Europaudvalget 2016
KOM (2016) 0082
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EUROPEAN
COMMISSION
Brussels, 18.2.2016
SWD(2016) 35 final
PART 1/2
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the document
Proposal for a Directive of the European Parliament and of the Council
on the recognition of professional qualifications in inland navigation and repealing
Council Directive 91/672/EEC and Council Directive 96/50/EC
{COM(2016) 82 final}
{SWD(2016) 36 final}
EN
EN
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Contents
1.
1.1.
1.2.
2.
2.1.
2.2.
2.3.
2.4.
3.
3.1.
3.2.
3.2.1.
3.2.2.
3.3.
3.3.1.
3.3.2.
3.4.
3.5.
3.6.
3.7.
3.8.
3.8.1.
3.8.2.
4.
5.
5.1.
5.2.
6.
6.1.
6.1.1.
6.1.2.
6.1.3.
6.1.4.
GENERAL CONTEXT ............................................................................................. 3
Policy context ............................................................................................................... 3
Legal framework .......................................................................................................... 4
CONSULTATION AND EXPERTISE .................................................................... 5
Interservice group......................................................................................................... 5
Consultation of the IAB ............................................................................................... 5
Consultation of stakeholders ........................................................................................ 6
External expertise ......................................................................................................... 7
PROBLEM DEFINITION ........................................................................................ 7
Description of the main problem.................................................................................. 7
Negative consequences of the problem ........................................................................ 9
Consequences for the IWT sector
............................................................................... 9
Consequences for the EU economy
............................................................................ 9
Underlying drivers of the problem ............................................................................. 12
Problem Driver 1: Workers face difficulties with mutual recognition of
professional qualifications ........................................................................................ 12
Problem driver 2: Knowledge of Specific Situations (KSSs) may create
unnecessary difficulties for boatmasters operating on certain river stretches
....... 17
Attempts by the sector to tackle the problems ........................................................... 18
Summary of the main problem and its underlying drivers ......................................... 19
Who is affected by the problem? ............................................................................... 19
How would the problem evolve, all things being equal (baseline scenario) .............. 19
Does the EU have the right to act? ............................................................................. 22
Legal basis ................................................................................................................. 22
Subsidiarity ................................................................................................................ 22
OBJECTIVES
.......................................................................................................... 23
POLICY OPTIONS
................................................................................................. 23
Step 1: Considered policy measures & mapping with problem drivers ..................... 23
Step 2: Combining the policy measures into policy options ...................................... 27
ANALYSIS OF IMPACTS......................................................................................
30
Social impacts ............................................................................................................ 30
Impact on labour mobility
......................................................................................... 30
Impact on access to the profession
........................................................................... 34
Impact on safety in the IWT sector
........................................................................... 34
Impact on job quality/attractiveness
......................................................................... 38
1
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6.1.5.
6.1.6.
6.2.
6.2.1.
6.2.2.
6.2.3.
6.2.4.
6.2.5.
6.2.6.
6.2.7.
6.2.8.
6.3.
6.4.
7.
7.1.
7.2.
7.3.
7.4.
7.5.
8.
Impact on labour costs
.............................................................................................. 39
Impact on employment
.............................................................................................. 40
Economic impacts ...................................................................................................... 40
Impact on the contribution of IWT to the European industrial base
..................... 40
Impact on the contribution of IWT to the European transport energy efficiency
.. 40
Impact on transport costs and on final consumer prices of goods
.......................... 41
Investment costs.........................................................................................................
41
Impact on recurrent administrative costs
................................................................. 42
Impact on different regions.......................................................................................
44
Impact on SMEs
........................................................................................................ 46
Impact on third countries
.......................................................................................... 47
Environmental impact ................................................................................................ 47
Summary of the economic, environmental and social impacts
............................ 47
C
OMPARING THE OPTIONS
........................................................................................ 48
Effectiveness .............................................................................................................. 48
Efficiency ................................................................................................................... 49
Coherence ................................................................................................................... 49
Summary on the comparison of policy options.......................................................... 50
Conclusion: preferred policy option........................................................................... 51
M
ONITORING AND EVALUATION
............................................................................... 52
Endnotes ................................................................................................................................... 53
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1.
1.1.
G
ENERAL CONTEXT
Policy context
A Deeper and Fairer Internal Market with a Strengthened Industrial Base is one of the ten
policy priorities
1
of the Commission. As Europe’s best asset in times of increasing
globalisation, the potential of the internal market needs to be exploited in all its dimensions.
This includes maintaining and reinforcing a strong and high-performing industrial base for
our internal market, bringing industry’s weight in the EU’s GDP back to 20% by 2020, from
less than 16% today. Competitive industries rely on the ability to transport large volumes of
freight in a cost-efficient way. Inland navigation plays a key role in this respect. Inland
navigation vessels have a loading capacity that is equivalent to hundreds of trucks
2
, which
could help to save transport costs
3
and decongest roads. The EU inland waterways network
spans 20 Member States
4
with about 41,527 kilometres of inland waterways
5
. Linked by the
Main-Danube canal, the Rhine and the Danube directly connect 13 Member States
6
from the
North Sea to the Black Sea over a length of 3,500 km. Every year, these waterways transport
around 500 million tons of cargo, with Rhine traffic alone making up 67% of transport
volume. Over 75% of Inland Waterway Transport (IWT) within the EU is cross-border
tranport. In Germany, Belgium and the Netherlands, the modal split share of IWT is 12.5%,
25% and 38.7% respectively and on the Rhine corridor, the industrial heartland of Europe,
even above 50%. With cargo of 150 billion tonne kilometres
7
on a yearly basis, IWT plays an
important role in the functioning of the EU's multimodal logistic chains. According to recent
studies
8
, the € 2.2 bn added value in the IWT sector leads to direct and indirect economic
added value of € 13.2 bn, i.e. a multiplier of 6.3. Through its support to strenthening the EU’s
industrial base, a more attractive IWT sector can help to maintain and further develop
employment in the EU’s industries, thereby also contributing to Commission President
Junckers’ priority of a New Boost for Jobs, Growth and Investment.
Transport also represents more than 30% of final energy consumption in Europe.
94% percent
of transport relies on oil products, of which 90% is imported. As
indicated in its Energy Union
package
9
, the Commission will pay special attention to those sectors with a huge energy
efficiency potential, in particular the transport sector. In this context, considerable fuel
savings could be realized by removing barriers to the development of less green-house gas
intensive modes of transport such as inland waterways, and by making these modes more
attractive and cost efficient.
At EU level, the IWT sector is small in relative terms with a 6.3%
10
share of total goods
transported by inland modes. The potential of IWT is not sufficiently exploited. Even on the
EU’s main waterway axes, Rhine and the Danube, there is still a lot of spare capacity,
contrary to the road and rail network which are heavily congested
11
. Multiple barriers faced
by the IWT sector include the ageing of the workforce and the difficulty to recruit new
entrants to the profession. They add to the economic difficulties following the economic and
financial crisis which put also pressure on working conditions. Combined with the expected
further increase in demand for IWT transport, the sector would, without mitigating actions,
face severe shortages of skilled personnel over the coming decades.
The Commission's policy framework for promoting IWT is NAIADES II
12
, which supports
the IWT sector striving to develop its full potential. NAIADES II identifies "Skilled
workforce and quality jobs" as a key area of intervention and pursues also better governance
through improved cooperation with the international River Commissions, which have
legislative powers in the field of inland navigation. As a result, the CESNI
13
has been created
on 3 June 2015 by the CCNR, which is part of a new framework for the elaboration of
uniform technical standards for all EU inland navigation activities coverring also professional
3
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qualifications, including on the Rhine. NAIADES II and EU action in the field of IWT
professional qualifications thus contributes also to the realisation of a fourth out of the ten
priority policy areas of the Juncker Commission: a Stronger Global Actor. Through the Trans-
European Transport (TEN-T) network
14
and the Connecting Europe Facility (CEF), the
Commission furthermore prioritises investments in inland waterway transport, for which co-
financing rates are amongst the highest compared to other transport modes.
1.2.
Legal framework
IWT in the EU is administered under various legal regimes. The main regulatory actors in the
inland navigation sector are the European Union (EU), the Central Commission for the
Navigation on the Rhine (CCNR)
15
, the Danube Commission (DC)
16
, the United Nations
Economic Commission for Europe (UNECE)
17
, the Sava Commission
18
, the Moselle
Commission
19
and individual member states, with each organisation having a different (but, to
an extent, overlapping) regulatory and geographical scope.
The various regulators also have different implementation mechanisms. Only the EU can
adopt binding rules which are valid for the entire inland waterway network in the EU. The
rules adopted by the CCNR, the Sava and Moselle Commission are binding for navigation on
their respective rivers. In the framework of the Belgrade Convention for navigation on the
River Danube, only 'Recommendations' can be adopted. The same applies for the UNECE.
In general, regulation on the IWT labour force aims at greater harmonisation. However,
differences remain for the recognition of workers' professional qualifications, including in the
area of requirements for boatmasters’ certificates, where efforts to harmonize have been
mainly focussed.
The highest level of harmonisation for professional qualifications has been achieved by the
CCNR that has drawn up rules governing navigation on the Rhine since 1868. Matters related
to personnel are ruled by the Regulations for Rhine navigation personnel (RNP)
20
. Stringent
standards are defined for crew members' qualifications and for obtaining Rhine patents, which
authorise boatmasters to navigate on the Rhine. In addition, CCNR has signed mutual
recognition agreements for boatmasters’ certificates and Service Record Books of crew
members
21
.
At EU level, two sets of rules are relevant for the recognition of professional qualifications.
For crew members other than boatmasters, Directive 2005/36/EC on the recognition of
professional qualifications
22
provides a general legal framework for professions that are
regulated in a host Member State and for which no EU sector-specific regulation has been
adopted. For boatmasters, a set of specific sectoral EU rules is applicable:
Council Directive 91/672/EEC of 16 December 1991
on the reciprocal recognition of national
boatmasters' certificates for the carriage of goods and passengers by inland waterway
provides for the mutual
recognition by the Member States of each other’s boatmasters’ certificates and
Council Directive 96/50/EC of 23 July 1996
on the harmonisation of the conditions for obtaining
national boatmasters' certificates for the carriage of goods and passengers by inland waterway in the
Community
lays down harmonised basic conditions for obtaining national boatmasters' certificates for inland
waterway navigation between EU member States.
As far as UNECE is concerned, Resolution 31 provides measures for the issuance of
Boatmasters Licenses
23
. The Recommendations of the Danube Commission on boatmasters’
licenses are built substantively on the provisions of Resolution 31 of the UNECE and of
Directive 96/50/EC.
24
The Sava Commission has issued binding resolutions on qualifications
for nautical personnel and set rules on minimum requirements for the issuance of boatmasters'
licences. The Moselle Commission does not regulate on qualifications.
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2.
C
ONSULTATION AND EXPERTISE
This Impact Assessment Report (IAR) was elaborated with the support of internal and
external consultation groups, as well as with the expertise of external consultants.
2.1.
Interservice group
This IAR was elaborated by DG MOVE. DG MOVE was assisted by a Commission Impact
Assessment Steering Group (IASG). The IASG met several times: in September 2012,
January 2013, February, October and December 2014, and February and October 2015. The
following DGs were invited: Secretariat General, Legal Service, DG EMPL, DG ENTR, DG
EAC, DG MARKT, DG ELARG, DG RTD, DG EAC, JRC and EEAS.
2.2.
Consultation of the Regulatory Scrutiny Board
This IAR was reviewed by the Regulatory Scrutiny Board (RSB) a first time on 21 January
2015. Based on the Board recommendations, the IAR has been revised as following:
Firstly the main problem, the problem drivers as well as the objectives have been
reformulated and better situated in the framework of the Commission's political priorities. The
focus has been restricted to the mobility barriers hampering the future development of IWT
sector. Whereas safety is not presented any longer as one of the problem drivers requiring EU
intervention in the field of qualifications, it remains a key element within the IAR through the
assessment of safety impacts for each measure as the level of safety has to be maintained (and
wherever possible even improved).
Secondly, policy options have been re-designed. The former option on the recognition of
professional qualifications at EU level based on minimum competence requirements for
boatmen and boatmasters has been differentiated into two suboptions: one suboption
including and one suboption excluding examination standards for training and education
institutes.
Finally, the various policy measures have been further clarified, the rationale for grouping
them into policy options has been better explained, quantitative data have been used in a more
balanced way and the contribution of the initiative to the streamlining of international IWT
governance has been updated.
The second version of the IAR received a positive opinion [link] on 31 July 2015. The present
final version of the IAR takes into account the recommendations for improvements by the
mean of clarifications or complementary information in the appropriate IAR section. The way
some issues considered important by stakeholders (including safety and communication) have
been addressed in the IAR has been clarified under section 2.3., the importance of IWT labour
mobility relative to other factors that might hinder achieving full growth potential of the IWT
sector has been highlighted under section 3.2., some measures have been further clarified
under section 5.1. and the reasons for discarding a number of policy options have been also
clarified under section 5.2. The impact of the different policy options on labour mobility,
access to the profession and labour wages are addressed in detail under sections 6.1.1. , 6.1.2
and 6.1.5. It has to be noted, however, that the nature and diversity of the IWT sector as well
as the lack of quantitative data makes it very difficult to provide further quantitative
projections. On the impact on wages stakeholders, including social partners, were consulted
following the first opinion of the Board. They considered it was not an issue raising concerns.
2.3.
Consultation of stakeholders
An online public consultation on the essential elements of the IA took place from 26/3/2013
to 21/6/2013
25
. The Commission services received a total of 94 replies from education and
training organisations, entrepreneurs/ship owners, shipping companies, public authorities,
5
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ports, workers' organisations and river commissions. Responses came from a total of
16
countries;
most responses were from Romania, Germany, the United Kingdom, Slovakia, the
Netherlands, Hungary, Austria, Croatia and Belgium.
The online public consultation confirmed that the problems identified in this IAR (cfr.
Chapter 3) are of high importance. The majority of the respondents considered the various
problem drivers, and subsequent policy objectives identified, highly relevant. All issues
considered important by stakeholders have been taken into account in the IAR
26
. The
responses indicated a high level of support towards regulatory measures in relation to the
harmonisation of professional requirements, qualifications and examinations in inland
navigation between EU Member States, whereas the introduction of voluntary measures or
recommendations received a considerably lower level of support. There is a large degree of
homogeneity between the views of the different stakeholder categories. There are no
dissenting opinions, apart from the United Kingdom's responses, which reflect their special
position as a non-interconnected inland waterway country. Stakeholders’ views expressed in
the online public consultation are presented in more detail in Annex 1.
Common Expert Group: In 2012 the Commission created a Common Expert Group on
professional qualifications and training standards in inland navigation (CEG). The objective
of this group is to support the Commission in developing legislative measures concerning
future European standards for professional qualifications, certification and a minimum level
of training in inland navigation. The consultation within the CEG (E01036/'CEG') took the
form of
11 expert meetings
between September 2012 and November 2014. The following
organisations were represented: 1) international river commissions: CCNR, DC, Sava
Commission, 2) UNECE, 3) National administrations in charge of IWT policy-making and
legislative and administrative activities, 4) Professional organisations: European Barge Union
(EBU-UNEF) & the European Skippers Organisation (ESO), 5) Trade unions: European
Transport Workers' Federation – IWT section, 6) PLATINA - Platform for the
implementation of NAIADES
27
, 7) IWT Training and education institutions in Europe
EDINNA
28
, 8) AQUAPOL
29
& European Federation for Inland Ports (EFIP). The studies
prepared by the external consultants in support of the present IAR were presented to the CEG
in order to receive feedback on the plausibility of the conclusions.
Meetings of the CEG confirmed a broad support for an initiative at EU level as expressed
through the online consultation. There were only few contradictory opinions on the objectives
to be pursued. In particular the CEG considered that the initially envisaged idea of a rapid
introduction of electronic tools (e-Electronic Service Record Books –e-SRB– and e-logbooks)
not mature enough and required further substantial analysis. This led to the decision to
separate (at least for this first stage) this aspect from the general initiative on professional
qualifications and to proceed for the introduction of electronic tools with a separate impact
assessment (see sections 3.3.1.2. , 5.1. and Annex 11). The CEG provided the opportunity for
useful exchanges on the measures envisaged for a possible Commission proposal.
The Sectoral Social Dialogue Committee for Inland Waterway Transport (SSDC) at European
level
30
was regularly kept informed about progress in the framework of the meetings of this
Committee. The social partners submitted a document called "social partners' position on
professional qualifications and training standards for crew members on inland waterways
transport vessels", dated 16/09/2013. In the framework of the preparation of this IAR, they
were also invited, at the SSDC meeting of 05/05/2014, to provide specific comments on the
social impacts of the envisaged measures through their representatives participating in the
CEG. The SSDC instrument welcomed the initiative and confirmed the need for a modern and
flexible regulatory tool regarding training and certification, which will allow the development
of a fair and competence-based access to the profession improving also the level of safety. In
this context, the social partners encouraged the use of CCNR's expertise and the work
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produced by EDINNA within the Platina I project
31
. After having been informed about the
negative IAB opinion, the Representatives of the employers' side re-affirmed at the SSDC
meeting of 30 January 2015, their continuing support for this initiative. The Representatives
from the trade unions pointed out that social partners have been heavily involved in the
process which has started already in 2012 and that they would regret if the initiative would
not go culminate in a Commission proposal.
From the numerous and repeated consultations with stakeholders, it can be deduced that
experts and stakeholders largely support a regulatory initiative at EU level. The stakeholders’
and expert’s views are presented in more detail throughout this IAR where relevant. The
minimum consultation standards of the European Commission have been respected.
2.4.
External expertise
External expertise was used to evaluate the legal framework on professional qualifications in
inland navigation
32
. The study showed that the existing framework has been partially effective
in fulfilling the objective of reciprocally recognising boatmasters’ certificates and
harmonising conditions for obtaining boatmasters' certificates, but that several barriers
remain. Based on this evaluation, an external impact assessment support study has been
launched
33
. The study confirms the mobility problem as defined in this IAR. Furthermore, it
analyses possible solutions and their impacts. The results of this study are referred to
throughout this IAR where relevant.
3.
3.1.
P
ROBLEM DEFINITION
Description of the main problem
The future development of the inland waterway sector is
hampered by difficulties in terms of
labour mobility, persistent vacancies and skills mismatches.
The potential benefits of inland
navigation can only be brought about if a skilled workforce is available to ensure that the
sector can take on its role in the logistics chain in a safe way.
Box: Key figures on the EU IWT labour market
41,500 workers: about 14,650 boatmasters and 26,850 operational workers
34
.
Netherlands, Germany, France, Luxembourg, Italy, Belgium, Romania and Bulgaria
represent 80% of the total IWT labour force.
75% of IWT within the EU consists of cross-border transport. The majority of workers
is active on the Rhine corridor.
Share of non-national workers: 27% in Netherlands, 23% in Germany, 14% in
Belgium
35
.
9,482 IWT companies:
36
45% of these are Dutch. Micro enterprises owning/operating
one vessel represent 80-90% of the market in the western part of the EU.
37
About 40% of the employment is linked to passenger navigation
38
.
The share of self-employed and employees in Europe is respectively 27% and 73%.
39
The situation on the IWT labour market is shaped by two market forces: the demand of
workers, determined by transport volumes of both the passenger and the freight market, and
the supply of workers, which is driven by career perspectives and new entrants to the sector.
Several submarkets can be identified in IWT. They are presented hereafter as four distinct
corridors.
40
As regions are interconnected, workers tend to be mobile. As shown in Figure 1,
there are nevertheless regional
differences in supply and demand of workers on the
various corridors:
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Figure 1 Gap in number of workers between demand and supply for corridors in Europe in 2013
Source: Panteia (2014)
Deficits currently exist for the Rhine corridor, while there is a surplus of workers on the
North-South and East-West corridor. As a result, a significant number of workers from
Eastern-Europe, in particular from Poland and Czech Republic are working on vessels sailing
under the flag of the Netherlands and Germany.
41
Annex 3 provides detailed information
about the labour market model developed by the external consultants, on which figure 1 is
based.
Overall, the current
skilled workforce is ageing.
The average age of Belgian, French and
German boatmasters is older than the European average. Most of these boatmasters will retire
within 10 to 20 years. There are also
difficulties in recruiting
young people. In recent years
workers' shortfall in Western-Europe has partially been resolved by hiring crew members
from Eastern European countries and to a lesser extent, from the Philippines and the 'hidden
reserve'.
42
Whereas over 75% of IWT within the EU consists of cross-border transport, the
internal
labour market is still not accomplished
due to the various drivers and root causes described
below. The various regulatory regimes that are simultaneously applicable in Europe, as
described under section 1.2., result in
different procedures, standards
and mechanisms for
the recognition of professional qualifications. Difficulties remain despite progress towards
harmonisation of the requirements applied under the various regulatory frameworks made
over the last two decades
.
