ECF’s feedback for the TEN-T Inception Impact Assessment
The European Commission has published the Inception Impact Assessment for revision of the Union Guidelines for the development of the trans-European transport network (TEN-T). The paper describes the Commission's plans, including problem definition, policy options and their preliminary assessment, and is open for feedback until 18 December 2020. ECF welcomes the recognition of the need to better integrate walking and cycling in the guidelines but considers the problem definition and proposed solution too narrow.
The Inception Impact Assessments correctly points out the need to adapt the TEN-T policy to the decarbonisation objective and other environment-related challenges set out in the European Green Deal. It also correctly recognises insufficient alignment with new transport policy developments and needs, which becomes an obstacle for more efficient and sustainable services. It gives a concrete example of an area for improvement (problem 1b): connection with active modes such as cycling or walking in urban node, and lists transfer facilities to active mobility solutions as one of the objectives.
However, the problem of insufficient integration of active modes is not limited to urban nodes and transfer facilities. TEN-T infrastructure, e.g. railroads or expressways, is a barrier for walking and cycling in a much wider context, including rural areas and trips that do not include a segment on TEN-T. Poorly designed TEN-T projects cut off suburbs from the cities and/or cut small towns into two. This promotes using unsustainable modes for short trips, that could easily be walked or cycled, if a sufficient density of safe and comfortable crossings for pedestrians and cyclists had been provided in the project. Which in turn leads to congestion and unnecessarily high emission levels.
In extreme cases the TEN-T projects destroy existing active mode infrastructure or undermine the effects of other EU-funded investments. For example, some ERDF-funded cycle paths will end with dead ends, because cycling facilities have not been included in a CEF-funded road expressway interchange, or a tunnel under a TEN-T railroad.
There are also examples of good practice, where a TEN-T project was used as an opportunity to improve conditions for active modes, or cycling infrastructure was added to a pre-existing TEN-T corridor (e.g. cycling bridge added to a railroad bridge). These demonstrated high potential of such interventions, with benefits exceeding costs as much as 14 times, but are still relatively rare across the EU. They are a result of determination of local authorities or civil society, not a coherent EU-policy.
To address that, cycling infrastructure should be systematically integrated into TEN-T. The potential for cycling traffic in the area covered by the respective projects should be evaluated and necessary elements of cycling infrastructure should be integrated into project planning, design, and construction. This should include, apart from cycling connections in TEN-T urban nodes, also cycle routes along selected sections of TEN-T corridors, safe and comfortable cycle crossings across TEN-T corridors as well as upgrading other roads affected by TEN-T projects to safe cycling standards.
As a parallel measure, EuroVelo, the European cycle route network, should be included in the TEN-T alongside the networks for other modes. The inclusion of a European cycle route network would recognise the importance of cycling to the continent’s transport system and its sustainability, particularly in achieving a more sustainable modal distribution and reducing GHG emissions in line with the 2050 climate neutrality objective.
The EuroVelo network is already well-established in most EU countries and therefore its integration into TEN-T would be easy to achieve. The cost of realising it would be relatively low in comparison with other networks and cycling infrastructure is far more cost-effective. Furthermore, its inclusion would directly contribute to meeting the TEN-T objectives, as listed in Article 4 of the current regulation, and stimulate the development of national, regional, and local cycle networks, as it serves as a backbone for such networks and provides a quality benchmark.
It is time that cycling was properly integrated in the EU’s flagship transport policy!
The full text of the Inception Impact Assessment and the feedback form More information on TEN-T and cycling
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