in traffic during
    67
    See e.g. Ricardo et al. (2014) Evaluation of the implementation and effects of EU infrastructure charging
    policy since 1995
    18
    peak times. In France, increasing toll rates during weekend rush hours resulted in a 10%
    transfer to off-peak times.
    2.2.5.1. The role of the current legislation
    A fundamental problem with the Directive is that it provides for two competing
    instruments to reflect the environmental performance of HGVs:
    - the differentiation of charges according to Euro classes and
    - the possibility to charge for the external cost of air pollution and noise.
    The Directive requires Member States to vary tolls (infrastructure charges) according to the
    Euro emission class (polluting emissions) of HGVs. However, the exact method of
    modulation is not harmonised, which results in a large variety of approaches across the EU
    (see Annex 10), while exemptions are allowed.
    Since the modalities of the variation are not precisely defined, it is less cumbersome to
    apply this differentiation than following the strict and complex requirements set out to
    charge for external costs. It is thus not surprising that the latter has hardly been used by
    Member States.
    There are also some regulatory obstacles to fully exploit road charging for optimisation of
    the infrastructure capacity. The current legislation allows differentiating tolls according to
    time of the day or season, but it requires that any differentiation be revenue-neutral. This
    requirement makes it burdensome for Member States to implement such schemes on
    specific parts of the network. At the same time, the Directive does not permit the
    application of genuine congestion charging, i.e. on top of the infrastructure charge, which
    could be financially interesting for Member States.
    Another instrument whose potential is not fully exploited is the application of mark-ups on
    roads suffering from acute congestion or the use of which leads to significant
    environmental damage, provided that revenues are invested in priority projects on the same
    corridor, contributing directly to the alleviation of the problem (a mark-up of up to 15-25%
    can be applied depending on whether the project is cross-border or not). Since it is not
    possible to apply mark-ups outside mountainous areas, this possibility has only been used
    for the financing of the Brenner Base Tunnel between Austria and Italy.
    2.3. Who is affected by the problem? What is the EU dimension of the
    problem?
    CO2 emissions from transport contribute to climate change, which is a global issue as
    greenhouse gases emitted anywhere contribute to global warming, rising sea levels,
    extreme weather conditions or desertification, with poorer world regions being most
    vulnerable. Mitigation measures have to be taken at all levels of governance and budgetary
    implications affect the entire population. The European automotive industry has an
    important role to play in exploiting the potential offered by technological progress.
    The problem of degrading road infrastructure also affects large segments of society. Road
    users (hauliers and private motorists) are most directly affected by the negative impacts
    including damage to their vehicles and increased congestion. All road users, including
    vulnerable road users, are affected by the higher risk of accidents on badly maintained
    roads. Beyond these direct effects, poor road quality affects the real economy, as transport
    19
    becomes slower and more costly; peripheral regions and Member States suffer most in this
    regard. Finally, when carried out too late, maintenance works have a higher cost, and the
    additional budgetary burden is eventually placed on taxpayers.
    Disproportionately expensive short-term vignettes essentially affect non-resident drivers.
    However, since such vignettes are in place in several Member States, all EU citizens who
    use their car for cross-border travel are potentially affected. Beyond the effect of
    discrimination per se, disproportionately priced vignettes can cause political division and
    damage to the coherence of the EU, as they are perceived as designed to "make foreigners
    pay".
    Air pollution generated by road traffic and road congestion are primarily local
    externalities, affecting mainly communities living where the pollution occurs, though air
    pollutants can travel long distances. Congestion on the interurban and suburban networks,
    in particular on road axes of international importance belonging to the TEN-T network,
    also negatively affects international traffic, and in particular the functioning of the coach
    transport and logistics sectors - just-in-time deliveries as well as scheduled bus services are
    disturbed by the increased unpredictability of the time of arrival due to congestion along
    the route.
    2.4. How is the problem likely to develop without action?
    2.4.1. Insufficient decrease in CO2 emissions from road transport
    In the Baseline scenario, CO2 emissions from road freight transport (HGVs and freight
    vans) are projected to increase by 6% between 2010 and 2030 (11% for 2010-2050).68
    For
    heavy goods vehicles, the increase would be somewhat higher (10% for 2010-2030 and
    17% for 2010-2050). At the same time, emissions from passenger cars and minibuses are
    projected to decrease by 22% between 2010 and 2030 (32% for 2010-2050) thanks to the
    CO2 standards in place and the uptake of electromobility. CO2 emissions from buses and
    coaches are projected to remain virtually unchanged by 2030, compared to their 2010
    levels, and to slightly increase post-2030 (3% increase for 2010-2050).
    2.4.2. Degrading quality of road infrastructure with negative economic,
    social and environmental impacts
    The current profile of annual road maintenance expenditure in Europe has been associated
    with declining road quality in some Member States. While more and more Member States
    are forced to start applying user financing, at least as a complementary measure, they often
    turn to the less efficient way of road charging (vignettes),69
    which have significantly lower
    revenue raising potential than distance-based charges.
    Even though a number of Member States do allocate (at least part of) the toll revenues to
    the maintenance and construction of the road network70
    , or to transport at large, since only
    a small share of the road network is tolled for only a share of vehicles and on those
    68
    See Annex 4 for a description of the Baseline scenario.
    69
    Estonia or Finland, the last two continental Member States without a road charging scheme, are planning
    to introduce time-based systems
    70
    E.g. in France, toll revenues are the main financers of the transportations infrastructures. Tolling revenues
    are collected on the oldest sections in order to finance the most recent ones. For more details see Annex 9.
    20
    sections the toll per vehicle cannot be higher than actual costs, a large part of the necessary
    funding would still need to come from other sources (i.e. transport taxes or the general
    budget). However, revenues from fuel taxes are projected to decrease by around 9%
    between 2010 and 2030 (17% for 2010-2050) in the Baseline scenario, thanks to efficiency
    improvements (lower fuel consumption) and the increasing share of hybrid and electric
    vehicles71
    . It is thus difficult to see where the additional resources necessary to fill the
    financing gap would come from, unless distance-based road charging is generalised to
    cover the large majority of the road network and all vehicle categories. Such changes in the
    structure of taxes and charges do not happen overnight and require strong political backing
    and public support.
    Without further action, it is therefore reasonable to expect a continuation of past trends of
    declining road quality and increasing maintenance backlogs, at least in some Member
    States72
    . In many cases the ‘savings’ from delaying maintenance will be false economies,
    as the roads will degrade to the point where they must be replaced, which is costly
    compared to ongoing maintenance or repair. These problems will be exacerbated due to
    expected increases in traffic volumes.
    2.4.3. Potential discrimination against occasional/non-resident users and
    unfair distribution of costs via road charging
    Table 2-6 shows the evolution of price ratios over the last 5 years, providing an indication
    on how the issue might develop in the future, including the forthcoming German scheme.
    While in half of the countries price ratios have decreased, in the other half, they have
    increased. However, it is clear that countries that priced short-term vignettes above a
    proportionate ratio of 3-4 in 2012 still have ratios above this level in 2017 (i.e., pricing
    remained disproportionate). In addition, the majority of Member States applying time-
    based charging schemes have significant differences (over a ratio of 5) between short-term
    and long-term vignette prices.
    Table 2-6: Evolution of vignette price ratios for cars between 2012 and 2017
    Member State 2012 Assessment
    Ratio of average daily prices for short-
    term vignettes compared to long-term
    vignettes
    (Booz & Co., 2012)
    2017 Assessment
    Ratio of average daily prices for short-
    term vignettes compared to long-term
    vignettes
    Austria 3.8 3.8
    Bulgaria 7.9 8.3
    Czech Republic 7.7 7.5
    Germany (planned) N/A 3.65 - 7.3
    Hungary 3.7 2.5
    Romania 5.4 5.6
    Slovakia 7.1 7.3
    Slovenia 8.2 7.1
    71
    Even though their share in total car sales is still limited, in the Netherlands and Denmark it reached 12%
    and 8% respectively in 2015. http://www.eea.europa.eu/highlights/reported-co2-emissions-from-new
    72
    One exception could be Germany, where the Federal Transport Infrastructure Plan adopted at the end of
    2016 has a value of EUR 270 billion until 2030 with 69% allocated to the preservation of existing
    infrastructure (up from 56% in 2003), and 49% allocated to roads:
    http://www.bmvi.de/SharedDocs/EN/PressRelease/2016/129-dobrindt-bvwp-2030.html?nn=187654 Nb.
    Germany is also extending its tolled network to all national roads and other vehicle categories.
    21
    Based on the above, it can be concluded that guidance documents on how to set up fair
    national vignette systems for light duty vehicles are not sufficient to ensure that vignettes
    are priced proportionately. There is no reason to assume that the issue would cease to exist
    without additional action.
    It is also uncertain that Member States would shift to non-discriminatory distance-based
    charging systems. Over time, there has been an evolution from vignette systems towards
    network-wide distance-based electronic tolling in the case of HGVs, and the trend is
    expected to continue, for example with Bulgaria planning to introduce its new network-
    wide distance-based tolling system in 2018. However, in some cases advanced plans to
    adopt electronic tolling had to be abandoned or postponed for various reasons. This was
    the case for example in Denmark, France and the Netherlands (see Figure 2-7).
    Figure 2-7: Development of infrastructure charging systems for HGVs in Europe
    1995-2015
    Source: Ricardo et al. (2014) Evaluation of the implementation and effects of EU infrastructure charging policy since
    1995
    Member States that have not had any road charging system in place so far seem likely to
    go down the same path of introducing a time-based (vignette). Recently Latvia and the UK
    introduced time-based schemes for HDVs, and Estonia and Finland are reported to have
    similar plans. The Commission has launched an infringement case against the UK on
    grounds of discrimination against foreign hauliers.
    22
    2.4.4. Negative environmental and socioeconomic impacts of road transport
    Under the baseline scenario, NOx emissions would drop by about 56% by 2030 (64% by
    2050) with respect to 2010 levels. The decline in particulate matter (PM2.5) would be less
    pronounced by 2030 at 51% (65% by 2050). By 2030, over 75% of the heavy goods
    vehicle stock is projected to be Euro VI in the Baseline scenario and more than 80% of the
    passenger cars stock. Overall, external costs related to air pollutants would decrease by
    about 56% by 2030 (65% by 2050). However, they would still represent an important cost
    for society (roughly €27 billion in 2030).
    The increase in traffic would lead to further increase of noise related external costs of
    transport, by about 17% during 2010-2030 (24% for 2010-2050). Thanks to policies in
    place, external costs of accidents are projected to go down by about 46% by 2030 (-42%
    for 2010-2050) – but still remain high at over €100 billion in 2050.
    As regards congestion, the situation is projected to worsen if its costs are ignored.73
    It is
    generally expected that congestion and its associated costs will increase, linked to the
    growth of economies, concentration of activities in urban areas and the rise in population.
    Under current trends and adopted policies, total congestion costs are projected to increase
    by about 24% by 2030 and 43% by 2050, relative to 2010. For heavy goods vehicles the
    delay cost from congestion is projected to increase by 76% by 2030. The growth of
    congestion on the inter-urban network would be the result of growing freight transport
    activity along specific corridors, in particular where these corridors cross urban areas with
    heavy local traffic (see also Figure 4-6 in Annex 4).
    According to the contribution of the UK to the public consultation, if no action is taken by
    2040 congestion will become a serious problem for many important routes in the UK – up
    to 16 hours stuck in traffic for every household each year, 28 million working days lost per
    year and a £3.7 billion annual cost to the freight industry, risking higher consumer prices.
    While the Connecting Europe Facility and the application of mark-ups (in mountainous
    areas) can contribute to the financing of alternative infrastructure, not all problems of
    congestion can be solved through additional infrastructure capacity, as this may in itself
    generate additional traffic.
    3. WHY SHOULD THE EU ACT?
    3.1. The EU's right to act
    Directive 1999/62/EC has a double legal base, notably Article 91 TFEU and Article 113
    TFEU (Article 71(1) and Article 93 of the Treaty establishing the European Community).
    It is to be noted that most of the amendments to the Directive as discussed here pertain to
    tolls and user charges (Chapter III of the Directive), an area to which Article 91 TFEU
    applies.
    As far as vehicle taxes may be affected by the amendment of certain provisions of Chapter
    II of the Directive, these would fall under Article 113 TFEU and would thus be subject to a
    separate legal proposal.
    73
    http://inrix.com/wp-content/uploads/2015/08/Whitepaper_Cebr-Cost-of-Congestion.pdf
    23
    3.2. Subsidiarity check
    The problems of emissions (in particular CO2 being a global externality) have a clear
    cross-border dimension. While Member States have the means to promote more fuel
    efficient vehicles e.g. through subsidies, if such measures are not coordinated and applied
    consistently, their effectiveness will be subject to the willingness of other countries
    applying similar measures. In the case of a global problem, such as the issue of climate
    change, concerted action is much more effective.
    The problem of degrading quality of roads, in particular of roads of international
    importance, such as TEN-T corridors, affects road users independently of their country of
    registration. Furthermore, as established in section 2.3, it negatively affects the functioning
    of the whole Internal Market, with a particularly heavy impact on peripheral regions.
    Impacts on efficient transport on trans-European corridors are not likely to be sufficiently
    taken into account by the Member States individual decisions on maintenance priorities,
    making some level of EU intervention justified. This EU intervention is limited, though,
    essentially to co-ordination and monitoring, as Member States retain a large level of
    control on the management of their own road networks.
    The problem of discrimination of non-resident users by disproportionately priced vignettes
    is by definition of a cross-border nature, and can only be solved by co-ordinated action at a
    supra-national level. Such action is notably necessary to avoid chain reactions of other
    Member States to what could in some cases be seen as schemes designed to "charge the
    foreigners".
    EU intervention to address interurban congestion is justified by the effect that it has on
    long-distance cross-border passenger and freight transport. This effect – disturbance to
    scheduled international bus services and to international road freight transport – has been
    described in section 2.3 above. However, since – with the exception to the abovementioned
    cases – congestion is a local externality, EU intervention is better placed for harmonising
    the tools used by Member States, rather than mandating any action.
    Finally, air pollution is equally a local externality, and must primarily be addressed at the
    local level. However, as the existing legislation established minimum standards of air
    quality throughout the Community, the EU is also well positioned to offer the right tools to
    tackle the air pollution problem. In addition, particulate matter in air consists of a
    substantial trans-boundary component and so all Member States must take measures in
    order that the risks to the population in each Member States can be reduced. Moreover, the
    huge scale of the problem (500,000 premature deaths per year, i.e. 20 times more than
    fatalities in road accidents) calls for action at all governance levels. In any case, solutions
    specifically addressing air pollution ("external-cost charges") have already been included
    in the Eurovignette Directive but their use should be made simpler.
    The extension of the analysis to passenger cars deserves special focus in the subsidiarity
    check. The private use of cars is predominantly limited to within the national borders of
    each Member States. Cross border travels are relatively sporadic, limited to holidays or
    commuting in border regions. Yet the impact of cars on problems on EU- and global levels
    must not be underestimated. The contribution of cars to overall transport CO2 emissions
    24
    has already pushed the EU to legislate on mandatory CO2 emission targets. Similarly, cars
    account for 2/3 of the total costs of road congestion and a large share of air pollution costs.
    It is therefore unlikely to be effective in terms of finding solutions to many of the problems
    identified, if passenger cars remain outside of the scope of EU action.
    Taking the above considerations, none of the proposed options goes beyond what is
    necessary as the proposed measures are focused on the areas where EU is best positioned
    to act. In addition, since the problems linked to current text of the Directive cannot be
    overcome by Member States alone and can only be addressed by amending the existing
    legislation, there is a clear need for EU action.
    3.3. EU added value
    The action at EU level helps ensuring a more coordinated and effective application of road
    charging in Europe. The Eurovignette Directive brings coherence to national road charging
    policies by defining available tools and harmonising their deployment. This is necessary to
    preserve the coherence of the Internal Market and to avoid that road charging is used as a
    non-tariff barrier to trade, or that it becomes an obstacle to the free movement of people
    and goods.