The Council of the European Union, in its Conclusions of 16 June
2011, stressed the
complexity
of the current organisational structure of the sector, and the
need to facilitate decision-making and reinforce cooperation between the different actors in
order to come to a more integrated and competitive EU inland waterway transport. 80% of
participants in the online public consultation are of the opinion that the multiplication of
national or transnational rules and regulations is an important or very important
problem for
the mobility of workers
(see details in section 3.3.). Indeed, whereas some years ago most
workers were generally only active in their native river basin, navigating personnel aboard a
vessel nowadays have increasingly diverse origins and need to be increasingly mobile.
The
current organisational structure and legal frameworks governing the sector have proven
to be a major obstacle to addressing these problems. Difficulties related to labour
mobility therefore cannot be solved by the sector alone.
They have an impact both at the
level of the individual workers (barriers to free movement) and at European level (integrated
market, regional differences in supply and demand of workers).
This IAR restricts itself to labour mobility issues. It does not address other problem drivers
linked to the lack of qualified staff and more globally to lack of sector attractiveness.
Increasing sector labour shortages can be further addressed through initiatives at other levels:
e.g. supporting innovations aimed at improving physical and mental working conditions,
dissemination of good practices of employability policies, IWT sector promotion campaigns,
building a continuous recruitment strategy, for instance in the form of a shared funding, to
make training of new employees a shared responsibility for all ship-owners
43.
The need for
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electronic tools (smart tachograph and an individual crewmembers’ smart card) is addressed
under section 3.3.1.2.
1.1.
Negative consequences of the problem
1.1.1.
Consequences for the IWT sector
Labour shortages in some regions in combination with difficulties related to mobility entails
the
risk of recruiting personnel that does not have the necessary competencies
(see more
explanation under section 3.3.1). AQUAPOL points out that the lack of uniform rules
hampers effective enforcement, which makes the inland shipping sector vulnerable to illegal
practices (e.g. forged documents) that threaten the level playing field.
Without the safeguard of a solid framework that governs professional qualifications for the
whole sector, fierce competition combined with unsolved difficulties described above will
also further
reduce the attractiveness
of the profession to new entrants. In the long-term, this
could potentially result in refusal of orders for shipping goods in regions with a shortage of
workers.
44
The resulting loss of reputation in the sector could
negatively impact its
competitiveness.
It
may also negatively impact the safety
of inland waterway transport.
Workers' competencies clearly have a correlation with human errors. Highly skilled workers
on board ships have the ability to prevent accidents whereas workers lacking competence can
cause accidents. It is important to highlight that
when accidents do occur in IWT, they can
have far-reaching consequences.
The “Waldhof” tanker accident in 2011 caused considerable societal loss due to the blockage of the Rhine River
for 33 days, resulting in a backlog of over 400 vessels, as well as the loss of two lives and considerable financial
losses.
The cause of the “Waldhof” accident can be linked to competencies as an improper load
distribution on the ship is considered to be the cause of the Waldhof’s poor stability. Another
frequent cause of accidents is miscommunication/language problems, another matter related
to skills
45
. As a third illustration of the importance of competence for safety is the increasing
importance of Liquid Natural Gas (LNG) as a fuel for inland shipping. It has already been
agreed among experts that specific knowledge and skills should be required from crew
operating on vessels functioning with LNG.
It should be also underlined that current safety levels in IWT are not only a product of
legislation in force but also of practices developed over many years by the profession.
Navigation on large convoys or on cruise ships is an example. Although according to the
regulatory framework a skipper can navigate these vessels with the patent/boatmaster
certificate, shipping companies have put in place a career management system that includes
additional requirements in terms of experience and lifelong training. However, increased
competition between operators could lead to the degradation of these voluntary practices with
negative effects on safety levels.
1.1.2.
Consequences for the EU economy
The indirect value added of IWT to Europe’s GDP is substantial but not directly visible in
official statistics
46
. According to recent studies
47
, the € 2.2 bn turnover in the IWT sector
leads to direct and indirect added value of € 13.2 bn, i.e. a multiplier of 6.3. However, the
potential of the IWT sector for strengthening the European industrial base is currently not
fully exploited.
Given that logistics, including transport and storage, account for 10-15% of the cost of a
finished product, economies of scale provide an incentive for industries to concentrate their
production in selected geographical areas where aggregate logistics costs are minimised. This
can be achieved by locating production either in the largest markets or along axis where
9
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transport costs to the markets are low. Population density and transport costs therefore affect
the degree of spreading of
manufacturing across a region.
Figure 2: Eurostat statistical atlas:
density of population by Nuts 3
region, 2012
Inland waterways play an
important role for the location
of
industrial
production
capacity. Half of Europe’s
population lives close to the
coast or to inland waterways
(see Figure 2). Since 2008,
waterway transport, already at a low level, has fallen most compared to other transport modes
(land and air transport)
48
. Increased use of inland waterway transport can help to keep the
costs for exports low and hence stimulate industrial export orientated activity. In particular
inland and sea ports are recognised as attraction poles of industrial activity. The 2014
European Competitiveness Report 'Helping Firms Grow' identifies transport costs associated
with export as one of the factors influencing SMEs' decisions to enter foreign markets.
Figure 3: Overlay of TEN-T Inland
Waterways with EU gross added value
from industrial economic activity
excluding construction
As can be seen from Figure 3 most
of the regions with a high
concentration of industrial activity
have good waterborne – maritime
and inland waterway – transport
links. Many of the industries in
these regions can be reached by
inland waterways, either alone or
in combination with other transport
modes.
Comparing figure 3 with Figure 4
showing the untapped potential for
transport by inland waterways of
export of containerized continental
cargo in north-western Europe,
allows seeing that many regions
with high industrial economic
activity also have a high potential
for increasing use of inland
waterway transport.
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Figure 4: Map of untapped potential of containerized continental cargo for export – North-west Europe
The map in Figure 4 results from an analysis
49
estimating that if only for the segment of
intercontinental container cargo the untapped potential would be realised, the overall volumes
transported in the EU by inland waterway transport would increase with 17%, with a resulting
decrease in overall logistics costs of 899 million € per year for the industry. Another recent
study for the Danube region
50
has identified significant indirect employment effects if the
share of IWT transport increased with 20% by 2020. Such increases can be captured by the
sector without major investments. Free capacity is still available on the EU’s inland
waterways. Even on the Rhine, the EU’s busiest river in the EU’s industrial heartland,
transport density can be further increased with 100% without recourse to major infrastructure
works.
Inland navigation is today a key asset for the manufacturing industry. For instance, inland
waterway transport is the dominant transport mode on the Rhine-Alpine corridor, with 54% of
the transport share in cross-border flows.
51
However, if the use of IWT in multimodal
corridors would not improve or even decrease, and the functioning of the IWT labour market
is an important factor for this, the IWT sector’s contribution to the European industrial and
the long term growth potential of the EU economy would not develop optimally.
As inland navigation is more than twice as energy efficient as road transport
52
, barriers to its
full development will also negatively impact the evolution of the overall energy efficiency of
the EU’s transport system.
Inland navigation is also a priority for support by the TEN-T and Connecting Europe Facility
Regulations. The EU is investing important budgets for the upgrading of Core network inland
waterway infrastructure.
Realising growth will also require innovation. The innovation gap has negative consequences
for the attractiveness, competitiveness, safety and sustainability of inland waterway transport.
I
nvestments and innovation are the most urgent needs for the sector development.
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However, they will only bring their full benefits if also the market-sided barriers are
tackled, including barriers to labour mobility.
3.3.
3.3.1.
Underlying drivers of the problem
Problem Driver 1: Workers face difficulties with mutual recognition of professional
qualifications
Since boatmasters and operational staff on board vessels are covered by different legislative
frameworks, these two categories of workers are addressed separately below.
3.3.1.1. Difficulties with recognition of professional qualifications at boatmasters level
National boatmasters' certificates issued on the basis of the EU Directive are not
automatically recognized for navigation on the Rhine
The CCNR celebrates this year its 200 year anniversary. The respective areas of competencies
between this long established international organisation and the EU have evolved over time
and have taken time to clarify. Because of this and because of the difference in the level of
minimum standards envisaged for the whole of the EU and those for the Rhine which were
more stringent, the Rhine was excluded from the scope of Directive 96/50/EC, which resulted
in two different legal regimes for boatmaster certificates. The EU Directive recognizes the
validity of the Rhine patent for all EU inland waterways but the national boatmasters'
certificates issued on the basis of the EU Directive
(hereafter, 'EU boatmasters' certificates')
are not automatically recognised for navigation on the Rhine. The Rhine Patent imposes a
higher threshold on age, physical and mental fitness, as well as experience and professional
knowledge. A comparative table is presented in Annex 4
53
.
As mentioned above, the CCNR recognizes boatmasters’ certificates issued by other EU
countries via
bilateral agreements,
following voluntary requests submitted by these
countries. At present, CCNR recognizes the national certificates of seven non-CCNR member
states (Austria, Bulgaria, Hungary, Poland, Romania, Czech Republic and Slovakia), and
three out of five CCNR member states (Belgium, Germany and the Netherlands).
Around 15% of the EU boatmasters' certificates are not covered (i.e. 6 Member States) by
bilateral agreements and as such are not automatically recognised as valid on the Rhine. The
requisites by the CCNR for automatic recognition are considered such an obstacle for some
countries, like France (a CCNR Member State), that they have chosen to stay outside the
CCNR recognition system. The main issue for France is that it has a different system for
calculating professional experience (100 days of navigation time-count as one year, instead of
180 days under RNP). In addition to France, also Croatia
54
, Sweden, Finland, Lithuania and
Estonia do not have their EU boatmasters' certificates recognised by the CCNR although these
are issued in line with Directive 96/50/EC
55
. In total, it represents around 1000 boatmasters.
56
See Annex 5 for countries that mutually recognize each other's boatmaster certificate.
These bilateral agreements, which are administrative arrangements, also have several inherent
limitations for the signatories (10 Member States):
1) Additional conditions are imposed for the certificate to be valid on the Rhine. These
conditions
57
mainly concern, the minimum age, the renewal of the physical and mental fitness
certificate and the knowledge of specific situations
58
required on the Rhine. Only Germany is
concerned only by the latter one. The other Member States (representing close to 70% of all
EU boatmasters) have to meet additional conditions. They are attested by additional
documents which must be presented at the same time as the national certificate.
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2)
The recognition process is based on a country individual request submitted to the CCNR
and is a very lengthy procedure due to a thorough assessment of each individual dossier, with
potential necessary adjustments in the legal system of the requesting party.
3)
There is legal uncertainty regarding provisions for recognising EU certificates on the
Rhine. The free movement of boatmasters within the EU is consequently not legally
guaranteed even for recognised certificates as the CCNR is free to withdraw recognition.
59
The arrangements do not constitute an international agreement under public international law,
involving the international responsibility of the contracting parties. If a change is made in an
uncoordinated way, it could justify denunciation of the arrangement. The basis for this
challenge is objective but could show a certain complexity of “proving” non-equivalent
performance. Furthermore, it is difficult and complex to modernise the existing set of
agreements in a coordinated way, as these have been negotiated on a bilateral basis. The
profession of inland waterway transport is in constant evolution. Technologies such as River
Information Services are under constant evolution, with the introduction of increasingly
sophisticated navigational aids with a future perspective of evolution towards (semi-)
automatic navigation. New vessel concepts are emerging (e.g. modular push-barges, new
markets are under development (e.g. container transport), new vessel technologies require
special competencies (e.g. LNG-fuelled vessels) and new training tools are under constant
development (simulators).
Although the mutual recognition process initiated by the CCNR has to a significant
extent enhanced labour mobility for boatmasters in the EU, it does not allow the full
mutual recognition of boatmasters' certificates across the EU's inland waterway
network and the system is difficult to adapt to evolution in the sector.
The legal frameworks are insufficiently focused on proven competencies
Under the existing system set up under the RNP and Directive 96/50/EC, it is possible to
become a boatmaster after respectively 5 and 4 years of experience. Both Directive 96/50/EC
and RNP require to pass an examination of professional
knowledge
with a specific list of
subjects that have to be included in examination. RNP requires a
theoretical exam
whereas
the EU Directive does not specify the method of examination. As a result, the majority of
boatmasters navigating on the IWT network does not pass a practical examination for
obtaining their navigation licence. The external evaluation pointed out that
sailing records
give no indication
about navigation skills acquired. For instance, hotel crew on passenger
ships can accumulate sailing time records without acquiring any navigation experience. The
evaluation concluded that it is necessary to verify through a practical exam whether the
required level of competence has effectively been reached. Competence-based standards have
to be set for examination in order to improve the qualification of workers and to enhance trust
necessary for eliminating barriers to labour mobility.
60
Regarding this latter aspect, it should
be noted that in the last two decades training and education systems in general have been
moving away from the traditional focus on knowledge towards more competence-based
teaching and assessment. This reflects the desire to assess the knowledge and practical skills
of candidates with differing abilities, cultural and linguistic backgrounds,
61
with the objective
of favouring mobility. In a competence-based approach, the criterion for awarding
qualifications is not duration of experience – it is based on whether candidates can prove they
have mastered competencies – the skills, abilities, and knowledge required for the function.
The best example illustrating how a competence-based system could facilitate cross-border
mobility is the current dead lock between France and the CCNR over the counting of
navigation experience as a criterion for recognition of boatmasters' certificates.
The existing possibility provided by RNP to exempt parts of the Rhine patent examination if
certain subjects have already been tested in the framework of examination carried out by
13
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recognised education
and training institutes
62
is not available in the EU legislative
framework and is also under-used on the Rhine. In the absence of common competence-based
standards for examination that could be applied by education and training institutes and
backed up by a quality assurance system, it is understandable that the administrative
authorities wish to keep responsibility for candidates' full assessment before issuing
boatmaster' licences.
As a result of the fact that for both the EU and CCNR systems the point of departure is
experience rather than competence,
competencies obtained outside the IWT sector are only
taken into account to a very small extent.
The RNP and Directive 96/50/EC allow for
reductions in required professional experience for obtaining the Rhine patent or boatmaster
certificate respectively, as a result of experience acquired on a seagoing vessel. The RNP and
Directive 96/50/EC allow a maximum reduction of two and three years respectively.
However, the actual reduction allowed varies from country to country.
63
Stakeholders in
general consider that the required IWT experience for seafarers is too stringent, in particular
on the Rhine and for countries applying a smaller reduction than the maximum allowed.
Potential career changers from sea to inland navigation may need to spend two years on board
of inland navigation vessels in a lower function and at reduced wages, which does not make
the career switch attractive. It is a real problem in particular as the sector suffers from
insufficient job attractiveness. A competence-based approach applied to the boatmaster exam
would offer much more flexibility for lateral entrants, regardless of their background.
3.3.1.2. Difficulties with recognition of professional qualifications of operational staff
There is no EU sectoral legislation covering operational workers and there are limitations to
the CCNR recognition system
Functions on board the vessel for operational staff are defined at national level and at the level
of the River Commissions. At European level, there is no EU sectoral legislation for the
recognition of professional qualifications for operational workers below the level of
boatmaster, which represent around 65% of IWT workers
64
.
Below the level of boatmaster, the main functions found in the manning regulations
65
are the
following:
'deckhand', 'apprentice', 'boatman', 'able boatman' and 'helmsman'.
The list
is presented in hierarchical order and may be considered as the classical career path. Besides
these functions, for certain convoys the function of 'engineer' also appears but this function is
part of a distinct career. 'Deckhand' and 'apprentice' are the two lowest levels of entry into the
career for which only minimum age and medical requirements apply. 'Boatman' is the first
level for which specific skills are needed and the only one on which IWT education focusses.
The set of competencies expected from a boatman is already very wide and demanding (it
covers navigation, cargo handling, engineering, maintenance, communication, safety,
operation of the ship)
66
. ‘Boatman’ is also the minimum qualification which is required
onboard of any vessels in addition to the boatmaster. Boatmen obtain the qualifications of
'able boatman' and 'helmsman' through additional navigation experience. Annex 6 shows the
existing functions and an overview of the professional requirements for these functions in the
main manning regulations
67
. The
national differences in defined
functions and related
professional requirements prevent a common understanding of what a function stands for, and
what qualifications are required to carry out the function.
The CCNR recognizes Service Record Books (SRBs) issued by other EU countries via a
multilateral Administrative Arrangement
68
,
following voluntary requests submitted by
these countries. Service record book record the experience of crew on board ships. They are
paper formulae that are manually filled out by the boatmaster and validated by authorities.
SRB are intended to attest experience of crew members. At present, CCNR recognizes the
SRBs of seven non-CCNR member states (Austria, Bulgaria, Hungary, Poland, Romania,
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Czech Republic and Slovakia), and three CCNR member states (Belgium, Germany and the
Netherlands).
Half of the EU Member States having inland waterways remain outside the scope of the
recognition system. On the interconnected network, this includes again in particular France as
well as Croatia, which represent more than 11% of the total operational workforce. Around
5% could be added if we consider workers from Estonia, Finland, Sweden, Lithuania.
69
The agreement has also inherent limitations for its signatories (i.e. 10 Member States
representing more than 55% of all operational workers):
1) Need for alignment to CCNR standards. SRBs covered by mutual recognition contain a
separate page reserved for the listing of qualifications obtained in compliance with Rhine
regulations. This page may only be filled in by a competent Rhine authority and the
qualification listed on this page is the only qualification valid on the Rhine. To list the
qualification in compliance with Rhine regulations, the competent Rhine authority only takes
account of the number of years of experience the boatman has accumulated. It does not
recognise the qualifications obtained through training and education outside the CCNR
Member States.
2) The accession to the multilateral agreement is based on an individual request of a country,
with potential necessary adjustments in the system of the requesting party. In addition, as
indicated under paragraph 1), for workers from non-CCNR member states, it remains
necessary to ask individually for the recognition of their qualification. There is no automatic
recognition.
3) Regarding the provisions for the mutual recognition of SRBs, there is similar legal
uncertainty and similar difficulties to adapt the system to evolution in the sector as for the
bilateral agreement for the recognition of boatmasters' certificates.
At EU level, the general
Directive 2005/36/EC
on the recognition of professional
qualifications is applicable to all EU State nationals
70
wishing to practice a regulated
profession on a regular basis (establishment) or on a temporary basis (provision of services),
in an EU Member State other than that in which they obtained their professional
qualifications. IWT professionals do not fall under the system of automatic recognition
foreseen for some specific professions but under the general system. This implies that each
worker that wishes to have his or her professional qualifications recognised needs to introduce
an individual request. Moreover, compensation measures could possibly be imposed by the
host Member State to the professional wishing to exercise a regulated profession there, if the
professional's qualifications are substantially different from those required in the EU Member
State in question. The compensation measures may differ from one state to another,
depending on the professional qualifications required in each state. With regard to the
temporary provision of services, in most cases the qualifications do not have to be approved
before the provision of service and only a prior declaration to the competent authority of the
host country may be required. However, if the profession involves a potential risk to safety, as
could be argued for IWT transport, the host States may verify the qualifications prior to the
first provision of services. In this case, it is possible that each host country imposes different
compensation measures on the IWT professional. Overall, it seems that the application of the
general system under Directive 2005/36/EC is too burdensome, not streamlined and
open to
different requirements
by each State concerned in a largely cross-border industry such as
IWT. That the general directive is currently under-used in that given field seems to provide
further evidence of this.
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The recognition systems are not sufficiently based on proven competences
In the context of the recognition systems as described above, many potential candidates have
difficulties in valorising their qualifications when working across borders as IWT
administrations are reluctant to recognise qualifications obtained elsewhere in the EU.
According to an ETF representative
71
, one of the aspects most frequently criticised regarding
the existing systems for establishing minimum requirements concerns the qualifications of –
candidate-boatmen. You can qualify as a
boatman
just by accumulating three years of sailing
time. However there is no requirement for any training content in those three years, no log of
the work carried out and
no examination
at the end.
In the absence of competence-based standards, the process of
mutually recognising training
programmes
is difficult
as there are substantial differences in EU Member States’ training
requirements, both in terms of the share of theoretical and practical training, and the duration
of the training programme. The complexity of putting in place such a recognition process was
experienced by the CCNR with the education institute of Decin
72
. Non-CCNR countries, in
particular those with training and education institutes, underlined on several occasions in CEG
meetings how problematic the absence of such recognition is for the mobility of their workers
and for the attractiveness of the profession.
Workers are facing downgrading as a result
The lack of harmonisation represents an obstacle to labour mobility because it results in some
workers being granted a lower function on the Rhine than in their country of origin and thus a
lower salary. The external study
73
estimated that
around 13% of all operational workers,
are
already now directly affected by such 'downgrading'.
The main types of crew members
concerned are helmsmen downgraded to boatmen, or able boatmen downgraded to boatmen.
Reasons for downgrading crew members include the
diverging approaches concerning
the
functions acquired through professional
experience only
74
, differences in the requirements
regarding professional
experience after completing a training course
75
and the fact that
education or training is not recognized
by the CCNR. 20% of boatmen are downgraded to
deckhands because of this latter reason whereas only 0.6% of their counterparts in CCNR
countries experiences similar situation.
76
As explained under 3.3.1.1 for boatmasters, the fact that the reference point for granting IWT
qualifications is sailing time as opposed to the level of competence does not allow a level
playing field. The figures mentioned in the previous paragraph only reflect the number of
operational workers that have actually suffered from downgrading.
