Ioannis Siamas, Ioannis Balkamos

Department of Logistics, University of Piraeus, Greece

[email protected], [email protected], [email protected]

Abstract

This paper aims to record and analyze the existing institutional framework of transport in Greece. It highlights the necessity for its revision in order to keep up with current developments and adapt to the requirements, primarily of the Greek and then the European economy. It notes the weakness of flexibility of legislation and the subsequent difficulties in the organization of means of transport, due to the joint responsibility of three ministries. Furthermore, it examines the contribution of the institutional framework in organizing supply chains and transportation systems, since the present legislation exclusively recognizes the physical transport, facing organization (Logistics, forwarding, etc.) only as an industry subset. It also investigates the actions needed in order to achieve sustainable mobility, which is a basic philosophy of the common European policy. This can be achieved through the modernization and the fundamental reform of the institutional framework. Additionally, it clarifies the institutional discrimination between the activities of supply chain, when they are part of the same company and when they are outsourced. All the above suspend the developmental course of the Greek transport sector, the competitiveness of Greek businesses and finally the exploitation of geopolitical advantages. Finally, profits of regulating interventions in financial, social and environmental level are indicated so as the transportation sector may fulfill its economic and social mission.

Keywords: Institutional Framework, Freight Transport, Transport Systems, Comodality, Supply Chain. 1. Introduction

The institutional framework of implementation of the terms of freight transport is characterized by shared jurisdiction of many government bodies, which fall into different ministries with shared responsibilities. When it was first created, it served an inferior transport infrastructure network, functioning as a gear of development in a totally different economic environment, in after-war and democratization times, with different than today’s needs. Anachronistic rules were accepted, as long as freight transport still took place in the level of carrier and carriage, alteration remained in low level, economies were closed and import trade was limited due to currency conversions. At the same time, achieving high speeds in long distance transport for perishable products was almost impossible. But, due to changes worldwide, national economies became part of the globalized economy, new markets emerged, the speed of means increased, border barriers disappeared and developing economies showed great potential for productive investments. Thus, the Supply Chain (SC) developed in an international level so as to cover a wide range of economic activities, from the preparation of production, movement, alternation and storage of products to ordering, redistribution and of course transportation.

Greek freight transport is characterized by the anachronistic Greek legislation, since there is no institutional organization in any level. This works as a disincentive against business actions and Greek legislation remains remote from the global trends of organization and modernization of the SC. The Greek government never took freight transport under serious consideration. That resulted in stagnation, since it was never effectively assisted in order to follow the European standards. The Greek state, despite its inability to complete the specialized infrastructures for the SC, must establish a suitable institutional framework in order to increase private initiative, regardless of the completion of the necessary infrastructures. On the contrary, the institutional framework of transport remains the same, from the time of the institutional evolution from carts to power driven vehicles, since the organization of transport has not been revised for the last 35 years. Starting from the producer, goods reach the retailer with basically the same institutional processes, while the organizational structure of the SC of markets and producers has changed those processes.

The bibliography of this paper concerns legislation of the Hellenic Republic, the White Paper and other directives of the European Union, scientific views of Iakovou et al., (2009), Fitzsimmons (2008), Samprakos E., (2008), The Economist, (2007) and the economic financial study of the Centre for Planning & Economic Research, (KEPE), (2001).

The contribution of this paper in the scientific community is the collection of scientific trends for the institutional intervention in developing the SC, their valuation and their shift in the political community so to be implemented immediately.This paper elaborates the basic proposals that would allow the reorganization of the SC in Attica for the benefit of the Greek economy and the competitiveness of services both for Greek and other passing products. Its contribution to the Greek SC, to the Greek economy and environmental balance is the scientific substantiation of the necessity of concentration of SC services and forwarders cross-docking in the Logistics Center (LC) of Thriassio Pedio, as their subsequent physical area.

In section 2 the institutional framework of freight transport in Greece is analyzed, starting from the transport means and ending to the transport systems. In section 3, the scientific trends of transport organization are presented and in section 4 the necessary changes so to implement the trends. The suggestions are summarized in section 5 with a presentation of the private and social benefits of the changes and a review of the conclusion closes the paper.