    As new challenges (global warming, road congestion, road financing gap) emerge, it is
    necessary that actions to tackle them are implemented in a harmonised and non-
    discriminatory way. There is a need for a EU response to these challenges and the
    Eurovignette Directive must evolve to accompany changes in the objectives of road
    charging schemes.
    Without specific new provisions in the Directive on the problems identified in section 2.1,
    Member States are unlikely to use road charging to address new challenges. Besides, if
    rules at EU level are insufficiently developed, there is a risk is that road charging schemes
    could become an element of economic competition between Member States.
    After 20 years and following two major amendments, the Eurovignette Directive has
    become a complex piece of legislation. A number of policy measures considered under
    various policy options below could contribute to simplifying the application of the
    instruments provided for in the current Directive. For example, the removal of one of the
    two competing measures (the obsolete differentiation based on Euro class) to promote
    more environmentally friendly vehicles, and making the application of the other (external
    cost charging) easier for Member States.
    The timing for the initiative is well justified by the recent developments in Member States
    in the area of road charging. The existing schemes are becoming more mature so it has
    become clear what the main deficiencies of the existing rules are and where new elements
    need to be added. At the same time, an increasing number of Member States introduces or
    considers the introduction/extension of road charging schemes. Given that these plans do
    not always correspond to the most optimal approach from an EU perspective, it seems
    necessary to act now to give the right incentives and eliminate barriers to the deployment
    of efficient and effective road charging systems.
    Also the recent technological developments call for changes in the existing rules. With the
    Euro classification becoming obsolete and new emission testing schemes becoming
    available it appears justified to reflect these developments in the Eurovignette Directive.
    25
    The progress and increasing uptake of electronic tolling also enables the use of more
    refined charging schemes and these new possibilities should be considered to facilitate
    better internalisation of external transport costs via tolling.
    4. OBJECTIVES
    The general objective of the initiative is to promote financially and environmentally
    sustainable and socially equitable road transport through wider application of the 'user
    pays' and 'polluter pays' principles (fair and efficient pricing).
    The specific objectives (SO) for the revision of Directive 1999/62/EC are the following:
    1. Contribute to the reduction of CO2 emissions in transport via pricing (demand side)
    supported by supply side measure to come (standards).
    2. Contribute to adequate quality of roads.
    3. Ensure fair and non-discriminatory road pricing.
    4. Make use of road charging as an effective tool in reducing pollution and
    congestion.
    These objectives are directly linked to the problems identified in section 2, as shown in
    Figure 2-1, with clear synergies with the goal of ensuring adequate infrastructure financing
    through the application of proportionate pricing. There could be a trade-off between
    addressing CO2 vs pollutant emissions, in that the most fuel-efficient vehicles might not be
    the cleanest and price signals could work against each other. This however can be
    overcome by removing unnecessary duplication of charge differentiation from the
    Directive and introducing CO2 differentiation, with only the least polluting HDVs
    benefitting from lower rates. For cars and vans, incentivising fuel-efficiency only could
    lead to further 'dieselisation' with negative impacts on air pollution and fuel balance. If
    differentiation of charges is applied, it should thus take account of both CO2 and pollutant
    emissions.
    The objectives are in line with the Charter of Fundamental Rights, in particular by ensuring
    the non-discriminatory application of road charges that reflect the environmental
    performance of vehicles thereby contributing to sustainable development and the free
    movement of citizens. More specifically, the first objective is in line with EU goals of
    reducing CO2 emissions and builds on the certification of CO2 emissions from HDVs
    under type approval legislation to be adopted in 2017, on the initiative on the monitoring
    and reporting of heavy duty vehicle fuel consumption and carbon dioxide emissions to be
    proposed at the same time with this initiative, and with upcoming initiatives on emissions
    from cars and vans. The second one, linked to the problem of degrading road quality, is
    coherent with the aims of the legislation on road infrastructure safety74
    . Finally, the current
    revision of the legislation on electronic tolling (EETS)75
    will be instrumental in achieving
    the third and fourth objectives by making proportionate distance-based charging more
    affordable.
    74
    Directive 2008/96/EC of the European Parliament and of the Council on road infrastructure safety
    management
    75
    Directive 2004/52/EC on the interoperability of electronic road toll systems in the Community and
    Commission Decision 2009/750/EC on the definition of the European Electronic Toll Service and its
    technical elements
    26
    5. POLICY OPTIONS
    Apart from the baseline scenario (no additional EU action), four policy packages are
    considered. Each of them addresses each policy objective but they differ in their focus and
    level of ambition. As some of the problems are linked to the current text of the Directive,
    the considered options all include regulatory elements, in line with the Commission
    Strategy on Low-emission Mobility, and simplification measures, in line with the
    objectives of ensuring regulatory fitness. This approach enjoys a wide stakeholder support
    as evidenced by the feedback received through the various consultation activities (cf.
    report on the stakeholder consultation in Annex 2).
    The concrete measures in each policy option are described below, while the rationale for
    the selection of these measures is provided in Annex 11, along with indications on which
    Member States would be affected. The way in which each member States would need to
    adapt its road charging practice is presented in Annex 4 (section 4.3).
    5.1. Baseline (no additional EU action)76
    In the baseline scenario, Directive 1999/62/EC would continue to apply in its current form
    to HGVs only. Road charges for HGVs would not be differentiated according to the CO2
    emissions since the differentiation based on Euro class would remain mandatory for HGVs
    (with continued exceptions). The heavy methodological requirement for the application of
    external cost charging would continue to apply and the Directive would not offer effective
    provisions to address the issues of degrading road infrastructure and congestion.
    Member States would thus continue their current practice of road charging and proceed
    with plans according to their own national objectives as illustrated in section 2.4 without
    necessarily being in line with EU objectives sometimes in contradiction with the principles
    of non-discrimination and proportionality (cf. section 2.1.3). This option has no real
    support among stakeholders and some Member States argue that at least the limits on
    vignette prices (for HGVs) should be increased (cf. sections 2.2.3.1 and 2.4.2).
    5.2. Discarded policy measures
    Soft law (e.g. a Communication with recommendations77
    ) was used in the past to address
    the issue of disproportionately priced short-term vignettes for passenger cars but was found
    not to have significant impact. For addressing the shortcomings of existing legislation, it is
    not a viable option.
    The most ambitious policy option introducing a full internalisation of external costs as
    suggested by the 2011 White Paper has also been discarded. This option is supported by
    some environmental NGOs in particular and remains a long-term goal of the European
    transport policy, but it does not currently appear to be achievable due to excessive
    implementation costs and for reasons of subsidiarity. Indeed, regarding certain aspects, it
    appears that Member States are best placed to act. For example, whether or not to apply
    road charging or congestion charging on a given part of the network can best be assessed at
    local/regional level.
    76
    See Figure 4-1 in Annex 4 for a summary of road charging systems applied by Member States in the
    Baseline scenario
    77
    COM(2012)199 final
    27
    A number of measures considered at an initial stage have been discarded following the
    stakeholder consultation and a pre-screening with regard to effectiveness,
    administrative/implementation costs, legal feasibility, subsidiarity and proportionality.
    These measures are listed here with a description on the reasons for discarding them
    available in Annex 11:
    • Making distance-based charging mandatory on the TEN-T network for HGVs / all
    goods vehicles
    • Inclusion of the external costs of accidents not already covered by insurance schemes
    • Mandatory application of genuine congestion charging on congested parts of the
    network in peak hours for HGVs / all vehicles
    • Awarding discounts for the use of specific fuel-saving equipment, such as low-
    resistance tyres of aerodynamic devices
    • Promotion of specific low carbon fuel technologies
    • Making it possible to apply genuine congestion charging (i.e. on top of infrastructure
    charges) on congested parts of the network in peak hours for HGVs only
    • Mandatory earmarking (ring-fencing) of revenues from road charging
    • Requiring Member States to prepare national plans on the maintenance and upgrade of
    their road networks
    • Introduction of rules on the liability of the keeper of a toll road to maintain the given
    road section in sufficiently good/safe condition
    For all these measures, less restrictive alternatives have been retained that are easier to
    implement and/or at lower costs.
    5.3. Policy option 1: minimum adjustments with rules for vehicles (including
    for passenger cars) (PO1)
    This option proposes the necessary legislative changes to make the Directive more fit for
    purpose and, in order to make it possible to address all four objectives at least to some
    extent, extends the scope to buses and coaches and, for some provisions, to vans and
    passenger cars. The application of coherent rules to all HDVs (HGVs and buses/coaches)
    not only ensures fairer treatment of the users of these vehicles but also contributes to
    achieving the other three objectives. In the absence of the strongest possible instrument of
    mandatory reinvestment of toll revenues in transport, enhanced reporting including specific
    information on the quality of roads could incentivise Member States to allocate the
    necessary resources to road maintenance (cf. Annex 12).
    In line with REFIT objectives, the option includes simplifications to current rules and
    proposes their more coherent application, while keeping the obligations on light vehicles to
    the minimum.
    SO1: Contribute to reducing CO2 emissions in transport:
    - Allowing reduced toll rates (for both HDVs and LDVs) in order to promote zero-
    emission vehicles; in this respect, the measure would also contribute to the
    Commission's objective of reducing regulatory burden.
    SO2: Contribute to adequate quality of roads:
    28
    - Monitoring and reporting by Member States through regular infrastructure
    reports, providing information on toll revenues, on their use, including expenditures
    on maintenance/operation of roads, as well as on the quality of roads based on key
    performance indicators.
    - Introducing common quality indicators. A harmonised definition based on current
    national practices in monitoring road characteristics could be adopted by the
    Commission through an implementing/delegated act.
    SO3: Ensure fair and non-discriminatory road pricing:
    - Removing the possibility to exempt HGVs below 12 tonnes from being subject to
    road charging (after a period of 5 years);
    - Extending the rules on tolls and user charges (Chapter III of the Directive) to include
    buses and coaches;
    - Introducing non-discrimination and proportionality requirements for LDVs: defining
    the maximum ratio of average daily price (or price proportions) between short-term
    and long-term vignettes, and clarify rules concerning possible compensation of
    national users.
    SO4: Make use of road charging as an effective tool in reducing pollution and congestion:
    - Simplification of the requirements for external cost charging:
    o Merging the charging of noise costs with the cost of air pollution;
    o Using more proportionate values instead of weighted average charges;
    o Removing the requirement for Member States to notify the Commission
    where these provisions are respected (i.e. the values set in the Directive are
    applied).
    - Reviewing of maximum values for external cost charging to better reflect external
    costs of pollution and noise;
    - Extending the possibility to use mark-ups (of 15-25%) beyond mountain regions to
    contribute to the financing of removing bottlenecks on the TEN-T network, while
    keeping the condition of acute congestion or significant environment damage
    generated by vehicles. The measure would apply to all HDVs (HGVs +
    buses/coaches).
    The measures set out in this option are generally supported by stakeholders. The promotion
    of zero-emission vehicles and the revision of rules on external cost charging are not
    contested by stakeholders. At the same time, some Member States oppose obligations
    regarding infrastructure maintenance (in particular the mandatory earmarking of revenues)
    voicing subsidiarity concerns, while SMEs, especially transport operators as well as private
    road users demand that any toll revenues be reinvested in roads. There is wide support for
    the application of the polluter pays and user pays principles, including proportionate
    pricing of vignettes. The exemption of HGVs below 12t is not considered justified by
    stakeholders, except for some Member States that still apply it. Regarding mark-ups, there
    is some interest in Member States to use the possibility outside mountain regions.
    29
    5.4. Policy option 2: rules for all vehicles and progressing on the 'polluter pays'
    and 'user pays' principles for HDVs (PO2)
    This option would address CO2 emissions in a more direct way by including a CO2 element
    in the road charge for HDVs, while encouraging the introduction of distance-based
    charging by removing an obstacle created by Directive 1999/62/EC, i.e. the application of
    a minimum vehicle tax for HGVs. It goes a step further than PO1 in making the legislative
    framework more coherent by phasing out the less effective forms of charging for the use of
    roads and for external costs. Gradual phasing out of existing vignette schemes would give
    Member States sufficient time to adapt their charging systems. Moving towards distance-
    based charging is necessary to achieve the overall objective of implementing the 'polluter
    pays' and 'user pays' principles, i.e. contributing to all four specific objectives.
    The concrete measures included in PO2, in addition to the measures of PO1, are described
    below.
    SO1: Contribute to the reduction of CO2 emissions in transport:
    - Introducing a mandatory differentiation of infrastructure charges according to CO2
    emissions for HDVs once vehicle certification data on CO2 emissions becomes
    available for new vehicles78
    . Distinction would be made between i) Euro 0-VI
    vehicles, ii) low-CO2 (new or retrofitted) vehicles. Since the certification data would
    only be available in 2019/2020, the precise method for differentiating charges would
    be defined by the Commission in an implementing/delegated act. Taking into
    account existing fuel taxes, the differentiation would be revenue-neutral based on a
    bonus-malus principle in order to avoid "double taxation". The cleanest and most
    efficient vehicles would pay less than the average.
    SO2 and SO3: Contribute to adequate quality of roads and ensure fair road pricing:
    - Where HGVs are subject to road charging, buses and coaches would also have to be
    charged.
    - Phasing out vignettes for HDVs (HGVs + buses/coaches) after 5 years (by 2023) –
    only distance based charging would be allowed for these vehicles. Distance-based
    charging would remain the only option facilitated by the possibility to decrease
    vehicle taxes (see measure below) but Member States would remain free to decide
    whether or not to introduce road charging on their territory and on which roads.
    Distance-based charging is also necessary to achieve SO1 and SO4.
    - As a complementary measure to incentivise the introduction of distance-based
    charging: Removing minimum levels of vehicle circulation taxes for HGVs above 12
    tonnes would allow Member States the reduction or complete abolishing of the tax in
    case of the application of distance-based charging. The measure would also
    contribute to the REFIT objective of reducing the burden on businesses.
    SO4: Make use of road charging as an effective tool in reducing air pollution and noise:
    - Phasing out differentiation of infrastructure charges for HGVs according to Euro
    emission classes (simplification) – with external cost charging remaining optional.
    78
    VECTO – Vehicle Energy consumption Calculation Tool developed by DG CLIMA and the JRC – will
    be ready to provide this information for HGVs above 7.5 t as from 2019.
    30
    Since external cost charging would be made simpler (as in PO1), Member States
    would still have the opportunity to take account of the environmental performance of
    vehicles under this option. The measure would also be extended to buses/coaches.
    A sensitivity case (PO2s) is provided for PO2 where the measures explained above are
    additionally implemented in Estonia and Finland. These two Member States plan to
    introduce road charges in the future but they do not qualify for being included in the
    Baseline because, at the time of preparing the impact assessment, the plans have not yet
    been adopted.79
    The promotion of low-CO2 vehicles has not met any notable opposition by stakeholders.
    While some Member States would prefer to keep the flexibility of opting in or out, others
    indicate that such a measure can only be effective if applied coherently. In practice, once
    CO2 emission certification data is available, the new scheme could replace the current
    differentiation based on Euro class, which will become obsolete by then.
    The phasing out of vignette schemes for HGVs is supported by many, including
    environmental NGOs, and representatives of the railway sector but also a number of
    Member States and operators, even though some Member States still operating such
    schemes would oppose this.
    5.5. Policy option 3: reducing CO2 and other externalities from all vehicles
    (PO3) – with two variants (3a and 3b)
    With a view to tackle the issues, which are related to primarily to light vehicles, this option
    includes additional measures for cars and vans, addressing interurban congestion as well as
    CO2 and pollutant emissions from all vehicles. The measures included in this option are
    described below, in addition to the measures of PO2.