Much more workers
would face such downgrading if they would decide to become mobile.
These
difficulties
therefore also have a
substantial
deterrent effect on mobility.
Close to 40% of all
operational workers work on the interconnected IWT network outside of the Rhine corridor
and could therefore potentially be concerned.
Finally, as also pointed out under 3.3.1.1 for boatmasters, again because the basis for granting
IWT qualifications is sailing time rather than competence,
early competencies obtained
outside the IWT sector are only taken into account to a small extent.
The RNP and most
EU countries take into account experience from the maritime sector for the qualification of
boatman but still require one year of inland navigation experience
77
.
The external study estimated that the number of workers from the maritime sector switching
careers to IWT per year is very low.
78
The amount of workers willing to change their career
from maritime to IWT is obviously higher, as the existing requirements are regarded as a
mobility barrier. Some stakeholders have repeatedly pointed out that persons from outside the
waterborne sector should also be given the possibility of becoming a qualified boatman in a
shorter period. In the online public consultation, 43% of respondents considered that
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difficulties with recognising relevant professional qualifications of workers from outside the
sector was 'relevant' or 'very relevant' to the problem of restricted labour mobility.
Specific difficulties with Service Record Books as a tool for recognition and enforcement
SRBs are a source of recognition and enforcement problems due to their content and format.
The difficulty of the recognition of information contained in the SRBs and, in particular, the
way navigation time and education are valued has already been addressed under the previous
section. Furthermore, in the
absence of a coordinated or central registration system
it is
possible for one person to be in possession of several SRBs. As a result, in some cases,
entries in the SRBs are regarded as not fully trustworthy. The fact that it is easy to impede
verification makes efficient or effective enforcement difficult. Finally and in close connection,
it is also considered that the present
paper format
of SRBs is largely outdated and generates
administrative burdens for both the authorities in charge of verification and for the crew
members. With no secure mechanism for registering data, manipulation of SRBs will remain
easy. It is clear for all stakeholders however that modernisation of SRBs is needed to alleviate
administrative burden and improve mobility. Such a development is also necessary as regular
abuses create unfair competition between those that play by the rules and those that do not,
negatively affecting working conditions, attractiveness of the profession and safety. As
mentioned under section 5.1, the decision to transition to an electronic version of these
documents has been postponed and therefore the measure has been discarded in this IAR. The
issues of harmonisation of SRBs content and registration remain however part of this IAR as
first steps to tackle the problem.
3.3.2.
Problem driver 2: Knowledge of Specific Situations (KSSs) may create unnecessary
difficulties for boatmasters operating on certain river stretches
Member States may require boatmasters to obtain a certificate that attests their knowledge of
the local situation in order to navigate on certain river stretches in Europe
79
. An overview of
EU inland waterways where Knowledge of the Specific Situations (KSSs) is required and the
procedures to obtain the relevant KSS certificate are presented in Annex 7. On the Rhine, for
instance, KSS is required on the German sector between Iffezheim and Spijksche Veer (more
than 500 km). In cases where boatmasters do not possess the relevant KSS-certificate, pilots
need to be hired to navigate the stretch.
The external study concluded that 28% of total IWT performance in Europe is subject to
KSS.
80
They estimated the costs of KSS for the IWT sector (considered as the total costs of
hiring pilotage services for this purpose) at around €8 million in 2011
81
. The Rhine, Seine and
Danube are the main contributors.
82
Mecklenburg-Vorpommern, Normandy, Île-de-France
and Croatia are most affected in terms of extra percentage of transport costs; up to a
maximum of 10% of the total transport costs.
KSSs are intended to increase safety in inland navigation. At the same time, the
implementation of KSS regimes inevitably affects labour mobility. A boatmaster who wishes
to acquire KSS has to make the required journeys at a lower function and then generally has
to pass an examination before the competent authority. Alternatively, there are pilotage costs.
Although there can be no trade-off between labour mobility and safety - a high level of safety
must prevail - there are two specific sub-problems related to KSSs which negatively affect
labour mobility. Alternative approaches could offer similar levels of safety whilst removing
unnecessary barriers to mobility:
1. No clear criteria for the definition of KSS: Under Directive 96/50/EC, Member States can
set KSSs and unilaterally change them subject only to a non-binding consultation with the
Commission. The absence of clear criteria for defining KSSs leads to a lack of transparency
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and legal uncertainty regarding the introduction and modification of KSSs. It may also have
resulted in too many KSSs, which negatively impacts labour mobility. In the online public
consultation, when asked whether KSSs in force in Member States are justified in view of the
criteria considered relevant by the CEG (hydro morphological characteristics, absence of
marking systems and local traffic regulations), 50% of respondents declared that KSSs are
not justified and 32% judged them as only partially justified. Moreover, the fact that the
evolution of River Information Services (RIS) are not taken into account in this context is
confirmed by responses to the public consultation. 70% are of the opinion that the information
provided by RIS could 'always' or 'sometimes' replace the need for KSSs.
2. Examination requirements to obtain a KSS certificate:
The application of the KSS regime under Directive 96/50/EC has also resulted in differing
practices regarding requirements for proving knowledge of a specific situation (see Annex 7).
Furthermore, the exams for KSS may only be taken in the local country or, in the case of the
Danube and Rhine, any Danube Commission or CCNR member country, which requires large
travel distances. Examination is often conducted in the local language, which is a further
difficulty to passing the KSS examination if language skills are lacking. The external study
83
concluded that taking into account transport costs, working time lost travelling to the exam
location, language course costs and KSS exam costs, it is estimated that a worker would lose
in certain cases, such as Romania and Bulgaria, up to 57-66% of their monthly salary.
1.2.
Attempts by the sector to tackle the problems
To facilitate mobility, the CCNR has recognized boatmasters’ certificates issued by other EU
countries via
bilateral
agreements since 2008
84
. The CCNR has also signed a
multilateral
Administrative Arrangement
85
which allowed the signatories to recognize the Service Record
Books issued by their respective competent authorities. The mechanisms for mutual
recognition set up by the CCNR have however several
inherent
limitations (see 3.3.1.2).
They were
seen from the beginning by the stakeholders as a transitional step towards a
new EU initiative
and harmonized standards at EU level including the Rhine. The objective
and composition of the CEG set up in 2012 as well as the constant fruitful cooperation of its
members (see 2.3) confirms that view.
In 2013, the
EU and CCNR signed an Administrative Arrangement
86
, which further
endorses that approach, as presented in the box below.
The purpose of the Arrangement is to increase synergies and make action on both sides more complementary and
mutually reinforcing. One of the two priorities for cooperation is the modernisation of professional qualifications
of IWT workers and therefore the contribution of the CCNR to the preparation of new initiatives that will result
in the modernisation of the legal framework currently outlined under Directive 96/50/EC.
This cooperation is
part of a broader approach under which uniform and high level
technical standards for IWT will be adopted
by a committee (called 'CESNI')
87
composed
of EU IWT stakeholders and consecutively integrated both into the EU legal framework and
Rhine regulations. The Commission proposal
88
for technical requirements for IWT vessels,
currently discussed by the EU co-legislators, already builds on common CCNR and EU
standards.
The European Parliament in its first reading strongly supported the use of
CESNI and the General Approach reached on 11 June 2015 in the Council makes
reference to such future CESNI standards.
For the sake of coherence, a similar approach
should apply to professional qualifications standards as the
evolution of competencies has to
go hand in hand with the on-going evolution of technical requirements for vessels.
In the online public consultation, stakeholders were also asked to assess the CCNR system of
recognition agreements.
71% of the respondents stated that mobility barriers for
boatmasters from non-Rhine EU Member States operating on the Rhine have only been
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partially or inadequately addressed. Regarding the recognition of SRBs,
40% of
respondents stated that this system only partially serves its purpose, 21% considered that it
does not serve its purpose, and
only 13% considered that it serves its purpose fully.
The
social partners are also of the opinion that action is now to be taken by the EU.
They
encourage the Joint EC and CCNR's initiative to establish a legal framework regarding
training and certification for the European IWT sector.
89
They have expressed the need for a
modern and flexible regulatory framework, which will allow the development of safety
together with fair and competence-based access to the profession. EU intervention is needed
as the goal is qualified as 'ambitious', and the
process 'complex',
requiring the
participation
of all stakeholders
(regulatory actors, training institutes,…).
The European network of nautical schools (EDINNA), in close consultation with other
stakeholders, has been working on the elaboration of Standards for Training and Certification
in Inland Navigation (STCIN)
90
in order to reach a level playing field in the IWT education
and training sector. At the current stage, STCIN are considered as recommendations for
common standards and could be used by EDINNA members to evaluate their situation with
regards to compliance with STCIN. However EU legislative action by the EU is seen as
necessary in order to effectively achieve harmonised education standards through the
implementation of STCIN, by rewarding compliance with standards with mutual recognition
and facilitation of certification.
1.3.
Summary of the main problem and its underlying drivers
Figure 5: The main problem and its underlying drivers
Difficulties in worker mobility result in the suboptimal functioning of the IWT labour market. Despite
attempts by the sector to tackle the problem at bilateral and multilateral level, the issue continues to hinder
the contribution of the IWT sector as a cost and energy efficient transport mode to EU energy efficiency,
growth and industrial development goals
Problem driver 1:
Workers face difficulties
with mutual recognition
of professional
qualifications
Problem driver 2:
Requirements related to
Knowledge of Specific
Situations (KSS) may
unecessarily restrict
labour mobility
1.4.
Who is affected by the problem?
The main affected parties are boatmasters, other crew members, workers from outside the
IWT sector, ship owners, barge operators, Member States regulators and enforcement bodies,
river commissions, UNECE, education and training institutes, industry using IWT and freight
forwarders. A description of these parties and their key interests are described in Annex 8.
3.7.
How would the problem evolve, all things being equal (baseline scenario)
According to the baseline market outlook for inland waterway transport, there will be an
increasing demand for IWT services, in particular in container transport. IWT performance is
therefore expected to rise
91
. However, it must also be taken into account that other modes of
transport will also show an increase in their performance.
92
In order to reach modal share
growth for IWT compared to road and rail, additional efforts are needed.
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Due to increasing demand for transport in the future, the IWT labour force will need to grow.
However, the available labour force is expected to decrease in the long term due to the ageing
workforce
93
and because young people face difficulties to enter the profession. This results in
a gap between the required and available amount of mobile workers.
As shown in figure 6 and further elaborated in Annex 2
94
,
regional differences in the
demand and supply of workers between corridors are expected to increase
in the long-
term. On the Danube corridor and the East-West corridor, by 2050 there will be a surplus of
about 2,500 and 4,000 workers respectively. The Rhine corridor however will face a shortage
of about 10,000 workers. On the North-South corridor, the situation will be balanced until
2020 and thereafter a shortage of labour will start too, gradually increasing to a shortage of
about 3,600 workers by 2050. Figure 6 demonstrates that gaps between supply and demand
develop slowly over decades. In the longer term, gaps between supply and demand will
however become more pronounced, especially on the Rhine corridor and regional differences
will further increase
95
. Only in the short term, the so-called 'hidden reserve', not taken into
account in figure 6, may to some extent cushion the shortages.
Figure 6 Evolution of the gap between supply and demand of workers in IWT per corridor (2013-2050)
Source: Panteia (2014)
It is likely that the
obstacles
to mutual
recognition
of professional qualifications of
boatmasters and operational crew will
remain.
This is because EU Member States, aside from
Croatia and potential new Member States (e.g. Serbia), will stay outside of the existing CCNR
system of mutual recognition, both for boatmasters and operational workers, due to the
unfavourable balance between the need to adapt national regulations unilaterally to the Rhine
system which is not offset by the economic interest in obtaining recognition.
For boatmasters, the difficulties in terms of recognition of qualification as outlined under
3.2.1.1. are expected to remain unchanged under the baseline scenario. The recent Council
Directive implementing the European Agreement concerning certain aspects of the
organisation of working time in
IWT
96
, which entitles navigation personnel to a free annual
health check, is not expected to alter the baseline scenario with respect to the frequency of
medical check-up for boatmasters as this agreement is only applicable to employees and a
very large proportion of boatmasters is self-employed.
For operational workers, recent efforts have led to the conclusion of bilateral administrative
arrangements for the recognition of the professional qualification of boatman acquired by
training delivered by one institute in Romania and another one in the Czech Republic. The
process is currently intended to be limited to these two education institutes. It is nevertheless
plausible that if it were decided that no action would be taken at EU level, other bilateral
agreements could be signed in the long-term for a limited number of education institutes of
countries that signed the SRB multilateral agreement. Mobility of a limited number of
20
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operational workers from these countries to the Rhine would be facilitated as a consequence.
In the absence of harmonisation of professional training objectives at EU level, it is
nevertheless likely that the number of education and training institutes that have their
education standards considered to be equivalent to those of Rhine countries will remain
limited. Globally, both for boatmasters and for operational crew, it is unlikely that recognition
would be eased substantially under the baseline scenario, as it would continue to be based on
experience requirements rather than on competence-based requirements. As such, the related
difficulties with mutual recognition of professional qualifications as identified in section 3.2.1
would continue to exist.
As a result of the increased transport demand and the 'hidden reserve' navigating in order to
bridge the gaps between labour demand and supply, the external study estimated
97
that the
amount of accidents increases from around 1,200 accidents in 2014 up to 1,600 accidents in
2030 and 2,200 accidents in 2050, as presented in Figure 7 below.
Figure 7
2500
2250
2000
1750
1500
1250
1000
2010
2015
2020
2025
2030
2035
2040
2045
2050
Source: Panteia (2014), based upon the Problem Definition (Panteia, 2014) and NEA et al. (2011)
Development of the amount of accidents per year (2013-2050)
Furthermore, the
legal framework
governing IWT qualifications will
remain fragmented,
including a specific system for the Rhine managed by the Rhine authorities falling outside the
scope of the EU legislative framework. The recognition of qualifications for operational
workers through Directive 2005/36/EC is not expected to increase as it does not offer the
appropriate response to regular cross-borders activities, as mentioned in section 3.3.1.2.
Under the CCNR administrative arrangements, the inherent limitations outlined under section
3.2.1 will remain.
The 2013 Administrative Arrangement between the EU and the CCNR aimed to work on
common standards between the EU and the CCNR and the on-going work on common
Standards for Training and Certification in Inland Navigation (STCIN) would in itself not be
able to remove the obstacles to mutual recognition of professional qualifications. The
Arrangement and STCIN work were set up with the goal of incorporating the resulting work
into an EU legal framework. Without such a framework, the resulting work would not have
the legal authority to ensure mutual recognition of professional qualifications.
As far as
KSS
are concerned, based upon forecasts of future tonnage transported in IWT
98
, the
external study
99
for the assessment of impacts highlighted that the tonnage affected by KSS is
expected to increase
100
. For 2011, around 23 million tonnes were transported on waterways
affected by KSS. This figure is expected to increase to 30 million tonnes in 2030 and up to 42
million tonnes in 2050. As the volumes of cargo transport subject to KSS will double in the
period 2011–2050, the Net Present Value (NPV) of costs due to KSS increases rapidly as
well. In 2030, the sector will have paid around € 125 million for pilotage and € 215 million in
2050. See Figure 8 for a breakdown of the costs per river basin
101
.
Figure 8 Accumulated Net Present Value of Costs due to KSS per river basin and total, base year 2013
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Millions
€ 225
€ 200
€ 175
€ 150
€ 125
€ 100
€ 75
€ 50
€ 25
€0
2010
2015
Odra
2020
Rhône
2025
Elbe
2030
Seine
2035
Rhine
2040
Danube
2045
2050
Source: Panteia (2014)
3.8.
3.8.1.
Does the EU have the right to act?
Legal basis
The general competence for this initiative derives from the aim to complete the internal
market as stipulated under Title I 'Internal Market' in Article 26 of the Treaty on the
Functioning of the European Union. It is also in line with EU competence under Title VI
'Transport' of the Treaty on the Functioning of the European Union (in particular Article 91).
The applicability of Title VI to transport by inland waterway is stipulated in Article 100.
3.8.2.
Subsidiarity
The necessity of an EU initiative aiming at the harmonisation and mutual recognition of
professional qualifications is justified because the identified problems cannot be sufficiently
addressed by Members States acting alone. The activity of inland navigation and all related
aspects of transporting goods over the IWT network are generally transnational. Whereas
Member States could enact national transport rules, they cannot do so for cross-border
transport. Moreover, the introduction of different national legislation in each Member State
undermines the functioning of the internal market for goods and workers. The completion of
the Trans-European Transport Network would be jeopardised if barriers for its efficient use
would not be addressed. Differences in legal regimes for professional qualifications in IWT
throughout the EU cannot be entirely solved by the Member States individually, neither in the
framework of international conventions, nor by the industry alone. The existing frameworks
do not provide sustainable solutions for labour mobility problems in the long term. This
results in suboptimal functioning of the internal labour market and legal uncertainty. These
problems exist for both boatmasters and operational workers. Therefore, extending European
action to operational workers is justified. This initiative would also enlarge the area of EU
intervention to the Rhine river basin located on EU territory. Therefore, the initiative does not
only provide added value compared to national or River Commission level action but is also
necessary to achieve a well-functioning internal market at the level of the EU and to ensure
the full contribution of IWT to Europe's industrial development.
The opinions and demands expressed by Member States and other relevant stakeholders
during the wide consultation process and at various expert meetings on the issues above – i.e.
the extension of EU action to the Rhine river basin, to operational workers and to
competence-based standards for examination of future boatmen and boatmasters, including
via education and training - underpin the justification for EU action in relation to professional
qualifications in the IWT sector.
22
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4.
O
BJECTIVES
The general objective is to improve the functioning of the IWT labour market to help ensure
the sector can play its role in contributing to EU energy efficiency, growth and industrial
development goals.
The specific objective is to facilitate labour mobility in the IWT sector by ensuring that
qualifications of skilled workers are aligned with the competencies needed on-board. This
leads to the following operational objectives:
Ensure mutual recognition of professional qualifications of workers
Ensure that KSS requirements are proportionate to their safety goal and do not
unnecessarily hamper labour mobility
In Annex 10 a visual overview is given of the objectives and the link to the identified
problems. The objectives are in line with other main EU policy objectives, such as the internal
market and free movement of workers. They contribute to four of President Juncker's
priorities: 'a deeper and fairer internal market with a strengthened industrial base','energy
union', 'a new boost for jobs, growth and investment' and 'a stronger global actor'.
5.
P
OLICY OPTIONS
The stakeholder consultation, the expert meetings, independent research and the
Commission's own analysis have allowed the Commission to identify different policy options.
The following process was applied for establishing the policy options:
Step 1: Identify policy measures addressing the problems (considered policy measures)
and those which can be discarded after a preliminary assessment
Step 2: Combine the considered policy measures into policy options and identify options
which can be discarded
5.1.
Step 1: Considered policy measures & mapping with problem drivers
Problem driver 1: Workers face difficulties with mutual recognition of professional qualifications
Measures
Boatmasters
1
Business as
(BAU)
Description
usual
The professional qualifications recognition system is fragmented. Directive
2005/36/EC applies to all professions regulated in the host EU Member State
unless there is another specific EU legislation regulating the recognition of
professional qualifications for a given profession. Such legislation exists for
boatmaster. However, it explicitly excludes the Rhine area. A mechanism for
mutual recognition set up by the CCNR exists, but has inherent limitations (see
3.2.1.1. for more information). Requirements for obtaining national boatmasters'
certificates/Rhine patents are primarily based on sailing time and not on
competencies. Required navigation time is set at 4 years minimum. A reduction
of sailing time of maximum 3 years under Directive 96/50/EC is granted to
candidates that got a recognised diploma/training certificate and 2 years in
practice under RNP
102
. Directive 96/50/EC and RNP do not require a practical
examination. Navigation education institutes do not use minimum competence-
based standards and are variable in terms of competencies taught and tested.
Directive 96/50/EC foresees the possibility of an exemption from the set
requirements for boatmasters operating exclusively on non-interconnected
waterways. Boatmasters that fall under this category do not benefit from the
mutual recognition enjoyed by those operating on the interconnected waterways.
Binding EU wide minimum requirements for the boatmaster certificate in relation
to age, mental and physical fitness, professional experience, and examination of
competence. The sub-components of this measure are:
2
EU
wide
competence-based
minimum
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requirements
for
boatmasters'
certificates
tested
through a theoretical
and practical exams
by an administrative
authority + mutual
recognition
of
boatmaster
certificates
3
EU wide minimum
competence-based
standards
for
examination of future
boatmasters
in
education
and
training
institutes
necessary for mutual
recognition of their
diplomas
and
certificates
Operational workers: all crew members below boatmaster rank
4
Business as usual To date, no harmonised system for professional qualifications exists and this will
(BAU)
remains so in the future. Regulations at national or River Commissions level refer
primarily to experience rather than to competencies. Whereas practical exams are
frequent under the education/training path, no exam is required under the
experience path. The mechanism for mutual recognition of SRBs set up by the
CCNR continues to exist, including its inherent limitations. If a given profession
is regulated in the host Member State, Directive 2005/36/EC applies (see for
more info 3.2.1.2), but very few crew member apply for qualification under this
system.