2.1 Analysis of current situation

Stagnation and weakness in following progress, is the biggest problem the system of freight transport in Greece, faces. According to the Commission of European Communities for freight Logistics in Europe, the SC is divided in four sectors. The preparation of goods for shipment and shipment from the production sites, transport of goods, forwarding of goods and warehousing, storage and inland terminal operations. From these four sectors, only transportation is recognized by Greece with a special institutional framework, with the rest functioning without a legal framework, subordinate to general provisions as any economic activity, removing from the State the strategic guidance of the SC, its internal organization and its international perspective. Thus, the organization of the Greek SC was done privately without extroversion and expansion plans. That is the reason why, all means of transport still maintain their functional autonomy, combined transport has no place in the Greek dictionary and the goal of Greece becoming an international LC and a hub of transit in the Balkan region, seems to be unrealistic when the goal of implementation is not defined politically. The slow territorial review, forced Logistics services, to work under outdated frameworks, and resulted in their spatial dispersion, without planning and organization. That led to the reduction of competitiveness of all Greek companies in international markets. The internal distribution of goods had to follow the growth of Greek economy and modernized by the pace of the market. The Greek SC should have been shield through internal development in order to prepare itself for its mandatory extrovert course, predetermined the past 30 years. Thus, the consequences from the inclusion of land adjacent countries to the European Union, the Monetary Union, the democratization of Eastern Europe and China and the international trade flows passing south and east of Greece were not valued as they should. That left a huge organizational gap that leads to the failure of extrovert activities of Greek companies in the SC. At the same time, other European countries (Italy, Spain, Germany, The Netherlands, Belgium, etc) took advantage of their internal development in the past 20 years and turned to new markets and services, while strong foundations built through internal activation secure them in times of financial crisis.

2.1. Means of transport Road transport

Road transport, which is the oldest form of transport, consists by a series of laws and decisions with earlier references in the Commercial Law of 1835 (Articles 95-107). The most recent Legislative Decree 531/1970 has enabled the replacement of animal drawn vehicles for transporting goods by trucks, achieving the renewal of transport. The 383/1976 law codified the rules on carrying out road freight transport with the use of public use vehicles. The above is up to date, the basic legislation for inland transport of goods. By law 1073/1980, came the replacement of three-wheeled public use vehicles with trucks. The 1959/1991 law consolidates all legislation relating to road transport by private truck cars. Recently, the inclusion of a series of new decrees regarding road freight transport is announced. These decrees point to the right direction. The number of licenses for public use trucks is freed, fare limits are abolished and transporters are organized in SAs and ltd companies. This effort will help the sector of freight transport in Greece, adjust to international trends. Specifically, it includes new intentions, such as liberation of freight transport (which practically means that anyone who wishes may, under certain conditions obtain a public use truck license), improvement of competitiveness for better services at better prices, abolishment of freight limits, which will be fixed between the lessee and the carrier, organization of transporters in companies, evaluation of the value of existing licenses, integration of transport, which means that the separation of international and national transport will be abolished, establishment of a national electronic registry for transporters, with new vehicle inventory, compulsory insurance of goods by transporters, environmental issues with the use of modern engines (at least Euro 4 or above) and the recommendation of National Committee on Road Transport. Also, cabotage, which remains indistinguishable, is determined by a specific number of licenses. That leads in the control of feasibility and creation of problems in controlling the flow of goods.

Rail, sea and air transport

The railway transport service in Greece is available by a public body, named “OSE”. Access to railway infrastructure, from other transport companies, became possible after the adoption of Council Directive 440/91 with the 324/96 Presidential Decree. But the liberalization of rail freight transport applies only on paper. The necessary regulatory framework which will regulate the entry of private companies in the Greek railway system was never created, since the legislative coverage of railway use still remains. For this reason, the creation of “Railway Regulatory Authority” based on the 101A Article of the constitution, is under consideration.

Things are different for air and maritime transport. All ships can enter the Greek ports and similarly, the access to airports is free of institutional constraints.

2.2 Transport systems

At institutional level, the law 3333/2005 has passed, regarding the establishment of LC. It defines the land required for the establishment of LC, the necessary transport infrastructure and regulations regarding their location. Despite the fact that the law passed 5 years ago, is not yet put into practice. Joint ministerial decisions still remain, regarding, the location of the centers and the terms of operation and funding. The 3710/2008 law (which revises the 3333/2005 law), gives the opportunity to establish LC in non tangential areas. This is about the adjustment in EU Directives and in trends of interoperability of transport systems. As part of the reconstruction of the transport system, the Ministry of Transport composed the findings of the Greek Logistics Committee regarding the development of specialized Logistics infrastructure which defines the strategies of creation and operation of LC.

