Increasing the competitiveness of the intermodal transport

Briefing 23-02-2024

The impact assessment (IA) sufficiently substantiates the need for a revision of the CTD, and provides a well-evidenced problem definition relying on various data sources. It presents a sufficient range of policy options, which appear to present self-standing alternatives. The IA qualitatively and quantitatively assesses all policy options' economic, social and environmental impacts, and explains the methods used in detail. It openly explains limitations in the analysis, for instance regarding employment consequences in the road transport sector and quantification of the impacts specifically for SMEs. As the initiative is relevant to SMEs, an SME test was performed. However, SMEs are not differentiated by size-classes (micro, small and medium enterprises) in the analysis, and overall, SMEs could have been discussed more. In the comparison of options, the IA could have clarified the scoring and the coherence assessment. Likewise, the arguments for the choice of the preferred option would have benefited from further clarification. The summary of stakeholder consultations describes stakeholders' views on the problems, objectives and different measures; however, the IA does not provide a description of the stakeholder groups' views on the policy options.