5
Extension of the The existing administrative arrangement would be extended to cover the mutual
CCNR system of recognition of qualifications of all crew members based upon harmonisation of
multilateral
minimum requirements for age, fitness, experience and mutual recognition of
agreement
training courses and examination programmes. Limitation inherent to the form of
the arrangement will remain though (cf.3.2.1).
6
Use
of
new Representative professional organisations at EU level as well as national
instruments
under professional organisations or competent authorities from at least one third of the
directive 2005/36/EC Member States, may submit to the Commission proposals for common training
on the recognition of principles (i.e. common training framework (CTF) and/or common training tests
professional
(CTT)) as introduced in Directive 2005/36/EC by its amending Directive
104
qualifications
2013/55/EC. Common training principles provide a new way of automatic
recognition, focusing on the standardisation of content, and training or test
outcomes. If adopted by the Commission, Member States may be exempted from
their application under certain conditions ('right of opting-out' mentioned under
2013/55/EC)
105
. In the Member States that have accepted them, CTF/CTT can
co-exist with other training and qualification systems.
7
EU wide minimum At EU level, the following crew qualifications will be part of the mutual
requirements
for recognition system: deckhand, apprentice, boatman, able boatman and helmsman.
harmonized
This will be made possible through harmonised definitions of qualifications and
a. Minimum standards will be identical as for the Rhine patent and therefore
the EU boatmaster certificate will also be valid on the Rhine. As in BAU,
possibility of exemptions remain for boatmasters operating exclusively on
non-interconnected waterways.
b. For mental and physical fitness, 3 alternatives are envisaged: alignment with
prescriptions of Directive 96/50/EC, with those of RNP or a new proposed
frequency of examination
103
.
c. Minimum requirements are based on competencies. Set of competencies
required would cover the following areas: navigation, cargo handling and
passenger transport, control of ship operation, engineering, maintenance,
communication and safety). This will be based on the work already done for
STCIN (managerial level). Navigation time will be set at a revised level of 1
year minimum.
d. An administrative authority will test competencies through practical exam
for candidates using the experience path (subcomponent d') [and also for
those using the education path (subcomponent d'') – only in case of option
C2].
e. A modular system will be proposed which will allow for limited licences
(e.g. for boats between 20-40m with a reduced list of required competencies
and navigation time) or extended licences (e.g. large convoys of more than 6
barges with additional required competencies and specific navigation time).
The EU adopts European competence-based minimum standards for examination
of future boatmasters in education and training institutes (equivalent to those to
be carried out by the administrative authority). The diplomas/certificates
awarded by training and education institutes awarded in line with these minimum
standards are mutually recognised throughout the EU. Such a recognition would
exempt the candidate from taking an examination with the administrative
authority covering the same competencies. This education path provides a direct
access to the qualification of boatmaster.
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qualifications
and
mutual
recognition
for all operational
staff
8
EU
wide
competence-based
minimum
requirements tested
through examination
by an administrative
authority
for
candidate-boatmen
EU wide minimum
competence-based
standards
for
examination of future
boatmen in education
and training institutes
necessary for mutual
recognition of their
diplomas
and
certificates
10
Harmonization
of The required information in SRBs and logbooks – in relation to identification
required information data, physical and mental fitness, professional qualifications and navigation time
contained in SRBs - is harmonised throughout the EU. These SRBs and logbooks, and information
and logbooks & contained therein, are harmonised and mutually recognised throughout the EU.
mutual recognition
Proper registration of these documents must be ensured.
Workers from outside the IWT sector
11
Business
(BAU)
as
usual
9
the introduction of related minimum requirements with regard to age, physical
and mental fitness and professional experience. 'Minimum requirements' means
that Member States are allowed to define higher requirements in their legislation
but will have to recognize on their territory crew with qualifications in line with
EU minimum requirements'. Member States are allowed to define additional
qualifications in their national system but only those defined at EU level will fall
under the mutual recognition system. Member States are also allowed to define
fewer qualifications, but the intoduction of the qualification of boatman in
national systems would however be mandatory, except for Member States not
connected to the IWT waterways network who can decide to opt out.
On top of measure 7, for all boatmen (first stage of the crew hierarchy for which
key skills are necessary, including as regards safety), the following sub-
components of this measure are adopted:
a. competence-based minimum requirements would be imposed. Set of
competencies required would cover the following areas: navigation, cargo
handling and passenger transport, control of ship operation, engineering,
maintenance, communication and safety). This will be based on the work already
done for STCIN (operational level).
b. competencies will be tested by an administrative authority for candidate-
boatmen using the experience path (subcomponent b') [and also for those using
the education path (subcomponent b'') – only in case of option C2]. Examination
could take the form of a theoretical and/or a practical exam.
On top of measures 7 and 8, the EU adopts EU competence-based minimum
standards for examination of future boatmen in education and training institutes
(same as under measure 8). The diplomas/certificates awarded by training and
education institutes in line with these minimum standards are mutually
recognised throughout the EU. This education path provides a direct access to the
qualification of boatman.
12
Mutual recognition of
a third path of entry
to the profession with
practical exam that
may be introduced by
MS
For boatmasters: In both the RNP and Directive 96/50/EC, a reduction in
required professional experience in lieu of experience on a seagoing vessel is
included to obtain the Rhine patent or the boatmaster certificate respectively. The
regulation is stringent as it means that potential career changers from sea to
inland navigation often still need to gain two years of experience on-board an
inland navigation vessel in a lower function unavoidably at reduced wages. For
boatmasters, under Directive 96/50/EC, passing a practical exam can give acces
to the boatmaster licence more quickly, but still requiring one year of inland
navigation experience. The licence is however limited to vessels with similar
charachteristics to those of the vessel on which the boatmaster took the test. For
operational crew: the RNP and most countries in the EU take into account
experience from the maritime sector for the qualification of boatman, but still
require one year of inland navigation experience before obtaining the
qualification. In most countries, there is no possibility for lateral entrants in
general (i.e. incl.from other sectors) to enter the profession through specific
programmes.
12a) for obtaining a boatmaster certificate: practical exam based on an intensive
training and testing programme including various types of vessels combined with
minimum navigation time, will become a fully-fledged recognised alternative for
accessing the profession at EU level.
12b) for obtaining the qualification of boatman: a practical exam combined with
a minimum navigation time will become a recognised alternative path at EU
level.
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For both levels, the same competencies as assessed in the education path shall be
tested. Member States are not obliged to use the third path, but if they do, the
crew shall have its qualifications recognised across the EU. Even if a Member
State chooses not to put in place the third path, a reduction of the navigation time
(to be defined but more favorable than in BAU) shall in any case be possible for
those with maritime experience.
Problem driver 2: Requirements on KSS may unnecessarily restrict labour mobility
Measures
13
Description
Business as usual
(BAU)
14
Commission
recommendations
on KSS
15
Binding
EU
criteria framing
the use of KSS
but leaving the
main
responsibility to
MS
16
All
MS
can
organise exams
and
issue
authorisation for
all KSS in Europe
Member States may impose a requirement to obtain a certificate that attests the
boatmasters’ knowledge of KSS (see 3.2.2). Requirements differ depending on the
authority that issues the certificate. If the boatmaster has no such certificate, his
vessel can still navigate on the specifc river section but a ‘pilot’ – a boatmaster with
the appropriate KSS certificate has to be hired. The introduction of fairway
information systems (FIS), including River Information Systems (RIS), have no
impact on KSS requirements, which are not expected to evolve over time.
The Commission issues non-binding recommendations on criteria related to 1) the
definition of KSS situations: checking the necessity of any given KSS (based on
relevance criteria: hydro morphological characteristics, FIS and existence of local
traffic regulations) and 2) the required knowledge and examination. The
identification of river sections subject to KSS would remain under the responsibility
of the Member State as under Directive 96/50/EC.
Before establishing requirements for KSS for a specific stretch of river, Member
States shall submit a justification to the Commission, based on the pre-defined list of
EU-wide relevance criteria and describing the specific risks inherent to the
navigation of the stretch concerned. Justification shall also be given for the
knowledge required to anticipate and alleviate such risks and the means chosen to
demonstrate the KSS (experience and/or examination) shall be proportionate to the
risks. Member States need to notify KSS and their requirements to the Commission,
which will share this information with stakeholders and, the KSS – if accepted by the
Commission – will be published in a register. All existing KSS stretches will be
examined in accordance with this procedure.
All MS are allowed to organise exams (through multiple choice questions, test on
simulators and/or verification of required minimum number of journeys on the
relevant stretch) and to issue attestation for all KSS in Europe based on the
requirements set by the Member State where the KSS is located (cfr. Measure 15).
Discarded policy measures
Several policy measures have been discarded after a first preliminary assessment (see Annex
11 for underlying justifications): rules for navigational workers operating on recreational
boats, the mandatory issuing and mutual recognition of certificates for all skilled crew
members after examination (in particular able boatmen and helmsmen, in addition to the
boatmen), the introduction of the electronic service record book and electronic logbook,
harmonised/identical EU wide requirements for professional qualifications (as opposed to
minimum requirements), centralised decision-making on KSS, and no exemption for crew
operating exclusively on non-interconnected waterways.
Stakeholders' opinions on the retained measures
In the framework of the CEG meetings, stakeholders had not only the opportunities to express
their opinion on most of the above measures but were also closely associated to their
formulation.
Generally, stakeholders in CEG,
most often represented at expert level from
Member State authorities,
are all supportive of measures 2, 3, 7, 8, 9, 10, 12, 15 and 16.
Some measures or some of their sub-elements are particularly strongly supported by certain
stakeholders e.g. modular system for large convoys under measure 2 by Danube countries,
new proposed frequency for medical check-up by experts from the Netherlands and France,
measure 8 (in particular the requirements for exam for candidates using the experience path)
by experts from ETF, measure 10 by AQUAPOL and experts from the Netherlands, measure
26
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12 by experts from the Netherlands, measures 3 and 9 by Edinna and experts from non-CCNR
countries having IWT education and training programmes (e.g. Czech Republic and
Romania), measure 15 by experts from Austria. Experts from some non-interconnected
countries (e.g. United Kingdom and Sweden) also expressed their agreement with measures
imposing common standards, subject to understanding that the possibility of exemption for
crew non-interconnected countries would subsist. Furthermore, some reservations have been
expressed by one expert from EBU regarding measure 8 and by experts from France,
Germany and the United Kingdom regarding measure 16.
5.2.
Step 2: Combining the policy measures into policy options
To address the problem and its problem drivers in full, besides the business as usual scenario
(option A), two policy options have been retained (option B and C), with option C subdivided
into two suboptions:
Policy option A: Baseline scenario
Policy option B: Initiatives taken by the sector with support of the EU
Policy option C: Recognition of professional qualifications based on minimum
competence requirements for boatmen and boatmasters,
o
C1
including examination standards for training and education institutes,
o
C2:
excluding examination standards for training and education institutes.
Each option is composed of a series of considered policy measures and addresses all the
problem drivers. As such, all policy options constitute true policy alternatives. Alternative
combinations of these policy measures are limited as the nature of the EU intervention is
different (via legal act or not) and coherence of the new system is to be ensured (see also
hereunder 'discarded options').
Under option A, no new EU action is proposed.
In option B, the emphasis is on initiative taken by the sector – with EU support – as regards
mututal recognition and also a Commission Recommendation on KSS is proposed to ensure
all problem drivers are addressed. The rationale behind this option is to examine the impact if
the sector (Member States, River Commission, Social Partners) would address the labour
mobility problems by themselves by exploiting to a maximum extent the existing
organisational and legal frameworks.
Option C consists of a regulatory intervention for mutual recognition of professional
qualifications for IWT workers at EU level, with minimum competence requirements for
boatmen and boatmasters. It also introduces binding EU criteria framing the designation of
KSS and allow Member States to organise exams and issue authorisation for all KSS in
Europe, whilst leaving the responsibility for defining the criteria and exam content to Member
States concerned by the river stretches for which KSS is required. This option has been
introduced to analyse the effect of replacing the 24 years old EU legal framework by new
legislation that builds upon the new governance model for inland waterway policy developed
under the NAIADES II programme and that tackles the root causes of remaining barriers to
labour mobility in the sector. Two variants have been introduced for Option C in order to
examine the impact if the proposed legislative framework would not establish standards for
training institutes:
Option C1 ensures the uptake of these competence based-standards through exams carried out
both by administrative authorities and by education and training institutes, to prevent that
candidates with a diploma from an education institute have to go again through a set of
examinations to obtain the certification of their qualifications.
27
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Option C2 consists of the uptake of competence based-standards only through a mandatory
administrative examination.
The table below shows how considered policy measures are packaged into the various policy
options.
POLICY MEASURES
POLICY OPTIONS
A B
C
1
C
2
Boatmasters
1. Business as usual
2. Competence-based (c) EU wide minimum requirements (a + b) for boatmasters
certificates tested through theoretical and practical exams (d) by an administrative authority
for candidates accessing the profession through the experience path (d') [and for candidates
using the education path (d'') – only for option C2] + mutual recognition of boatmaster
certificates
3. EU wide minimum competence-based standards for examination of future boatmasters in
education and training institutes implying mutual recognition of their diplomas and
certificates
X
X
a,
b,
c,
d'
X
a,
b,
c,
d'+
d''
Operational workers
4. Business as usual
5. Extension of the CCNR system of multilateral agreement
6. Use of new instruments under directive 2005/36/EC (CTT and CTF)
7. EU wide minimum requirements for harmonized qualifications and mutual recognition
8. EU wide competence-based (a) minimum requirements for candidate-boatmen tested
through exam by an administrative authority for candidates accessing the profession through
the experience path (b') [and those using the education path (b'') – only for option C2].
9. EU wide minimum competence-based standards for examination of candidate-boatmen in
education and training institutes necessary for mutual recognition of their diplomas and
certificates
10.Harmonization of required information in SRBs/logbooks + mutual recognition
X
X
X
106
X
a,
b'
X
a,
b'
+
b''
X
X
X
X
X
X
X
X
X
X
Workers from outside the sector
11. Business as usual
12. Mutual recognition of a third path with practical exam that may be introduced by MS
X
Knowledge of specific situations (KSS)
13. Business as usual
14. Commission Recommendation on KSS
15. Binding EU criteria framing the use of KSS but leaving the main responsibility to MS
16. All MS can organise exams and issue authorisation for all KSS in Europe
X
X
Discarded policy options
For the sake of clarity and to take account of subsidiarity concerns, only a limited number of
policy options have been retained. Other options have been examined thoroughly but have
been discarded because they would have represented only minor variations of the retained
policy options, because they would not consistently address all the problems identified or
because they would not have been consistent with the principle of subsidiarity.
For example, the option to adopt
minimum standards identical to the Rhine standards or
to those of the Directive 96/50/EC without a competence-based approach
was discarded
from the outset as it would not tackle adequately the problem linked to the lack of proven
competencies in the inland waterway sector, as described in section 3.3.1. (knowing that
scope and level of minimum standards in legal instruments is different). Action towards a
competence-based approach is also a necessary move towards a modern qualification policy
and the standard approach to qualifications in the European labour market. In the last two
28
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decades training and education systems in general have been moving away from the
traditional focus on knowledge and experience towards more competence-based teaching and
assessment, in particular in the field of transport. This reflects the desire to assess the
knowledge and practical skills of candidates with differing abilities, cultural and linguistic
backgrounds
107
, with the objective of favouring mobility. This is also expected to better
accommodate future trends in man-machine interface in the context of training and
assessment. The approach is in the line of the Recommendation of the European Parliament
and of the Council on the establishment of the European Qualifications Framework for
lifelong learning
108
Also, the possible option to introduce mutual recognition of competence-based professional
qualifications
for boatmasters only,
in combination with only soft instruments for boatmen,
has been discarded as it would not have been a coherent approach and because of the limited
overall impact. There are synergies between the regulatory measures for operational crew and
boatmasters, which would be lost if only boatmasters would be addressed. This is particularly
the case for the competence-based system which should be seen as a global approach to crew
qualifications. Not addressing operational crew through EU regulatory measures would result
in a much lower global impact as only one third of the workers are boatmasters and many of
them already enjoy mutual recognition of their qualifications through the existing legal
frameworks.
A third example of discarded option is a 'fully harmonised competence-based legal framework
for operational workers and boatmasters on the whole EU territory'. Adopting EU
requirements for qualifications in a uniform manner (identical instead of minimum
requirements), including for KSS, and extending the requirements to crew working on non-
connected inland waterways has been discarded for reasons of subsidiarity and
proportionality. As a last example, the option of stopping all current EU action in the field
was discarded. EU action is needed because there are problems which need to be addressed as
shown by this impact assessment. Stakeholders are asking for EU intervention and the
Commission109 has already announced its intention to act under the NAIADES II framework.
Stakeholder support for the retained policy options
Stakeholders have been extensively consulted on the policy options on several occasions to
ensure the largest possible outreach. The CEG has been intensively involved in the process of
the formulation of the options. They are most supportive of option C and more specifically of
option C1. There is strong support for a regulatory competence-based approach, including
practical exams for boatmasters and exams for boatmen. They support EU criteria framing the
use of KSS. The CEG is not in favour of option A and judges option A (in particular the
CCNR administrative arrangements) as only a transitory step towards EU regulatory action
(option C). In the online public consultation, the wider inland waterway stakeholder
community was targeted. With regard to mutual recognition of professional qualifications,
stakeholders do not favour keeping the CCNR scheme of bilateral/multilateral agreements as
the main regulatory framework (option B): only slightly more than 10% of the respondents
agree that this scheme fully serves its purpose of removing labour mobility barriers. It is seen
as a transitory instrument as a suboptimal response to the substantial shortcomings of the
current EU legal framework which has not been revised since 1996, pending further action at
EU level. EU mandatory requirements for professional qualifications and training standards
(option C1) receive support from around 90% of the respondents (who find the measure either
“somewhat appropriate” or “very appropriate"). The introduction of KSS related measures
also receive large support from the respondents. Section 5 of Annex 1 provides more detailed
information (e.g. on support per stakeholder category).
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2.
A
NALYSIS OF IMPACTS
Each policy option has been analysed in terms of its economic, environmental and social
impact against the baseline scenario. Where possible, quantitative estimates are given.
Because of the nature and diversity of the IWT sector and the lack of quantitative data, the
calculations and assumptions needed to be aggregated and sometimes generalised. Thus,
while the quantified estimates do indicate a trend-line, caution is needed in the interpretation
of the figures. This is the reason why the quantitative estimates are often presented as being
indicative or a means to illustrate the points made in the qualitative assessment. Under each
section only measures are presented for which an impact has been identified or for which a
specific explanation was considered useful. The impacts for option B and C (and when
relevant making distinction between C1 and C2) are presented compared to the baseline
scenario (option A).
6.1.
2.1.1.
Social impacts
Impact on labour mobility
A) Impact on labour mobility due to the measures on mutual recognition of professional
qualifications
Option
B
Boatmasters and workers entering the profession from outside the sector: no effect
on
labour mobility is expected as no specific measures are foreseen.
Operational workers:
the introduction of CTT or CTF as proposed under amended Directive
2005/36/EC (measure 6) will have a positive impact on mobility. The impact however is
expected to be rather small since CTT/CTF is a voluntary agreement on common standards
for operational workers' qualifications and there is high uncertainty about the use of
exemptions, which can be easily invoked by Member States. The adoption of a CTF/CTT in
the IWT sector does not exclude maintaining parallel national training structures in the
Member States. Training/examination schemes that are not elaborated according to CTF/CTT
could remain valid (a) in the Member States opting-out or, (b) in the Member States adopting
CTF/CTT. Workers who obtained their qualifications under these schemes would not be able
to benefit from the mobility offered by CTF/CTT (in Member States that have adopted
CTF/CTT), but could still exercise their profession in Member States by making an
application under the general system of Directive 2005/36/EC which as explained in point
3.3.1.2 is rather burdensome in a cross-border industry such as IWT. In addition, CTF/CTT
cannot address a number of supporting or organisational aspects that would need to be
regulated for IWT professions in order to facilitate the recognition of qualifications e.g. the
procedure for obtaining and checking SRBs. Finally, it is likely that the introduction of CTT
or CTF would co-exist with the CCNR multilateral administrative agreement (measure 5),
which would further fragment and complicate the framework for mutual recognition of
qualifications. Alternatively or additionally to CTT/CTF, a CCNR multilateral administrative
arrangement for the recognition of qualifications for crew members under boatmaster level
(measure 5) could also have a positive mobility impact, though this is also expected to be
minor as access would be limited to those that have signed the administrative arrangement for
SRBs and the limitations inherent to the form of the arrangement as described under
3.3.1.2.will remain.
Option C
Boatmasters:
Option C is expected to significantly affect labour mobility in a positive way due to measures
2 and 3, in particular as regards the recognition of EU boatmasters' certificates on the Rhine.
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Impact on labour mobility due to medical check-up frequency requirements: the impact will
be limited, as the estimated difference in the yearly number of boatmasters entering and
exiting the market resulting from changes in frequency (available workforce) is very small.