In 2006, the law 3446/2006 came into force, on the organization and functioning of the supervisory authorities on the movement of vehicles. Defines the framework for establishment and operation of “Joint Control Teams” and proportions the responsibility for loading and transportation of any shipment. However, responsibilities are required from people that have no training on loading units.

Forwarding, Logistics

The organizational aspect of transport includes the activities of forwarding and storage, which do not fall under institutional frameworks due to the anachronistic view that transport is only the physical transport, leaving out an entire service system, which exists and operates smoothly, with private criteria.

3. The organization and reorganization trends of transport system.

The global economic growth of the last 20 years boosted the development of freight transport in order to cover all new production sectors that emerged all over the planet. The big extension of the SC, which emerges from distant markets and the expanded network of consumers, forced SCs to explore new ways in solving problems, by improving the efficiency of all means separately, achieving the goal of improvement of the entire transport system (Iakovou et al., 2009). The new production sites contribute to international competitiveness, while smaller production processes and limited lifetime of products impose cost reduction (Samprakos, 2008). Through the composition of the White Paper (COM (2001) 370) takes place an effort to face transportation as a whole, taking advantage of the abilities of all means, for the benefit of the functionality of the SC and for resource savings and the achieving environmental sustainability. Through the improvement of transportation systems, parallel objectives emerge, such as sustainable development and sustainable mobility (COM 336/2006). The organization of means, introduced new terms in the transportation systems, such as comodality and intermodality (COM (2007) 606).

New trends treat the contributors in the SC, as a part of a big transportation system, disassociating from the traditional view of treating each mean of transport separately. The acceptance of these new trends is determined by the change of the institutional framework of each country, shifting the focus, from means to systems of transport and from the traditional physical transportation, to the integrated processes of shipment (COM (2001) 370, White Paper). This leads to the connection of all SC rings, which acquire common ways of communication and activities, acting competitively inside a physical network that sustains itself, by high quality synergies (The Economist, 2007). It is clear that for private companies, the implementation of transport systems is easier (using private use trucks), because there are no institutional requirements, except for sustainability. On the contrary, when transportation services are outsourced, institutional coverage is necessary, since a third member is involved (public use trucks). Transport systems develop networks, with hubs connecting crucial regions with big supply needs. The location of SC services is determined by international standards of development through the use of hubs. Specifically, the first step is the interconnection of national networks and then follows the regional and national development, to eventually integrate into the global physical internet. The effective use of all ways of transport, individually or in combination (comodality), leads to reduction of transportation costs, to optimization of the use of all existing means available, to the provision of the best possible quality of service to the customer, direct and continuous information at all stages, to continuous search for new ways of obtaining advantages against competition, to the need of environmental protection (which from now on will work as a regulatory factor), to the creation of a new web of production and disposal of transport services, to the liberalization of transport services (by the privatization of the rail and the liberalization of internal transport) and to the creation of a new form of network for companies providing transport services (mainly Logistics services) regarding all means of transport.

In the private sector, companies that need to increase their productivity and improve their competitive position, turn to experts in order to outsource any activity, not associated to their core business. It is an effort of adjusting supply with demand, through agile business procedures (Fitzsimmons, 2008). Thus, transportation, which clearly is not included in the production process, probably is the first area that outsourcing should take place. Despite all that, outsourcing is blocked by the Greek institutional framework, since companies that are part of the SC, cannot vertically integrate their actions and are forced to turn to PUT in order to outsource their activities. For years, the number of PUT remained the same and that led to the great increase of private use vehicles, despite the fact that in other European countries their number is decreasing. In countries where the boundaries of working as a transporter were banned, companies tend not to buy their own trucks to cover their transport needs but to relieve themselves from the ones that they already possess. Although in Greece, we do not possess any comparable evidence, the purchase of new vehicles shows a disproportionate increase on private use vehicles with a number of 1.000.000 against 28.000 PUT. This negative effect is probably the biggest problem created by the licensing system which remains the same for the past 40 years, creating substitution conditions of PUT with private (KEPE, 2001). Similarly, the establishment and operation, of companies operating the railway network is not yet been settled by law, although theoretically freight exploitation is freed.

