Response of the Alliance Internationale de Tourisme (AIT) and the Fédération Internationale de l’Automobile (FIA) to the European Commission’s Communication Towards a Thematic Strategy on the Urban Environment (COM (2004) 60)
Publication date: 08 April 2004
The AIT and the FIA are pleased to have this opportunity to comment on the Commission’s Communication and take part in the consultation on the development of the forthcoming Thematic Strategy. The development of policies that allow for sustainable mobility are key amongst the priorities of the AIT and the FIA, and our member organisations. For a number of years now, the AIT and the FIA have been involved with programmes and policies that have sought to make car use more sustainable. These have included programmes aimed at making the car safer and more environmentally friendly. Indeed, it is our belief that the car has never been safer or cleaner than today. However, as the representatives of European Touring and Automobile Clubs with a combined membership of some 40 million ordinary motorists we also aim to ensure that the needs of the vast majority of Europe’s citizens are not ignored. Thus, many of our rejoinders are based on the transport reality of modern Europe. The car is, and will continue to be, the transport mode of choice in Europe. Indeed, nearly 80% of journeys in the EU are made using the car. The car offers citizens levels of efficiency, convenience, comfort, and safety unrivalled by any other transport mode. Therefore, when making policy we need to remember that citizens will not simply give up their cars and make provisions to include this fact in our policy solutions.
Before commenting on the specificities of the Communication, we would like to comment on a number of the assumptions and methodologies used in the development of the proposals. Firstly, we find that whilst the Communication is able to talk of the costs of urban transport there is no mention of its benefits, both economic and social, nor is there any recognition of the fact that many people due to poor public transport links have no choice but to use their cars. It seems incorrect to the AIT and the FIA to propose plans to limit the use of the private car whilst doing little to tackle the inadequacies of Europe’s public transport systems. The AIT and the FIA fully support the greater use of public transport in urban areas. However, this will not happen unless more is invested to make these systems more attractive to citizens. Simply making car use more expensive or more inconvenient will not lead to desired policy effect and may prove to be counter-productive. Secondly, the notion of the Communication that in some way we can make efforts to decouple transport growth and economic growth are simplistic and unobtainable. Put simply, the economy cannot grow without transport. Thus, rather than try to reduce the use of transport we need to find ways to manage it more sustainably. As a third point, the AIT and the FIA welcome the efforts made in the Communication to ensure that sustainable development is defined as more that environmental issues. We need remember that sustainability should also consider economic and social needs as well as those of the environment. Finally, we would like to raise concerns about the consultation process that led to the development of the Communication. The Commission states that a wide-ranging consultation took place with all actors in society. However, on closer inspection it can be seen that many of the NGOs consulted are environmental groups with views and agendas that do not reflect economic and social reality. The AIT and the FIA wonder why more groups were not asked to take part in this consultation programme. Surely it would have been wise for the Commission to do so? That said, the AIT and the FIA are pleased to have this opportunity to comment on the Communication. We will now provide comments to the proposals. As would be expected from the nature of our interests, we will restrict the majority of our comments to those proposals concerning transport.
Sustainable Urban Management
Overall, the AIT and the FIA encourage the development of policies which raise the profile and importance of environmental considerations in policy decisions, especially at the local level where these concerns are not always raised. However, we must once again emphasise that these decisions should be taken within the context of sustainable development which should mean more than simply environmental concerns. The AIT and the FIA believe that if the Commission does decide to legislate in the future this point of view should be foremost in its mind.
Sustainable Urban Transport
The Commission is correct to highlight some of challenges facing Europe’s transport system in the coming years. However, the AIT and the FIA believe that the Communication over states the problem, as does the 2001 Transport White Paper. Certainly congestion does occur and pollution is a problem. However, much congestion occurs on the edge or urban areas not in the centre. Thus, this a problem of adequate road links and public transport, neither of which are fully dealt with by the Communication, not simply one of punishing motorists by increasing the already high costs they face. In the same regard, the Communication does not take account of the improvements in the environmental performance of the modern car, which is around 95% cleaner that cars in the 1970s. Additionally, when mentioning the use of charging schemes and the internalisation of external costs, the Communication fails to note the already high taxes paid by motorists (in the view of the AIT and the FIA, motorists already internalise their externalities) and the negative economic effects of charging schemes such as the one in London. Damaging a cities economy for simple environmental goals is not sustainable development.
Indeed, throughout the Communication we find a general anti-car bias. It is the view of the AIT and the FIA that the Communication seeks to dream of a future without the car. The reality is somewhat different. The car will remain the vehicle of choice for the a majority, especially where no alternative exists. Investment is needed in our public transport systems rather than symbolic policies that exclude that majority of citizens from their right to mobility. Additionally, more attention needs to be paid to the fact the car will remain. We simply cannot ignore the road. To this end it is not enough that the Commission develops action plans, concrete policies and investment is needed if we are really develop a sustainable transport system for our towns and cities. A systems that looks after the needs of all our citizens and considers all modes of transport as vital cogs in the system.
The AIT and the FIA has little say on this subject, except that we welcome the fact that limiting the use of the private car is not presented as the panacea to all of our environmental problems.
Sustainable Urban Design
It is the view of the AIT and the FIA that urban design is a key theme for improving the transport situation in our towns and cities. However, unless this is coupled with improved public transport, we will not see a reduction in car use. In addition, the role of the road sector should not be ignored.
In conclusion therefore, the AIT and the FIA welcome the chance to comment on these proposals from the Commission and only regret that we did not have a chance to do so earlier. The AIT and the FIA, and our member organisations, are committed to policies aimed at bringing about sustainable development and mobility. However, we are of the view that this can only be done by taking full account of the role of the car in our economy and society. To simply ignore the car will result in no positive gains and risks alienating Europe’s citizens. Thus, the AIT and the FIA call on the Commission to ensure that the future Thematic Strategy reflects the centrality of the car to our daily lives.
For More Information Contact:
AIT&FIA European Bureau
Rue d’Arlon 50
Tel: +32 (0)2 282 0825
Fax: +32 (0)2 280 0744