110
Impact on labour mobility due to competence-based minimum requirements and mutual
recognition of related boatmaster certificates:
As the existing EU Directives already ensure mutual recognition in EU Member States with
the exception for the Rhine, the most substantial impacts due to mutual recognition of
boatmasters' certificates is expected on the Rhine River, with
benefits for all Member States
issuing EU boatmasters' certificates.
6.6% of the total estimated boatmaster workforce
111
and
around 15% of the
number of boatmasters working on the Rhine corridor
could benefit from an
automatic recognition of their qualification
112
if EU certificates are
recognized on the
Rhine.
65% of these boatmasters operate on interconnected IWT network (in
particular from France and Croatia)
113
and the remaining 35% come from Member
States that have no interconnected inland waterways but issue certificates in line with
the requirements of Directive 96/50/EC (i.e from Sweden, Finland, Lithuania and
Estonia).
All Member States concerned by the CCNR bilateral arrangements
would also
enjoy mutual recognition benefits due to the elimination of the
limitations
inherent to
the bilateral agreements as described under 3.3.1.1. In particular, the vast majority of
their boatmasters would enjoy direct benefits as additional requirements would no
longer be imposed on them
114
. This concerns boatmasters coming from Austria,
Bulgaria, Hungary, Poland, Romania, Czech Republic, Slovakia, Belgium and the
Netherlands.
It should be underlined that the mutual recognition is made possible because of a competence-
based system is put in place through measure 2. The most significant example is the case of
France as highlighted under 3.3.1.1. It is only because of the increased
confidence
generated
by the shift from a common means (time)-based system of qualifications to a system based on
objectives (competence) that the automatic mutual recognition is possible.
The competence-based approach produces an additional benefit with respect to labour
mobility compared to the baseline scenario as
boatmasters will be active sooner
on the
labour market (workers operating on the Rhine would only need one year of professional
experience after they have graduated instead of the two years before). The impact of this
measure could be slightly lower if some Member States decide to keep two years as minimum
required navigation time.
Impact on labour mobility due to the introduction of a limited certificate for vessels between
20 and 40 metres: this measure will have some effect on new entrants to the sector as they
will be able to become boatmasters more quickly as less navigation time would be required.
The expected impact of this measure is limited however considering the estimated number of
additional boatmasters that would apply for limited boatmaster certificates
115
.
Impact on labour mobility due to the introduction of an extended certificate for large convoys:
This measure will have a limited impact as it would only concern a very small number of
crew yearly on the Danube corridor only (where these large convoys are found). For these
workers the impact will be negative as they access boatmaster level less quickly than in the
baseline scenario
116
.
Labour mobility effect is broadly similar for suboptions C1 and C2 but is somewhat higher in
case of C1 through the recognized recognized diplomas or certificates issued by education and
training institutes (measure 3), which prevents that candidate-boatmasters with a recognised
31
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diploma/training certificate (85% of the inflow
117
) would be required to take additional
examinations with an administrative authority. Section 6.2.3. shows the main difference
between suboptions C1 and C2, namely, a reduced administrative burden in option C1 due to
the fact that candidate boatmasters with a recognised diploma/training certificate do not need
to take additional exams with an administrative authority.
Operational workers:
Impact on labour mobility due to mutual recognition of EU harmonized qualifications and
additional competence-based requirements for boatmen (measures 7, 8 and 9): due to mutual
recognition of qualifications, positive impact is expected
for all Member States and on all
rivers:
All skilled workers from any Member States who might postpone or renounce
working on the Rhine or on another river
in another Member State due to the fact
that they have not reached yet the sailing time required for the qualification they have
already been granted in their country of origin (as mentioned under section 3.3.1.2.
close to 40% of all operational workers could potentially be concerned).
Concretely,
around 13% of the crew below boatmaster level
118
operating on the
interconnected IWT network who are
currently
working on the Rhine
and are being
downgraded
(as described under 3.3.1.2.) due to the absence of a qualification system
harmonised at EU level. This may concern workers from both CCNR and non-CCNR
countries. Although no estimates exist, this phenomenon also exists outside of the
Rhine depending upon the national legislation.
Boatmen from individual Member States like France that currently do not have the
qualification of boatman in their system and would wish to have their competence
recognised in another country.
In the same way as for boatmasters, it should be underlined that the mutual recognition of
qualification at EU level is made possible because of a competence-based system is put in
place through measure 8. It is only thanks to the increased confidence generated by a system
based on objectives (competence) that experience (navigation time) becomes less central in
the recognition process. As a result, the competence-based approach should generally allow
boatmen,
in particular those using the experience path,
to access the qualification sooner.
Labour mobility effect is broadly similar for suboptions C1 and C2 but is somewhat higher in
case of C1 through the recognized diplomas or certificates issued by education and training
institutes (measure 9) which prevents that candidate-boatmen with a recognised
diploma/training certificate would be required to take additional exams with an administrative
authority.
Impact on labour mobility impact due to harmonised content of SRB/logbooks (measure 10):
since almost all SRBs and logbooks on interconnected waterways are mutually recognised
under BAU through the CCNR multilateral agreement, the impact of this measure on mobility
should per se not be significant; it is mainly a supporting tool for the implementation of the
other measures.
Workers entering the profession from outside the sector:
Option C introduces with measure 12 mutual recognition of a fully-fledged ‘third path’, an
intensive training programme which includes a series of competence-based practical exams
that allow lateral entrants to enter the IWT sector more quickly. The impact on cross-sector
mobility is shown by the recent results of such programmes in the Netherlands where
demand
has
increased
since commencement of the programmes
119
. It should be even more
significant if mutual recognition of the qualification is guaranteed by an EU legislative
framework. The extent to which other Member States would integrate this 'third path' is
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uncertain. The effect over the long-term is therefore difficult to quantify. However it is likely
that
countries with training capacity and/or a workforce deficit would
put such a
programme in place as the first experiences showed that it is a useful tool for increasing the
attractiveness of the IWT sector for lateral entrants. Option C will therefore increase labour
mobility possibilities for these workers: the ‘third’ path in place in some countries will be
mutually recognized by all Member States. In the Member States where the 'third' path is not
put in place, a positive but much smaller positive impact on the mobility of lateral entrants is
expected. This would be due to a larger reduction of required navigation time for
maritime or
fisheries
sector workers switching to IWT. This would be a consequence of the introduction
of the mandatory exam as foreseen under measure 8. The external study estimated that
aligning all EU IWT-interconnected countries with the reduction presently offered in
Directive 96/50/EC by 2030 would benefit around 500 candidate-boatmasters originating
from outside the sector and that furthermore, reducing the required navigation time by 3/4,
instead of 2/3 as presently applied, could yield up to 250 additional lateral entrants at
operational level.
The total effect as regards increased labour mobility on the supply-demand gap of
workers:
As described above, options B and C have both a positive impact on labour
mobility, but to a varying extent. It is impossible however to estimate the exact impact on the
worker supply-demand gap because the number of IWT workers that will ultimately take
advantage of increased labour mobility possibility is unknown.
B
+
0
+
0
C1
++
+
++
+
C2
++
+
++
+
Impact on labour mobility due to measures on mutual recognition of professional
qualifications (all crew)
-
Boatmasters
-
Operational IWT sector workers
-
Workers from outside the sector
B) Impact of the policy options on labour mobility due to KSS measures
Option B
(measure 14) could result in increased labour mobility, as the Commission
Recommendation on KSS may incentivise Member States to re-evaluate their rivers stretches
which are subject to KSS. If judged no longer appropriate or necessary, Member States may
remove these stretches from their KSS list or may consider decreasing their knowledge related
requirements. As a result, there might be positive effects on labour mobility. However, as the
Commission Recommendation would not be binding, the effects are uncertain and no
estimates can be given. Moreover, no detailed assessments are currently available which
would indicate which specific rivers or Member States would be more likely to take this
measure up. Each Member State would be expected to make its own judgement.
Option C
Measure 15 will oblige Member States to re-evaluate existing river stretches that
are subject to KSS. Removing or adapting non-justified KSS requirements may have a
positive impact on labour mobility. As the detailed effects of this measure are not known as
long as the stretches have not been evaluated by the Member States in the context of a revised
EU regulatory framework, its magnitude cannot be estimated. It is nevertheless expected that
there will be a greater impact than under option B because of the mandatory evaluation and
the requirement to justify the KSS. The Seine, Rhine and Danube are most affected by this
measure. A second impact from option C may arise through measure 16 from the possibility
of Member States organising exams and issuing authorisations for all KSS river stretches in
Europe. Compared to the baseline scenario, taking the KSS exam in a worker's home country
may sharply reduce the cost as a percentage of a worker's monthly salary. According to the
external study,
120
estimations of exam costs would be reduced to maximum 5% of a worker's
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monthly salary. At present, this percentage reaches 57% and 66% for workers from Romania
and Bulgaria respectively. Although workers from all Member States would benefit from this
measure, the greatest savings would be for Central and Eastern European countries. Reduced
costs would increase labour mobility as a labour mobility barrier – attending a KSS exam in
order to navigate on KSS stretches –, is lowered. In view of the estimated number of
boatmasters per year that can’t do KSS exams in their own country
121
, the Elbe and the Seine
are particularly concerned by this measure. The exact impact of option C will depend on the
extent to which Member States make use of the possibility of organising KSS exams for
stretches located in other Member States.
Impact on labour mobility due to KSS measures
B
0
+
C1
+
C2
+
(“0” refers to a neutral effect compared to the baseline scenario; "+" refers to the strength of a positive correlation; the small
sign “
+
” just above the main sign indicates an (additional) positive effect but of a lower magnitude than a “+”).
2.1.2.
Impact on access to the profession
Under the baseline scenario (option A) the profession is regulated in a different way at various
levels, e.g. the UN ECE level, the European level, the level of River Commissions (CCNR
level and administrative arrangements) and the national and regional levels. As described
under section 3.3.1 this has led to difficulties with regard to mutual recognition of
professional qualifications, thereby making access to the profession more difficult in certain
countries. As both policy options B and C will have a positive impact on the conditions for
mutual recognition of professional qualifications (see section 6.1.1.), these options will also to
the same extent ease the access to the profession, both for workers having started their career
in the IWT sector or for lateral entrants. The impact of option B will thus be smaller than for
option C. Under option C, the benefits of the career prospects offered by the competence-
based minimum requirements (see also section 6.1.4 on 'job attractiveness') for boatmen and
boatmasters are expected to largely outweigh the difficulties that the necessary examination
requirements could represent for a number of individual candidates (in particular boatmen
using the experience-based path). The recognition of diplomas/training certificates and the
associated exemption from exams taken with an administrative authority under suboption C1
represents significant additional benefits for access to the profession compared to C2. Overall
the competence-based approach should not be perceived as imposing stricter requirements for
the access to the profession as its expected impact on the inflow of new intrants is positive.
Impact on access to the profession
B
0
+
C1
++
C2
+
2.1.3.
Impact on safety in the IWT sector
A) Impact of the policy options on safety due to measures linked to mutual recognition of
professional qualifications
Option
B
Boatmasters and workers from outside the sector: no effect
is expected as no specific
measures are foreseen.
Operational workers:
the impact on safety from the implementation of CTF/CTT, as
proposed under amended Directive 2005/36/EC (measure 6),
would be positive
because the
common minimum standards for operational workers' qualifications would refer to common
standards that ensure a high degree of safety. The extent of the effect
however
is
unsure
(for
the same reasons as those mentioned under section 6.1.1.). The impact of the extension of the
CCNR mutual recognition system to operational workers (measure 5) would also be positive
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but limited. The arrangement would be based on an alignment with CCNR standards that
ensure that navigation safety levels are high. However, participation would be limited to those
that already signed the administrative arrangement for SRBs and the inherent limits of the
instrument, as described under 3.3.1.2., would remain. Moreover, the administrative
arrangement cannot put in place a competence-based system with an organised and permanent
quality system. For ensuring stability and sustainability of the system, a stronger legal
framework is needed that establishes clear responsibilities of the Member States regarding
verification and evaluation of assessment and certification methods.
Option C
Boatmasters
(measure 2):
Impact on safety due to standards linked to the frequency of the medical check-up: As
mentioned under section 5.2, three levels of standards on the frequency of the medical check-
up are considered for application at EU level. The CCNR standards would be most stringent:
as a result, more accidents will be avoided, thereby positively affecting safety. The new
frequency proposing the lowest frequency of the medical check-ups, results in a negative
impact on safety. Directive 96/50/EC standards score in between. If all costs and benefits are
taken into consideration and considering proportionality, the new frequency (with savings in
terms of administrative costs estimated at 13,2 million by 2050) can be considered as the most
efficient level of minimum standards. Compared to the baseline scenario, according to the
estimates of the external study, the new frequency could lead to a limited number of extra
accidents, estimated at a maximum of 5 yearly, potentially leading to extra costs (NPV) up to
3.3 million by 2050.
122
Impact on safety due to competence-based minimum requirements and mutual recognition:
Positive effect on safety in terms of avoided accidents is expected thanks to the following
elements:
The competence based approach
– in comparison to the baseline scenario – sets high
standards. Increasing the coverage of competence required and making them up-to-
date with technological development will have a positive effect on safety both in
CCNR and non-CCNR countries.
The practical examination
as a prerequisite to becoming a boatmaster will ensure
that every candidate has the required competencies. Under the baseline scenario, only
a theoretical examination is imposed. This new practical examination will target the
entire new boatmaster population. This should result in a yearly increasing safety
effect in countries where such an exam was not required (e.g. the Netherlands,
Germany, Slovakia, Czech Republic.) and particularly for the candidates using the
experience path.
Increased mutual recognition
in itself will also slightly improve safety by increasing
the size of the workforce and thereby ending (or at least
limiting)
the use of the
"hidden
reserve"
which is more accident-prone as not active on a regular basis.
The external study has provided some indication of possible safety effects in monetary
terms.
123
Results should only be seen as illustrative. A methodological remark has been
included in Annex 12. Overall, according to the study, the NPV of the benefits of
competence-based minimum requirements and mutual recognition as defined under
measure 2, in terms of
accidents avoided per year is estimated at around €73 million for
2030 and € 183 million for 2050.
Impact on safety due to limited certificates for vessels between 20 and 40 m: in order to
obtain such a certificate, reduced navigation time would be required. Although it could be
expected that less experienced boatmasters have a higher accident probability, option C
includes a competence-based approach built on relevant competencies to be tested, including
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a practical exam. In addition, accidents involving smaller ships on average cause less damage
than larger ships and, under the baseline scenario, there is a small patent under the RNP that
can be considered as an equivalent to the new EU limited certificate. As a result, it is
concluded that the safety effect of this certificate is
insignificant.
Impact on safety due to certificates for large convoys: A complementary boatmaster
certificate for navigating on large convoys will have a
positive
impact on safety. It is difficult
to quantify the safety effects of this measure as no data is available on the number of
accidents in which large convoys are involved. However, public authorities responsible for
the Danube (river commissions and Member States) have been asking with a single voice for
an EU regulatory qualification framework including that aspect for safety reason. According
to them the lack of specific competence/experience in navigating on large convoys is the
cause of a significant number of accidents involving this type of vessels.
Operational workers:
Impact on safety due to EU harmonized qualifications for operational crew (measure 7) and
additional competence-based requirements for boatmen (measure 8):
The
harmonised
qualifications with regard to age and fitness for all operational workers
(measure 7) is expected to have an
insignificant
effect on safety as these EU standards are
expected to be very similar to those applied under the baseline scenario. The possible
reduction of minimum navigation time required is not considered to have a safety impact in
view of the higher safety benefits of the competence-based approach.
The competence-based standards for
boatmen
tested through
examination
(measure 8) will
in a significant way
positively
affect safety in terms of avoided accidents on a yearly basis
in
both CCNR and non-CCNR countries.
This is because - compared to the baseline scenario
– the competence-based approach introduces an examination of competencies as a
prerequisite to becoming a boatman; competencies which are based on
high standards that
are up-to-date with technological development.
In principle, a more significant impact is
generally expected from the application of the measure to workers that acquire their
qualifications through the experience-based path as they do not go through specific
tests/training under the baseline scenario.
The external study has provided some indication of
possible safety effects
due the
competence-based approach and mutual recognition at operational level.
124
The NPV of
harmonised standards as foreseen under option C
for 2030 and 2050 amounts to around
€4.2 million and €11.8 million respectively
in terms of work related accidents avoided.
These results should only be seen as illustrative and a methodological remark has been
included in Annex 12. It can nevertheless be noted that these estimates take into account only
the impact for non-CCNR Member States whereas – as mentioned above – a positive impact
is also expected for candidates from CCNR Member States.
Impact on safety due to harmonised content of SRB and logbooks (measure 10): the effect on
safety from the harmonisation of the models can be considered small but not insignificant.
The SRB is mainly a support for the other measures and the logbook a means to check the
information inserted in the SRB. The single SRB format and improved registering of related
information will contribute to improved compliance and have a positive effect on safety.
Workers entering the profession from outside the sector:
A
positive impact
on safety is expected from the new possibilities for external workers to
enter the IWT labour market through the recognised
third path consisting of an intensive
training and testing programme
(measure 12). This results from the additional guarantees
the required competencies are obtained, in comparison with the experience path (based on
number of years of navigation) as defined under the baseline scenario. The impact would
36
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remain modest however in view of the size of the population targeted (i.e. a maximum 15% of
new entrants
125
in countries having put in place such a system).
All the benefits in terms of safety outlined for option C are valid both for suboptions
C1 and
C2
as all candidates will have to go through examination in accordance with the same high
level and up-to-date standards to obtain their qualification. Under suboption C1, a higher
impact can be expected in terms of less work-related accidents involving boatmen from non-
CCNR countries as the standards used in education will improve more significantly for these
countries as shown in the comparative analysis of curricula of navigation education institutes
of figure 9 below. The analysis has been elaborated by the external study based on the work
of the PLATINA I project
126
. The analysis presented in figure 9 also indicates that not only
non-CCNR countries can benefit from competence-based standards in education, but also
CCNR countries, in particular for the level of boatmaster.
Figure 9 Percentage of relevant competences mentioned in STCIN covered by boatmasters and
operational workers curricula in two groups of Member States
Boatmasters
Cargo handling
92%
79%
Operational workers
Cargo handling
100%
90%
Safety
100%
83%
70%
48%
Communication
Safety
100%
77%
53%
97%
Communication
Navigation
81%
100%
86%
96%
Construction ship
Navigation
84%
99%
48%
92%
97%
Construction ship
75%
83%
86%
Engineering
98%
100%
Maintenance
Engineering
100%
100%
Maintenance
NL + BE + FR + DE
Other countries
NL + BE + DE + FR
Other countries
Source: Panteia (2014), based on data from PLATINA 1 D3.8
Impact on safety due to measures on mutual recognition of professional
qualifications (all crew)
-
Boatmasters
-
Other IWT sector operational workers
-
Workers from outside the sector
B
0
+
0
+
0
C1
++
+++
++
+
C2
++
+++
++
+
B) Impact of the policy options on safety due to KSS measures
None of the KSS related measures of options B and C are expected to impact safety as all
measures aim at ensuring that KSS requirements are proportionate to their safety goals and do
not unnecessarily hamper labour mobility. The intention is only to target disproportionate
KSS requirements. Any changes would therefore not affect the safety levels.
Impact on safety due to KSS requirements
B
0
C1
0
C2
0
2.1.4.
Impact on job quality/attractiveness
Regardless of the policy option, most of the measures are aimed at reducing labour market
barriers in the EU. The job quality and attractiveness of IWT careers in the sector will
37
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improve. As a result of measures which have positive impact on safety, job quality and
attractiveness will also improve as the risk of accidents decreases.
The impact of option C: Measures that introduce EU wide minimum competence-based
standards for boatmen and boatmasters also increase job quality as they positively influence
work autonomy and participation as well as workers' health. The external study used
indicators
127
for the various aspects of job quality/attractiveness and assessed which aspects
were affected by each measure. Table 1 shows the overall score for each of the measures
included in Option C, taking into account the population size of the targeted group. Measures
related to the mutual recognition of competence-based minimum requirements, both for
boatmasters and boatmen have the highest (positive) impact on job quality and attractiveness.
Table 1: Job Quality scores per measure
Job quality / attractiveness indicators
Work autonomy
Social working
environment
Advancement
opportunities
Health
implications
Meaning
fulness
Measures
Boatmaster-certificates for vessels between 20 and 40 m
Boatmaster-certificates for large convoys
Boatmaster-new frequency of medical checks
Boatmaster – mutual recognition of competence-based
minimum requirements, tested through a practical exam by
an administrative authority
Operational Crew - mutual recognition of harmonized
qualifications
Boatman - mutual recognition of competence-based
minimum requirements, tested through examination by an
administrative authority
Boatmasters and boatmen-Competence-based standards for
examination in education and training institutes implying mutual
recognition of their diplomas and certificates (option
C1 only)
Lateral entrants - recognition of practical exams programs
Harmonised paper SRB and logbooks + mutual recognition
Criteria for KSS and improved access to KSS-exam
Formal
training
Risks
Total
score
+
-
0
+
++
++
++
+
-
+
+
+
+
+
+
+
+
+
+
+
+
+
-
+
++
+
+
++
+
+
+
+
+
+
+
+
+
+
+
+
+
++
+
0
+
+
Source : Panteia (2014), adjusted by the Commission. Total score takes into account the size of the impact and of the targeted group.