Regarding the public sector, the right solution in organizing freight transport, leads to the creation of a network of nodes, with freight infrastructures of high capacity. Thus, LC were established (Law 3333/2005) in order to organize all freight infrastructures according to European standards. But the legislation is not yet implemented, since no license is been given so far. The competitive functioning requires integration into a network of LC, using the entire capacity of the system. The General Framework of Territorial Planning and Sustainability (GFTPS, 2008), defines the guidelines for the development of SC and describes the territorial position (location) of Logistic centers as well as the mandatory inclusion of any SC service in it. The stability of the supply infrastructure ensures sustainable development and energy savings. The European policy on Freight transport defines a series of sustainable transporting solutions, such as combined transport, the development of the railway network, the increase of rail freight transport and the increase of rail and maritime transport compared to road and air transport. Thus, organizational improvement of transport systems is achieved, which contributes to the reduction of transportation cost, the improvement of transportation chains by high quality service level, regarding safety and reliability and adaptation to international standards for the development of combined transport, which is a primary policy of the European Union. Additionally, the reorganization of the freight transport system in Greece will contribute to the increase of road safety, the protection of the environment and the economic revitalization of regional development through private investment initiatives. The dominant trends, are forcing the Greek government to implement necessary reforms in order to organize the SC. It is significant that the present institutional framework that does not focus in transportation systems, does not support the international agreements between Greece and COSCO which require high-performance services, reduction of service time and reduction of cost in the market.

4. Need of reorganization plan

The strategic option for the development of freight flows and the modernization of the institutional framework, are necessary and efficient conditions for the reorganization of the SC. The term “supply chain” and the sectors it contains are not included in an institutional framework. On the contrary they are included in scattered legal texts of different Ministries. Only transporters have legal coverage, while the rest sectors of the supply chain are not defined and subject to the Ministry of Finance and Development as any commercial activity. The number of licenses for PUT is basically the same since 1976 causing supply chain services to function without the possibility of vertical integration, decreasing the quality of the services provided. Today, licenses are granted under the principle of legality, but the measure is recent and its effects are not yet distinct.

The national territorial planning requires the development of supply infrastructure in specific locations (GFTPS, 2008). The absence, however, of organization nodes and combined transportation services contributes to the organizational gap. At the same time, urban planning legislation does not include SC activities for building outside the urban plan, resulting in a building factor of 10% (PD 24/31-5-1985). There is no strategy and national planning.

The country is lead by territorial plans, without consulting the experts. Thus, any LC can operate without control on the effects it may have over the National Strategic Plan, whereas normally such an operation would require initial testing and subsequent revision of the strategy. The result could be the anarchic development of sectoral companies in disparate locations, without strategy, without an organized plan, without node development and polluting the environment, while trying to serve the needs of the market (Iakovou et al., 2009).

The principles of sustainable mobility and development are primarily reflected in the White Paper in 2001 (COM (2001) 370). Aspects of this Directive are embodied in the national legislation, for minor issues, without achieving a new approach in the transportation sector as a whole. Then follows a series of Directives by the Commission, for the organization of the SC, such as COM (2006) 79 and COM (2006) 336, regarding the enhancement of safety in freight Logistics in Europe and the separation of transportation in 4 sectors such as: handling of raw materials and products in production, transport of goods, forwarding of goods, warehousing, storage and inland terminal operations, defining the activities by which services are vertically integrated. Also, the White Paper was checked and revised by COM (2006) 370, pointing to countries such as Greece, that have not reconciled, the need for liberalization of their transport services. Such discrimination can be divided into two main sections, the organizational and executive transportation. The first as static includes forwarding and the organization of land stations and the second as dynamic the means of physical transport. This new discrimination is based on Directives from the Commission, but in a more aggregated structure. But, effective separation of the sectors is required, in order for the European Directive to be applicable with the creation of transport systems. For the development of the international role of Greece in the Balkan region, internal transportation should develop, as a necessary substrate for outward-looking development of the transport sector. This means adapt international models in Greek geographic and demographic requirements. Obtaining a single legal responsibility and common transport documents for each type of transport, national, intra-European, and international, requires codification of legislation, simplification by adapting terms from the CMR Convention for all transport and adjustment of 3446/2008 law to international practices of accountability, regarding loading and transportation. The legal uniformity will contribute to the single transport insurance coverage. Similar problems are faced regarding the safety of dangerous goods, which are transported to islands with no legal ways, using ordinary passenger ships. All institutions involved, know the truth, since the supply of the islands is not in any other particular manner but with the same passenger ships, with constant risk of accidents. In shipping, CMR and RID conventions are not accepted for goods that take part in intermodal transport. Thus, combined transport cannot be applied under legal procedures and islands cannot be served since they do not always have RoRo ships.

