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Association Européenne des Concessionnaires d'Autoroutes et d'Ouvrages à Péage

ASECAP

ASECAP represents European toll road operators and promotes tolling for sustainable infrastructure finance.

Lobbying Activity

ASECAP Urges Recognition of Road Operations in EU Taxonomy

5 Dec 2025
Topic — The initiative reviews technical screening criteria for the EU environmental taxonomy.
Message — ASECAP requests that motorway operation be classified as a sustainable economic activity. They advocate for simpler biodiversity rules and lower mandatory recycled material thresholds. Finally, they propose a flexible scoring system to replace the current approach.123
Why — Lowering these standards would significantly increase the sustainability alignment of road projects.4
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Meeting with Alexandra Mehnert (Member of the European Parliament)

23 Sept 2025 · Roadworthiness Package

Meeting with François Kalfon (Member of the European Parliament)

12 Jun 2025 · Réseau routier

Meeting with Apostolos Tzitzikostas (Commissioner)

8 Apr 2025 · Exchange of views

ASECAP urges EU to promote toll-based road concessions

7 Mar 2025
Topic — The European Commission is evaluating public procurement and concession contract directives.
Message — The organization calls for a less restrictive definition of operational risk and clear links between project profitability and specific risks. They request a white paper promoting toll-based models and the 'user-pays' principle to secure sustainable road financing. Additionally, they advocate for simplified procedures to reduce administrative costs for long-term infrastructure contracts.123
Why — This would facilitate more toll road projects, increasing business opportunities for private infrastructure operators.4
Impact — Road users could face higher costs as financial responsibility shifts from national governments to drivers.56
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Response to Interim evaluation of the Connecting Europe Facility 2021-2027

23 Sept 2024

ASECAP, the European Association of Operators of Toll Road Infrastructures across 18 member countries representing 124 companies would like to provide feedback to the Connection Europe Facility evaluation. As motorway operators we strongly support the European Commissions orientations focusing on the decarbonization of transports aiming at eliminating CO2 emissions and addressing climate issues. Innovation efforts allow to optimize the efficiency of the network and ASECAP members have been very much committed to implement the ITS-directive. ASECAP fully supports automated driving, believing that connected and automated driving contributes to enhancement of road safety, efficiency to achieve environmental objectives and accessibility, comfort as well as social inclusion to all users. The CEF funding was and is Europes booster to achieve the set goals by the European commission. In the field of ITS, the Arc Atlantique Corridor, Crocodile, MedTIS, NEXT-ITS, X4ITS, NAPCORE and URSA Major Corridor are examples that show the progress made possible by CEF. The development and deployment of new traffic management services, multimodal and cross-network implementations, more detailed real-time travel and traffic information were key to increase traffic safety and efficiency on Europes road-network. Most importantly, through extensive standardization and harmonization efforts, profiles like DATEX II now lay the basis for cross border cooperation and exchange of traffic-information all over Europe. Further, CEF funding allows to deploy harmonised and interoperable technologies boosting innovation first and foremost in the field of C-ITS. The C-ROADS projects accelerated Europes V2X deployments across all sectors putting Europe in the leading position. Already today, the C-ITS ecosystem comprises vehicles, special vehicles, road infrastructure and public transport with vulnerable road users projects (persons, bicycles, scooters) extending the ecosystem as a next step. EU-wide harmonized standards and message specifications are now the base and backbone for future services and users ready to join the C-ITS ecosystem and operate together with existing services. With the electrification of traffic to reach the targeted CO2 emissions reduction, motorways, including TEN-T sectors, will have an important role to distribute the demand of electrical energy. The AFIR program is a significant accelerator to develop the energy infrastructure along Europes road network but will require important investments which could be foster by CEF. All in all, the CEF program is the main booster for the development of future services and infrastructure. Without this incentive, the harmonised deployment achieved on the European network would not have been possible. It has allowed to stabilised data communication protocole, harmonised cross border traffic information services allowing to improve road safety and enhance congestion. Deployment of green alternative fuel on all TENT-T network and above is a priority if we want to achieve net zero carbon by 2090. It will be the same for vision zero fatalities with safe system approach with the deployment of tolls allowing to have forgiving road which will be possible only if the infrastructure is fully digitalised so that there will be enhanced traffic management allowing perfect interaction between vehicles and infrastructure being connected to supply human mistakes and providing strong . CEF funding is a crucial enabler to achieve the set goals for a sustainable future. Tomorrows road operator not just provide safe and secure roads they will have to decarbonise the infrastructure, distribute the energy for future mobility services and provide smart services to increase road safety and efficiency. In order to continue doing it in a harmonised way and to foster it, CEF fundings will be necessary to continue incentives.
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Response to Working Programme of the ITS Directive for the period 2024-2028