    SO4: Make use of road charging as an effective tool in reducing pollution and congestion
    (in both PO3a and PO3b):
    - Allowing (optional) genuine congestion charging on top of the infrastructure charge
    in distance-based environment, on congested parts of the network, for all vehicles
    (LDVs + HDVs) – such a congestion charge, should Member States decide to
    implement it, would apply to all vehicles (LDVs and HDVs) according to their size.
    The Directive would require the revenues generated by congestion charging to be
    invested in the maintenance/development of the road in question or alternative
    transport/mobility solutions. This could raise the level of acceptability of an extra
    charge by users80
    .
    SO1 and SO4: Contribute to the reduction of CO2 emissions in transport and make use of
    road charging as an effective tool in reducing air pollution (only in PO3b):
    - Introducing a mandatory differentiation of tolls and user charges (i.e. both distance-
    and time-based) for LDVs (vans and passenger cars) from 2020 when Member States
    apply road charging. Distinction would be made between different emission classes
    based on WLTP81
    for CO2 and based on real driving emissions (RDE) testing for
    79
    The Estonian Government has approved the introduction of a time-base road charging schemes for HGVs
    since, but it is still to be enacted by Parliament.
    80
    Please see Annex 11 and for more background information.
    81
    World harmonised Light vehicle Test Procedure adopted by the UNECE
    31
    pollutant emissions (NOX). In order to provide a coherent price signal and have an
    effective impact, Member States would be required to differentiate tolls accordingly.
    The stakeholder survey suggested that any legislation introduced should not be focused
    solely on HGVs, but on all road vehicles including both freight and passenger transport
    based on the polluter pays and user pays principles. While different options on congestion
    charging were met with scepticism, stakeholders agreed that if congestion charging was
    applied, it should cover all vehicles, not just HGVs. The proposed optional measure is in
    line with this view.
    5.6. Policy option 4: optimisation of tolls for all vehicles (PO4)
    While not obliging Member States to apply road charging, this is the most ambitious
    option as it extends the requirement to use distance-based tolling only to all vehicles,
    including passenger cars, while making external cost charging mandatory for heavy duty
    vehicles (HGVs above 3.5 tonnes and buses/coaches). The concrete measures would
    include measures of PO3b plus:
    SO2, SO3 and SO4: Contribute to adequate quality of roads, ensure fair road pricing and
    make use of road charging as an effective tool in reducing air pollution, noise and
    congestion:
    - Phasing out vignettes for vans – only distance based charging would be allowed for
    these vehicles.
    - Phasing out vignettes for cars – only distance based charging would be allowed for
    these vehicles.
    SO4: Make use of road charging as an effective tool in reducing air pollution and noise:
    - Making external cost charging mandatory on the tolled TEN-T network for all
    heavy-duty vehicles.
    A sensitivity case (PO4s) is provided for PO4 where the measures explained above are
    additionally extended to Belgium, Germany, Luxembourg and the Netherlands, to illustrate
    possible effects when distance-based charging is applied to all vehicles in all centrally
    located Member States (i.e. those with highest levels of transit traffic).
    A general comment from the consultation was that the more restrictions were imposed on
    charging by the Directive, the less likely it was that a Member State would voluntarily
    implement a charging scheme, in spite of its potential benefits. This option, if selected,
    should be implemented with special care. The fact that it would bring HGVs and LDVs on
    a more level playing field was applauded by some stakeholders, including road transport
    associations and environmental organisations, while Member States are divided regarding
    the inclusion of vehicles lighter than 3.5t.
    5.7. Overview of measures and objectives
    Since other possibilities than revising the existing legislation have been ruled out (business
    as usual or soft law), the measures have been packaged in a way to put more or less
    emphasis on the different objectives while addressing passenger and freight transport. At
    the same time, truly alternative options (e.g. addressing only freight or only passenger
    transport) are not viable if all the objectives are to be addressed. The options show
    32
    therefore a cumulative pattern, which allows assessing the effects of key measures, which
    differentiate them, and gauging the desired level of ambition.
    Figure 5-1: Relation between the proposed measures and the specific objectives
    Measures and specific objectives
    Policy Options
    1 2 3a 3b 4
    SO1: Contribute to the reduction of CO2 emissions in transport
    Allowing reduced rates for ZEVs (HDVs and LDVs) 9 9 9 9 9
    Mandatory differentiation of infrastructure charges according to CO2 emissions for
    HDVs
    9 9 9 9
    Mandatory differentiation of tolls and charges for LDVs according to CO2 and
    pollutant emissions
    9 9
    SO2: Contribute to adequate quality of roads
    Regular infrastructure reports 9 9 9 9 9
    Road quality indicators 9 9 9 9 9
    Phase out vignettes for HDVs after 5 years – only distance-based charging 9 9 9 9
    Phase out vignettes for vans – only distance based charging 9
    Phase out vignettes for passenger cars – only distance based charging 9
    SO3: Ensure fair and non-discriminatory road pricing
    Remove exemptions for HGVs <12t 9 9 9 9 9
    Extend rules on tolls and user charges to include busses and coaches 9 9 9 9 9
    Introduce non-discrimination and proportionality requirement for LDVs 9 9 9 9 9
    Phase out vignettes for HDVs after 5 years – only distance based charging 9 9 9 9
    Remove minimum levels of vehicle circulation taxes for HGVs above 12 tonnes 9 9 9 9
    Phase out vignettes for vans – only distance based charging 9
    Phase out vignettes for passenger cars – only distance based charging 9
    SO4: Make use of road charging as an effective tool in reducing pollution and congestion
    Simplification of the requirements for external cost charging 9 9 9 9 9
    Review of caps/values for external cost charging 9 9 9 9 9
    Extend the possibility to use mark-ups beyond mountain regions 9 9 9 9 9
    Phase out Euro class-differentiation 9 9 9 9
    Allow genuine congestion charging for all vehicles (LDVs + HDVs) 9 9 9
    Mandatory differentiation of tolls and charges for LDVs according to CO2 and
    pollutant emissions
    9 9
    Make external cost charging (for air pollution and noise) mandatory for HDVs on the
    tolled TEN-T (charges are applied on top of infrastructure costs)
    9
    Phase out vignettes for passenger cars – only distance based charging 9
    Sensitivity cases (PO2s and PO4s) are not shown in the table above because they include
    the same measures as the main policy options (PO2 and PO4, respectively), while only
    extending the implementation of the measures to few additional Member States. Details are
    available in Annex 4 (section 4.3).
    Some important clarifications at this point:
    • Directive 1999/62/EC does not oblige Member States to introduce road charging on
    their TEN-T or motorway network. All policy options would maintain the same
    approach.
    • Quantifying the impacts of such optional rules requires making assumptions on the
    uptake of road charging by Member States. These assumptions carry important
    uncertainties; the decision of France to abandon the deployment of its network-
    33
    wide distance-based tolling for HGVs (the so called Ecotaxe) just before its launch
    is an example of how national policy orientations can change unexpectedly.
    Denmark and the Netherlands had similar plans to introduce distance-based tolling
    for HGVs but they have also shelved them. For this reason, quantification,
    including modelling results, will only be used to indicate the scale of foreseeable
    impacts rather than their exact estimation. Two additional sensitivity cases (PO2s
    and PO4s) have been quantified for illustration purposes.
    • A model suite has been used for the analytical work, combining the strengths of
    three different models: ASTRA, PRIMES-TREMOVE and TRUST. The model
    suite covers the entire transport system82
    and the macroeconomic impacts. A
    description of each model and its use is provided in Annex 4, section 4.3.
    • For each policy option, assumptions on the changes in Member States responses to
    specific policy measures were made; they are described in Annex 4, section 4.3
    (see Tables 4-1 to 4-13), and have been used as input for modelling. The proposed
    changes are assumed to be applied in full to the schemes that are already in place.
    That is, in case a Member State currently applies time-based charging and this
    possibility is phased out, it is assumed that it will apply distance-based charging in
    order to cover infrastructure costs. The alternative solution for such a Member State
    would be to cover the loss of revenue by increasing taxes (a plausible example is
    provided in Annex 3), but this decision is not possible to predict.
    • The main economic, social and environmental impacts of these policy choices are
    summarised in the following section. A full description of quantifiable effects at
    national level for each policy option is provided in the impact assessment support
    study (see Annex A)83
    . Unless indicated otherwise, quantifiable impacts are
    expressed in percentage changes for each policy option in 2030 compared to the
    Baseline.
    6. ANALYSIS OF IMPACTS
    6.1. Economic impacts
    6.1.1. Transport costs
    The deployment of new tolling schemes and higher toll levels would increase the direct
    costs of both passenger and freight road transport (not taking account of the indirect
    savings accruing from better roads and less congested traffic).
    Changes in transport costs and impact on overall mobility
    The measures introduced in PO1 would be expected to slightly increase road freight
    transport costs in those countries where a change in the existing charging system would
    82
    E.g. transport activity represented at Member State level, by origin-destination and at link level,
    technologies and fuels at Member State level, air pollution emissions at Member State and link level and
    CO2 emissions at Member State level.
    83
    Idem Footnote 14
    34
    take place (i.e. extension of road charging to smaller HGVs or the introduction of mark-
    ups), with marginal impact on road freight transport activity and on its modal share.
    The most significant increase in road freight costs (2.3% in 2030 relative to the Baseline)
    would take place in Germany, where the distance based charging system is extended to
    HGVs below 7.5 tonnes and the external costs charges for air and noise pollution would
    apply to all HGVs (see Figure 6-1).84
    In other Member States where road charging would
    be extended to all HGVs (i.e. Denmark, Luxembourg, the Netherlands, Sweden), smaller
    increases in road freight costs are projected (between 0.2 to 0.5% in 2030 relative to the
    Baseline); impacts are negligible in the UK given the possibility to deduct the vignette
    price from taxes. In Austria the application of higher external cost charges (i.e. for air and
    noise pollution) for HGVs would increase road freight transport cost by 0.8% in 2030
    relative to the Baseline. The application of mark-ups would lead to a 0.5% increase in road
    freight transport costs in Slovenia in 2030 relative to the Baseline, while the impact would
    be more limited in France (0.1% increase).85
    Overall, at EU level PO1 would result in
    0.2% increase in road freight transport costs in 2030 relative to the Baseline and 0.1%
    reduction in road freight transport activity (see Figure 6-2). The extension of road charging
    to buses would not have a significant impact on road passenger transport costs and activity
    in PO1 (see Figure 6-3 and Figure 6-4).
    In PO2 and PO2s, increases in road freight transport costs would be more significant (i.e.
    0.9 to 1.0% in 2030 relative to the Baseline at EU level leading to around 0.2% decrease in
    road freight activity) since all Member States that already have a charging system in place
    for HGVs would have to apply distance-based tolls to all HGVs. The increases in road
    freight transport costs are projected to range between 1.1 and 3% in Denmark, Estonia,
    Finland, Latvia, Luxembourg, Lithuania, the Netherlands, Romania, Sweden and the
    United Kingdom to over 3% in Bulgaria, where current vignette prices are very low (see
    Figure 6-1). The phasing out of vignettes for buses and their replacement with distance-
    based tolls would results in 0.1 to 0.2% increase in road passenger transport costs in
    Bulgaria, Denmark, Finland, Hungary, Romania, Sweden and the United Kingdom, with
    no significant impact on road passenger transport costs and activity at EU level (see Figure
    6-3 and Figure 6-4).
    In PO3, the possible application of congestion charging on the inter-urban network in
    those Member States where this is allowed (i.e. Greece, Spain, France, Croatia, Ireland,
    Italy, Poland and Portugal86
    ) would be expected to lead to a slight increase in road
    transport costs for both freight and passenger transport (0.1 to 0.6%) relative to the
    Baseline in 2030, except for those Member States where the assumed congestion charge is
    similar to the current (relatively low) level of infrastructure charge. The effects would be
    felt in areas where congestion charging is deployed (if a Member State decides so), i.e.
    around major agglomerations where local traffic meets long distance (mainly freight)
    84
    Germany has introduced an external cost charge for air pollutants in 2015 and Austria an external cost
    charge for air pollutants and noise in 2017. For these two Member States that already have external cost
    charges in place, in PO1 it is assumed that the values of the external costs charges are aligned to those of
    the 2014 Handbook on external costs of transport. (Source:
    http://ec.europa.eu/transport/themes/sustainable/internalisation_en.)
    85
    The differences in the magnitude of impact in the two countries can be justified by the lower share that
    the network charged for mark-ups in France has on the total tolled network in the country.
    86
    Member States which apply distance-based charges to all vehicles.
    35
    transport. Overall, at EU level, road freight transport costs would increase by 1.0 to 1.1%
    in 2030 relative to the Baseline in PO3 and road passenger costs by up to 0.1%.
    The mandatory external cost charging for HDVs and the phasing out of vignette systems
    for vans in PO4 and PO4s would result in increased transport costs for users of these
    vehicles (e.g. up to 6% increase in road freight costs in Germany). For road passenger
    transport costs, the changes would be largest in Member States which are assumed to
    implement distance-based charging for passenger cars to replace existing vignette
    schemes (e.g. up to 15% increase in Austria). The overall increase in costs at EU level
    would reach 1.3 to 2% for road passenger transport, due to the phasing in of distance-based
    charges for passenger cars, and 1.5 to 2% for road freight transport with somewhat greater
    impact on transport activity (i.e. 0.2 to 0.6% decrease for road passenger transport and 0.3
    to 0.5% for road freight transport in 2030 relative to the Baseline).
    Figure 6-1: Percentage change in road freight transport costs by Member State in
    Policy Options 1 to 4 relative to the Baseline for 2030
    Road freight cost (%
    change to the Baseline in
    2030)
    Baseline (in
    euro/tkm)
    PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    AT 0.18 0.8% 0.9% 0.9% 1.0% 1.0% 3.9% 4.4%
    BE 0.21 0.2% 1.1% 1.1% 1.2% 1.2% 1.3% 3.7%
    BG 0.22 0.0% 3.9% 3.9% 3.9% 4.0% 5.1% 5.1%
    CY 0.34 0.0% 0.1% 0.1% 0.1% 0.1% 0.4% 0.4%
    CZ 0.15 0.2% 0.6% 0.6% 0.6% 0.6% 0.7% 0.9%
    DE 0.17 2.3% 1.9% 2.0% 2.0% 2.0% 2.1% 6.0%
    DK 0.18 0.3% 2.6% 2.6% 2.6% 2.6% 2.6% 2.9%
    EE 0.19 0.1% 0.6% 2.0% 0.6% 0.6% 0.7% 0.7%
    EL 0.26 0.0% -0.1% -0.1% 0.1% 0.1% 0.4% 0.4%
    ES 0.17 0.1% -0.6% -0.6% -0.4% -0.4% -0.1% 0.0%
    FI 0.24 0.0% 0.3% 1.1% 0.3% 0.3% 0.3% 0.3%
    FR 0.22 0.1% -1.3% -1.3% -1.0% -1.0% -0.5% -0.5%
    HR 0.18 0.3% 0.4% 0.4% 0.5% 0.5% 0.9% 1.2%
    HU 0.18 0.2% 0.8% 0.9% 1.0% 1.1% 2.8% 3.1%
    IE 0.29 0.0% -0.1% -0.1% -0.1% 0.0% 0.0% 0.0%
    IT 0.19 0.0% -0.6% -0.6% 0.1% 0.3% 1.0% 1.1%
    LT 0.19 0.2% 2.3% 2.3% 2.3% 2.3% 2.4% 2.7%
    LU 0.19 0.5% 2.4% 2.4% 2.5% 2.5% 2.7% 5.1%
    LV 0.18 0.3% 2.6% 2.9% 2.8% 2.7% 3.0% 3.5%
    MT 0.23 0.0% 0.2% 0.2% 0.4% 0.4% 0.7% 0.7%
    NL 0.21 0.3% 1.4% 1.4% 1.4% 1.4% 1.5% 3.9%
    PL 0.17 0.1% 0.5% 0.5% 0.6% 0.6% 0.5% 0.7%
    PT 0.20 0.0% -0.6% -0.6% -0.5% -0.5% -0.3% -0.3%
    RO 0.18 0.1% 2.7% 2.7% 2.7% 2.8% 4.9% 5.0%
    SE 0.20 0.2% 2.9% 3.0% 2.9% 2.9% 2.9% 3.1%
    SI 0.22 0.5% 0.9% 0.9% 1.0% 1.0% 1.0% 1.3%
    SK 0.17 0.2% 0.3% 0.3% 0.3% 0.3% 0.3% 0.6%
    UK 0.27 0.0% 1.3% 1.3% 1.3% 1.3% 1.7% 1.8%
    Source: ASTRA model; Note: Road freight transport costs cover fuel costs and road charges applied for HGVs and vans.