These problems create bureaucratic procedures that delay the SC, creating vulnerable links resulting in delays throughout the SC. The adjustment of internal legislation to international rules and the reorganization of transport from securing the means to organizing transportation systems is the only way to development, for Greece.

5. Suggestions

The lack of strategy for meeting the objectives of the Greek state combined with the differentiation between Greek and international legislation, the delay of implementation of European Directives, the slow territorial arrangement and the weakness of developing transportation systems characterize the current state of freight transport in Greece. Focusing on serving loads for 3PL, leads the country in a developmental course, and includes it, in European corridors of freight flow. To implement the proposals, should first define a strategic direction, that will monitor and record progress and will be controlled by a public entity, ministry or an independent administrative authority, to be followed in any proceedings relating to transport.

The proposed suggestions are:

• The creation of an institutional framework for the SC that defines and distincts all sectors and includes them in one institution, is a necessity for the change of way of confrontation of transport
• Focus on the transport system rather than the mean, were interest is based on the load, on the speed that it can achieve and the on the correctness of the procedures
• In order for the SC to be functional and reliable, is necessary to reinforce the trend of hub development of all those involved in the SC
• The territorial arrangement with hubs, connected with the LC, must be accompanied by accelerating the creation of the centers. The new LC will increase the service rate of cargos and the speed of transportation by including Forwarders Cross-Docking, into the LC
• Gradual increase over three years of the number of PUT, according to factual data, that will decrease the vibrations of the sharp increase in the total number of transportation means (public and private use trucks). That will also lead to increased competitiveness and maintenance of the characteristics of the sector. This flexible political solution provides the opportunity for the Ministry to choose the field of organization
• Single transport document for all means and types of transport. Effective implementation of ADR, RID Conventions and similar acceptance by the maritime community within the limits set by the IMO, but at the same time accepting the corresponding forms of other conventions
• Create training organizations for safe loading, for transport, for workers, operators, shippers and forwarders to the proper implementation of civil and criminal law. Upgrading workers from the rate of unskilled worker in register and loader, depending on the materials they handle. License for safe loading, especially for drivers and loaders. Continuous training for the workforce. Creation of special education departments for new innovative specialities required for the LC.

The service of internal, European and international transport and the favour of investors are the benefits that will contribute to the emergence of Greece as a hub of transit in the Balkan region. Outsourcing will be easier to implement, while the transport system will reduce bureaucratic involvement of businesses with tax documents. The simplification will facilitate decision-making for perusing combined transport as way for its development. The increase of the speed of cargos will be a criterion in the preservation of combined transport.

The increased speed of combined movement of goods, the redirection of cargos, the improvement of handling and the opening of new ways for distributing goods are the business benefits that will emerge. The above are based in synergies that allow functioning through the use of economic scales and the operation of specialized infrastructure, which in smaller scale would have been impossible. The common transport law will contribute to the investigation of new ways of transporting goods, adapted to transport systems, and will resolve bureaucratic problems due to the legal compatibility of means.

Basic social benefits, from the separation of each participant in the SC according to his activities, are the maintenance of social balance in the SC and avoidance of conflicts of interest within the sector, nationally. Thus, SC is normalized and distortions of the market are erased. Environmental benefits emerge from the decongestion of cities, with the purification of urban centers from the SC services by their organized translocation in hubs. The translocation of the informal LC of Eleonas, in new operational facilities inside LC will contribute to environmental benefits, especially for Athens. Finally, LC will create the demand of new professions, increasing employment throughout the whole transport sector.

6. Conclusions

The contribution of the private sector in the development of the economy and especially the SC, takes place according to business practices and rules of the market. But, the public sector is the one that will have to set the conditions, restrictions and strategies according to national and international goals.