25 Aug 2024

ASECAP, European Association of toll road infrastructures operators, would like to make remarks on the following items of the proposed working programme. C-ITS operates on the 5.9 GHz frequency band as regulated in the Commission Implementing Decision 5875-5935. The 5.9 GHz poses a challenge to any radio service, as this band and its adjacent bands constitute a highly complex operating environment that demands highest agility from radio technology and the ability to be compatible with a range of other radio technologies, as well as different life-cycles of radio services. ASECAP believe that any C-ITS service has to be compatible with existing C-ITS services in the 5.9 GHz frequency band, as deployed by ASECAP Members or C-ROADS and the Car2Car Communication Consortium, or other services operated urban rail operators. We furthermore believe that radio services in adjacent bands, such as road tolling or the smart tachograph require protection from radio interference potentially caused by C-ITS radio services. We urge the European Commission to maintain the high performance standards for radio services in the 5.9 GHz frequency band that assure compatibility with radio services in the 5.9 GHz frequency band and with services in adjacent bands such as road tolling or the smart tachograph. ASECAP attaches specific significance to Annex II of the ITS Directive 2010/40/EU, the principles of ITS deployment. The principles highlight that ITS specifications are part of an ecosystem. For this ecosystem we believe that the principles of interoperability; support to backward compatibility; respect existing national infrastructure and network characteristics; support for maturity and respect coherence are of particular importance. C-ITS has to be capable of co-existing with all of them in technical and policy terms. ASECAP welcomes the mapping exercise under point 3.2.1 of the Annex. We urge the European Commission and the EU Member States to consider compatibility with existing radio services in and around the 5.9 GHz frequency band that are affected by C-ITS, namely: 1.) road tolling systems and their enforcement systems fixed and mobile; 2.) the smart tachograph and its fixed and mobile enforcement systems; 3.) fixed satellite systems, as well as 4.) NATO or defense requirements in and around the 5.9 GHz frequency band. ITS is envisioned a coherent ecosystem, this counts for C-ITS in particular, hence we also underline the importance of the principles for specifications and deployment in Annex II of Directive 2010/40/EC. ASECAP believes that data sharing will play an essential part in making ITS work. Data sharing requires a clear governance, ranging from questions on data quality and when high quality is essential, when it matters less, to security and to which data should be shared at which commercial conditions or which data serve the public good and have to be made available at non-commercial conditions. There should be clear rules on how the data will be put at disposal: they will be made accessible by NAP but to ensure LOS and quality of services, data services have to be preferably delivered by infrastructure managers or aggregated organization initiatives (e.g. IDSA International Data Spaces Association) to implement specific services and use cases. Clear rules on who will access the data, authorized and with a legal basis agreement under which cost and data quality requirements will be defined.
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Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

24 Jul 2024

ASECAP, the European Association of Operators of Toll Road Infrastructures, would like to take the opportunity to highlight the following points: - In the Road Transport sector, cybersecurity is of particular importance as the sector is named as Critical Infrastructure by the EU directive 2016/1148, the NIS directive, which has been repealed by the EU directive 2022/2555. Those EU directives mandate member states to legislate cybersecurity aspects of critical infrastructures, including Road Authorities and Intelligent Transport System Service providers and operators. - The objective of the NIS 2 directive is to build security capabilities and ensuring continuity of essential services across the union. ASECAP members enable the transport of goods across the union by providing a network of tollways which are digitally interconnected. The interconnection is multifold: it enables cooperative traffic management, management of crisis through the automatic exchange of control messages, run of a variety of Intelligent Transport Systems, or sharing of similar life-saving platforms in Tunnel Automation Systems. Moreover, each operator is running (eventually) automated systems (NIS 2 Critical Assets) to enable traffic management, implementing life-saving tunnel automation systems, or static monitoring of their assets. - Most of the NIS 2 requirements cover aspects of cybersecurity governance, creating a potential interoperability problem among the technical resources. For this reason, the EU commission started to finance research and innovation actions aimed at cross-sector cyber risk evaluation frameworks and ENISA started studies and published guidance on this regard. - Recently, cybersecurity projects started to stimulate industrial research in key digital areas, such as Collaborative ITS, Traffic Management Plans and Regulations, and situation awareness. Initiatives such as the C-Roads platform, or the NAPCORE project aim at initiating a set of international standards agreed and supported by the operators. - Cybersecurity is a key enabler for those critical sectors who embrace digitalization.
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Meeting with Ciarán Cuffe (Member of the European Parliament)

