On the 15th of September 2016, FEDEMAC responded to the European Commission's Consultation on the revision of the Directive on the European Electronic Toll Service.
FEDEMAC took the opportunity of drawing attention to the fact that the European Commission should harmonise the procedures for accrediting an EETS provider to a toll domain, with the aim to reduce the cost and burden associated to it.
The Consultation's aim was to establish whether the EU legislation should provide for the separation of accounts between toll-charger and toll-service-provider activities, when they are both performed by the same company. The European Commission reported that a large proportion of respondents (63%) felt that the EU legislation should provide for the separation of accounts between toll charger and toll service provider activities.
The EETS legislation, as it stands today, applies to all electronic tolling systems, urban or interurban, for any types of vehicles, which require the installation of on-board equipment. In other terms, the EETS does not need to cover systems using automatic number plate recognition (ANPR) as primary vehicle recognition system, such as the London Congestion Charge or 'electronic vignettes'. By definition, ANPR-based systems are not concerned by the problem of lack of interoperability of on-board equipment, since they do not require such equipment to be installed in the vehicle. However, the fact that they are not covered by the EETS implies that users receive separate invoices, and must pay separately for the use of roads covered by these systems. Therefore, FEDEMAC noted that the scope of EETS should be extended to systems based on automatic number plate recognition, such as e-vignettes or the London congestion charge. Analysis of the European Commission revealed that 60% of respondents felt that the EETS scope should be extended to ANPR based systems. This is consistent with road users (road freight transport operators, users, etc.) wanting maximum flexibility in accessing toll services.
On cross-border recovery and enforcement of tolls, currently there are no harmonised rules at EU level governing the recovery of unpaid tolls from users of vehicles registered in another Member State. FEDEMAC stressed the need of the European Union to establish a mandatory mechanism for the exchange of data on toll offenders to facilitate recovery of unpaid tolls. FEDEMAC would like to see focus on needs to be done on simplicity and efficiency. The European Commission noted a strong consensus was observed regarding responses to this question, showing that 77% of respondents agreed that the EU should establish a mandatory mechanism for the exchange of data on toll offenders to facilitate recovery of unpaid tolls.
It is important to bear in mind that most of the big electronic tolling systems for trucks cost around 600-800 million euros to set up and yearly operation and maintenance costs consume up to 15% of the toll revenues. Therefore, FEDEMAC sees it as necessity that the European Commission be given the right to scrutinise the planned architecture of new electronic tolling systems (including tender specifications for the contract to set up and operate the tolling scheme) and take a position, before they are put in practice.