In summary we conclude to the following interventions:

· Organizing Logistics in legal and scientific basis, with separation of roles. The separation contributes to the organizational reliability

· Organization of transport in the Attica basin, which is currently unregulated

· Unified operation of LC and implementation of management system of freight flows

· Inclusion of all SC services into a vertically integrated framework with organizational guidance from the state, which should have a say in the infrastructure it provides

· Resolution of emerging problems from the joint responsibility between the ministries

· The organization of the sector with flexible, goal-oriented decisions, because each activity takes place without context and without targeting

· Adjustment to the European institutional framework regarding the safety of transport and the sustainable mobility

· Training of participants in the SC at all levels.

The results of the proposed interventions will be:

· Enhancement of competitiveness in the transport sector

· Possibility of investment by foreign companies when there is a stable operating framework

· Reduction of the unnecessary transport of cargo from the insertion point to redistribution point and return to the points were the transportation procedure begins

· Increased speed of combined movement of goods and redirection of loads

· The railroad will become more attractive due to close connections with forwarding and its single functional structure, resulting in the increase of rail transport, to environmental protection and traffic reduction

· Forwarding growths and obtains competitive means as tools for the entrance of cargos in harbors

· Legal Facilitation of intermodal transport

· Uniform treatment of transport and transportation means

· Facilitation of internal distribution

· Reduction of bureaucracy

• Facilitation of outsourcing
• Reduction of insurance costs
• Safe services provided to islands and their passengers, under legal procedures
• Reliability of services through proper training and certification.

The development of the SC services should focus in third (3PL) and forth party Logistics (4PL), without excluding companies with vertically integrated structures, as happening to trade and industrial companies, with the supply of production contributing to the chain. Greek corridors will achieve reliability, accuracy, qualified and certified value-added services and they will become part of the value chain that leads to consumers. The international obligations of Greece with Cosco require Logistics companies that will reliably support this project, bringing out the competitive advantage of Greece, as the closest route that lacks infrastructure, organization and reliability. The development of the project for the emergence of Greece as a transit hub in the Balkans passes through the national strategy in order to reflect to the reorganization of the institutional framework of the SC.

Bibliography

1. Fitzsimmons, J.A. Fitzsimmons, M.J., 2008. Service Management, Operations, Strategy, Information Technology. 6th ed. McGraw Hill Higher Education.
2. Iakovou E., Kapros S., Siamas I., Tsamboulas D., Vamvakopoulos D., July 2009. Development of Specialized Logistics Infrastructure (in Greek), Hellenic Ministry of Infrastructure, Transport and Networks, Athens.
3. KEPE, Centre for Planning & Economic Research, 2001. Study of … professions (in Greek), Athens.
4. Samprakos E., 2008. The sector of freight transport and the combined transport.
5. The Economist, June 17th 2006. The physical internet, A survey of Logistics.

Legislation

Greek legislation (Hellenic)

6. Commercial Law, Royal Decree 19-4/1-5-1835
7. General Framework for Territorial Planning and Sustainable Development, GFTPSD, Government Gazette 128/3-7-2008, Issue A
8. Government Gazette, 1049/30-11-1995, Issue D Approval of urban planning study for the revision and extension of parts of municipalities of Athens, Agios Ioannis Rentis, Egaleo, Peristeri and Tauros (Area of Eleons) (Attica district)
9. Hellenic Republic Constitution
10. Law 383/1976, PUT freight transportation
11. Law 1073/1980, Replacement of three-wheeled trucks with PUTs
12. Law 3446/2006, Organization and operation principles of traffic control vehicles, Government Gazette 49/10-3-2006, Issue A
13. LD 531/1970, Replacement of carts with PUTs.

European Union Legislation

14. COM (2001) 370 White Paper. European transport policy for 2010: time to decide
15. COM (2006) 79 Communication from the Commission. Proposal for a Regulation of the European Parliament and of the Council on enhancing supply chain security (SEC(2006)251).
16. COM (2006) 314 Communication from the Commission. Keep Europe moving - Sustainable mobility for our continent Mid-term review of the European Commission’s 2001 Transport White Paper {SEC (2006) 768}
17. COM (2006) 336 Communication from the Commission. Freight Transport Logistics in Europe – the key to sustainable mobility {SEC(2006) 818} {SEC(2006) 820}
18. COM (2007) 606 Communication from the Commission. The EU's freight transport agenda: Boosting the efficiency, integration and sustainability of freight transport in Europe {SEC(2007) 1351} {SEC(2007) 1367}
19. Council directive 440/91/EEC of 29 July 1991 on the development of the Community's railways.