28 Nov 2023 · Future of Road Safety Transportation event

Response to Evaluation and revision of the Weights and Dimensions Directive

11 Nov 2023

ASECAP European Association of toll motorways, tunnels and bridges operators considers that the policymakers, must first consider the following infrastructural aspects as key elements/inputs for their analyses. Motorways built in Europe are designed to meet the existing standards of weights and dimensions for a long-term perspective going beyond 45 years and even more. The existing motorways network is not designed for the longer and heavier vehicles that the Commission would like to introduce. The change in maximum permissible weights and dimensions, as specified in the draft to revise Directive 96/53/EC, is very far-reaching and requires a detailed consideration of the effects on high-level road infrastructure as follow: 1. The consequence of the planned increase in weight (total weight and higher axle loads) will require recalculation of the structural capacity of all, especially the old bridges. 2. The planned release of a vehicle height of 4.3 m for regular operation is not possible across the entire European road network due to the geometrical conditions on the motorway network. In the area of tunnels, the prescribed minimum clearances cannot be maintained, and the tunnel lighting, exhaust fans and other equipment placed on the ceilings, as well as the ceilings themselves are exposed to a significant risk of being damaged. 3. Negative effects on bridges; bearing structures have to be massively reinforced due to the heavier loads but also to maintain the current safety standard. The acceleration and accentuation of fatigue phenomena on pavements and structures, with repeated passages of stresses at high sized limits, lead to potential long-term degradation that is difficult to estimate. 4. Negative effects on Tunnels; several European countries have territorial characteristics (Alpine regions etc.). Increasing the maximum authorized truck dimensions also increases the fire load (proportionally to the cargo which is carried). This requires massive structural changes to the tunnel cross-sections. For all these reasons, ASECAP has strong reservations about any increase in the maximum weight and the dimensions of heavy goods vehicles in the current state of knowledge. ASECAP highly recommend making deep analysis of impacts first and take into consideration aspects detailed hereafter. An increase in weight (+ 4t) and dimensions (especially height to 4.3 m) has a detrimental impact on existing road infrastructure, road safety and availability and should therefore temporally limited for weight increase and be rejected for height increase from the point of view of ASECAP. In any case, in the course of a temporally increase of the weights and dimensions, compensation measures would have to be demanded that make road freight transport safer overall and appreciate the protection of residents accordingly. The appropriate framework conditions for far-reaching and, if possible, digital enforcement must be established. This applies to on-board systems as well as infrastructure-related systems. A general review of this legislation leading to change the existing maximum weight and dimensions would require massive investments and infrastructural adjustments. The revision of the Directive should include clear provisions to compensate road operators for such cost increase.
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Response to Revision of the specifications for the harmonised provision for an interoperable EU-wide eCall

20 Oct 2023

ASECAP, European Association of tolled road infrastructures, welcomes the possibility to comment on the draft of the Commission Delegated Regulation amending Delegated Regulation (EU) No 305/2013 supplementing Directive 2010/40/EU which has been published for feedback ASECAP would like to highlight the following points. In the context of promoting road safety measures, ASECAP emphasizes the efficient transmission of eCall data to National Access Points (NAPs), emergency organizations and road authorities/operators throughout the value chain. The draft Commission Delegated Regulation, which aims to amend the Delegated Regulation (EU) No 305/2013 on eCall Public Safety Answering Points (PSAPs) and to ensure backward compatibility across generations of mobile networks (including beyond 5G), is a key initiative in this regard. ASECAP's expertise in road safety is invaluable and warrants careful consideration. By prioritizing the seamless flow of eCall data to the relevant stakeholders, we are not only embracing technological progress, but also reaffirming our unwavering commitment to saving lives on the road. It is imperative that these regulations are formulated with precision and clarity, ensuring that they are seamlessly aligned with the overarching goal of promoting a safer road environment for all citizens. Collaboration and data sharing with all road safety stakeholders will be the cornerstone of our collective efforts to achieve this shared vision. About ASECAP: ASECAP is the European Association of Operators of Toll Road Infrastructures across 18 member countries representing 125 companies employing more than 44.000 direct jobs and 200.000 indirect jobs. They operate, maintain, manage a network of 81.700 km with a long-term vision that ensures highest quality standards to make the road infrastructure safest targeting vision zero fatality and moving toward net zero carbon thank to the user/payer principle providing sustainable financing.
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Response to CO2 emission class of heavy-duty vehicles with trailers