    For the Baseline, the levels of road transport costs are provided for 2030, expressed in euro per tonne-kilometre
    (euro/tkm).
    36
    Figure 6-2: Percentage change in road freight transport costs and road freight
    transport activity for EU28 in Policy Options 1 to 4 relative to the Baseline for 2030
    Road freight transport (% change to the
    Baseline in 2030)
    PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    Road freight transport costs 0.2% 0.9% 1.0% 1.0% 1.1% 1.5% 2.0%
    Road freight transport activity -0.1% -0.2% -0.2% -0.2% -0.2% -0.3% -0.5%
    Source: ASTRA model
    For freight transport, the modelled increase in transport costs takes into account the
    possible use of revenues from road charging to reduce vehicle taxation for HGVs and vans.
    The results of the modelling show therefore net changes in costs.
    Figure 6-3: Percentage change in road passenger transport costs by Member State in
    Policy Options 1 to 4 relative to the Baseline for 2030
    Road passenger cost (%
    change to the Baseline in
    2030)
    Baseline (in
    euro/pkm)
    PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    AT 0.18 0.0% 0.0% 0.0% 0.0% -0.1% 14.8% 15.2%
    BE 0.15 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 4.6%
    BG 0.13 0.0% 0.1% 0.1% 0.1% 0.1% 2.3% 2.4%
    CY 0.20 0.0% 0.0% 0.0% 0.0% 0.0% 0.3% 0.5%
    CZ 0.17 0.0% 0.0% 0.0% 0.0% -0.1% 2.9% 3.2%
    DE 0.21 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 5.6%
    DK 0.15 0.0% 0.1% 0.1% 0.1% 0.1% 0.1% 0.6%
    EE 0.17 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.4%
    EL 0.20 0.0% 0.0% 0.0% 0.6% 0.3% 0.4% 0.4%
    ES 0.16 0.0% 0.0% 0.0% 0.3% 0.2% 0.2% 0.2%
    FI 0.16 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0%
    FR 0.16 0.0% 0.0% 0.0% 0.4% 0.1% 0.1% 0.2%
    HR 0.28 0.0% 0.0% 0.0% 0.0% -0.2% 0.3% 0.5%
    HU 0.17 0.0% 0.1% 0.1% 0.1% -0.1% 1.7% 1.8%
    IE 0.19 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
    IT 0.18 0.0% 0.0% 0.0% 0.5% 0.4% 0.5% 0.5%
    LT 0.13 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.3%
    LU 0.14 0.0% 0.0% 0.0% 0.1% 0.0% 0.1% 4.7%
    LV 0.16 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.2%
    MT 0.15 0.0% 0.0% 0.0% 0.1% 0.0% 0.1% 0.1%
    NL 0.19 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3.8%
    PL 0.15 0.0% 0.0% 0.0% 0.1% 0.0% 0.1% 0.2%
    PT 0.21 0.0% 0.0% 0.0% 0.0% -0.1% -0.1% -0.1%
    RO 0.15 0.0% 0.1% 0.1% 0.1% 0.0% 4.7% 4.8%
    SE 0.18 0.0% 0.2% 0.2% 0.2% 0.2% 0.2% 0.3%
    SI 0.21 0.0% 0.2% 0.2% 0.2% 0.0% 1.3% 1.6%
    SK 0.18 0.0% 0.0% 0.0% 0.0% -0.2% 4.9% 5.0%
    UK 0.18 0.0% 0.1% 0.1% 0.1% 0.1% 0.1% 0.1%
    Source: ASTRA model; Note: Road passenger transport costs cover fuel costs and road charges applied for cars, buses
    and coaches. For the Baseline, the levels of road transport costs are provided for 2030, expressed in euro per passenger-
    kilometre (euro/pkm).
    Figure 6-4: Percentage change in road passenger transport costs and road passenger
    transport activity for EU28 in Policy Options 1 to 4 relative to the Baseline for 2030
    37
    Road passenger transport (%
    change to the Baseline in 2030)
    PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    Road passenger transport costs 0.0% 0.0% 0.0% 0.1% 0.0% 1.3% 2.0%
    Road passenger transport activity 0.0% 0.0% 0.0% -0.1% 0.0% -0.2% -0.6%
    Source: ASTRA model
    For passenger transport, the modelled increase in transport costs does not take into account
    any possible reduction in vehicle taxation, by which Member States might want to
    compensate for the higher costs attached to the introduction or extension of road charging
    to passenger cars and buses. The results of the modelling show therefore potentially larger
    increase in costs than what motorists might face in reality.
    Impact on consumer prices
    The extent to which the above cost increases for road freight would result in increased
    consumer prices depends on the extent to which road charges make up a significant
    proportion of the final costs (0.01 to 1.43% for typical consumer goods)87
    , and the extent to
    which cost increases faced by hauliers are passed through. Even if 100% of cost increases
    are passed through to shippers, an assumption which is consistent with studies in Germany,
    Austria and Switzerland, the impact on consumer prices would be negligible. According to
    the impact assessment support study, the average increase in product prices would be in the
    range of up to 0.02% for PO1 and up to 0.25% for PO4.
    6.1.2. Congestion cost
    The level of road charges has an impact on the behaviour of road users, which can be
    affected in different ways: route shift, modal shift and travel frequency reduction. Time-
    differentiated charges also result in travel time shift.
    In PO1, the level of charges would only change for the use of HGVs between 3.5 and 12
    tonnes as explained above, which would result in a reduction of the HGVs delay costs from
    congestion of about 0.1% at EU level in 2030 relative to the Baseline (0.4% decrease in
    Germany). In areas with acute congestion, where significant environmental damage is
    caused by heavy traffic and mark-ups are applied for HGVs to finance the construction of
    alternative transport infrastructure (e.g. in France and Slovenia), there would be some
    limited redistribution of HGVs traffic on the adjacent network (1% reduction in Slovenia
    for HGVs delay costs in 2030 relative to the Baseline and 0.2% decrease in France).
    However, the overall road congestion costs at EU level (i.e. delay costs from congestion
    for passenger cars and HGVs) in PO1 are similar to those in the Baseline.
    Under PO2 and PO2s road congestion cost at EU level would only be marginally affected
    (0.2% reduction in 2030 relative to the Baseline) with a slightly more important decrease
    for HGVs (1.5% decrease) thanks to the generalised application for them of distance-based
    charging. HGVs delay costs from congestion would decrease by 3 to 7.1% in Belgium,
    Denmark, the Netherlands, Slovakia and the United Kingdom in 2030 relative to the
    87
    Calculation assuming that road charges represent 1 to 15% of operating cost of hauliers and transport
    costs make up 0.8 to 9.5% of the final price. Cf. impact assessment support study. Nb. transport costs may
    not only mean road transport costs, nevertheless, these numbers provide a good indication of the
    magnitude of possible changes in consumer prices induced by the variation of road charges.
    38
    Baseline (0.7 to 1.7% decrease for overall road transport). Substantial decreases in road
    congestion costs (i.e. for passenger cars and HGVs) at EU level are only projected under
    PO3 (2.4% reduction in PO3a and 2.5% reduction in PO3b in 2030 relative to the
    Baseline) with the positive effects felt in those Member States in which congestion
    charging can be applied as all vehicles are charged per km (such as Greece, France, Italy,
    Poland and Portugal), and in PO4 and PO4s (2.5 to 6.1% reduction), under which vans and
    passenger cars are charged by distance and Member States can apply congestion charging
    on congested sections of the network.
    Benefits resulting from congestion costs savings relative to the Baseline over time,
    represented as present value in 2015, are projected to be significant in PO3 and PO4 (i.e.
    €8.8 billion in PO3a, €8.9 billion in PO3b, €9.1 billion in PO4 and €22.2 billion in PO4s)
    while they are more limited in PO1 and PO2 (i.e. €0.1 billion and 0.8 billion).
    6.1.3. Impact on SMEs88
    Close to 100% of firms in the road freight sector are companies with fewer than 250
    employees, while 90% are micro-enterprises (Eurostat, 2017). The proposed policy
    measures are likely to involve small increases in the costs of transport (see Section 6.1.1)
    due to the introduction of new road tolls in certain Member States and the greater use of
    external cost charges (under PO2, PO3 and PO4). However, because of very small profit
    margins in the road haulage sector, most of those increases (see Figure 6-1) would be
    passed through to shippers as indicated above (on average max. 1.5 to 2% increase in road
    freight costs in PO4 and PO4s in 2030 relative to the Baseline). As such, it is expected that
    increased transport costs in all policy options could only have minor negative impacts on
    SMEs; they may be less able to absorb additional costs, but no substantial distortions are
    expected.
    Introducing congestion charging would also likely impact the small firms, which may have
    no choice but to drive in peak hours because they have to maximise utilisation of their
    vehicles (Mahendra, 2010). At the same time, the same firms would benefit from lower
    congestion, which would result in time savings and an effective increase in the catchment
    area for the business. Given limited experience with inter-urban congestion charging, it is
    difficult to say what the net impacts would be – however, evaluations of the London
    congestion charge found no discernible impact on businesses (TfL, 2008), suggesting that
    more limited, targeted interurban congestion charging foreseen in PO3 and PO4 would not
    have significant impacts on SMEs (positive or negative).
    The measures to promote low and zero-emission vehicles (all POs) may benefit SMEs less
    in the short-term compared to larger firms, since SMEs may face more difficulties in
    making the upfront investment for more expensive low CO2 vehicles89
    . If SMEs are less
    able to purchase or lease low CO2 vehicles, they would initially benefit less from the
    88
    More details are available in Ricardo et al. (2017), Support Study for the Impact Assessment
    Accompanying the Revision of Directive 1999/62/EC.
    89
    For example, Nissan e-NV200 electric van is 47% more expensive to purchase and lease compared to its
    diesel equivalent, the NV200 (Low Carbon Vehicle Partnership, 2016), and for electric trucks are priced
    170-280% higher than a conventional equivalent (CE Delft, 2013).
    39
    measure compared to a larger firm. However, in the longer term it can be expected that the
    price of electric vehicles will reduce (Wolfram & Lutsey, 2016), making the upfront
    investment less of a barrier. Furthermore, SMEs typically buy their vehicles on the second-
    hand market (BCA, 2012). If the measure stimulates additional first-hand purchases of
    zero-emission vehicles, these would eventually reach the second-hand market and SMEs
    will also benefit from having access to zero-emission vehicles.
    6.1.4. Member States budgets
    6.1.4.1. Revenues from tolling
    One of the main impacts of the analysed options is on revenues from road transport.
    Percentage changes in toll revenues from road transport at EU level relative to the Baseline
    for 2030 are shown in Figure 6-5 and their absolute levels by Member State in Figure 6-6.
    Toll revenues are marginally affected by promotional rates for zero emission vehicles as
    generally these would still represent a small share of vehicle fleet in 2030.
    In PO1, the main driver of the increase is the extension of tolling to HGVs below 7.5
    tonnes in Germany, which is expected to increase revenues by 51% in 2030 relative to the
    Baseline. The introduction of vignettes for HGVs below 12 tonnes is expected to lead to
    increases in total revenues varying from 155% in Luxembourg (where most of domestic
    traffic is performed by vehicles below 12 tonnes) to 17% in Sweden in 2030 relative to the
    Baseline. In Slovenia the application of mark-ups would increase revenues from HGVs and
    buses by 13% in 2030 relative to the Baseline. In large countries, such as France, the effect
    of mark-ups on revenues would be smaller (2% increase in revenues from HGVs and
    buses).
    In PO2 and PO2s, revenues would be larger thanks to the generalised application of
    distance-based tolls to HGVs and buses. In this case, overall revenues increase by 15% at
    EU level, with the entire burden borne by HGVs and buses. The impact on specific
    Member States would be different depending on whether they already have distance-based
    charging in place or not. For example, larger increases would take place in Member States
    that have treated buses differently so far (e.g. 58% increase in total toll revenues in
    Germany in 2030 relative to the Baseline, 23% increase in Belgium and 13% in Hungary).
    For Member States which do not currently have distance-based charging in place, increases
    in revenues vary between 32% in Romania and can reach up to a 19-fold increase in
    Luxembourg.
    Under PO3a and PO3b, revenues would further increase by 25 to 28% compared to the
    Baseline in 2030 thanks to the application of congestion charges in eight Member States90
    .
    Overall increases are largest in Greece, Italy and Poland (over 20%), with significant
    increases (over 10%) in Portugal, Spain and France.
    PO4 and PO4s will generate most revenues (60 to 160%) with the phase in of distance-
    based schemes for vans and passenger cars in Member States applying road charges.
    Figure 6-5: Percentage change in EU toll revenues from road transport in Policy
    Options 1 to 4 relative to the Baseline for 2030
    90
    Greece, Spain, France, Croatia, Ireland, Italy, Poland and Portugal.
    40
    Revenues from road charging (%
    change to the Baseline in 2030)
    TOTAL HGVs Buses Vans Cars
    Baseline (in billion euro) 39.5 12.1 0.0 1.1 26.2
    PO1 5.2% 19.2% 2.6% -0.9% -1.1%
    PO2 14.5% 49.3% 92.2% -0.7% -1.1%
    PO2s 14.8% 50.3% 97.6% -0.7% -1.1%
    PO3a 28.0% 54.2% 108.1% 13.2% 16.4%
    PO3b 24.7% 54.2% 107.4% 26.2% 10.9%
    PO4 60.2% 64.8% 154.3% 64.6% 57.7%
    PO4s 160.5% 86.0% 173.0% 209.3% 192.9%
    Source: ASTRA model
    The level of revenues from road charging in the Baseline and PO1 to PO4 by Member
    State is provided in Figure 6-6.
    Figure 6-6: Projected annual toll revenues from road transport by Member State in
    2030 (in billion euro)
    Country Baseline PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    AT 2.2 2.3 2.4 2.4 2.4 2.3 8.8 8.7
    BE 0.6 0.6 0.7 0.7 0.7 0.7 0.7 3.6
    BG 0.1 0.1 0.3 0.3 0.3 0.3 0.6 0.6
    CY 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
    CZ 0.5 0.5 0.6 0.6 0.6 0.5 2.1 2.1
    DE 4.2 6.3 6.6 6.6 6.6 6.6 6.6 39.9
    DK 0.0 0.0 0.2 0.2 0.2 0.2 0.2 0.2
    EE 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
    EL 0.9 0.8 0.8 0.8 1.2 1.0 1.1 1.1
    ES 3.0 3.0 3.0 3.0 3.4 3.4 3.5 3.5
    FI 0.0 0.0 0.0 0.1 0.0 0.0 0.0 0.0
    FR 14.5 14.3 14.8 14.8 17.1 16.4 16.9 16.8
    HR 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5
    HU 0.7 0.7 0.8 0.8 0.8 0.7 1.2 1.2
    IE 0.4 0.4 0.4 0.4 0.4 0.3 0.3 0.3
    IT 8.6 8.5 8.5 8.5 10.5 10.4 10.7 10.7
    LT 0.0 0.0 0.1 0.1 0.1 0.1 0.1 0.1
    LU 0.0 0.0 0.1 0.1 0.1 0.1 0.1 0.2
    LV 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
    MT 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
    NL 0.0 0.0 0.3 0.3 0.3 0.3 0.3 3.6
    PL 0.8 0.8 1.0 1.0 1.1 1.0 1.0 1.0
    PT 1.0 1.0 1.0 1.0 1.2 1.1 1.1 1.1
    RO 0.5 0.5 0.7 0.7 0.7 0.7 3.2 3.2
    SE 0.1 0.1 0.5 0.5 0.5 0.5 0.5 0.5
    SI 0.4 0.5 0.5 0.5 0.5 0.5 0.9 0.9
    SK 0.3 0.3 0.4 0.4 0.4 0.3 1.4 1.4
    41
    Country Baseline PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    UK 0.1 0.2 1.2 1.2 1.2 1.2 1.4 1.4
    EU28 39.5 41.5 45.2 45.4 50.6 49.3 63.3 102.9
    Source: ASTRA model
    The modelled increases in revenues does not take into account any possible reduction in
    vehicle taxation, by which Member States might want to compensate for the higher costs
    attached to the introduction or extension of road charging.
