EU-kommissionens konsekvensanalys av EU:s Färdplan för transportsektorn: en granskning

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Björn Carlén

This review of the EU Commission’s “The Impact Assessment to Roadmap to a Single European Transport Area – Towards a competitive and resource efficient transport system” has been commissioned by the Swedish Energy Agency. The result shows that the Commission’s assessment for the transport sector is defective. The background is that the EU has articulated an ambition to reduce its greenhouse gas emissions with 80 per cent to the year 2050, relative the level of 1990. The transport sector has hereby been given a target to reduce its emissions by 60 percent. The objective for the “Roadmap to a Single European Transport Area” is to propose a policy that attains this target. The review comprises a discussion about (a) the stated emission targets for the whole EU and for the transport sector from a cost-effectiveness perspective, (b) whether the Commission’s analyses are consistent and comprehensive, (c) the scope for designing more cost-effective policy packages, and (d) the need for additional assessments. The Commission’s assessment for the transport sector is defective. It is not sufficiently transparent for the reader to fully understand the results and their drivers. It is not possible to find a clear accounting for the carbon prices that are needed for attaining the 60 percent target level in the “price based” policy scenario. And, the reader is not given a clear presentation of the assumed dose-response relationships between R&D and emissions as well as physical planning and emissions. Furthermore, the assessment does not comprise all relevant cost components, resulting in that the analysis become examples with limited values. Perhaps most grave is the circumstance that the Commission proposes a policy package implying that the transport sector within the EU would meet a carbon price that lies substantially below the price level assumed for the rest of the world. In addition, the Roadmap defines a policy package that seems to contain several large investments/projects that not easily can be associated with the objective of reducing greenhouse-gases in cost-effective way. It is not difficult to construct more cost-effective policy packages. In some instances it is difficult to avoid the thought that the climate problem has been hijacked in order to motivate the implementation of projects or undertaking of investments that have only small effects on the emissions or even increase them. Thus, when it is time for the next evaluation of the EU’s transport policy the risk is substantial that we have to observe that the transport sector once again has developed along other lines than the one outlined in the White Paper for the transport sector.

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