30 Jun 2023

ASECAP would like to draw attention on the following points: - The operational implementation of this measure seems particularly complex and its impact highly uncertain. - Yet the clarity and relative simplicity of tariffs are essential to their acceptability. The predictability of these charges does not also seem to be guaranteed, even though it is also an essential element in the effectiveness of any incentive measure, as called for by the reform of the Eurovignette Directive. - The authors of the text state that they have consulted the industry on the draft proposal, which does not seem to have been the case for toll operators / collectors. Indeed, while they rely on the information provided by service providers, it is not clear how that information is read but also they are required to verify this information in order to ensure that the vehicle is paying the right tariff. Information provided via on-board equipment must be verifiable by other means. As the Interoperanbility Directive states, in case of divergency of the vehicle classification the one determined by the toll charger is to prevail (article 8/1). - It is not clear in the text which document is legally valid (or enforceable) to ensure the classification of the trailer, and what will be the means of accessing, consulting and verifying this information. If a trailer weighs more than 750 kg, it will have a vehicle registration document, so by querying the vehicles national register, the motorway companies will be able to collect information from the owner of the vehicle registration document. With the Eucaris system, the process will be the same if, and only if, the States have the same regulations regarding the obligation to hold a vehicle registration document for trailers. And even in this case, the proposed text for the amendment of Annex I of the Directive (UE) 2019/520 identifies as optional the information regarding CO2 classification, efficiency ratios and others. However, it seems unlikely that the vehicles national registerand/or Eucaris will have the information needed to classify trailers in terms of CO2 emissions, at least for the oldest trailers and it is also not clear how can the operators process automatically these new sets of data. - The trailer used must be identified individually and not just by its category, in order to limit the risk of fraud. This means adding the trailer licence plate to the encoded information or equipping it with its own on-board equipment. For toll collectors, this would mean scanning the front and rear plates of the combination to distinguish the tractor from the trailer, provided that this is physically possible, given the length of HGVs with trailers, and without the protection of the canopies traditionally used in the conventional toll system still deployed in many European countries. Also this introduces new processes in the current toll operations that may lead to new problems by reducing current redundencies of the existing information. -Furthermore, the responsibility for determining the right tariff remains with the toll operator / collector, who is the only economic player to ultimately bear the financial consequences. The toll operator / collector must therefore be able to ensure, ideally in real time or, if not possible, in deferred time, that the appropriate reduction is applied. In traditional toll collection, it is extremely complex to read the rear plate because of the length of the vehicle in the toll lane. As a result, it will not be possible to determine the appropriate tariff without extensive adaptation of the current existing toll systems. - Given the volume of transactions to be managed and the absence of automatic and secure devices able to determine the type of trailer, this additional control will necessarily entail significant management costs.Toll operator / collectors will have to be able to apply the lowest reduction if it is not possible to determine & verify the class.
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Response to Cross-border enforcement of road traffic rules