    6.1.4.2. Costs to authorities
    The setup of new electronic distance-based road charging systems induces considerable
    costs. For DSRC systems, roadside infrastructure constitutes the heaviest cost element: a
    gantry must be installed on each stretch of road at a cost of around €150,00091
    . For satellite
    based systems, on-board units (OBUs) are the most important setup cost element: an OBU
    for a satellite-based road charging scheme will cost between EUR 90 and EUR 150. While
    exact cost structure depends on the specific network covered, as a general rule satellite-
    based systems are more economic when a larger network is to be covered (over 1000 km)
    and building roadside infrastructure would be very expensive.
    Under PO1, additional costs would not be significant as no new system would be
    implemented. The costs of PO2 and PO3 would be similar, driven by the replacement of
    vignette systems with distance-based tolls within 5 years for HGVs and buses. PO4 has the
    highest cost because of the assumed extension of distance-based systems to passenger cars
    and vans in some Member States as a result of phasing out time-based charging.
    The costs were estimated using reference countries for which the system costs are well-
    understood92
    . It was assumed that countries with a larger tolled network would, in most
    cases, choose GNSS, whereas those with smaller ones would generally opt for DSRC93
    :
    • GNSS: Bulgaria, Netherlands, Romania, United Kingdom
    • DSRC: Denmark, Latvia, Lithuania, Luxemburg, Sweden
    For Member States choosing to introduce new road tolls, this result in an initial investment
    cost of around €150 million (€82 million to €232 million, depending on the size of the
    country) and ongoing maintenance/enforcement costs of around €20 million per year (€9
    million to €41 million). These costs would be largely counterbalanced by increased
    revenues from road user charges in all cases, which would be significantly greater than the
    ongoing costs.
    91
    Commission Staff Working Paper (2013), Impact Assessment accompanying the initiative on fair and
    efficient pricing (not published).
    92
    For GNSS-based schemes the reference country is Belgium, for DSRC-based countries the reference
    country is Slovenia
    93
    In line with the Study on “State of the Art of Electronic Road Tolling” MOVE/D3/2014-259, which
    reported that GNSS is generally of greater economic interest where the size of the tolled network is
    larger.
    42
    Figure 6-7: Impact on costs to authorities (in addition to the Baseline costs)
    PO1 PO2 and
    PO2s
    PO3a PO3b PO4 and
    PO4s
    Total investment
    costs
    0
    Not significant
    €1,202 (main option) to €1,387 million
    (sensitivity option)
    €1,334 to
    €2,139 million
    Total annual
    operational costs
    € 168 (main option) to €200 million/year
    (sensitivity option)
    €184 to €313
    million/year
    Total investment and
    operational costs till
    2030 (present value)
    0
    Not significant
    €2,036 (main option) to €2,382 million
    (sensitivity option)
    €2,247 to
    €3,682 million
    The investment expenditures of €1.2 to 1.4 billion in PO2 and PO3 and €1.3 to 2.1 billion
    in PO4 are assumed to take place in 2025, in line with the assumed introduction of
    distance-based charges. Figure 6-8 shows the impact on Member States budgets in 2030,
    considering the additional revenues from road charges relative to the Baseline and the costs
    to authorities in 2030.
    Figure 6-8: Impact on Member States budgets in 2030
    € billion/year PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    Additional revenues from road
    charges relative to the Baseline in
    2030 2.0 5.7 5.9 11.1 9.8 23.8 63.4
    Additional annual costs to
    authorities 0 0.2 0.2 0.2 0.2 0.2 0.3
    Balance 2.0 5.5 5.7 10.9 9.6 23.7 63.1
    Figure 6-9 provides the overall impact on Member States budges over time by considering
    the present value of revenues from road charges and of the total investment and operation
    costs to authorities. The balance is positive for all policy options.
    Figure 6-9: Overall impact on Member States budgets over time (till 2030)
    Present value (in billion €) PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    Additional revenues from road charges
    relative to the Baseline 20.8 34.2 34.6 52.6 40.5 89.6 226.2
    Total costs to authorities 0.0 2.0 2.4 2.0 2.0 2.2 3.7
    Balance 20.8 31.8 32.2 50.2 38.1 85.9 222.6
    6.1.5. Compliance costs to road users
    Apart from increased transport costs shown in section 6.1.1, the main costs to road users
    relate to the on-board unit (OBU) procurement costs and related compliance costs. These
    are calculated based on the findings of the Support study for the Impact Assessment for the
    Revision of EETS Legislation94
    . The overall costs to users in PO4 is higher compared to
    PO2 and PO3 because of the large number of additional vehicles that are under the scope
    of the toll schemes (i.e. due to the relatively larger fleet of vans and passenger cars
    compared to HGVs and buses); however, the unit costs are the same, composed as follows:
    94
    Ricardo/TRT/4icom, 2017
    43
    • 104€ yearly per OBU, for OBUs provided by the Member States95
    ;
    • 15€ yearly per OBU, for OBUs provided by EETS providers, which corresponds to the
    extension to a new MS of the fees paid by users contracting with EETS providers96
    .
    It is assumed that passenger cars are not required to equip with OBUs (but may do so
    voluntarily, as a matter of convenience, as is the case today in France and Italy etc.). The
    impact of PO4 and PO4s on costs to road users is evaluated at €8 million yearly from 2020
    (the assumed year of introduction of the new Bulgarian system) to 2025 and at €320
    million yearly from 2025 onward, when the other Member States would have to adapt their
    charging systems. If passenger cars were equipped with OBUs, the annual cost would be
    €850 million. Detailed calculations are provided in Annex G of the impact assessment
    support study97
    .
    Figure 6-10: Impact on compliance costs to road users
    PO1 PO2 and
    PO2s
    PO3a PO3b PO4 and PO4s
    OPEX
    (€million/year)
    0
    Not
    significant
    €8 million/year from 2020 to 2025;
    €198 million/year from 2025 onward
    (€228 million/year from 2025 onward
    for the sensitivity case)
    €8 million/year from 2020 to
    2025;
    €240 million to 850 million /year
    from 2025 onward
    OPEX
    (present value)
    0
    Not
    significant
    €889 to €1,018 million (for the
    sensitivity case)
    €1,070 million
    (€3,698 million if passenger cars
    were equipped with OBUs)
    Overall compliance costs by 2030, expressed as present value, would be €889 to €1,027
    million for PO2 and PO3 and €1,070 to €1,371 million in PO4 (€3,698 million if passenger
    cars were equipped with OBUs).
    6.1.6. Road quality
    Since Member States tend to allocate at least part of the toll revenues to the maintenance of
    roads, the level of the collected revenues can serve as a proxy indicator. Thus, it is
    assumed that if more revenues are collected from road charges, the quality of the
    corresponding network would improve. Under this assumption, PO1 would have very
    limited to no impact on road quality, while the subsequent options (PO2-3-4) would have
    increasingly positive impact thanks to the increasing amount of toll revenues. Since
    revenues from congestion charging would have to be allocated to investment in transport,
    the positive impact in PO3 and PO4 would in principle be greatest.
    95
    This is composed of the following average costs: rental or deposit of OBUs (€10,84), fees for bank
    guarantee (€6), installation/removal costs (€12,55); training to the drivers (for the use of OBU,
    compliance, €6,14); time losses (i.e. installation/removal of OBUs, registration at Service Point, €13,51);
    administrative costs (translated from FTEs, €55,28).
    96
    The cost is much lower as it is assumed that users operating with this type of OBU already have an OBU
    for other countries by the time of the application of the measure; thus, additional costs include the
    extension to a new Member State of the fees paid by users contracting with EETS providers, i.e.: 0,5%
    fees applied on an assumed €250 monthly paid toll (0,5% x €250 x 12 = €15)
    97
    Idem footnote 14
    44
    Based on the latest infrastructure maintenance plan of Germany98
    , the yearly expenses
    necessary to keep main national roads in stable condition would amount to roughly €61
    billion for the EU in 2030. This, compared to projected revenues gives an indication of the
    expected quality of roads. Figure 6-11 presents the difference compared to financing needs
    under each policy option. It appears that only in the case of PO4 would toll revenues cover
    all maintenance needs, thereby raising sufficient funds for developing alternatives to
    congested road transport.
    Figure 6-11: Comparison of financing needs and road charging revenues for PO1 to
    PO4 against the Baseline in 2030
    € billion Baseline PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    Revenues from tolls 39.5 41.5 45.2 45.4 50.6 49.3 63.3 102.9
    Financial needs for road maintenance
    60.8 60.8 60.8 60.8 60.8 60.8 60.8 60.8
    Level of coverage of maintenance
    needs 65% 68% 74% 75% 83% 81% 104% 169%
    Missing/remaining revenues -21.3 -19.3 -15.6 -15.4 -10.2 -11.5 2.5 42.1
    Annex 12 provides more information on the possible impact of specific measures designed
    to ensure better road quality and synergies with the main policy packages.
    6.1.7. Regional distribution of impacts
    Road pricing affects central and peripheral regions differently. While centrally located
    Member States are most affected by the negative impacts of transit traffic, they have the
    possibility to collect the corresponding higher amounts of revenues to mitigate those
    impacts (e.g. through external cost charging following the phasing out of differentiation
    according to Euro class in PO2, PO3 and PO4). At the same time, businesses (and to a
    lesser extent citizens) located in peripheral Member States can face higher overall costs
    from road charges depending on their choice of route but they are also the ones who make
    most use of the infrastructure and thus cause more environmental damage (they would not
    pay more per km). Looking simply at who pays more between central and peripheral
    Member States would only show one side of the coin.
    Desk research99
    of studies on existing tolls across Europe indicates that regional impacts
    are small, and not necessarily clearly negative. Specifically, studies on the German toll and
    those conducted in Sweden and Switzerland (mountain regions) found that the impacts of
    tolls on businesses were insignificant (thanks to the relatively small share of road charges
    in the total cost of operation). In any case, lower level roads giving access to remote
    regions with no alternative transport solution are generally not tolled, while in the case of
    long distance travel there are usually different options to choose from. It can therefore be
    concluded that greater uptake of road tolls/external cost charges will result in small or
    negligible negative impacts for peripheral economies in relation to central regions.
    Congestion charging would have additional impacts in PO3 and PO4. Since inter-urban
    congestion has not been studied as extensively as urban schemes, a parametric assessment
    98
    Ibid Footnote 72
    99
    Ibid Footnote 14
    45
    of the relationship between accessibility and local/regional impacts quantified according to
    literature was performed as part of the impact assessment support study100
    . The analysis
    found that congestion charging can have an effect of between -1.1% and +1.0% on regional
    GDP, depending on the case (but can be slightly negative or positive in each case). The
    impact would be largest and most likely positive in more congested areas such as around
    major economic centres. It seems plausible to assume that Member States would only
    implement congestion charging where local conditions justify it. Overall impacts would be
    small but increasing from PO1 to PO4 as shown in the table below.
    Figure 6-12: Impact of road user charging on peripheral regions
    Indicator PO1 PO2 PO3a PO3b PO4
    Road pricing
    0
    Negligible
    2
    Peripheral regions could face a marginal increase in the costs for their
    imports and exports that in the short run may not be compensated by
    the increase in welfare from the reduction of externalities in the
    region. Overall, any negative impacts are expected to be small.
    Regions with a high proportion of through-traffic would benefit from
    the reduction of externalities and increased toll income
    Congestion
    charges
    0
    N/A
    3
    Potential positive impact (up to 1% GDP) in some
    regions with high congestion, due to introduction
    of congestion charges
    CO2 measures
    0
    Negligible
    Overall regional
    impacts
    0
    Negligible
    0
    Negligible
    3/2
    Small positive impact in regions of high
    congestion. Small negative to no impact on
    peripheral regions.
    6.1.8. Macroeconomic environment
    The direct impact of road charging at macro-economic level is small due to the relatively
    low share of road charges in transport operation costs and even lower share in product
    prices (cf. section 6.1.1). The evaluation performed with the ASTRA model does not take
    into account the possible reinvestment of at least part of the additional toll revenues
    (relative to the Baseline), which, if used for the maintenance of roads typically generates 2
    to 3 euro for each invested euro101
    . The results therefore do not reflect possible positive
    second order effects. The modelling results show very limited impacts (below 0.1%
    relative to the Baseline in 2030) on GDP at EU level in case of PO1, PO2 and PO3. PO4
    and PO4s would result in 0.1% decrease of EU GDP in 2030 relative to the Baseline, in
    case no reinvestment of toll revenues is assumed. If 100% of the additional revenues
    relative to the Baseline were reinvested in road maintenance, the economic benefit
    generated at EU level would be in the range of €6.1 billion (PO1) to €190.2 billion (PO4s),
    equivalent to 0.04 to 1.2% of GDP in 2030. However, if only 30% of the additional
    revenues relative to the Baseline were reinvested in road maintenance, the economic
    100
    Full details of the analysis can be found in Annex D of Ricardo et al. (2017), Support Study for the
    Impact Assessment Accompanying the Revision of Directive 1999/62/EC. See Annex 13.
    101
    According to the Impact Assessment accompanying the Proposal for a Regulation of the European
    Parliament and of the Council on Union Guidelines for the development of the Trans-European
    Transport Network, SEC(2011) 1212 final, the multiplier effect is 2.34
    46
    benefits would be more limited, in the range of €1.8 billion (PO1) to €57.1 billion (PO4s),
    equivalent to 0.01 to 0.36% of GDP in 2030. Effects on employment are described in
    section 6.3.1.
    Figure 6-13: Potential economic benefits (in case of 30% and 100% earmarking to
    transport investments) – in 2030 compared to the Baseline
    Earmarking
    Additional benefits,
    expressed in:
    PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    30%
    - € billions per year 1.8 5.2 5.3 10.0 8.8 21.4 57.1
    - % of annual GDP 0.01% 0.03% 0.03% 0.06% 0.06% 0.14% 0.36%
    100%
    - € billions per year 6.1 17.2 17.6 33.2 29.3 71.4 190.2
    - % of annual GDP 0.04% 0.11% 0.11% 0.21% 0.19% 0.45% 1.20%
    At Member State level, the impacts may be larger depending on the size of the Member
    State and specific measures implemented. For example, in Slovenia the benefits could be
    higher due to the application of mark-ups; in this case the revenues must be reinvested to
    remove bottlenecks on the TEN-T network.
    In addition, there will be positive impacts stemming from the reduction of negative
    externalities in PO2, PO3 and PO4 (cf. section 6.3.2); as well as from reducing the
    dependence on oil as shown in Figure 6-14, which is mostly imported.
