T&E has prepared this paper as an input to the Commission "Communication on EU policies and measures to reduce greenhouse gas emissions: towards a European Climate Change Programme". It includes various observations on the proposed approach, including some constructive suggestions of ways in which T&E considers that the process could be reinforced or broadened.

T&E welcomes the Communication as it sees the developments of policies and measures "towards a climate change programme" as the way forward for the European climate change policy.

This approach is particularly relevant for the transport sector, which is the main and fastest growing contributor to CO2 emissions. Only concrete policies and measures, which are defined for the community as a whole but are implemented mainly at a national or local level, can help to reverse the trend in this sector.

However, when doing this, it is important to define clearly from the start which policies are of community, and which are to be co-ordinated policies of member state competence. This will help to avoid duplicating the measures, or using the community competence as an excuse for lack of action at the national level, or vice versa.

Regarding the process itself, T&E welcomes the Commission approach, which is to involve member states and NGOs at an early stage in the process. We hope that this programme is an important first step leading to implementation of transport and climate change measures community-wide. We do however, have two concerns:

Firstly, the process was rather confusing in its set-up and it is difficult to have an overall view of the linkages and interactions between the different working groups and other work in the areas listed, particularly because some of the transport sub-groups are open to stakeholders and others are not. For example, on the common transport policy and the green paper on urban transport papers, T&E has some bilateral contacts with the units and people involved; there is however, not an official consultation process in place in these areas as yet. T&E considers that it would strengthen the process if these areas were opened up to proper stakeholder dialogue at the earliest possible stage.

Secondly, the medium and long-term objectives of the ECCP are not very thoroughly defined in the paper. Furthermore, it seems that every working group has its own objectives, not all of which are entirely transparent; it is difficult to see how these will feed into the overall process, and how both duplication and gaps can be avoided.

In addition, it would be of great utility to state explicitly from the outset if sectoral targets are envisaged, and whether objectives of the exercise would include de-coupling transport and economic growth.

Given the wide range of possible measures to deal with climate change from the transport sector, it is necessary as a first preliminary step to set up a list of these possible measures. The second preliminary step would be to identify the work already done in these areas (eg. in the Commission work programme, or in other fora). A third and last preliminary step would be to identify which policies and measures are of Community competence; which are incumbent on the member states but would benefit from a better level of co-ordination; and which are best left entirely to national and local authorities.

The approach taken in the Communication did not appear to cover the first or the third preliminary steps, which are in our views essential for an integrated transport and climate change policy.

Another important point for such a policy, and recognised by the Commission, is to link this process with other processes dealing with the environmental impacts of transport. It is therefore clear that some of these processes will be able to feed into the ECCP. It is however, important to identify both these measures and make the link with the bodies considering these issues.

For example, whilst the policies and measures assessed by the Auto Oil Programme targeted other environmental problems, their impacts on CO2 emissions were also assessed. The CO2 effects of the range of measures assessed under this programme, technical and non-technical, are therefore available for the Commission to use as are some useful modelling scenarios and tools. This is also true for research projects such as CANTIQUE.

Equally, the policies and measures listed so far in the Communication appear to identify only areas for which an identifiable Community policy process is already in train. T&E has identified a number of areas that could have been listed in the Communication. For additional information, see also the paper called "Road Transport in Europe: a Critical Challenge for Policies and Measures" developed by Fergusson and Skinner, 1999. Possible additional areas for common or coordinated action include, for example:

• fiscal measures for heavy goods vehicles;
• fuel tax;
• speed and safety policies;
• enlargement and the TINA process;
• general investment policies;
• best practice examples;
• measures in the aviation sector (this could be dealt with in the emissions trading sub-group; the community could come up with a cap for the aviation sector, as this sector falls out of the EU "mandate" and include it in the internal emissions trading scheme; this point needs further elaboration).

Transport being responsible for a whole range of environmental problems, CO2 can and should not be looked at in isolation from other community policies. The paper rightly recognises this. It is however, still unclear how these links will be made to existing community policies for air quality, noise (framework directive under preparation) etc.

By way of concluding, T&E would like to state that it would be happy to participate in this process and provide its expertise whenever possible.