8 May 2023

ASECAP feedback to the revised text for the Cross-border Directive (Directive (EU) 2015/413 ASECAP welcomes the possibility to comment on the proposal of revision of the Directive (EU) 2015/413. ASECAP congratulates all the extensive work already done regarding this text which will certainly make the European legal framework stronger, uniform and respectful for the guiding principles of a common policy. ASECAP as already stated in the past, understands that both the text under revision of the Directive (EU) 2015/413 and the EETS Directive (Directive (EU) 2019/520) share common ground of application (mainly in what concerns with procedural aspects) and difficulties of effectiveness of application, essentially on matters of cross border enforcement. Considering that: i) the problems the revision of the Directive (EU) 2015/413 aims to tackle, namely inadequate investigation to enforce financial penalties (due to issues connected with vehicle registration errors/incompletions and others), inadequate recognition of decisions on financial penalties and in particular the one identified as related to the Directives scope, have common ground both for cross-border enforcement of road traffic rules and on cross-border enforcement of the obligation to pay road fees; ii) the transversal principle of equality and the inherent necessity of elimination of distortions and differences of treatment between Member States and its citizens, it is ASECAP understanding that it would serve such objectives to have a uniformed procedure on the topic of cross-border enforcement. This understanding is reinforced by the similarity between the Directives 2015/413 and 2019/520, in particular its articles 4 (and 4a of the revised text) and 23, respectively. In fact, both apply to deviant conducts carried out on European roads, both have the same liable person, and share the necessity of its correct identification and need for safeguard of such personal data, both share the tool for such procurement (Eucaris). Nonetheless the EETS Directive is not mentioned on the chapter dedicated to the consistency of this Directive with other Union policies or any other chapter. ASECAP understands that the extension of cross-border enforcement procedure could be achieved either through an extension of scope (as previously proposed) or through the determination of applicability of the clauses regarding the Procedure for the exchange of information between Member States to the scope of the Directive 2019/520 therefore ending the impunity of non-resident offenders and ensuring equal treatment of all road users across the Union on both matters. We also identify as a clear advantage the consequence of a broader application the sharing of the cost on IT developments and/or others necessary for the exchange/sharing of information as it would serve a wider application. Likewise ASECAP sees as a clear advantage the possibility to apply to the scope of the EETS Directive on the cross border enforcement topic, the measures introduced on the revised text of the CBE Directive regarding mutual assistance procedure. ASECAP believes that the uniformization of procedures considered the nature and identity of both legal texts would benefit all the parties involved. About ASECAP: ASECAP is the European Association of Operators of Toll Road Infrastructures across 19 member countries representing 128 companies employing more than 44.000 direct jobs and 200.000 indirect jobs. They operate, maintain, manage a network of more than 82.200 km with a long-term vision that ensures highest quality standards to make the road infrastructure safest targeting vision zero fatality and moving toward net zero carbon thank to the user/payer principle providing sustainable financing.
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ASECAP urges EU to include road maintenance in taxonomy

3 May 2023
Topic — The initiative defines environmentally sustainable economic activities for the EU’s green investment classification.
Message — ASECAP requests that road tolling and traffic management be recognized as a substantial contribution to climate mitigation. They also advocate for including road furniture and noise barriers to avoid shortcomings in the taxonomy.123
Why — This would allow road operators to access green finance and avoid disadvantages in public procurement.45
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

10 Dec 2022

ASECAP believes that the European Commission should define sustainable funding mechanisms to implement measures aiming at preserving the environment and biodiversity. Road operators have always been committed to responsible management of the environment, going well beyond the legal requirements they have to comply with. Insertion into the countryside, enhancement of the landscape, preservation of biodiversity have become crucial challenges to which satisfactory solutions have been proposed and adopted (eg, noise fences, noise-reducing road surfaces). Important environmental upgrading programmes aiming to rebuild old networks up to modern environmental standards. The user pay principle has allowed to built a robut road infrastructure network of more than 82 000 Km in Europe. User/polluter/ is not only a mechanism to finance the needed investments on road infrastructure (to build, enlarge and make resilient the EU road network and adapt it to the digitalisation and green evolutions) but it is also a key mechanism to manage the traffic demand, boosting the transition to cleaner, safer, connected and automated vehicles and to place the right incentives to our mobility. ASECAP would like to recall that earmarked tolling has allowed the development of efficient safe road infrastructure with high-level of services, long-term optimization, proper maintenance and investments. These infrastructures achieve the best level of quality, safety and protection of the environment and biodiversity, based on user/polluter/payer principle which is a sustainable financing scheme. The user/polluter/pays principle is the fairest way to finance Infrastructure projects as tax payers no longer have to bear the cost of infrastructure. Public funds are released and can be allocated to other social priorities such as health, education or public transport. Investors can act in long-term liaison between administrations to ensure the pursuit of sustainable goals through long term public-private partnerships. A transparent mechanism with an entity bearing and managing most of the risks, having an economic incentive to ensure that infrastructure, is resilient. This sustainable mechanism can be transferred to future generations in the same or better conditions. It has already been tested by concession models or PPP schemes and should be encouraged in compliance with the regulation. Polluter pay principle is key to ensure sustainable development.Therefore, it is important that EU law in particular continue to promote, extend and enforce polluter pay and thus user pay principle. In this context, it is a pity that the latest version of Eurovignette Directive (2022/362 from 24 February 2022) as adopted is still a missed opportunity, capping road tariffs and related variations in a way which does not allow to really address climate change and does not allow for a genuine polluter pay model. At the same time, we consider that Concession Directive (2014/23) has allowed higher and better harmonised legal framework for a legal model which is key to support user pay and thus polluter pay principles in the financing and management of infrastructure. Since the Concession Directive is under review, we call for stability of this existing framework, rather than reopening a good text. Last but not least, we consider that greening of mobility will not be achieved based on one single solution. While promotion of greener transport mode and greener vehicles is key, while infrastructure should be adapted to such changes and can be as such be more sustainable, "tech" is still the missing piece. ITS which has be key to promote smart and safe mobility is not yet as such focused on greener mobility. As far as possible on going trialogues regarding the revision of Directive 2010/40 should also take this objective into account.
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Response to Creation of the Common European Mobility Data Space