    Figure 6-14: Gasoline and diesel consumption from road sector relative to the
    Baseline in 2030 (% change)
    47
    6.1.9. Competitiveness of the EU economy
    As shown in section 6.1.1, all policy options would affect transport operators in a limited
    way through a slight increase in transport costs but this would not have a significant impact
    on the EU economy. The reinvestment of revenues from road charging would bring
    economic benefits, as described in the previous section. Indirectly, operators who chose to
    adapt their behaviour to improve their efficiency would gain a competitive advantage, as
    well as contributing to the overall competitiveness of the EU economy.
    Even under scenarios of 100% cost pass-through to customers, any reduction in the
    competitiveness of European manufacturing products on the global market would be
    minimal in all Policy Options. PO3 and PO4 would have more positive impact as
    congestion charging will improve the reliability of deliveries, which can allow keeping
    smaller stocks, and thus will be beneficial the competitiveness of businesses, especially
    those that make use of just-in-time manufacturing (where delays can cost much more than
    just the truck delay) or in which goods are perishable, costly or difficult to warehouse.102
    The measures designed to promote low- and zero-emissions HGVs and buses (PO2, PO3
    and PO4), and low- and zero-emission passenger cars and vans (PO3b and PO4) would
    have a positive impact on the automotive industry as they would speed up fleet renewal.
    According to the modelling results, in 2030 the share of hybrid HGVs below 12 tonnes at
    EU level would be about 3.6 percentage points higher in PO2, PO2s, PO3, PO4 and PO4s
    than in the Baseline scenario. For heavier HGVs the impact would be smaller (i.e. the share
    of hybrid HGVs above 12 tonnes would be 2.2 percentage point higher relative to the
    Baseline) but positive. These measures would also drive a slight increase in the share of
    LNG HGVs in PO2, PO2s, PO3, PO4 and PO4s (around 0.7 percentage points increase in
    2030 relative to the Baseline). In PO3b, PO4 and PO4s the differentiation of charges
    according to CO2 emissions additionally targets the fleet of passenger cars and vans,
    resulting in a slightly higher uptake of conventional hybrid (0.2 percentage points) and
    electric vehicles (0.2 percentage points) in 2030 relative to the Baseline, to the detriment of
    conventional diesel vehicles. The structure of the vehicle fleet in PO1 would be similar to
    the Baseline.
    6.1.10. Functioning of the internal market
    Tolls and user charges reflect a part of real costs that transport users generate in relation to
    infrastructure and other externalities. Unless these real costs of transport are paid by users,
    they will have to be borne by society through other instruments such as taxes. However,
    road user charges are more efficient – by sending the correct price signals: user charges
    can shape more sustainable transport behaviour, e.g. re-directing road users to acquiring
    and using cleaner vehicles or using the roads outside peak hours. Moreover, distance-based
    charges are paid by users independent of their country of establishment (unlike time-based
    vignettes or vehicle taxes).
    Since road pricing across the EU becomes more consistent under each option (to an
    increasing extent from PO1 to PO4), the transport sector as well as other sectors relying on
    102
    Cf. section 4.2.10 of the impact assessment support study.
    48
    transport services will face similar or at least proportionate costs when making use of the
    European road network. In this sense, PO1 will ensure minimal progress by eliminating
    exemptions and making all HGVs and buses subject to charging, while in PO2 and PO3,
    the level playing field will be further ensured for HGVs and buses due to generalised
    distance-based charging. PO4 will have the most positive impact as distance-based charges
    would also apply to vans and passenger cars.
    In addition, in PO2, PO3 and PO4 more consistent price signals would be achieved through
    the phasing out of Euro class differentiation allowing more extensive use of external cost
    charging. PO3 and PO4 would add further benefits by allowing freer traffic flows by
    internalising the cost of congestion.
    6.1.11. Impact on third countries
    Third country residents would benefit from proportionate pricing of short term vignettes
    under each policy option as any occasional EU driver (see also section 6.3.4). By having
    access to proportionately priced vignettes for shorter time periods, users are more likely to
    consider single day leisure or business trips across borders encouraging cross border
    trading, commuting, commercial or social trips103
    . Where a Member State would replace
    their vignette scheme by distance-based charging (in PO4), the increase in transport costs
    would be the same for third country residents as for EU nationals.
    Hauliers from Russia, Turkey, Ukraine and the Balkans, who are some of the EU’s main
    commercial partners, are most likely to be impacted by the small increases in transport
    costs under PO2, PO3 and PO4. However, they are not likely to be more affected than
    European operators established in peripheral regions, as described in section 6.1.7.
    6.2. Environmental impacts
    6.2.1. CO2 emissions
    The impact of policy options on CO2 emissions depend on changes in transport activity and
    in the share of low- and zero-emission vehicles in the fleet compared to the Baseline. PO1
    has no impact on HGVs fleet composition (the rebates applied to zero-emission vehicles
    alone would not have noticeable effect) and induces a marginal shift of traffic from road to
    rail transport (i.e. 0.1 percentage point decrease in road freight modal share in 2030
    relative to the Baseline). Consequently, it has no significant impact on fuel consumption
    and road transport CO2 emissions (157 ktonnes of CO2 emissions saved) relative to the
    Baseline in 2030.
    PO2, PO2s and PO3a introduce the differentiation of infrastructure changes according to
    CO2 emissions for HGVs and buses. In addition, the generalisation of distance-based
    charges for HGVs and buses has somewhat larger effect on modal shift (i.e. 0.1 to 0.2
    percentage point decrease in road freight modal share in 2030 relative to the Baseline) but
    this remains limited. Most of the impacts are thus driven by changes in fleet composition
    due to the modulation of charges. As noted in section 6.1.8, a shift away from diesel can
    103
    Ibid Footnote 65
    49
    mainly be observed among vehicles below 12 tonnes (to hybrids and LNG trucks) and to a
    more limited extent for vehicles above 12 tonnes. This would result in a small reduction of
    0.4% in road transport CO2 emissions (i.e. 2,490 to 2,505 ktonnes of CO2 emissions saved
    in PO2 and PO2s and 2,878 ktonnes of CO2 emissions saved in PO3a) relative to the
    Baseline in 2030.
    The differentiation of charges for vans and passenger cars under PO3b, PO4 and PO4s
    would drive changes in the composition of the fleet, resulting in a reduction of road diesel
    consumption of 1.3 to 1.8% and an increase in the use of electricity in road transport of 3.3
    to 3.4% relative to the Baseline in 2030. In addition, in PO4 and PO4s, the phasing in of
    distance-based charging for vans and passenger cars further increases the CO2 reduction
    potential. These changes would result in a reduction of CO2 emissions from road transport
    of 0.5% in PO3b and 0.7 to 1.0% in PO4 and PO4s relative to the Baseline for 2030 (i.e.
    3,812 ktonnes of CO2 emissions saved in PO3b and 4,765 to 7,100 ktonnes saved in PO4
    and PO4s).
    As explained in section 2.1.1, the analytical work underpinning the European Strategy for
    Low-Emission Mobility showed cost-effective emissions reductions of 18-19% for
    transport by 2030 relative to 2005104
    . For road transport, this translates into a cut of about
    206-221 Mtonnes of CO2 by 2030 relative to 2005105
    , 52 to 67 Mtonnes additional
    reduction relative to the Baseline. As explained above, PO2, PO3, and PO4 could save
    2,490 to 7,100 ktonnes of CO2 emissions. This represents between 4 to 14% of the
    additional road transport emission reductions needed on top of the Baseline by 2030
    relative to 2005106
    . Monetising them, this translates into €0.3 to 0.7 billion of external costs
    savings by 2030 expressed as present value.
    Overall, PO2, PO3 and PO4 would lead to around 17.4 to 17.9% CO2 emissions reductions
    from road transport by 2030 relative to 2005 compared to 17.2% in the Baseline scenario
    (i.e. a reduction higher by 0.2 to 0.7 percentage points).
    6.2.2. Air quality
    Changes in air pollution generated by road transport would also depend on the extent to
    which the options can induce modal shift and fleet renewal. PO1 has no noticeable impact
    on NOx and PM emissions while PO2, PO2s and PO3a would reduce emissions of NOX
    from road transport by 1% at EU level compared to the Baseline in 2030 (i.e. 6,774 to
    6,796 tonnes of NOx saved in PO2 and PO2s and 6,911 tonnes of NOx saved in PO3a); the
    impact on PM emissions would be lower (0.2% reduction relative to the Baseline,
    equivalent to 79 tonnes of PM saved in PO2 and PO2s and 82 tonnes of PM saved in
    PO3a). PO3b, with the introduction of modulation of charges according to pollutant
    emissions for vans and passenger cars, would have a slightly larger impact (1.2% reduction
    in NOX equivalent to 8,254 tonnes of NOx saved, and 1% reduction in PM equivalent to
    104
    This outcome is in line with the 2011 White Paper which established a milestone of 20% emissions
    reduction by 2030 relative to 2008 levels, equivalent to 19% emissions reduction compared to 2005
    levels, and with the 2050 decarbonisation objectives.
    105
    SWD(2016) 244 final
    106
    However, potential overlaps with future policy measures may lower these CO2 emissions savings.
    50
    352 tonnes of PM saved) relative to the Baseline in 2030. The reduction is even more
    pronounced in PO4 and PO4s (1 to 1.4% reduction for NOx equivalent to 8,461 to 9,345
    tonnes of NOx saved and 1 to 1.2% reduction for PM equivalent to 360 to 423 tonnes of
    PM saved), thanks to the extension of distance-based charging to vans and passenger
    cars107
    . The external costs of air pollution are discussed in section 6.3.2.
    It is important to note that the transport network model used to simulate the changes in
    traffic flows108
    does not take into account existing and possibly extended traffic bans for
    certain type of vehicles on secondary roads. The diversion to these non-tolled roads may
    thus be overestimated and the real air quality improvements could be greater, especially in
    cases where Member States implemented network-wide distance-based charging, which
    would prevent traffic diversion.
    6.2.3. Noise
    Linked to the extent of modal shift and possible traffic diversion, there may be some
    impacts on the external costs of noise generated by road transport. Under PO1, since there
    could be some diversion of traffic to secondary roads (where the cost of noise is higher109
    ),
    a marginal overall increase is projected relative to the Baseline in 2030 for some Member
    States (i.e. this is largely due to the inclusion of HGVs below 7.5 tonnes in the distance-
    based charging scheme in Germany). However, at EU level the impacts on the external
    costs of noise relative to the Baseline are not significant in 2030. In PO2, a slight increase
    in noise costs (0.4% relative to the Baseline in 2030) would take place due to the wider
    application of distance-based charges for HGVs and buses on the TEN-T network and on
    motorways. It is important to note that the transport network model does not take into
    account possible network-wide introduction of distance-based charges that would prevent
    any diversion of traffic to alternative routes.
    For PO3 and PO4, the inclusion of congestion charging on the congested part of the inter-
    urban network is projected to result in an increase of 0.8 to 4.1% in noise cost, due to
    diversion of traffic to non-tolled roads. However, since congestion charging would be
    voluntary, it is reasonable to assume that Member States would only implement such
    schemes after thoroughly assessing local conditions and accompanied them with adequate
    complementary measures mitigating any undesired traffic diversion (such as improving
    access to alternative transport modes, limiting transit traffic on secondary roads or
    charging during peak hours). The impacts on noise levels are therefore considered to be the
    upper bound in case complementary measures are not taken by the Member States. As
    noted in section 6.2.2, the transport network model does not take into account possible
    traffic bans for certain type of vehicles on secondary roads. The diversion to these non-
    tolled roads is thus overestimated, suggesting higher noise costs.
    107
    The impacts on NOx emissions in relative terms are larger than those on CO2 emissions. This is due to the
    slightly higher uptake of LNG and hybrid HGVs relative to the Baseline in PO2, PO3a, PO3b and PO4,
    which have a higher impact on NOx emissions.
    108
    TRUST, a description of the model is available in Annex 4
    109
    See e.g. Ricardo-AEA et al (2014), Update of the Handbook on External Costs of Transport:
    http://ec.europa.eu/transport/themes/sustainable/studies/sustainable_en
    51
    6.2.4. Land use
    Costs in terms of habitat loss and fragmentation have been estimated to € 49-110 thousand
    per year for each kilometre of motorway (CE Delft, 2008). To the extent that policy
    options can shift transport activity to other modes and reduce congestion by spreading
    traffic more evenly and thus making more efficient use of the infrastructure, it can be
    expected that they would reduce the need for building new or expanding existing
    motorways and hence would have a positive impact compared to the Baseline. PO1 would
    not have a significant impact, while all other policy options would have some positive
    effects with respect to reducing road transport activity. PO3 and PO4 would have an
    additional benefit in terms of greater deployment of congestion-reducing schemes.
    6.3. Social impacts
    6.3.1. Impacts on employment
    The impact of the options on employment levels depends on the extent to which increases
    in transport costs affect the competitiveness of businesses, and on the extent to which
    increased revenues are reinvested. The impact of transport costs were simulated by the
    ASTRA model, showing no significant impact in all policy options. The second-order
    effects of investing revenues in road maintenance are estimated based on literature. The
    results are closely linked to the estimated benefits described in section 6.1.8. As such, PO1
    would have virtually no impact on employment, while in the other options the reinvestment
    of revenues from road tolls can generate jobs.
    The Impact Assessment accompanying the proposal on TEN-T guidelines110
    included the
    job creating potential of public spending on transport infrastructure. According to a
    conservative estimate, the investment of EUR 1 billion would generate 21,260 new direct,
    indirect and induced jobs.111
    Using this figure, Figure 6-15 presents the estimated potential
    of the policy options to create new jobs in the EU economy.
    Figure 6-15: Potential of the policy options to create jobs (30% and 100%
    earmarking to transport investments) – compared to the Baseline in 2030
    Earmarking
    Job creation
    potential
    PO1 PO2 PO2s PO3a PO3b PO4 PO4s
    30%
    Additional
    investment from
    toll revenues (in
    € billions)
    0.6 1.7 1.8 3.3 2.9 7.1 19.0
    Job creation 12,978 36,571 37,386 70,588 62,345 151,734 404,305
    110
    Impact Assessment accompanying the Proposal for a Regulation of the European Parliament and of the
    Council on Union Guidelines for the development of the Trans-European Transport Network, SEC(2011)
    1212 final.
    111
    First round effects concern direct employment in construction and materials supplying industries. A
    second round of employment and income effects occurs in the production sector in response to the
    demand for additional inputs required by construction materials supplying industries. A third round
    employment and income benefits occur in the guise of what is termed “induced” employment and reflects
    producers’ response to an increase in the demand for all goods and services. Source: OECD, Impact of
    Transport Infrastructure Investment on Regional Development, 2002:
    http://www.internationaltransportforum.org/Pub/pdf/02RTRinvestE.pdf.
    52
    potential
    100%
    Additional
    investment from
    toll revenues (in
    € billions)
    2.0 5.7 5.9 11.1 9.8 23.8 63.4
    Job creation
    potential
    43,260 121,904 124,622 235,294 207,817 505,780 1,347,684
    It needs to be underlined that the job creation potential has been estimated assuming that
    Member States reinvest 30% or 100% of revenues from new road charges (additional road
    charges to the Baseline in 2030) into transport infrastructure; in case some revenues are
    used for compensating measures, such as reduction of transport related taxes, the number
    of jobs created would be proportionately lower.
    6.3.2. Public health
    The impacts on public health are directly linked to the foreseen reduction in emissions of
    air pollutants from road transport such as CO, NOx, volatile organic compounds (VOC)
    and particulate matter (PM); any possible change in noise levels, and in the risk of
    accidents. Given the limited impact on total road transport activity, on modal split and
    vehicle fleet composition at EU level compared to the Baseline in 2030, the model
    indicates small reductions in pollutant emissions from road transport for the policy options
    (see section 6.2.2). However, congestion charges (PO3 and PO4), leading to more
    important reductions in local traffic and pollution, can have a more significant positive
    impact on public health in the concerned areas. As noted in section 6.2.2, the road network
    model does not take into account possible traffic bans for certain type of vehicles on
    secondary roads. The diversion to these non-tolled roads is thus overestimated suggesting
    relatively higher levels of air pollution in more sensitive areas.
