REGULATORY SCRUTINY BOARD OPINION Proposal for a Directive of the European Parliament and of the Council amending Directive 2010/40/EU on the framework for the deployment of Intelligent Transport Systems in the field of road transport and for interfaces with other modes of transport

EUROPEAN COMMISSION
SEC(2021) 436
27.9.2021
REGULATORY SCRUTINY BOARD OPINION
Proposal for a Directive of the European Parliament and of the Council
amending Directive 2010/40/EU on the framework for the deployment of
Intelligent Transport Systems in the field of road transport and for
interfaces with other modes of transport
COM(2021) 813
SWD(2021) 474
SWD(2021) 475
Offentligt
KOM (2021) 0813 - SEK-dokument
Europaudvalget 2021
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This opinion concerns a draft impact assessment which may differ from the final version.
Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: regulatory-scrutiny-board@ec.europa.eu
EUROPEAN COMMISSION
Regulatory Scrutiny Board
Brussels,
RSB
Opinion
Title: Impact assessment / Revision of the Intelligent Transport Systems Directive
Overall opinion: POSITIVE WITH RESERVATIONS
(A) Policy context
This initiative aims to revise the Directive on the framework for the development of
Intelligent Transport Systems (ITS). The ITS Directive aims to increase the deployment
and use of ITS services across the EU. This should improve road safety and the efficiency
of transport and foster a multimodal transport system.
The initiative builds on the evaluation of the existing ITS Directive published in October
2019. While the evaluation confirmed its relevance, it highlighted the slow and fragmented
deployment of ITS services. The initiative aims to contribute to the objectives of several
other strategies. These include the European Green Deal, the Sustainable and Smart
Mobility Strategy and making Europe fit for the digital age.
(B) Summary of findings
The Board notes the additional information provided in advance of the meeting and
the commitments to make changes to the report.
However, the report still contains significant shortcomings. The Board gives a
positive opinion with reservations because it expects the DG to rectify the following
aspects:
(1) The main focus of the initiative is not clear. The report does not sufficiently
explain in what way the initiative will contribute to climate change and to
multimodality.
(2) The report is unclear on the most important specific problems to be tackled. The
presentation of options does not bring out clearly the critical policy choices.
(3) The analysis of impacts, including the administrative costs and the benefits, is not
sufficiently elaborated.
(4) The choice of the preferred option and its proportionality is not adequately
argued.
(5) Stakeholder views are not sufficiently integrated throughout the analysis in the
report.
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(C) What to improve
(1) The main focus of the initiative should be clarified. While making references to a
selection of key strategies, the report should be clear upfront what the added contribution
of this initiative is, including being more specific on the contribution the initiative will
have to each of the objectives of enhancing efficiency and safety of road traffic, fighting
climate change and facilitating multimodal mobility.
(2) The report should provide a clear description of the most important specific problems
to be tackled by this initiative and provide information about their scale. In particular, the
problem definition should clearly identify and assess the issues for which later the most
intrusive measures are proposed under the preferred option so that their proportionality can
be properly assessed. This relates in particular to: (i) the expansion of the scope of
application of the priority areas to include deployment; (ii) standards for in-vehicle
generated data; and (iii) mandating the availability of certain data and services. On the
basis of a refined problem analysis, the report should explain what success would look like.
(3) Given the cumulative construction of the policy options (with two thirds of the
measures being identical) the report should bring out more clearly how they differ in terms
of key measures and what difference these measures are expected to make.
(4) The impact analysis should be strengthened. First, the information regarding the
administrative costs should be further elaborated. In particular, more details are needed
with regard to the administrative burden linked to the many new policy measures that aim
to promote the provision of different kinds of data/information. Second, additional
explanation is needed on the reliability and relevance of the estimates of the benefits, in
particular in relation to reduction of travel time.
(5) The report needs to better justify the choice of the preferred option (containing all
proposed measures) and its proportionality given that it comes with a significantly lower
benefit-cost ratio (compared to the package excluding some costly requirements), while
delivering relatively small additional net benefits. The report should be more explicit that
this is largely due to the inclusion of measures aiming to reduce the external costs of
accidents, which come with a relatively low benefit-cost ratio.
(6) While the report makes extensive use of the targeted stakeholder survey, the results
from the open public consultation are hardly reported. The use of the targeted survey
should be treated with more caution and at the same time the results of the public
consultation should be better refelected in the report, in particular the views of the different
stakeholder categories on the problem, the scope of the action needed, the options and their
expected costs and benefits. Any relevant issues where stakeholders have divergent views
should be identified.
(7) Building on clarification of the focus and of the definition of the problem, the overall
narrative of this initiative needs to be strengthened. In addition, the report should be less
technical, with fewer abbreviations and it should be made accessible to non-specialists.
The Board notes the estimated costs and benefits of the preferred option(s) in this
initiative, as summarised in the attached quantification tables.
Some more technical comments have been sent directly to the author DG.
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(D) Conclusion
The DG may proceed with the initiative.
The DG must revise the report in accordance with the Board’s findings before
launching the interservice consultation.