Table 1 shows that suboption C1 with its recognition of diplomas and training certificates
brings additional benefits compared to option C2 in terms of attractiveness. As already
explained previously this is due to the exemption from taking additional examinations with an
administrative authority for candidates coming from education institutes.
A number of measures under option C will affect the speed of the career path of workers:
some measures will speed up the career path, whereas others will slow it down. The career
path is expected to influence the received wage in a given year, thereby affecting job
attractiveness from the point of view of the workers:
-
The boatmaster certificate for large convoys:
one extra year of experience in the function of
helmsman is needed before becoming a boatmaster on large pusher vessels. During that year,
the wage level could be lower. The external study
128
estimated the NPV of the total
accumulated salary difference for the EU workers at around € -0.1 million in 2030 and € -0.2
million in 2050.
-
The introduction of the competence-based approach for boatmasters:
there is a positive
effect in terms of salaries paid to workers that now work on the Rhine, as it will only take one
year before they become boatmaster, against two under the baseline scenario. The external
study
129
estimated the NPV at around € 21.0 million by 2030 and € 31.6 million in 2050.
38
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-
The mutual recognition of harmonised competence-based qualifications for operational
crew members:
as under BAU 6.6% of the operational workers do not have their
qualifications recognised, resulting in a lower function and a lower salary, the effects of
mutual recognition of their qualifications can also be calculated in terms of wage gains. The
external study
130
estimated the NPV benefits up to around € 10.4 million in 2030 and € 15.9
million in 2050.
Overall, option C is expected to lead to faster career paths compared to option B and the
baseline option, thereby positively influencing job attractiveness.
The benefits of option B for job quality and attractiveness will be smaller than those under
option C if CTT/CTF are put in place, because mobility benefits will be smaller. Also, if a
CCNR multilateral agreement is signed for the mutual recognition of qualifications, the
impact on attractiveness would be smaller than under option C, because existing CCNR
standards are likely to remain predominant over a potential competence-based approach.
Moreover, as previously mentioned, the degree of uncertainty of the effect is rather high.
Impact on job quality /attractiveness
B
0
+
C1
++
C2
+
2.1.5.
Impact on labour costs
In the baseline scenario, several regions face a supply/demand gap of workers. In line with
general wage trends in these countries, differences also exist in IWT wages. In regions with
labour shortages, e.g. in the Rhine area, this might result in labour cost increases. However,
the way wages will react to this supply/demand gap in the baseline scenario cannot be
estimated, as a lot will depend on the rigidity of wages in the various countries and on other
external factors. As the EU as a whole and certain regions face shortages of workers, it is
however likely that no decrease in labour cost will occur in regions with labour surpluses.
Policy options B and C will increase labour mobility and attractiveness and could to some
extent reduce the supply/demand gap of workers. Labour shortages would therefore decrease
in the respective regions and could as a result diminish the upward pressure on IWT labour
costs, compared to the baseline scenario.
The effect of possible wage gains by individual workers resulting from higher classification
and fasters career paths, as described in section 6.1.4, on labour costs for employers, is
limited. This is because an employer will not have to face higher labour costs for the same set
of required qualifications. Policy options B and C only make it possible for employees to
move faster towards certain higher crew categories, but this does not result in a higher pay for
a given crew category. Taking into account manning requirements as set in the relevant
manning regulations, it remains the prerogative of the employer to determine the composition
of its crew.
In all options, also in the baseline scenario, several vacancies related to skilled workers
remain open. Under the baseline scenario there is thus already a willingness to pay from the
employer side for more skilled crew. To a large extent, options B and C will make it easier for
employers to recruit these required skilled workers, thereby giving them the opportunity to
further expand their businesses. This is particularly valid for SMEs who often face difficulties
in fulfilling their staffing needs.
In the last round of stakeholder consultations during the process of revising the first IAR,
representatives of the industry confirmed that they do not expect higher labour costs as a
result of the policy options B and C.
39
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To conclude, as other external factors will also play an important role in wage levels, it is
almost impossible to accurately single out the effect of the policy options on wages. However,
as argued above, compared to the baseline scenario the effects are expected to be limited.
Impact on labour costs/wages
B
0
C1
0
C2
0
2.1.6.
Impact on employment
Compared to the baseline scenario, options B and C are not expected to result in significant
job creation or job losses for inland waterway crew. However, options B and C aim to
contribute to reducing the supply-demand gap by stimulating job mobility across regions and
improving the sector's attractiveness in order to fill existing vacancies. Options B and C will
therefore have a positive impact on employment through a higher filling-rate of vacancies.
For each option, the impact will be proportionate to their impacts on mobility and
attractiveness. On a very small scale new jobs could be created as a result of option C (and
particularly under C1) in the fields of quality standards, assessment of competence and
examination, as well as in the embryonic simulator business. With respect to potential
negative impact, KSS creates a small but distinctive labour market for pilots. Under all
scenarios, but slightly more likely under C, some pilots could lose their jobs if a stretch is no
longer considered as KSS or if the demand for pilotage services decreases if KSS examination
for the stretch is facilitated. It is difficult to make projections for both aspects, but in practice
the impact on pilot employment should remain very limited. In view of the expected shortage
of skilled personnel, pilots who could lose their job should be expected to find easily a job as
boatmaster.
Impact on employment (filling rate of vacancies)
B
0
+
C1
+
+
C2
+
+
2.2.
2.2.1.
Economic impacts
Impact on the contribution of IWT to the European industrial base
As discussed in section 3.2.2, the IWT sector has a role to play in strengthening the European
industrial base. Under the baseline scenario, this contribution is threatened as the suboptimal
labour mobility will hamper the efficient functioning of the IWT sector. As under option B
and C, the functioning of the labour market will be improved, these options will also
contribute to maintaining or improving the strength of the European industrial base. For each
option, the impact will be proportionate to their impacts on mobility and attractiveness.
Impact on the contribution of IWT to the European industrial base
B
0
+
C1
+
C2
+
2.2.2.
Impact on the contribution of IWT to the European transport energy efficiency
As discussed in section 3.2.2, the IWT sector has a role to play in strengthening the European
industrial base. Under the baseline scenario, this contribution is threatened as the suboptimal
labour mobility will hamper the efficient functioning of the IWT sector. As under option B
and C, the functioning of the labour market will be improved, these options will also
contribute to maintaining or improving the contribution the IWT sector can make to energy
efficiency goals by taking up a higher part of the overall transport in the EU. For each option,
the impact will be proportionate to their impacts on mobility and attractiveness.
Impact on the contribution of IWT to the European transport energy efficiency
B
0
+
C1
+
C2
+
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2.2.3.
Impact on transport costs and on final consumer prices of goods
Transport costs could be marginally influenced by changes in labour costs in the IWT sector
(that only concern a small proportion of the total transport costs). However, as explained
under section 6.1.5. the impact of all policy options on labour costs is insignificant from an
EU-wide point of view. Furthermore, IWT is facing fierce competition with other transport
modes. It is therefore unlikely that there will be any subsequent effect on transport costs.
Nevertheless, there may be an indirect benefit for transport costs as inland waterway transport
is more cost-efficient compared to other modes of transport under certain conditions.
Eliminating barriers for the uptake of inland waterway transport can therefore reduce the
overall costs of transport for certain industry sectors. However, it is unlikely that any of the
policy options influence consumer prices of goods at a European scale, knowing also that
transport costs only concerns a small proportion of the price of goods.
Impact on transport costs and on final consumer prices of goods
B
0
C1
0
C2
0
2.2.4.
Investment costs
131
Under option B,
the investment in human resources time for the implementation of new
instruments proposed under the amended Directive 2005/36/EC (measure 6), in particular for
national administrations and training institutes, is significant as the sector has to take the
initiative and come with a CTF or CTT proposal. Some of the costs related to developing a
competence-based approach for operational workers will also be needed for the CTF or CTT.
Costs will be linked to the setting up a quality system which includes certifying/recognising
training institutes and their curricula. However, few costs for adapting the curricula should be
incurred at EU level since setting up the platform does not require replacement of the national
system, unless a Member State decides otherwise. Investment costs would also be incurred if
the CCNR set up a multilateral administrative arrangement for the recognition of crew
qualifications. This would include audit, reporting and meeting costs for Member States and
staff costs to manage the recognition process for the CCNR. The CCNR estimated that two
audits could be processed per year with a maximum of 5-6 additional requests in total.
Contrary to CTT/CTF, there will be costs for adaptation of curricula of education institutes as
the CCNR requires alignment to their standards. For both alternatives, it is possible that
mandatory examination is not included under option B. In this case, the related investment
costs (in particular for the development of the programme) may not be necessary under option
B. At EU level, investment costs under option B will be lower than under option C since the
number of participants will be lower. No significant investment costs are expected for the
Commission Recommendation on KSS.
Investment costs related to
option C
are presented in the table below. Only significant costs
are presented. They are all related to measures linked to mutual recognition of professional
qualifications. Further information on the underlying assumptions and calculations can be
found in Annex 13.
Table 2: Significant investments costs per measure
Investment costs (in euro)
Measures linked to mutual recognition of professional qualifications
Introduction of competence-based
minimum
requirements
for
boatmasters
certificates
tested
through a practical exam (measure 2)
0.01 to 0.1 million per Member States
for the development of
the exam programme (only needed in some countries where
practical exams do not exist yet e.g. Bulgaria, Croatia, Czech
Republic, Germany and Slovakia). In addition, investment
costs for a ship or simulator for the purpose of examination
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may have to be considered in countries where not available.
Asking candidates to bring the boat (their own or rented) could
be an alternative entailing no investment. This option is
already used in several Member States (0-2.6
million per MS).
For an estimation based on average costs for all MS, a rough
estimation of
5.5 million
can be given
knowing that cheaper
alternatives exist.
Accreditation/recognition of training 9000 per programme accreditation, which would make max
institutes
and
their
curricula
0.4 million
if all 43 programmes among the 11 interconnected
(measures 3 and 9
in C1)
Member States having training institutes are accredited. Note
that a
recognition process is much less costly
than an
accreditation. Costs in this case could be considered as
insignificant.
Analysis and modification of For 43 programmes, roughly an investment in the range of
0.4
curricula (measures 3 and 9
in C1)
– 4 million.
It could also be considered that these costs
although significant are inherent to the necessary adjustments
education and training system have to make anyway if they
wish to keep up with external (including technological)
developments. For an estimation based on average costs for all
programmes, a rough estimation of
2.2 million
can be given
knowing that this could also be reasonably considered that the
marginal cost of this would be negligible in view of the
ongoing activities under the BAU.
Optional
introduction
of
an 9000 per programme accreditation. For the Member States
intensive training programme for potentially concerned, this would represent a maximum of
workers entering from outside the 216,000 for two programmes (boatmaster and boatman) in all
sector (measure 12)
these Member States. More realistically, investment costs
could be estimated at
0.1 million
assuming that within the 11
interconnected Member States which have training institutes,
the "participation rate" would be 50%, either because a
number of Member States would organize such a programme
only at one level (boatmaster or boatman) or would not
organize it at all. However, as this measure is optional, neither
the investment costs nor the benefits have been taken into
account.
In total,
upfront investment costs of
8.0 million for suboption C1
and of
5.6 million for
suboption C2
are expected for the public sector and, in case of C1, for IWT education and
training institutes. For the private IWT sector itself, no significant investment costs are
expected, neither for employers nor for employees.
B
C1
C2
-
Impact on upfront investment costs
0
-
-
-
(the sign’ ’ just above the main sign indicates a negative effect i.e. costs but of a lower magnitude that a ‘-’).
2.2.5.
Impact on recurrent administrative costs
The impact on recurrent administrative costs is presented in the table below for option C. The
impacts for option B are presented thereafter. Further information on the assumptions and the
underlying calculations can be found in Annex 14.
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Table 3: NPV (in million) of the recurrent administrative costs under option C 2030 and 2050
Policy measures causing administrative burdens
Minimum standards linked to the frequency of the
medical check-up
Directive 96/50/EC
CCNR
New frequency
At boatmaster level, competence standards tested by
practical exam - measure 2 + measure 3 (in case of
option C1 only)
Introduction of a boatman exam (theoretical or/and
practical - optional) - measure 8 + measure 9 (in case
of option C1 only)
For boatmasters and boatmen, recognition/certification
system for education/training programs and mutual
recognition of diplomas (measure 3 and 9)
Harmonization of required information in SRBs and
logbooks (measure 10)
Practical exam for workers entering from outside the
IWT sector
(optional
measure 12)
Suboption C1
2030
2050
+2,3
-1,3
+7,7
all
-0.5
132
Private/all
-0.8
133
private/all
-2.8
public
+3,3
-2,1
+13,2
all
-0.7
private/all
-1.3
private/all
-4.4
public
Suboption C2
2030
2050
Idem C1
-1.9
private/all
-2.8
private/all
-3.5
private/all
-5.2
private/all
n.a.
+0,1
+0,2
private
private
(-800€ per boatman exam
-6000€ at boatmaster level)
private
Idem C1
Idem C1
Organisation of exams and issuance of authorisations
for all KSS in Member States (optional measure 16)
Idem C1
insignificant
Impact for Member States
i
nsignificant
(0 to +0,7)
Benefits for boatmasters taking the exam
(0 to +0,8)
Total administrative costs (on the basis of the new
frequency for medical check-up and excluding costs
+3.7
+7.0
+2.4
+5.4
for optional measures 12 and 16)
(‘+’ represents administrative savings and ‘-‘ administrative costs; optional costs are put between brackets)
From the above table the following conclusions can be drawn:
-
The total administrative savings for suboptions C1 and C2 are relatively similar, with a
small advantage on the long term for suboption C1.
-
With regard to the minimum standards linked to the frequency of the medical check-up, the
suboption “new frequency” has the most beneficial cost-benefit ratio over time (based on
the comparison between negative safety impact of only 3.3 million by 2050 and the above-
mentioned administrative costs benefits). This new frequency already received explicit
support in the CEG from some experts (e.g. from NL and FR). Savings generated by this
measure are relatively high resulting in a positive ratio for total administrative
costs/savings.
-
The most significant administrative costs are related to the mandatory examination to test
the competencies at boatmen and boatmaster levels (more significantly for boatmen and
under C2) and, in case of C1 only, to the recognition/accreditation system for exam
programs. For the first cost category, it should be noted that that the estimates take into
account a number of scenarios related to the examination, including more costly ones. As
regards the second cost category, the estimates is based also upon the assumption that that
some Member States will opt for an accreditation system whereas it is likely that most
Member States adopt a (cheaper) recognition that will be integrated in existing national
quality assurance systems.
-
Significant costs are also related to the organisation of practical exams for lateral entrants
but this is optional for the Member States.
-
For a number of measures, e.g medical checks or exams, it is not possible to clearly
identify whether the private or the public sector will bear the costs. Already in BAU this
varies from one Member State to another. However suboption C1 should be more costly
for the public sector (due to quality assurance system covering also education/training
43
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institutes) but less costly for the private sector (SMEs). Comparing both suboptions, C1
represents overall less administrative burden due the exemption from taking administrative
exams for those using the education path.
Under option B, no significant savings are generated as there is no measure tackling medical
check-up for boatmasters. On the other hand, less administrative costs will be incurred as the
number and scope of measures are less important. However, for the CTF or CTT for
operational workers (measure 6), there will be similar recurrent costs related to organising the
competence based approach. These relate, in particular, to the management of the quality
system including the compliance check that will be required on a regular basis. In addition,
under Directive 2005/36/EC, also for professions under automatic recognition, in case of
provision of services, there is an obligation to submit a declaration to the authorities of the
host country. Beyond the administrative burden it represents, this could involve some costs
for applicants as some Member States charge a fee for processing the declarations. This might
also be the case under CTT/CTF. The setting up by the CCNR of a multilateral agreement for
the recognition of crew qualifications (measure 5), would require less administrative costs as
no permanent quality system is put in place. Only costs inherent to regular meetings related to
the implementation of the agreement would be incurred. In view of the fact that these already
exist for the agreement for SRBs, additional costs are considered negligible. For both
measures, due to the fact that mandatory examination may not be included under option B,
related administrative costs that were unavoidable under option C might not be incurred under
option B. At EU level, administrative costs to incur under option B will be lower than under
option C since the number of Member States adopting CTT/CTF will be lower. With the
Commission guidelines on KSS, no significant administrative costs are expected. In total,
however, in the absence of significant savings, the ratio savings/costs is expected to be less
favourable under option B.
Impact on recurrent administrative costs
(‘+’ represents administrative savings and ‘-‘ administrative costs)
B
0
-
C1
+
+
C2
+
2.2.6.
Impact on different regions
All IWT Member States will be positively affected in terms of labour mobility, safety and
increased attractiveness of the profession. Any implementation costs are outweighed by
benefits. Experts from IWT Member States, representatives from the main River
Commissions (Rhine, Danube, Sava) as well as social partner organisations representing at
EU-level the IWT employers and the employees actively contributed in a positive way to the
development of EU initiative and did not signalled any overall negative impacts on certain
regions or countries. Only the representative of some non-interconnected countries (in
particular from UK and SE) called upon the Commission to keep the possibility of exemption
as currently foreseen under Directive 96/50/EC.
This said, some European regions or individual Member States may be affected in a different
manner depending on the measure. The section below highlights the most significant
variations of impacts.
In terms of mobility,
In general,
the Member States on the interconnected IWT network with the largest workforce
will have more benefits: CCNR countries (NL, DE, FR, BE), and RO.
With regard to
mutual recognition
of professional qualifications, the workers from non-
CCNR countries and from FR will enjoy larger benefits. This is because in policy option C,
non-CCNR countries' boatmaster certificates and operational workers’ qualifications will,
44
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contrary to the BAU situation, automatically be recognised on the Rhine, thereby increasing
possibilities for labour mobility.
Suboption C1 will have a higher impact in non-CCNR countries with IWT training/educations
institutes (AT, BG, CZ, HU, PL, RO and SK) as their education/training programmes are,
with only a few exceptions, not recognised by CCNR countries. In view of the yearly number
of entrants in IWT institutes per country, RO will by far be the biggest beneficiary among
these countries, followed to a much less extent by PL, CZ and BG (see table 2 under
Annex 2).
The increased labour mobility resulting from options B and C will have a positive effect on
reducing the
gap between the supply and demand
of workers and on labour mobility in the
different regions. As mentioned under section 6.1.1., it is impossible however to estimate the
exact impact on the worker supply-demand gap because the number of IWT workers that will
ultimately take advantage of increased labour mobility is unknown. The Rhine region - which
under the baseline scenario is expected to face a large labour deficit – is very likely to benefit
much more in this respect. Indeed, due to increased labour mobility, workers from the Danube
(AT, BG, HU, RO and SK), the East-West (NL, DE, PL, CZ), and the North South (BE, FR,
NL) corridor will gain access to the Rhine labour market more easily. On the other hand,
surplus workers from the Danube, the East-West and the North South (till 2020) corridors will
also benefit as they will be able to leave the saturated labour market in their own region.
Depending on its effectiveness as regards mutual recognition, option B could also have
similar effects with respect to operational workers in case of full uptake of the instruments. As
explained in previous sections, it is however unlikely that option B would achieve similar
results as option C. On a different note, the online public consultation, when comparing
harmonised requirements (option C) with the voluntary approach (option B) for two important
river areas, the Rhine and the Danube, indicates that mandatory harmonised professional
qualifications and training standards will, according to 85% of CCNR stakeholders, and a bit
less than 80% of Danube stakeholders, result in fairly to very positive effects on labour
mobility. For voluntary measures these percentages are respectively around 50% and 60%.
In terms of safety
In general, the Member States on the interconnected IWT network with more IWT freight
transport volumes will have more safety benefits i.e. CCNR Member States (NL, DE, BE and
FR). From the point of view of the workers, the competence-based qualification system
should have more safety benefits for workers from non-CCNR countries as training standards
in general have kept up less with technological developments.
By the way, the online public consultation indicates that mandatory harmonised professional
qualifications and training standards (option C) will, according to around 90% of CCNR
stakeholders, and more than 85% of Danube stakeholders, result in fairly to very positive
safety effects. For voluntary measures (option B) these percentages are for both rivers only
around 60%.
In terms of costs,
Under option C, the introduction of mandatory practical examinations for boatmasters will
impact regions and individual Member States in a different way as certain Member States do
not have such exams (e.g. DE, NL, CZ or SK) nor use training ships or simulators (most
Danube countries e.g. BG, CZ, HR). It should nevertheless be stressed that the measure is
supported by all stakeholders, including from the expert in the CEG that do not organise such
exams for the moment.
Regarding suboption C1, Member States with more education/training programmes will in
general face higher costs for their recognition (RO, NL, FR, BE, DE). Furthermore, non-
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CCNR countries will face more significant costs per programme for their adaptation to the
new competence-based requirements. These Member States are in favour of establishing such
a recognition system for professional training as recognition/employment benefits should
largely compensate the costs. CEG experts unanimously supported the establishment at EU
level of a quality system for recognition that would allow using the recognised
diplomas/training certificates in the procedure for the issuance of boatmasters' certificates.