    In addition, congestion charges have been associated with the reduction of accidents112
    .
    Better quality of roads thanks to the reinvestment of at least part of the additional toll
    revenues in road maintenance can have further positive impacts on road safety (cf. section
    2.1.2), but no data exists which would allow quantifying these impacts. Overall, the
    impacts on public health would be small but positive in all scenarios.
    Figure 6-16: Impact on public health and safety for each policy option
    Indicator PO1 PO2, PO2s and
    PO3a
    PO3b PO4 and PO4s
    Overall
    assessment
    Negligible
    Small positive impact
    (0.3 to 0.4%
    reduction in external
    costs of pollution
    from road transport
    relative to the
    Baseline in 2030;
    €0.32 to 0.41 billion
    costs savings for air
    pollution and
    Small positive impact
    (0.5% reduction in
    external costs of
    pollution from road
    transport relative to the
    Baseline in 2030; €0.37
    billion costs savings for
    air pollution and
    accidents by 2030,
    expressed as present
    Small positive impact
    (0.5 to 0.6% reduction
    in external costs of
    pollution from road
    transport & 0.2 to 0.6%
    reduction in accident
    costs relative to the
    Baseline in 2030; €0.82
    to 1.56 billion costs
    savings for air pollution
    112
    Cf. section 4.4.2 of the impact assessment support study.
    53
    Indicator PO1 PO2, PO2s and
    PO3a
    PO3b PO4 and PO4s
    accidents by 2030,
    expressed as present
    value)
    value) and accidents by 2030,
    expressed as present
    value)
    6.3.3. Social inclusion and distributional impacts
    Distributional effects could potentially arise from any of the policy options, since they
    imply changes to the cost of transport. As seen in section 6.1.1 the potential for changes in
    freight costs to affect consumers via cost pass-through to increased product prices is rather
    limited; hence, the main element of relevance to distributional effects are changes to the
    costs of passenger transport.
    The impact assessment support study has looked at different concepts of equity to consider
    the potential impacts. The findings suggest that greater implementation of the 'user-' and
    'polluter-pays' principles have greater market equity compared to the current situation, as
    they place the primary responsibility for payment on those responsible for the
    use/pollution, and not on those too poor to afford vehicles or who choose to travel by other
    means (NTPP, 2010)113
    .
    While road pricing may disproportionately affect lower-income groups, the magnitude of
    impacts is expected to be negligible. For the case of PO1-2, no new tolls are introduced for
    passenger cars, so the policy measures would only result in very minor, if any, changes in
    their costs. The impacts would also be limited in PO3. For PO4, the impact depends on the
    phasing in of the distance-based charges for passenger cars, however, even in this case the
    impacts are small – annual toll charges typically amount to small share (i.e. around 2%) of
    the total annual ownership cost of a car114
    .
    Road pricing could also benefit lower-income groups as higher-income individuals tend to
    drive the most. Furthermore, the negative effects of congestion, traffic safety problems and
    air pollution often affect lower income groups much more than the higher income groups
    (van Amelsfort et al, 2015)115
    . The overall impact of all POs on mobility and outcome
    equity is considered to be low.
    Congestion charging (PO3 and PO4) often raise equity concerns and has therefore been
    analysed in some depth. Different studies suggest that the social impacts of congestion
    charging depend on local conditions and that in the longer term winners and losers are
    difficult to identify as people change job or move house (Walker, 2011).116
    Whether in our
    case it would have overall positive or negative social impacts would depend on the use of
    revenues, which would be earmarked to transport in both options, and could be used by
    Member States to invest in alternative solutions to the individual use of private car.
    Decisions regarding the design of such schemes would therefore have to be taken at the
    local level with the needs of lower income groups in mind. If new congestion charging
    scheme is perceived not to be equitable is likely to be rejected by the public in any case.
    113
    Cf. section 4.4.3 of the impact assessment support study
    114
    Annual ownership costs are approximately €6,000/year (Together EU, 2012).
    115
    Ibid.
    116
    Ibid.
    54
    Experience with urban road charging schemes show that where the system is well-designed
    and communicated to the public, after an initial period of reluctance, the public generally
    embraces the scheme when its positive impacts are becoming evident117
    .
    Whilst not contesting the potentially negative impact of congestion charging on social
    inclusion, users tend to overestimate the costs road user charges represent for them. As an
    Australian transport expert put it, "in Brisbane people object to paying a AUS$4 toll to use
    a new tunnel beneath the city – but do not hesitate to purchase a cup of coffee for the same
    amount of money".118
    Similarly, the increase in fuel prices between January 2009 and
    September 2012 increased the cost of the use of the vehicle on all roads and throughout the
    day by some 5 eurocents/km119
    without considerably affecting accessibility and social
    inclusion.
    Figure 6-17: Impact on equity and distributional effects
    Indicator PO1 PO2 PO3b PO3a PO4
    Overall
    assess-
    ment 0
    Very
    minor /
    negligible
    3
    Small positive
    impact due to
    phase out
    vignettes
    3
    Greater internalisation of
    external congestion costs (all
    vehicles).
    Congestion charges are likely to
    be designed to be progressive /
    equitable to gain public
    acceptance
    3
    Greater internalisation of
    external congestion costs &
    air pollution for bus/coach.
    Congestion charges are
    likely to be designed to be
    progressive / equitable to
    gain public acceptance.
    6.3.4. Equal treatment of citizens
    Equal treatment of citizens refers mainly to the principle of non-discrimination. The main
    policy measure that is relevant is the proposed change to the rules on pricing of long-term
    versus short-term vignettes (included in all POs). The measure targets the problem of
    discrimination directly by ensuring that price ratios of short-term versus long-term
    vignettes are proportionate. Consequently, drivers using short-term vignettes in any
    Member State that introduces a new passenger car and/or van vignette will experience
    benefits in terms of more equal treatment under PO1-4.
    Estimating the magnitude of such impacts is challenging because data on the share of
    foreign road users that use short-term vignettes is limited. Available figures for selected
    Central and Eastern European Member States suggest that the estimated proportion of
    foreign car journeys on main routes is similar across the countries, with an average share
    around 30%120
    . Hence, around 30% of road users in a typical country could benefit from
    more equal treatment under PO1-4.
    In addition, the expected generalisation of distance-based charging for HGVs and buses
    due to the phasing out of vignette systems (for PO2, PO3 and PO4), would make sure that
    117
    See e.g. the examples of London or Stockholm
    118
    Road user charging: coming, ready or not?, Thinking Highways, Vol. 7 No 4, 2013.
    119
    Impact assessment accompanying the proposal for an Initiative on fair and efficient pricing (2013) based
    on fuel prices from the European Commission's Oil Bulletin,
    http://ec.europa.eu/energy/observatory/oil/bulletin_en.htm.
    120
    AT, CZ, HU, SI, SK – cf. Table 2-3Table 2-3
    55
    hauliers are treated the same way when they use tolled roads in any Member States. This
    provision extends to the user of passenger cars and vans in PO4.
    7. HOW DO THE OPTIONS COMPARE?
    7.1. Key economic, social and environmental impacts
    The analysis of economic impacts shows the most important differences. The main trade
    off is between the increased costs for transport users and to authorities, balanced against
    increased revenues and reductions in congestion costs and other externalities. There are
    also some potentially negative impacts in terms of distribution and impact on SMEs, as a
    result of increased costs, although these are minor in most options and small in PO4.
    In terms of environmental impacts, PO4 and PO4s would have the largest positive effect,
    while PO3a and PO3b would also have measurable impact. In any case, this initiative has
    to act in concert with other instruments aiming at reducing emissions from transport, such
    as emission standards (supply side) for air pollutants and CO2.
    In terms of social impacts, all policies can be expected to make some positive
    contribution, in particular through their job creation potential and by increasing the fairness
    of road user charges. PO3 and PO4 are expected to have more positive effects due to
    greater internalisation of external costs (contributing to fairness) and somewhat higher
    benefits for public health and safety.
    Figure 7-1: Main economic, environmental and social impacts
    Key: Impacts expected
    88 8 O 9 99
    Strongly negative Weakly
    negative
    No or negligible impact Weakly
    positive
    Strongly positive
    PO1 PO2 and PO2s PO3a PO3b PO4 and PO4s
    Economic impacts
    Transport costs
    Road passenger transport
    (% change to the Baseline
    in 2030)
    0.0% 0.0% 0.1% 0.0% 1.3 to 2.0%
    Transport costs
    Road freight transport %
    change to the Baseline in
    2030)
    0.2% 0.9 to 1.0% 1.0% 1.1% 1.5 to 2.0%
    Congestion costs - %
    change to the Baseline in
    2030
    0.0% -0.2% -2.4% -2.5% -2.5% to -6.1%
    Congestion costs savings
    by 2030 - present value
    (€bn)
    0.1 0.8 8.8 8.9
    9.1 to 22.2
    Additional tolling
    revenues – present value
    (€bn)
    20.8 34.2 to 34.6 52.6 40.5 89.6 to 226.2
    Total costs to authorities
    – present value (€bn)
    0.0 2.0 to 2.4 2.0 2.0 2.2 to 3.7
    56
    PO1 PO2 and PO2s PO3a PO3b PO4 and PO4s
    Budgetary implications –
    present value (€bn)
    20.8 32.1 to 32.2 50.5 38.4 87.3 to 222.5
    Compliance cost to road
    users – present value
    (€bn)
    Insignificant 0.889 to 1.018 0.889 0.889 1.070 to 3.698
    Impact on SMEs 0/2
    Minor negative impacts due to the lower capacity of SMEs to absorb increases in cost, but no
    significant distortions expected
    Road quality
    Missing/remaining
    revenues (€bn/yr)
    0/3
    Very minor
    positive impact
    due to 5%
    increase in
    revenues
    -19.3
    3
    Small positive
    impact due to
    15% increase in
    revenues
    -15.6 to -15.4
    3
    Positive impact
    due to 28%
    increase in
    revenues
    -10.2
    3
    Positive impact
    due to 25%
    increase in
    revenues
    -11.5
    33
    Very positive
    impact due to 60
    to 160% increase
    in revenues
    +2.5 to 42.1
    Additional benefits due to
    investments in transport
    expressed in % of GDP
    0.01 to 0.04% 0.03 to 0.11% 0.06 to 0.21% 0.06 to 0.19% 0.14 to 1.20%
    Competitiveness 0
    No impact on
    competitiveness of
    European
    manufacturing
    products on the
    global market.
    3
    Minor positive
    impact on
    competitiveness
    due to
    differentiated
    CO2 charging for
    HGVs and buses
    leading to slightly
    higher uptake of
    low- and zero-
    emission vehicles
    3
    Minor positive impact on competitiveness due to
    differentiated CO2 charging for HGVs and buses, and
    also for passenger cars and vans, leading to slightly
    higher uptake of low- and zero-emission vehicles.
    Increased uptake of congestion charging would be
    beneficial to the competitiveness of businesses,
    especially those that make use of just-in-time
    manufacturing or in which goods are perishable, costly
    or difficult to warehouse.
    Internal market
    3
    Small positive
    impact due to
    removal of
    exemptions for
    HGVs < 12 tonnes
    and extension to
    buses/coaches
    3
    Small positive
    impact due to
    phase out of
    vignettes and
    EURO class
    differentiation –
    potentially
    leading to more
    tolls and external
    cost charging
    3
    As for PO2, plus allowing genuine
    congestion charging that would
    encourage more Member States to
    apply such charges on congested
    links
    33
    Highest uptake of
    tolls likely due to
    phase out of
    vignettes for vans
    and the phase in
    of distance-based
    charging for
    passenger cars.
    Mandatory
    external cost
    charging
    Environmental impacts
    CO2 from road transport
    (1000 tonnes of CO2
    saved)
    157 2,490 to 2,505 2,878 3,812 4,765 to 7,100
    Air pollution: NOx and
    PM emissions from road
    transport (tonnes of NOx
    and PM saved)
    267 6,774 to 6,796 6,911 8,254 8,461 to 9,345
    4 79 82 352 360 to 423
    Social impacts
    Employment – job
    creation potential 12,978 to 43,260 36,571 to 124,622
    70,588 to
    235,294 62,345 to 207,817
    151,734 to
    1,347,684
    57
    PO1 PO2 and PO2s PO3a PO3b PO4 and PO4s
    Public health & safety
    0
    Negligible
    3
    Small positive
    impact (0.3%
    reduction in
    external costs of
    pollution from
    road transport
    relative to the
    Baseline in 2030;
    €0.32 billion
    costs savings for
    air pollution and
    accidents by
    2030, expressed
    as present value)
    3
    Small positive
    impact (0.4%
    reduction in
    external costs of
    pollution from
    road transport
    relative to the
    Baseline in 2030;
    €0.41 billion
    costs savings for
    air pollution and
    accidents by
    2030, expressed
    as present value)
    3
    Small positive
    impact
    (0.5% reduction in
    external costs of
    pollution from road
    transport relative to
    the Baseline in
    2030; €0.37 billion
    costs savings for
    air pollution and
    accidents by 2030,
    expressed as
    present value)
    33
    Positive impact
    (0.5 to 0.6%
    reduction in
    external costs of
    pollution from
    road transport &
    0.2 to 0.6%
    reduction in
    accident costs
    relative to the
    Baseline in 2030;
    €0.82 to 1.56
    billion costs
    savings for air
    pollution and
    accidents by
    2030, expressed
    as present value)
    Social inclusion
    0
    Very minor /
    negligible
    3
    Small positive
    impact due to
    phase out
    vignettes
    33
    Greater internalisation of external
    congestion costs (all vehicles).
    Congestion charges are likely to be
    designed to be progressive / equitable
    to gain public acceptance
    33
    Greater
    internalisation of
    external
    congestion costs
    & air pollution for
    bus/coach.
    Congestion
    charges are likely
    to be designed to
    be progressive /
    equitable to gain
    public acceptance
    Equal treatment of EU
    citizens
    3
    More proportionate charges for occasional users in countries with vignettes (52% lower for
    passenger cars; 45% for vans)
    7.2. Effectiveness
    The analysis of the overall effectiveness of the options must consider the extent to which
    the objectives are achieved. Figure 7-2 presents the key indicators which have been
    developed to monitor the level of achievement of the specific objectives.
    Figure 7-2: Linking of objectives to key indicators
    Specific objective Key indicators
    Contribute to the reduction of CO2 emissions from
    transport
    Impact on CO2 emissions from transport
    Contribute to adequate quality of roads Impact on road quality
    Ensure fair and non-discriminatory road pricing Impact on equal treatment of occasional / non-resident
    motorists
    Impact on the costs distribution among road users in
    line with the user pays principle
    Make use of road charging as an effective tool in
    reducing pollution and congestion
    Impact on external costs
    Impact on congestion costs
    Figure 7-3: Effectiveness of the policy options presents the effectiveness of each option in
    achieving the specific objectives using the key indicators.