If there are any changes in the choice or design of the preferred option in the final
version of the report, the DG may need to further adjust the attached quantification
tables to reflect this.
Full title Proposal on the revision of Directive 2010/40/EU on the
framework for the deployment of Intelligent Transport Systems
in the field of road transport and for interfaces with other modes
of transport
Reference number PLAN/2020/7429
Submitted to RSB on 25 August 2021
Date of RSB meeting 22 September 2021
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ANNEX: Quantification tables extracted from the draft impact assessment report
The following tables contain information on the costs and benefits of the initiative on
which the Board has given its opinion, as presented above.
If the draft report has been revised in line with the Board’s recommendations, the content
of these tables may be different from those in the final version of the impact assessment
report, as published by the Commission.
I. Overview of Benefits (total for all provisions) – Preferred Option – PO3 (expressed relative to the
baseline)
Description Amount Comments
Direct benefits
Consumer and business
benefits
The completion of the core and the
comprehensive network will benefit
the users of transport services, both
citizens and undertakings, as there
will be better connectivity, more
reliability, or faster connections. This
should lead to better or cheaper
services, in particular for the most
environmental friendly transport
modes.
Indirect benefits
Safety improvements –
reduction in external
costs related to
accidents relative to the
baseline (i.e. present
value over 2021-2050)
€3,930 million Indirect benefit to society at large.
Improvements of road safety are
brought by the extension of the
motorway standard and the related
safety features to all network
sections above a certain daily traffic
threshold reducing the number of
fatalities and injured persons. The
reduction in the external costs of
accidents is estimated at around
€3,930 million relative to the
baseline over the 2021-2050 period,
expressed as present value. Transport
users and society as a whole do
benefit.
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Reduction in external
costs related to inter-
urban congestion
relative to the baseline
(i.e. present value over
2021 – 2050)
€2,891 million Indirect benefit to the society at
large. Improvements on the level of
interurban congestion are brought by
a shift of transport volumes to more
sustainable modes of transport
decongesting especially the road
mode and reducing delays. The
reduction in external costs related to
inter-urban congestion is estimated at
around €2,891 million relative to the
baseline over the 2021-2050 period,
expressed as present value. Transport
users and society as a whole do
benefit.
Reduction of external
costs related to CO2
emissions relative to the
baseline (i.e. present
value over 2021-2050)
€387 million Indirect benefit to society at large.
Savings of CO2 are an effect of
modal-shift to environmental
friendly modes and efficiency gains.
The reduction in the external costs of
CO2 emissions is estimated at around
€387 million relative to the baseline
over the 2021-2050 period,
expressed as present value.
Reduction of external
costs related to air
pollution emissions
relative to the baseline
(i.e. present value over
2021-2050)
€420 million Indirect benefit to society at large.
The reduction in air pollutant
emissions is driven by modal-shift to
environmental friendly modes and
efficiency gains. The reduction in the
external costs of air pollution is
estimated at around €420 million
relative to the baseline over the
2021-2050 period, expressed as
present value.
Positive impact on GDP
relative to the baseline
GDP increase of 0.4% in 2030, 1.3% in
2040 and 2.4% in 2050 relative to the
baseline. This translates into €57 billion
increase in GDP relative to the Baseline
in 2030, €229 billion in 2040 and €467
billion in 2040.
Indirect benefit to society at large.
These benefits are the result of large
scale investments, driven by the
measures of the policy option. These
impacts account for wider effects
than only the construction of
projects, namely the indirect effects
on other economic sectors and the
effects induced by increased
productivity, improved conditions
for international trade and
technological spill-overs. The whole
society benefits: citizens by higher
income, business by higher revenues,
government by higher tax revenues.
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Positive impacts on
employment relative to
the baseline (additional
persons employed and
percentage change to
the baseline)
200,000 additional persons employed in
2030 (0.1% increase to the baseline),
561,000 additional persons employed in
2040 (0.3% increase to the baseline) and
840,000 additional persons employed in
2050 (0.5% increase to the baseline)
These benefits include direct jobs
created due to the construction of
projects and indirect jobs created
thanks to the positive impact on
GDP. EU employees and self-
employed do benefit.
II. Overview of costs – Preferred option – PO3 (expressed relative to the baseline)
Citizens/Consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurrent
Investment
costs
Direct
costs
relative to
the
baseline
(i.e.
present
value over
2021-
2050)
€1,754
million
(linked to
road tolls to
fund
investments)
€1,350
million
€178 million
(linked to
multimodal
digital
mobility
services for
passenger
transport)
€242,584
million
(investme
nt
support)
€1,605
million
(linked to
multimodal
digital
mobility
services for
passenger
transport)
Administrat
ive costs
Direct
costs
relative to
the
baseline
(i.e.
present
value over
2021-
2050)
€8.6 million
(linked to
adjustments
for
compliance
with new
requirements
mainly rail/
road
businesses)
€25.4
million
(linked to
participatio
n in TEN-T
governance
processes):
€15.8
million for
the
Commissio
n and €9.6
million for
Member
States
public
authorities.
Electronically signed on 27/09/2021 08:05 (UTC+02) in accordance with article 11 of Commission Decision C(2020) 4482