Option C will also reduce the administrative burden of the CCNR countries and the countries
with which the CCNR has concluded administrative arrangements (AT, BG, CZ, HU, PL,
RO, SK), because these recognition agreements could be abolished and related administrative
costs for their implementation would no longer be incurred.
As a side note, the online public consultation indicates that mandatory harmonised
professional qualifications and training standards (option C) will, according to 54% of CCNR
and more than 70% of Danube stakeholders, result in fairly to very positive effects on the
administrative burden. For voluntary measures (option B) these percentages are respectively
around 23% and 62%.
As far as KSS is concerned,
the Rhine, the Seine and the Danube area will be more
significantly affected, as they represent the largest share of transport affected by KSS
requirements (see 3.3.2). Therefore, those regions will be more impacted by the KSS related
measures under both options B and C. It should be noted that CEG experts from FR and UK
opposed KSS examination by other Member States.
2.2.7.
Impact on SMEs
The IWT is sector composed almost exclusively of SME's.
134
Therefore, the direct private
sector impacts described in the previous sections are all affecting SME's only. 90% of
enterprises in the Netherlands are micro-enterprises with 1 to 5 people employed
135
. In many
cases, the vessels are owned and operated by a family. The rest of the Western part of Europe
where most of the IWT activities takes place i.e. Belgium, France and Germany, shows a
similar business structure. Policy options B and C will both positively impact SMEs. As
described above, these policy options will have positive effects on labour mobility and safety
compared to the baseline scenario. In particular, increased labour mobility resulting from
option B and – with significantly higher effectiveness – from option C will make it easier for
SMEs to recruit staff from across the European Union, thereby reducing labour shortages.
Increased safety will also reduce accident costs for SMEs. Effectiveness with regard to safety
is expected to be higher under option C compared to option B. These benefits are estimated to
largely off-set administrative and investment costs, which are anyway largely borne by the
public sector, rather than the private sector. SMEs will therefore have to bear only a small
proportion of the costs (e.g. those related to participating in some Member States in
administrative exams), which will be more than off-set by the positive labour effects with
respect to labour mobility, safety and attractiveness of the profession. In addition, under
suboption C1, significant benefits for SMEs are expected in terms of reduced administrative
burden compared to C2 as candidates entering the profession via the education path will be
exempt from taking an administrative exam. More information on quantitative estimations of
the costs and benefits for SME's can be found in a table under Annex 15.
The European Skipper Organisation (ESO) which represents the independent IWT
entrepreneurs has actively participated in the preparation of the initiative at EU level,
including the impact assessment, through its active participation in the CEG meetings. ESO is
in favour of the adoption of a modern and flexible regulatory tool for training and certification
at EU level, which will improve safety and provide fair and competence-based access to the
profession.
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Impact on SMEs/micro-entreprises
B
+
C1
++
C2
+
+
2.2.8.
Impact on third countries
The impact on third countries is limited for options B and C. Switzerland would need to adapt
its legislation in case of changes in regulations on the Rhine river. The same would apply for
Serbia and Bosnia and Herzegovina in case of changes of the legislation for the Sava river.
Ukraine, Russia, and Moldova may adjust their legislation in case of modification of the
Danube recommendations. In any case, crew from third countries will need to adhere to the
future new prescriptions on crew qualifications.
The impact of measures linked to mutual recognition of professional qualifications would be
positive for both options B and C. The external study
136
has identified the following benefits
by 2030 under option C for third countries: firstly, administrative savings as a consequence of
the new frequency of medical check-ups (€ 0,6 million); secondly, gains in salary due to the
quicker recognition of qualifications of boatmasters resulting from a competence-based
approach (€2,1 million); and thirdly, and this would also be valid for option B, gains in salary
due to the recognition of harmonized qualifications of other crew members (€1 million).
Conversely, the introduction of certificates for large convoys would be associated with some
limited costs, corresponding to the loss of salaries for the additional experience the boatmaster
has to gain on large convoys before obtaining the special authorization (€ -0,1 million). The
benefits from prevented accidents however are expected to largely outweigh these costs.
Measures related to KSS are considered to have little impact on third countries. There would
be benefits if some KSS requirements are dropped or reduced or if boatmasters of third
countries could take their KSS exams in one single country.
Impact on third countries
B
0
+
C1
+
C2
+
2.3.
Environmental impact
While an increased use of IWT will contribute to the overall energy-efficiency of the whole
transport system, the proposed policy options on their own are not expected to have a
significant impact on modal shift and thus on the environment including fuel use, emissions,
pollution etc.
2.4.
Summary of the economic, environmental and social impacts
The table below summarizes the impacts addressed under sections 6.1., 6.2. and 6.3.
137
Information on quantitative estimations of the costs and benefits for the private and public
sector can be found under section 7.2. and in Annex 15.
Table 4: Summary of the economic, social and environmental impacts compared to the baseline scenario
Impact compared to the baseline
A (baseline)
B
C1
C2
Labour mobility
Access to the profession
Safety
Job quality/attractiveness
Labour costs/wages
Employment (filling rate of vacancies)
Contribution to the European industrial base
Contribution to the EU transport energy efficiency
Transport and final consumer prices
Investment costs
Recurrent administrative costs
SMEs/Micro-enterprises
0
0
0
0
0
0
0
0
0
0
0
0
+
0
0
+
0
+
0
0
+
0
+
0
+
0
0
-
0
-
+
+
++
++
++
++
0
+
+
+
+
0
-
+
+
++
++
+
++
+
0
+
+
+
+
0
-
+
+
+
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Third countries
0
0
+
+
+
Environmental impact
0
0
0
0
(number of "+" refers to the strength of a positive correlation, “ –“ refers to a negative correlation; ; the small
sign “
+
” just above the main sign indicates an (additional) positive effect but of a lower magnitude than a “+”).
Apart from investment and recurrent costs, all the other impacts are estimated to be positive.
This was also confirmed through the online public consultation. More than 75% of the
respondents expect a positive impact on labour mobility and more than 85% on safety in case
of regulatory intervention (option C). As regards impact on job quality 70% of the
respondents have a positive opinion and for impact on SMEs, 65% of the respondents expect
a positive impact. For the voluntary support measures (option B), the respondents estimate the
positive impacts to be considerably lower. Certain categories of stakeholders expect more
positive impacts than others: boatmasters, public authorities and training institutes. But each
stakeholder category the balance is always positive: a substantial larger proportion of the
respondents expects positive impacts from the proposed measures.
3.
3.1.
C
OMPARING THE OPTIONS
Effectiveness
The ineffectiveness of policy option A, the baseline scenario, has been demonstrated above
when describing the identified problems and its likely evolution in the future (see section 3).
Policy option B is expected to be more effective than option A in reaching the objectives of
this initiative based on the following considerations:
the mutual recognition of professional qualifications of workers (operational objective 1)
will be promoted further by the use of new instruments under directive 2005/36/EC (CTF
and CTT) and/or through a CCNR multilateral agreement covering crew qualifications.
it is most likely that a Commission Recommendation on KSS will only marginally impact
the proportionality of KSS requirements (operational objective 2).
However, the improvement of the effectiveness of option B is uncertain, because these
measures rely on initiatives and commitments to be made at the initiative of the profession,
which proved to be only partially effective in the past. (see section 3.4).
Moreover, the adoption of a CTF/CTT does not exclude maintaining parallel training
structures in the Member States. In addition, CTF/CTT cannot address a number of supporting
or organisational elements needed to support the recognition of qualifications that would still
need to be regulated for the profession e.g. the procedure for obtaining and checking SRB.
Finally, in view of the possibility of exemption for Member States to adopt CTT/CTF under
Directive 2005/36/EC, it is likely that the CCNR would maintain their agreements or
conclude new ones to cover the exempted countries. The existing fragmentation of the legal
framework would even likely increase since Directives 96/50/EC and 91/672/EEC would
most likely not be repealed. When a new CCNR administrative arrangement would be
created, existing problems related to the coverage and legal uncertainty linked to the form of
the arrangement as explained in sections 3.3.1. would remain.
Policy option C is judged to be more effective than options B and A, as all boatmasters and a
larger proportion of operational workers on interconnected waterways would be mutually
recognised throughout the EU (operational objective 1). In comparison to option B, all the
remaining drawbacks from the use of the new instruments under Directive 2005/36/EC or the
administrative arrangements with the CCNR would be eliminated. The fact that Member
States will be allowed to organise exams and issue authorisations for all KSS in Europe could
further promote the proportionality of KSS; the same applies to binding EU criteria framing
the use of KSS (operational objective 2).
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With a broadly comparable impact in terms of mobility, the effectiveness of suboptions C1
and C2 is comparable, with some advantage for suboption C1, in particular if the linkage with
attractiveness is considered. This is due to the more positive impact on attractiveness
generated by the recognition of diplomas and training certificates during the procedure for
obtaining a qualification.
3.2.
Efficiency
As shown in previous sections, it was not possible to monetize all costs and benefits. Some
estimates are available for option C for investments costs, administrative costs, safety effects
and job quality/attractiveness. For other impacts, only qualitative assessments are available.
Comparing only the total monetised cost and benefits for option C yields benefits in terms of
safety (NPV of around € 75 million (2030) and € 191 million (2050) and job
quality/attractiveness (around € 31 million (2030) and € 47 million (2050)) which more than
compensates the upfront investment costs (NPV estimated at € 8 million for suboption C1 and
€ 5.6 million for suboption C2). Investment costs are all borne by the public sector.
Considering only the benefits in terms of administrative savings (€ 13.2 million by 2050 due
to the new medical check-up frequency), they would already outweigh the to-be-incurred
administrative costs (for suboption C1 around € 4 million by 2030 and € 6 million by 2050
and for suboption C2 around € 5 million by 2030 and € 8 million by 2050). It should also be
noted that the administrative cost for suboption C1 are significantly lower than for suboption
C2. Under suboption C2, education/training institute examinations for boatmen and
boatmasters are not mutually recognized, which generates a substantial additional
administrative burden compared to suboption C1 as candidates have to go through additional
examinations before obtaining their qualification (administrative exams after education
exams). It is estimated that this would affect 85% of the candidates. Suboption C1 is therefore
considered to be more efficient than suboption C2. Further details on these estimates can be
found in Annex 15.
Apart from these available monetised impacts, other impacts are also relevant for assessing
the efficiency of option C. For example, as far as labour mobility is concerned, the impact was
calculated in terms of extra workforce available on the labour market, and not in monetary
terms. It has been demonstrated in section 6 that a positive impact is to be expected in this
respect. A significant number of boatmasters would be added to the available workforce on
the Rhine if all certificates issued under Directive 96/50/EC are recognized on the Rhine and
those that are already part of the CCNR recognition system will also benefit from a more
automatic recognition. Moreover, whereas a significant number of operational workers will
directly benefit from the measure on recognition of qualifications as they are currently facing
downgrading; many others will see mobility as a real opportunity since they can access sooner
with equivalent qualification to navigation on the Rhine. Finally, other main impacts for
which qualitative assessments are available (e.g. reduction of vacancies in the sector – ‘the
employment effect’) further add to the effectiveness and efficiency of policy option C.
Investment and administrative costs are expected to be lower for option B compared to option
C. However, the positive effects are more than proportionally lower, due to the partial uptake
of instruments. Option B is therefore less cost-effective than option C. More information can
be found in sections 6.2.1. and 6.2.2.
3.3.
Coherence
Compared to the baseline scenario, options B and C are more coherent with the completion of
the internal transport market and the EU policy objectives reflected in the Europe 2020
growth strategy and the political priorities of the Juncker Commission. As option C
49
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(regardless of its suboption) will be most effective in contributing to the mutual recognition of
workers, it would also contribute most to the EU energy efficiency, growth and industrial
development political priorities of the Juncker Commission. Therefore, option C is considered
to be more coherent than option B. The competence-based standards for examination of future
boatmen and boatmasters appears to be necessary to fully achieve the mutual recognition of
professional qualifications of boatmen and boatmasters. As both boatmen and boatmasters are
skilled workers and need to possess certain competencies, another Member State needs to be
confident about the skill levels of these workers before granting the recognition of
professional qualifications. For workers using the education path to access the profession,
these skills are developed and tested through the education system. In order to come to mutual
recognition of diplomas and training certificates, EU minimum requirements would need to be
set for the competencies to be demonstrated by candidates before the award of their diplomas
and certificates. These competencies only cover the aspects which are relevant for the safe
operation of vessels and therefore do not interfere with the general education aspects which
remain under the competence of the Member States. The EU minimum requirements set
minimum levels of competencies, necessary for the safe navigation of vessels. These
requirements do not entail a full harmonisation of training and education in IWT. Member
States can continue to differentiate IWT training and education to take account of the national
situation. The identification of the required minimum competencies is supported by the efforts
of the European network of nautical schools (EDINNA) which has developed (competence-
based) Standards for Training and Certification in Inland Navigation (STCIN). In the
framework of two recent bilateral agreements, the CCNR considered these standards
necessary for assessing training institutions prior to granting recognition of diplomas. The
approach is coherent with the spirit of the European Qualifications Framework
138
which
focuses on learning outcomes rather than on the duration of training schemes. The reference
to these minimum standards is considered essential for developing a European internal market
for employment in IWT as it helps Member States, education institutions, employers and
individuals compare qualifications across the EU’s diverse education and training systems.
Moreover, in line with measures taken for other modes of transport, competence-based EU
minimum requirements are only foreseen for skilled crew - boatmen and boatmasters. For
unskilled crew, such as deckhands, only minimum requirements with regard to age, physical
and mental fitness are considered, in order to facilitate labour mobility. As such the proposed
intervention is necessary and proportionate to its goals.
The policy options were developed with a balance between economic and social measures, in
order to avoid that action on one pillar would negatively affecting the other. No significant
environmental impacts are expected.
3.4.
Summary on the comparison of policy options
Table 5: Effectiveness, efficiency and coherence of the policy options compared to the baseline scenario
A
B
C1
C2
+
+
0
0
+
+
Effectiveness (total)
Operational objective 1: Ensure mutual recognition of professional
0
0
+
+
+
+
qualifications of workers
Operational objective 2: Ensure that KSSs are proportionate to their safety
0
0
+
+
+
goal and do not unnecessarily hamper labour mobility
+
Efficiency
0
++
+
0
0
+
++
++
Coherence
+
("+" refers to the intensity of a positive correlation, “0” refers to a neutral impact, the small sign “ ” just above
the main sign indicates an (additional) positive effect but of a lower magnitude than a “+”, no negative
correlation has been identified)
50
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3.5.
Conclusion: preferred policy option
Taking into account effectiveness, efficiency and coherence, option C is preferred over option
A and B. Under option C, suboption C1 is judged to be slightly more effective and efficient
than suboption C2.
This Impact Assessment Report leaves it up to the political decision-makers to decide on the
preferred policy suboption under option C. The difference between suboption C1 and C2 is
the introduction under C1 of minimum competence-based standards for examination of future
boatmen and boatmasters in education and training institutes and additional administrative
exam waivers for those with a diploma or certificate issued by those institutes. The minimum
standards only cover the aspects with are relevant for the safe operation of vessels and
therefore don't interfere with the general education aspects which remain under the
competence of the Member States. Similar Union legislative requirements for education and
training institutes already exist for the rail and air transport sector. In these sectors, the
requirements go further as they also entail continuous training requirements. Under option C2,
no requirements are set for training and education institutes as all boatmen and boatmasters
are required to pass an administrative exam organised under the responsibility of a competent
authority in order to have their qualifications recognised across the EU, also if they are
already in the possession of a diploma or certification of an IWT education or training
institute.
The two suboptions are in line with stakeholders' opinion expressed both in the online public
consultation and in the Common Expert Group (CEG). Opinions indicated a high level of
support towards regulatory measures in relation to the harmonisation of professional
requirements, qualifications and examinations, whereas the introduction of voluntary
measures received a considerably lower level of support. The experts from the competent
authorities in the Member States represented in the CEG considered the mutual recognition of
diplomas and training certificates based on competence-based standards as a necessary step
towards improved mobility of workers.
The two suboptions are also in line with the proportionality principle. In line with measures
taken for other modes of transport, competence-based EU minimum requirements, verified
through examinations, are only foreseen for skilled crew - boatmen and boatmasters. For
unskilled crew, such as deckhands, only minimum requirements with regard to age, physical
and mental fitness are proposed. The recognition of a third path via an intensive training
programme is proportionate as its introduction is made optional. Under option C1, the
measure to certify training programmes is considered proportionate to its goals as it does not
interfere with the national education curricula on general subjects and it allows preventing
those who have already successfully completed an approved training programme in the EU be
obliged to pass additional administrative exams on the same subjects that were already
covered by their training programme. To instil the necessary confidence for the mechanism of
mutual recognition, the requirements of quality standards with respect to assessment of
competences, recognition of programmes and monitoring of the whole certification system
are considered proportionate. Finally, introducing common criteria for establishing
requirements for knowledge of specific situations is necessary as the establishment of such
requirements should be justified on safety grounds and the knowledge required should be
proportional to the safety issues at stake.
Regarding implementation and compliance issues with respect to option C, it should be noted
that a final decision has not been taken yet on the form of the legislative instrument to be
proposed (directive or regulation). There was already some discussion with the sector in CEG
about a reasonable implementation period as well as specific and realistic transitions measures
and periods for various measures.
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4.
M
ONITORING AND EVALUATION
The Commission services will monitor the implementation and effectiveness of this initiative
through a set of core progress indicators, listed in the table below. It is foreseen that seven
years after the end of the transposition period date of the proposed legislation, the
Commission services will carry out an evaluation to verify whether the objectives of the
initiative have been reached. This evaluation will be carried out inter alia based on the core
progress indicators referred to below. This evaluation will be in line with Commission's
evaluation requirements.
Table 6: Core progress indicators for monitoring purposes
Operational objective
Ensure
mutual
recognition
of
professional
qualifications
of
workers
Ensure that KSSs
requirements
are
proportionate to their
safety goal and do not
unnecessarily hamper
labour mobility
Core progress indicators
- Absence of complaints to the Commission from
the sector
- Positive assessment of the IWT sector, Member
States and River Commissions
- decrease in the number of CCNR administrative
arrangements
139
- number of questions / complaints from the
sector to the Commission
- increase of KSS authorization delivered on
those stretches where they are maintained.
- number of river streches for which KSS
requirements are withdrawn or reduced by
Member States
- number of countries organising exams and
issuing authorisations for KSS throughout Europe
- number of exam programs of training and
education institutes in line with the EU minimum
requirements
Source of data
- questions / complaints to the
Commission from the sector
- fact finding survey/public
consultation
- Expert group, - River
Commissions
- questions / complaints to the
Commission from the sector
- fact finding survey/public
consultation
- Expert group, - River
Commissions
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E
NDNOTES
1
A New Start for Europe: My Agenda for Jobs, Growth, Fairness and Democratic Change Political Guidelines
for the next European Commission, Opening Statement in the European Parliament Plenary Session Strasbourg,
15 July 2014
2
1 convoy with four pushed lighters (=7 000 net tons) is the equivalent of 280 trucks at 25 net tons each. Source:
Via Donau.
3
Recent research carried out by the PLATINA II project indicates that seizing the potential for IWT continental
container transport would reduce transport costs for the industry every year with 899 million of Euros (
http://naiades.info/repository/public/documents/Downloads/118_Study_Market_Potential_Continental_Market_
2015_04_24.pdf
)
4
AT, BE, BG, DE, CZ, FR, HR, LU, NL, HU, PL, RO, SK as well as EE, IT, LT, FI, PT, SE and UK. CY, DK,
EL, ES, IE, LV, MT and SI are considered not having inland waterways transport in the framework of this study.
5
European Commission (2014) EU transport in figures: Statistical pocketbook 2014.
6
AT, BE, BG, DE, CZ, FR, HR, LU, NL, HU, PL, RO, SK.
7
European Commission (2014) EU transport in figures: Statistical pocketbook 2014, p.42.
8
CE Delft (2012),
Medium & Long Term Perspectives of IWT in the EU
and NVB/Erasmus Universiteit (2012),
Blue Ports: de onmisbare schakels,
p. 11 Conclusion.
9
Communication from the Commission to the European Parliament, the Council, the European Parliament,
European Economic and Social Committee, the Committee of the Regions and the European Investment Bank on
A Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy,
COM/2015/080 final
10
European Commission (2014) EU transport in figures: Statistical pocketbook 2014, p.82.The figure is the
average for the 28 EU Member States. The average also includes Member States in which there are no navigable
rivers, which results in a downward distorting effect. Figures on modal split share is according to CCNR-EU-
Panteia (2014) Market Observation, p.50-51.
11
E.g. Extract from TEN-T project “Upper Rhine, a connected corridor”: La région du Rhin Supérieur dispose
d'une offre infrastructurelle dense. D'une part, le Rhin, et son réseau de canaux connectés (notamment au
Danube, au Neckar et au Main), constitue la voie fluviale la plus fréquentée d'Europe mais dispose encore
d'importantes réserves de capacités. D'autre part, les réseaux ferroviaire et routier présentent une offre de
capacités très importante. Plusieurs points de saturation ont néanmoins été relevés aux niveaux ferroviaire et
routier dans le cadre de l'étude sur les capacités des réseaux magistraux et portuaires conduites par les ports du
Rhin Supérieur en 2014. According to the Study on TEN-T Core Network Corridor “Rhine–Danube”
(http://ec.europa.eu/transport/themes/infrastructure/ten-t-guidelines/corridors/doc/2014-11-05-tent-rhi-dan-draft-
final-report-v4.pdf), lock capacity utilization on the Danube is situated between 11 and 37%.