    Figure 7-3: Effectiveness of the policy options
    58
    PO1
    PO2 and
    PO2s
    PO3a PO3b PO4 and PO4s
    Specific Objective 1: Contribute to the reduction of CO2 emissions from transport
    CO2 emissions from
    road transport
    No significant
    effects
    expected
    Small effect
    due to CO2
    differentiation
    for HGVs and
    buses
    2,490 to 2,505
    ktonnes of
    CO2 saved
    (-0.4%)
    Small effect due to
    CO2
    differentiation for
    HGVs and buses
    2,878 ktonnes of
    CO2 saved
    (-0.4%)
    Positive effect
    due to CO2
    differentiation
    for HGVs and
    buses and
    passenger cars
    and vans
    3,812 ktonnes of
    CO2 saved
    (-0.5%)
    Most effective due to CO2
    differentiation for HGVs and
    buses and passenger cars
    and vans
    4,765 to 7,100 ktonnes of
    CO2 saved
    (-0.7% and -1.0%)
    Specific Objective 2: Contribute to adequate quality of roads
    Impact on road
    quality
    In proportion
    to additional
    toll revenues
    (+5%)
    In proportion
    to additional
    toll revenues
    (+15%)
    In proportion to
    additional toll
    revenues
    (+28%)
    In proportion to
    additional toll
    revenues
    (+25%)
    In proportion to additional
    toll revenues
    (+60 to 160%)
    Specific Objective 3: Ensure fair and non-discriminatory road pricing
    Equal treatment of
    occasional/non-
    resident motorists
    All equally effective due to rule on proportionate pricing
    Fair distribution of
    cost among road users
    All HDVs
    treated equally
    Distance based charging for all HDVs (user pays) –
    heavy users pay proportionately more
    Distance based charging for
    vans and passenger cars
    (user pays)
    Specific Objective 4: Make use of road charging as an effective tool in reducing pollution and congestion
    Impact on external
    costs
    No significant
    effects
    expected
    Positive outcomes due to replacing vignettes by
    distance-based charging, but can be limited by the
    voluntary nature of external cost charging
    Most effective due to
    mandatory external cost
    charging
    Congestion costs - %
    change to the Baseline
    in 2030
    No significant effects
    expected
    Allows genuine
    congestion
    charging,
    although uptake
    is voluntary (-
    2.4%)
    Allows genuine
    congestion
    charging, although
    uptake is
    voluntary (-2.5%)
    Potentially most effective
    due to phase out of vignettes
    and phasing in of distance-
    based charges for passenger
    cars and vans, leading to
    infrastructure available for
    congestion charging in more
    countries (-2.5% to -6.1%)
    In terms of effectiveness, PO1 and PO2 do not contribute significantly to the key
    objectives of reducing congestion costs and CO2 emissions from transport. Conversely,
    PO3a, PO3b and PO4 show average or good effectiveness against all of the objectives,
    with PO4 being slightly ahead of PO3 due to the wider scope of road tolls (after phase out
    of vignettes for vans and passenger cars) and mandatory inclusion of external cost charges.
    The key uncertainty with respect to all POs is that the introduction of tolls remains
    voluntary, which makes the ultimate outcomes uncertain.
    7.3. Efficiency
    Efficiency can be defined as "the extent to which objectives can be achieved for a given
    level of resource/at least cost". The major costs of the policy options come in the form of
    higher direct transport costs, as well as the implementing and operational costs of the
    charging schemes. These additional costs can be balanced against the additional revenues
    generated by user charges, as well as the achievement of the objectives (outlined above).
    As can be seen in Figure 7-4, higher additional costs are generally associated with higher
    additional benefits and vice versa.
    • PO1 shows limited effectiveness and limited costs.
    59
    • PO2 and PO3a perform similarly in terms of cost-effectiveness, since they have
    similar costs and benefits – although PO3a has slightly better effectiveness and
    higher revenues.
    • PO3b shows better cost-effectiveness than PO2 and PO3a, since it has similar costs
    but much higher effectiveness.
    • PO4 has the highest effectiveness, but also involves higher costs to authorities and
    users (due to the larger user base that would result from including passenger cars
    and vans in road tolls schemes).
    Figure 7-4: Indicators of efficiency
    PO1 PO2 and PO2s PO3a PO3b PO4 and PO4s
    Additional costs
    Total investment and
    operational costs for
    authorities (present
    value)
    Insignificant €2.4 billion €3.7 billion
    Compliance cost to
    users (present value)
    Insignificant €1 billion €1.4 billion
    (€3.7 billion if passenger
    cars were equipped with
    OBUs)
    Benefits
    Additional revenues
    from tolls relative to
    the Baseline (present
    value)
    €20.8 billion € 34.2 to 34.6
    billion
    €52.6 billion €40.5 billion €89.6 to 226.2 billion
    Effectiveness in
    achieving objectives
    No
    significant
    effects
    expected
    Some
    contribution to
    lower CO2 and
    wider uptake of
    tolls
    Good
    contribution to
    objectives to
    reduce CO2 and
    external costs
    Good contribution to
    objectives to reduce
    CO2 and external
    costs (slightly higher
    than PO3a in terms of
    CO2 reductions)
    Potentially most
    effective due to widest
    uptake of tolls,
    congestion charges and
    external cost charges
    Even with the highest cost among the options, PO4 achieves the objectives most efficiently
    as it not only is the most effective but also generates largest revenues that outweigh any
    costs by far. PO3b comes second since it is more effective in achieving the objectives than
    PO2 and PO3a, albeit at the same cost.
    7.4. Coherence
    Since the objectives are in line with those of relevant EU policies, including the Charter for
    fundamental rights (cf. section 4), in principle all options are also coherent with these as
    they point in roughly the same direction (the internalisation of external costs of transport
    through fair and efficient pricing). By promoting more proportionate pricing and stepwise
    harmonisation of road charging methods, all options contribute to achieving a Deeper and
    Fairer Internal Market, though because of its primary objective, the initiative is part of the
    actions aiming at creating a Resilient Energy Union with a Forward-Looking Climate
    Change Policy.
    The differences are in the emphasis put on achieving one or the other specific objective
    and in the extent to which these can be achieved by the different options. In that sense,
    PO2 performs better than PO1 as it directly builds on the future certification, monitoring
    and reporting of CO2 emissions from HGVs and buses as outlined in the European Strategy
    for low-emission mobility. PO3b performs even better as in addition it links road pricing
    60
    for passenger cars and vans to CO2 emissions. PO3a does not include this measure but is
    still ahead of PO2 by also allowing efficient marginal cost charging to deal with the issue
    of congestion, a major problem identified in the 2011 White Paper on Transport. Finally,
    PO4 performs best in terms of internal coherence as it is closest to the full application of
    the polluter pays and user pays principles, as set out in the White Paper.
    7.5. Proportionality
    None of the options go beyond what is necessary to achieve the objectives. On the
    contrary, all of them can only contribute to a certain extent compared to the "ideal"
    scenario of full internalisation of external costs, with PO4 being the closest to the scenario,
    while PO1 can only achieve one objective satisfactorily. The scope of the options is limited
    in that where they address areas that are primarily national competence (infrastructure,
    congestion), they either do not interfere in how road quality is ensured or do not impose
    the application of congestion charging on Member States. Costs to Member States,
    businesses and citizens are limited compared to the potential benefits for each policy
    option. The choice of instrument (Directive) is adequate as it allows satisfactory
    achievement of the objectives, at least in PO2, PO3, and PO4. Soft law has not been able to
    achieve the objectives.
    7.6. Preferred option
    Based on the above assessment, it can be concluded that PO4 would be the most effective
    in reaching all four specific objectives, but at relatively higher cost than the other options.
    At the other end of the spectrum, PO1 can contribute to achieving the objectives only in a
    very limited way although at practically no cost. PO2, PO3a and PO3b are more balanced
    in their economic, social and environmental impacts and can achieve these results at a
    reasonable cost. While the differences compared to the baseline are limited between these
    three options, PO3b stands out somewhat in that it has more important positive
    environmental impacts, while also having significant impact on reducing congestion.
    PO3b is therefore the preferred option. PO4 could be considered as an ambitious
    alternative, including the phasing out of time-based charges for passenger cars and
    light commercial vehicles and mandatory external cost charging for all heavy-goods
    vehicles and buses. If the additional revenues and other benefits under PO4 are
    appealing enough to face the expected opposition to generalised distance-based road
    charging for cars and the higher costs attached to this, then, subject to a phasing-in
    period, this could be the preferred option.
    In the case PO4 is the selected option, the phasing out of time-based vignettes for
    passenger cars should be longer than for HDVs to allow for the effects of the revision of
    the EETS legislation to materialise (decrease in costs of implementation/operation), which
    is difficult to predict but could be after 2025 – this date is considered in PO4 as year of
    introduction of distance based systems for light vehicles in a number of Member States.
    If an earlier or later date was selected, that would shift the increase in costs to that year but,
    in the absence of reliable estimates, it is not possible to indicate potentially higher or lower
    costs by then. Since at this stage there is no support from Member States for distance-based
    61
    charging for cars, a longer perspective is necessary for them to consider if they would
    indeed want to implement it.
    7.7. Effectiveness in achieving the objective to reduce regulatory burden
    (REFIT objective)
    It is clear that the regulatory costs related to the initiative would increase with the change
    to distance-based tolling, as it would increase the compliance costs for many market
    players. However, these costs would be compensated by higher revenues (toll chargers,
    Member States) and better road quality and more reliable travel times (road users).
    Moreover, the shift from time-based to distance-based system should be more looked at
    from the perspective of social benefits, which would increase, rather than from the
    reduction of the regulatory costs. Benefits would include reduced negative environmental
    and health impacts (citizens), and related external costs borne by society (taxpayers), while
    regulatory costs should be reduced by the initiative on the EETS.
    The REFIT dimension of this proposal comes more from the simplification and updating of
    the requirements for distance-based charging so that they are fit for purpose, that is:
    • replacing an obsolete system of not well-defined modulation according to Euro
    classes for HDVs with more adequate and harmonised CO2 emission-based
    modulation of charges (to be based on a robust testing scheme);
    • simplification of the application of the additional charges for external costs of noise
    and air pollution (that is a more accurate and thus fairer instrument than modulation
    by Euro class) by allowing the use of reference values without the need to do any
    calculation;
    • updating of the unit values for external cost charging to better reflect the
    environmental impact of different vehicle categories;
    • simplification and updating of the application of mark-ups and facilitation of
    application of congestion charges; and
    • allowing the reduction of circulation taxes for HGVs above 12 tonnes, which would
    facilitate Member States in replacing these taxes with more progressive distance-
    based charges.
    The simplifications concern mainly national authorities rather than businesses, with the
    exception of the last measure, which could decrease the burden on hauliers (SMEs) by
    63% or over €2 billion in vehicle tax paid for the use of HGVs. Overall costs to road users,
    including citizens and business, are likely to increase, even if only to a small extent.
    While regular infrastructure reports by Member States may cause some administrative
    costs, these should be relatively insignificant compared to:
    • The benefits generated by the initiative, in particular in terms of improved road
    quality and reduced negative impacts attached to poor quality;
    62
    • The administrative burden Member States already face linked to reporting
    requirements under Regulation 1108/70 from 1970 introducing an accounting
    system for expenditure on infrastructure, which may be repealed – compared to that
    act, this initiative would only require the most relevant information, necessary for
    the monitoring of the progress towards the objectives, to be reported by Member
    States.
    Much as it is difficult to quantify the impacts of these measures, they could also reduce the
    administrative burden and enforcement costs when applying distance-based charges. All
    these measures are applied from PO2 onwards and three out of five are already applied in
    PO1 and maintained in the other options. Thus, from the REFIT perspective all options
    perform better than the baseline. PO2, PO3 and PO4 introduce additional requirements that
    would increase administrative burden and compliance costs compared to the baseline, but
    these are necessary to meet the specific objectives of the initiative and should not be
    looked at from the REFIT perspective.
    8. MONITORING AND EVALUATION
    In order to assess the impact of the legislation on overcoming main identified problems, it
    would be necessary to make a thorough evaluation once all the changes have been phased
    in. 5 years after the new framework becomes applicable in its entirety would seem to be
    right moment to do such an evaluation.
    8.1. Indicators
    For the main policy objectives, the following core monitoring indicators have been
    identified:
    • The evolution of CO2 emissions form HDVs; specific and total:
    o CO2 emissions from every single vehicle will be monitored using
    VECTO121
    , making annual comparisons per vehicle category to the previous
    year;
    o Total CO2 emissions will be monitored by the European Environment
    Agency based on data reported by manufacturers using VECTO.
    • The state of tolled road infrastructure as reported by Member States through
    specific quality indicators (e.g. surface quality, safety, level of service…). Key
    performance indicators to be developed by CEDR122
    will also provide useful input.
    o Data on expenditure on the maintenance of road infrastructure will be
    reported by Member States through their annual infrastructure reports.
    • The proportionality and coverage of social costs by road charges in the EU:
    o The Commission continuously keeps track of the evolution of road charging
    systems in the EU, including charged vehicle categories, charge levels,
    121
    cf. upcoming proposal for a Regulation on the monitoring and reporting of heavy duty vehicle fuel
    consumption and carbon dioxide emissions resulting from the certification process planned for adoption
    by the Commission in Q2 2017.
    122
    Conference of European Directors of Roads, http://www.cedr.eu/strategic-plan/fa3/
    63
    differentiation of charges according to environmental performance or time,
    vignette prices (with special attention to cars).
    o The Commission observes the evolution of the vehicle fleet using toll roads
    according to environmental performance (Euro class, in the future CO2
    emissions) based on publically available industry and government data123
    (annual).
    • The level of congestion on the inter-urban network in the EU:
    o Member States monitor and report annually the evolution of traffic levels in
    peak hours on the interurban road network with real life traffic observations
    performed on a representative number of congested road stretches
    belonging to the primary national network.
    o The Commission establishes and updates a register of congestion charging
    schemes deployed by Member States on the basis of the notifications in
    receives.
    The benchmarks for these indicators are the Baseline developments, i.e. the projected
    situation in 2025 without further action. For the levels of CO2 emissions and congestion,
    the values are readily available in the EU Reference scenario 2016 as indicated in section 2
    of this report. Since estimating the future quality of roads or spending on maintenance is
    less straightforward, the current levels of indicators (satisfaction with road quality and
    expenditure data) can be used as benchmarks. The progress on applying the polluter pays
    and user pays principles can be made in a more qualitative way, based on different factors
    outlined above. The current levels of charges, the length of tolled network and covered
    vehicle categories as well as the practice in applying external cost charging will be a useful
    basis.
    8.2. Operational objectives
    Based on the preferred option, the following operational objectives have been identified (if
    not indicated otherwise, the measures would be applicable with immediate effect):
    Objectives and targets Indicator
    Phase-out time-based charges for HDVs: No
    vignette systems for HDVs in the EU – in 5 years
    (2023).
    • Level of implementation of the provision
    by Member States (number of
    infringement cases);
    • Number of new distance-based charging
    systems for HDVs
    Introduce CO2 differentiation of road charges for
    HDVs: Road charges are differentiated according to
    CO2 emissions of HDVs (as soon as technically
    feasible, probably 2019-2020).
    • Level of implementation of the provision
    by Member States (number of
    infringement cases)
    Increase the application of external cost charging
    for HDVs: At least half of the Member States apply
    Take-up of external cost charging by
    Member States (number of cases) for
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    See e.g.: https://www.bag.bund.de/DE/Navigation/Verkehrsaufgaben/Statistik/statistik_node.html
    64
    external cost charging for HDVs (2020). different vehicle categories
    Introduce CO2 differentiation of road charges for
    LDVs: Road charges are differentiated according to
    real-driving emissions (CO2 and pollutant) for
    LDVs, from 2020.
    • Level of implementation of the provision
    by Member States (number of
    infringement cases);
    • (Number of new distance-based charging
    systems for vans124
    and cars)
    Ensure more proportionate pricing: Proportionate
    pricing for all HGVs, buses/coaches and light
    vehicles – after 2 years (2020).
    • Level of implementation of the provision
    by Member States (number of
    infringement cases);
    • Changes in charging systems for buses
    and light vehicles
    Increase application of time-differentiated charging:
    At least 8 Member States apply time-differentiated
    charging to address inter-urban congestion (2023).
    Number and extent of new congestion
    charging schemes
    Introduce requirement to monitor and report on toll
    revenues: All Member States monitor and report on
    toll revenues, expenditures on maintenance and on
    road quality indicators (2020).
    Level of compliance by Member States,
    number and quality of reports received by
    the Commission.
    124
    according to experience with Euro class differentiation for HGVs, the effects on fleet renewal in
    case of distance-based charging are more pronounced