7 Dec 2022

ASECAP, European Association of Toll road infrastructure companies, is convinced that the new digital era based on data will allow to reach the ambitious political goals to foster digitalisation of society. Data sharing to enhance real time information in terms of traffic and services is of high importance for road operators. In view of the consultation, ASECAP would like to raise attention to the fact that provision and access to data should satisfy the following two points: - The control of the quality of the information throughout its production, from the source to the final form in which it is delivered to the user, the traveller, or the carrier of goods. Data exchange should not rely on a single direction but has to be considered for all stakeholders - The homogeneity of the security and information services on all journeys made on the Trans-European transport network. Control of the quality of traffic information: - The quality of information is measured by its ability to improve safety by avoiding accidents and to optimise traffic both for light and heavy vehicles. Traffic safety and optimisation require for information to be qualified and validated, and comply with road operators' management measures when it is produced. Poor quality information might be against the general objectives of safety and traffic flow as well as mobility services. A qualification of the data from the source to the final production must be introduced to check the reliability of the information provided. This requires compliance with rules to be defined throughout the production chain, involving the various stakeholders as well as responsibilities of parties disseminating information. Cyber security: Security of data remains of high importance in order to secure both the infrastructure and the private data from cyber criminal activities. It is essential for the functioning of the tunnel management and safety, for traffic management systems, for instance. A cyber attack can stop the functioning of the safety equipment in a tunnel, stop the red lights, or shut down tolling stations. The production of quality information has a cost that includes the cost of collecting data at the source, processing large amounts of data, creating information adapted to drivers, as well as the media for editing, disseminating, and receiving data. ASECAP would like to recall that the cost must be recognised and acknowledged within an open market for traffic information and mobility services, combining where appropriate at one stage or another in the production chain, both: - a public policy (information paid by the public budget) - a private policy (information paid by the user to allow a return on investment of producers). An obligation to provide information free of charge is a hindrance if the responsibility for its financing is not ensured simultaneously as well as the quality of its dissemination. In conclusion, ASECAP would like to highlight the following points: -New organisational models will be required involving the different stakeholders, the ones providing mobility data and information on services and the ones who will be using them to make business -As road operators, there are sensitive data that require specific processing and cannot be shared without being sure that the data will be used for road safety purposes and to improve mobility solutions -All sectors including automotive industry, telecom operators, traffic information providers should be committed to have the same obligations to provide their mobility data. The obligation should not only be for road operators or public transport organisations. -Requests should be the same for all sectors -There should be clear rules on how the data will be put at disposal -Clear rules on who will access the data -Responsibility of each stakeholder will also need to be defined and clarified -Cyber security remains of high importance -Data protection compliant with GDPR regulation
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Response to Revision of the Intelligent Transport Systems Directive