12
Communication: Towards Quality Inland Waterway Transport Naiades II COM(2013) 623 final.
13
European Committee for the elaboration of standards for inland navigation
14
EU Transport infrastructure policy that connects the continent between East and West, North and South.
15
The CCNR is an international intergovernmental organization established by the Revised Convention for
Navigation on the Rhine - referred to as the Mannheim Convention - of 17 October 1868. It has five member
states: BE, CH, DE, FR and NL. See:
http://www.ccr-zkr.org
16
The DC is an international intergovernmental organization established by the Convention regarding the regime
of navigation on the Danube signed in Belgrade on 18 August 1948. The Member States of the Danube
Commission are AT, BU, HU, DE, MD, RU, SR, SK, UA, HR). See
http://www.danubecommission.org
17
United Nations Economic Commission for Europe has 56 member states and two working parties dealing with
inland waterways. See:
http://www.unece.org/trans/main/sc3/sc3.html
18
The Sava Commission is an international organisation established by the Framework Agreement on the Sava
River Basin (FASRB) in 2002 between HR, SR, BA and SI. See
http://www.savacommission.org
19
The Moselle Commission is an international intergovernmental institution established by the Moselle
Convention signed by DE, FR and LU in 1956.
http://www.moselkommission.org
20
RNP was adopted through Resolution 2010-I-8-Annex 1.
21
The composition and functioning of these agreements will be developed under section 3.2.1. Service Record
Books (SRBs) register navigation time and qualifications. They as also provide proof that mental and physical
fitness requirements have been met by each crew member. In this respect, SRBs are an important factor for
obtaining a certificate to operate in a certain Member State or river basin.
22
Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition
of professional qualifications, OJ L. 255, 30.09.2005, p. 22.
53
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UNECE, ‘Resolution No. 31 Minimum Requirements for the Issuance of Boatmasters Licenses in Inland
Navigation with a view to their Reciprocal Recognition for International Traffic’, Doc
ECE/TRANS/SC.3/WP.3/2009/8/Rev.1 (18 May 2009).
24
Danube Commission, ‘Recommendations of the Danube Commission on Boatmasters’ Licenses’, Doc.
CD/SES/77/7.
21
All relevant documents can be found on:
http://ec.europa.eu/transport/media/consultations/2013-06-21-
inlandnavigqualifications_en.htm
26
Note that the way some issues are presented might be different in the publication consultation report and in the
IAR. For example, as explained under section 2.2. safety is no longer a problem driver but a key element in the
analysis of impacts; level of safety has to be maintained (and even possibly improved). In a similar way,
language is not considered any more as an individual problem driver but is included in the more global need for
'competence-based standards'. As one of the consequence, 'River Speak' is no longer proposed as an individual
measure but remains targeted as a 'communication' competence under the common minimum standards on
competence. The specific issue of SRB has been addressed under section 3.3.1.2.
27
http://ec.europa.eu/transport/modes/inland/promotion/platina_en.htm
28
see http://www.edinna.eu
29
Self-governing association of maritime and inland navigation related law enforcement authorities from EU
Member States and Switzerland.
30
The European Inland Waterways Transport Social Partners include EBU (European Barge Union), ESO
(European Skippers' Organisation) and ETF (European transport Workers' Federation).
31
Within PLATINA, the European network of nautical schools (EDINNA) is elaborating Standards for Training
and Certification in Inland Navigation (STCIN), similarly to the existing system of Standards for Training and
Certification and Watch keeping for Seafarers (STCW) by the international maritime organisation (IMO).
32
The evaluation of the current framework can be found on:
http://ec.europa.eu/transport/facts-fundings/evaluations/doc/2014-03-evaluation-report-directive-1996-50.pdf
33
The external impact assessment study can be found on:
http://ec.europa.eu/transport/modes/inland/studies/inland_waterways_en.htm
34
See Annex 2. Source: Panteia et al (2014), Contribution to the problem definition in the context of the
preparation of the Impact Assessment regarding the recognition of professional qualifications in inland
navigation, p.10. Figures for 2011. Source Ecorys (2013) updated by Panteia. These employment figures include
the owner-operators, part-time and temporary employment in the IWT freight and passenger transport (excluding
land-based personnel). From the total mentioned, the Commission has deducted the figures related to ES, DK,
LV, SI and CH. It is important to note that these numbers do not include a ‘hidden reserve’ of personnel who
have the necessary sailing licenses, but are not active on a regular basis.
35
Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding
the recognition of professional qualifications in inland navigation, Panteia et al, 2014, p.15.
36
EU Transport in figures 2014, p.25.
37
In particular BE, NL, FR and DE.
38
CCNR, EC, Panteia (2013), Market Observation 2013, p.98.
39
Study on the costs and benefits of the implementation of the European Agreement on working time in inkand
waterway transport – A comparison with the status quo, Ecorys, 2013, p.12.
40
For the Danube corridor, countries concerned are AT, BG, HU, SK and RO. The Rhine countries are BE, CH,
DE, FR and NL. The North-South corridor includes the following river basins: Scheldt, Rhône, Meuse and
Seine. In terms of countries, it includes NL, BE and FR. The East-West corridor includes the following river
basins: Elbe, Weser and Odra. In terms of countries, it includes NL, DE, PL and CZ.
41
Contribution to the problem definition in the context of the preparation of the Impact Assessment regarding
the recognition of professional qualifications in inland navigation, Panteia et al, 2014, p.66.
42
The "hidden reserve" is a capacity reserve which consists of persons with the right qualifications but that are
available for IWT work on an incidental basis only. This concerns for example persons that are of an age older
than 65 years and/or relatives that may provide support in exceptional cases.
43Panteia/PWC(2014),Analysis of the trends and prospects of jobs and working conditions in transport,Annex
23
13.
44
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation: technical
support for an impact assessment, p 28.
45
Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact
Assessment regarding the recognition of professional qualifications in inland navigation, p.53-57.
46
CE Delft (2012),
Medium & Long Term Perspectives of IWT in the EU,
chapters 1, 2 and 3.
47
CE Delft (2012),
Medium & Long Term Perspectives of IWT in the EU
and NVB/Erasmus Universiteit
(2012),
Blue Ports: de onmisbare schakels,
p. 11 Conclusion.
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48
EU Industrial Structure Report 2013, Competing in Global Value Chains, See
http://ec.europa.eu/enterprise/policies/industrial-competitiveness/competitiveness-analysis/eu-industrial-
structure/files/report_euis_2013_final.pdf
49
Panteia/Nea (2015 – forthcoming), Macro analysis of the market potential in the continental cargo market
50
Ecorys et al (2014), Danube+20, Job creation scenarios from a 20% increase of IWT on the Danube by 2020
compared to 2010.
51
HaCon (2014), Rhine-Alp corridor study, p. 17, p.48, p.88-89.
52
NAIADES II Commission staff working document “Greening the fleet: reducing pollutant emissions in inland
waterway transport”, SWD(2013) 324 final
53
As far as the boatmasters are concerned, the focus in this IAR is mainly on the differences between the RNP
and Directive 96/50/EC. This is because the Danube Commission and UNECE do not issue binding legal rules,
and because the national certificates issued by EU member states that fall out of the scope of Directive 96/50/EC
are considered not to affect free navigation in the EU (source: study on the evaluation of the existing legal
framework).
54
Croatia has submitted a request for recognition on 28 November 2013.
55
Other countries like Portugal, United Kingdom, Italy and Luxembourg do not issue certificates in line with
Directive 96/50/EC.
56
Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact
Assessment regarding the recognition of professional qualifications in inland navigation, p.10. Figures for 2011.
57
See
http://www.ccr-zkr.org/12020300-en.html
.
58
See more information on this specific aspect see problem driver 2.
59
As stipulated in the 7th Protocole to the Mannheim Convention.
60
Panteia (2014), Evaluation of the relevant directives related to the initiative on recognition and modernisation
of professional qualifications in inland navigation (Directives 91/672/EEC and 95/50/EC), p.29-30, p.48.
61
Susan Farber,
Expanding the Potential for Competency-Based Models, See
http://www.evolllution.com/
62
See article 7.13 of RNP.
63
For example, the Netherlands grants a reduction of only two years to a seafarer on all its waterways. This is
based on Dutch regulation: Besluit tot goedkeuring examenreglementen en examenprogramma's voor de
binnenvaart 2013
.
Most of the EU countries outside of the Rhine grant a reduction of three years.
64
Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact
Assessment regarding the recognition of professional qualifications in inland navigation, p.10. From the total
mentioned, the Commission has deducted the figures related to ES, DK, LV, SI and CH.
65
Rhine Regulations, UNECE regulation and Sava Commission regulation.
66
See
Platina
competence
table
for
operational
level,
available
under
http://www.platina1.naiades.info/platina/downloads
49
Overview prepared by EDINNA as input for meetings with the Common Expert Group E01036, focused on
recognition and modernisation of professional qualifications in inland navigation. This overview was meant to
support the discussion and to reach an agreement on the relation between the existing functions and professional
qualifications. EDINNA is the educational network of inland waterway navigation schools and training
institutes, see
http://www.edinna.eu
68
CCNR (December 2010), ‘Administrative Arrangement on the Mutual Recognition of Service Record Books,
Strasbourg.
69
Countries that are not part of the interconnected IWT network but already issue boatmasters certificate in line
with Directive 96/50/EC and could therefore more likely consider issuing also other qualifications in line with
EU requirements. Note that if we would also add workers from Portugal, Italy and United Kingdom (2848), it is
a total of 7,136 operational workers, i.e. 27% of the operational workers within the EU, who do not have their
qualification recognised on the Rhine and in other EU member states.
70
and, under certain conditions, to third country nationals.
71
ILO working paper, Living and Working Conditions in Inland Navigation in Europe, December 2013.
72
In December 2015 the bilateral agreements that recognise specific training programmes provided by the
training institutes of Decin (CZ) and CERONAV (RO) should enter into force. In view of the different education
systems, recognition was only made possible thanks to the use of the STCIN and following a relatively long
process. The reference framework allowed the CCNR to indicate the shortcomings in terms of competence and
find an agreement on the adjustments to be made to reach CCNR standards. Both Romania and Czech Republic
emphasised how important such recognition is for the mobility of their workers and the attractiveness of the
profession.
73
Panteia (2014), Recognition and modernisation of professional qualifications in Inland Navigation, Technical
support for an impact assessment, Final report, p.57-58, based on SAB data.
74
See example for the qualification of boatmen in annex 6.
75
CCNR awards the function of Able Boatman after successfully finishing an educational program of three years
in inland navigation, whilst the Dutch authorities award the function of helmsman.
55
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76
Only a list of diplomas delivered by specific training centers all located in CCNR member states are
recognised by the CCNR
77
Germany is however less strict regarding lateral inflow, as it generally requires only six months experience in
inland navigation.
78
i.e. 27 boatmasters and 7 operational workers. Source: Panteia (2014), Recognition and modernisation of
professional qualifications in Inland Navigation, Technical support for an impact assessment, Final report, p.91-
93 based on Nederland Maritiem Land (2012) and Guy Sulpice (2011).
79
Article 8(2) of Directive 96/50/EC, supra note 4; Article 2.05 of the Rhine Patent Regulation, supra note 5.
80
Equivalent to 38,525,854,822 tonne kilometres. Data communicated by Panteia to the Commission on
10/12/2014.
81
Panteia (2014), Recognition and modernisation of professional qualifications in Inland Navigation, Technical
support for an impact assessment, Final report, p.106-107. The assumptions, methodology and calculations
behind KSS figures and a regional breakdown of the costs can be found in pages 100-110 of the report.
82
In total, € 2,613,661 of extra costs are made on the Danube due to pilotage. On the Rhine, this figure equals €
2,990,652. Also the Maritime Seine has got a large contribution to pilotage costs: € 2,058,778 .
83
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, p. 118-119
84
In the aftermath of 2004 EU enlargement, the possibility to recognize non CCNR document was given by the
entry into force in December 2004 of the additional Protocol No. 7 to the Mannheim Convention.
85
CCNR (December 2010), Administrative Arrangement on the Mutual Recognition of Service Record Books,
Strasbourg.
86
Administrative Arrangement concerning a Framework for Cooperation between the Secretariat of the Central
Commission for the Navigation of the Rhine and the Directorate-General for Mobility and Transport of the
European Commission (2013). See
http://ec.europa.eu/transport/modes/inland/doc/2013-05-22-rhine.pdf
87
CESNI (Comité Européen pour l’élaboration des standards pour la navigation intérieure) has been created on 3
July 2015.
88
Commission proposal of 10 September 2013, which aims at repealing Directive 2006/87/EC.
89
Social partners' position on professional qualifications and training standards for crew members on inland
waterways transport vessels, September 2013.
90
Within PLATINA, the European network of nautical schools (EDINNA) is elaborating Standards for Training
and Certification in Inland Navigation (STCIN), similarly to the existing system of Standards for Training and
Certification and Watch keeping for Seafarers (STCW) by the international maritime organisation (IMO).
91
NEA et al (2011), Medium and Long Term Perspectives of IWT in the European Union.
p.21” for
an
estimation of the forecasted IWT performance in the EU up to 2040. It is consistent with the 2013 EU Reference
Scenario (http://ec.europa.eu/transport/media/publications/doc/trends-to-2050-update-2013.pdf)
92
Idem.
93
Regarding boatmasters, the ageing is more significant in BE, FR and DE (with majority that will retire within
10-20 years). As far operational workers are concerned, ageing is an issue for BE and DE but not for FR and NL
that have an age curve below the EU average. Source: CCNR, EC, Panteia (2014), Market Observation 2014,
p.97-98.
94
The demand for workers has been estimated in relation to the total number of vessels (and the amount of cargo
transported) and the manning requirements. Assumptions used to determine the supply of workers are based on
expert judgements from the external consultant.
95
As in the calculations the lateral in/outflow has not been taken into account, it is not possible to exactly predict
how large the gaps exactly are. Furthermore, it must be noted that the “hidden reserve” can be used but is not
integrated in the supply/demand model.
96
Council Directive 2014/112/EU of 19 December 2014 implementing the European Agreement concerning
certain aspects of the organisation of working time in inland waterway transport, concluded by the European
Barge Union (EBU), the European Skippers Organisation (ESO) and the European Transport Workers'
Federation (ETF) Text with EEA relevance , OJ L 367, 23.12.2014, p. 86–95.
97
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, p. 71.
98
NEA et al (2011), Medium and Long Term Perspectives of IWT in the European Union, p.21.
99
Panteia (2014), Recognition and modernisation of professional qualifications in Inland Navigation, Technical
support for an impact assessment, Final report, p.105.
100
With a number of KSS remaining identical.
101
The assumptions, methodology and calculations behind these figures can be found in Panteia (2014),
Recognition and modernisation of professional qualifications in inland navigation : technical support for an
impact assessment, p. 100-110.
56
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102
Though RNP mentions a possible maximum reduction of 3 years under article 7.01. Appendix 1 to the
instructions for the services mentions in practice a maximum of 2 years. See
http://www.ccr-
zkr.org/files/documents/reglementSTF/stf2_122013_fr.pdf
103
Under Directive 96/50/EC, medical check-up is foreseen at minimum every year after 65 years old. Under
RNP every 5 years between 50-65, yearly after 65 years old. Based on a study, a "Dutch proposal" has been put
forward i.e. medical checks at 60, 65 and 70 and thereafter every two years. When the IAR refers to the "new
proposed frequency", it refers to that proposed measure.
104
Measures 5 and 6 are rather to be seen as alternatives as these are two different ways aimed at facilitating
mutual recognition of qualifications. The two measures/instruments target similar population, both in terms of
scope (crew) and voluntary Member States. Analysis of impacts of these measures will therefore be very similar
as shown under section 6. Nevertheless, it should be noted that it is possible that the two measures co-exist in a
limited way. In particular if the sector would opt for measure 6 it is likely that a number of CCNR arrangements
would remain/be needed to cover countries or limited aspects not covered by CTT/CTF. This would of course
add a certain legal and administrative complexity compared to BAU.
105
Directive 2013/55/EU sets the conditions for CTT/CTFs adoption and of their potential scope. CTT/CTFs are
introduced by delegated acts of the Commission. The Directive clearly provides that Member States may, under
certain conditions, opt out of the delegated act. It is not legally possible for a delegated act by the Commission to
deny Member States a right that they enjoy under the Directive itself and which is not conditional upon a
decision of the Commission.
106
Full application of measures 5 and 6 together does not make sense (see footnote 96). For the sake of
simplification they are however integrated in the same option.
107
Susan Farber, Expanding the Potential for Competency-Based Models, See http://www.evolllution.com/
108 Recommendation of the European Parliament and of the Council of 23 April 2008 on the establishment of
the
European Qualifications Framework for lifelong learning, OJ C 111, 6.5.2008.
http://www.eqavet.eu/gns/policy-context/european-vet-initiatives/european-qualifications-framework.aspx.
109
COM(2013) 623 final
110
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, Final report, p. 45-46. Ranging from a decrease of 2 workers in case of
alignment with existing CCNR standards, to an increase of respectively 2-4 and 6-9 workers in case alignment
on Directive 96/50/EC or new frequency.
111
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, Appendix 5 as adjusted by the Commission.
112
Boatmasters still need to prove knowledge of specific situations on the Rhine.
113
657 boatmasters from France + 20 from Croatia - 19 French boatmasters that have a Rhine patent. This results
in 658 boatmasters that have more difficulties to be accepted the Rhine. Note, that French boatmasters are
allowed on the Rhine too if they possess a Directive 96/50/EC license and can prove at least 4 years (720 days
under CCNR system instead of 400 under the French system) of navigation experience.
114
see:
http://www.ccr-zkr.org/12020300-en.html
Putting the issue of KSS apart, all boatmasters have additional
conditions to fulfil with the exception of those from DE.
115
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, p. 45-46
116
Ibidem.
117
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, Appendix 4.
118
Percentage based on figures from CCNR, EC, Panteia (2014), Market observation 2014, p.95.
119
In 2013, STC Group organised exams for 32 applicants at boatman level and for 7 candidates at boatmaster
level. “Onderwijscentrum Binnenvaart” reported that 54 applicants passed the boatman practical exam program
in 2013 and that, for the first half of 2014 they had an average of 8 applicants a month. In June 2014, they also
reported 10 candidates enrolled for the practical exam at boatmaster level
.
120
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, p. 120.
121
Idem, p.115.
122
Idem p.65-67
123
Panteia (2015), Addendum, complementary figures on safety impact in the context of the technical support
for the impact assessment on the recognition of professional qualifications in inland navigation.
124
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, p.74-75.
125
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, Appendix 4.
126
PLATINA 1 D3.8, Strategy for harmonized IWT education and training standards, Annex II (BDB, 2010)
127
European Parliament (2009), Indicators of job quality in the European Union.
57
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128
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment, p. 39-42.
129
Idem, p. 47-49.
130
Idem, p. 58-60.
131
Investment costs are considered as upfront costs necessary to implement a measure.
132
The figures shown in the table as administrative costs for boatmaster practical exam represent average costs
between estimates in case exam has to be carried out on a dedicated training ship that needs to be chartered for a
day or in case the candidate uses his own. Source: Panteia (2015), Addendum, complementary figures to Panteia
(2014), Recognition and modernisation of professional qualifications in inland navigation : technical support for
an impact assessment.
133
The figures shown in the table as administrative costs for boatmaster practical exam represent average costs
between two averages: 1) for the scenario where the MS would opt putting an assessment only through a
theoretical exam and 2) for a combination of both theoretical and practical exams. In each case, several options
including various form of exams have been taken into account. Source: Panteia (2015), Addendum,
complementary figures to Panteia (2014), Recognition and modernisation of professional qualifications in inland
navigation : technical support for an impact assessment.
134
Panteia et al (2014), Contribution to the problem definition in the context of the preparation of the Impact
Assessment regarding the recognition of professional qualifications in inland navigation, p.11.
135
Market observation 2013, CCNR-EC-Panteia, based on Dutch Central Bureau of Statistics, p.102.
136
Panteia (2014), Recognition and modernisation of professional qualifications in inland navigation : technical
support for an impact assessment.
137
Impact on different regions has not been inserted as by its nature it cannot be expressed in one single trend.
138
http://www.eqavet.eu/gns/policy-context/european-vet-initiatives/european-qualifications-framework.aspx
139
The difficulty to specify suitable core indicators for monitoring, in particular to monitor the impacts of the
initiative on labour mobility and the filling of the demand supply gap of IWT workers, should be noted. As
explained in the introduction of section 6 (analysis of impact), this is due to the existing situation where the
availability of specific data for IWT us very limited. Quantitative monitoring is therefore focussed on
measurable outcomes expected to result from the future implementation of the initiative.
58