- the current economic context, the uncertainty on how recession will develop over the years and its impact on transport;
- contrary the Mid-term Review in 2006 of the White Paper on Transport Policy, the text avoids using the term “co-modality” but refers t“modal shift”. The fact is that some modes are in competition for transport of certain commodities but, in general, modes are complementary. The wrong belief that some modes are by default better from an environmental point of view than others is at the origin of such a “modal shift” approach, but modal shift is suitable from an environmental point of view in some very specific cases, but it is neither possible nor suitable in the majority of the traffic flows;
- the promotion of fleet renewal and the need of an integrated approach for reducing CO2 emissions, including a fiscal policy that does not lead tmarket fragmentation.
ACEA looks forward tthe next stakeholders’ consultation meeting in November 2009 and hereby contributes tthe debate by submitting its views on the seven policy fields for possible intervention that have been identified by the Commission’s Communication.
The comments that ACEA sent tthe Commission in March 20091 before the publication of the Communication remain still valid.