17 Feb 2022

ASECAP Statment Data sharing to enhance real time information in terms of traffic and services is of high importance for road operators. ASECAP members already provide to their grantor the requested data to enhance road safety. In view of the consultation, ASECAP would like to make the following points: - The control of the quality of the information throughout its production, from the source to the final form in which it is delivered to the user, the traveller, or the carrier of goods. Data exchange should not rely on a single direction but has to be considered for all stakeholders - The homogeneity of the security and information services on all journeys made on the Trans-European transport network. Control of the quality of traffic information: - The quality of information is measured by its ability to improve safety by avoiding accidents and to optimise traffic for all vehicles. The risk of information contrary to the measures taken by road operators must be prevented. - Among the essential information for safety, there is the alert on incident (accidents, breakdown, construction site, object on the road, special weather conditions,...), and alerts on traffic management, such as speed limits, overtaking bans on heavy goods vehicles… Traffic safety and optimisation require qualified and validated information, and to comply with road operators' management measures when it is produced. Poor quality information might be against the general objectives of safety and traffic flow as well as mobility services. A qualification of the data from the source to the final production must be introduced to check the reliability of the information provided. This requires compliance with rules to be defined throughout the production chain, involving the various stakeholders as well as responsibilities of parties disseminating information. The question of financing of the production cost and qualification/ check of traffic & service information: The production of quality information has a cost that includes the cost of collecting data at the source, processing large amounts of data, creating information adapted to drivers, as well as the media for editing, disseminating, and receiving data. National Access Point (NAP) The consultation of the provision of the Delegated regulation supplementing Directive 2010/40/EU is making a specific emphasis on the NAP to foster its deployment by members’ states. ASECAP would like to recall that the cost must be recognised and acknowledged within an open market for traffic information and mobility services, combining where appropriate at one stage or another in the production chain, both: - a public policy (information paid by the public budget) - a private policy (information paid by the user to allow a return on investment of producers). An obligation to provide information free of charge is a hindrance if the responsibility for its financing is not ensured simultaneously as well as the quality of its dissemination. Additionally, the governance of NAPs has to be considered with respect to distributed data collection and provision. - New organisational models will be required involving all stakeholders, the ones providing mobility data and information on services and the ones who will be using them to make business - As road operators, there are sensitive data that require specific processing and cannot be shared without being sure that the data will be used for road safety purposes and to improve mobility solutions - All sectors including automotive industry, telecom operators, traffic information providers should be committed to have the same obligations to provide their mobility data. The obligation should not only be for road operators or public transport o - Requests should be the same for all sectors - There should be clear rules on how the data will be put at disposal - Clear rules on who will access the data - Responsibility of each stakeholder will also need to be defined and clarified
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Response to EU standards for safe and secure parkings

10 Feb 2022

ASECAP Feedback to the EC Consultation on EU standards for safe and secure parking area for trucks The European Commission has launched a consultation on EU standards for safe and secure parking area for trucks through supplementing Regulation (EC) No 561/2006 of the European Parliament and of the Council with regard to the establishment of standards detailing the level of service and security of safe and secure parking areas and to the procedures for their certification. This initiative sets EU standards for safe and secure truck parking areas (SSTPAs). As motorway operators we are strongly supporting appropriate EU legislative measures to move Europe closer to ‘Vision Zero’ fatalities. Road safety is the first priority of toll road operators. This initiative sets EU standards for safe and secure truck parking areas (SSTPAs) based on four levels of security, a common level of service and certification procedures and builds on the work of the 2019 Commission study on SSTPAs. This classification will allow to better define level of services offered in the different service area. ASECAP would like to take the opportunity of this consultation to recommend that the criteria for minimum level of service for power supply as mentioned in annex 1 remains an optional criteria or target only gold or platinum level. Indeed, the establishment of these facilities will lead to high financial expenses, especially on existing parking areas where they were not foreseen when they have been constructed. In some ASECAP members network, resting areas are equipped with electric power facilities for refrigerated road transport vehicles, but the demand is close to zero. Most of the drivers prefer cargo cooling by fuel aggregate rather than electric power. Building those facilities also requires an electric transformer station. Because of the low demand of electric cargo cooling, it will be important to raise the question of their necessity since they are barely used. Therefore, it will not make sense to make huge investments which will need to be compensated to the road operators. Further, the new proposal of the EC guidelines for the development of the TEN-T includes “safe and secure parking areas is considering to deploy secure parking available at a maximum distance of 100 km from each other,…” by 31 December 2040. By that deadline, ASECAP members are assuming that a wide part of road transport will already be almost electrified. Therefore, it could be wise that synergies could be used for cargo cooling. ASECAP is also recommending that a more precision and definition could be added for the terms “Perimeter” and “Parking area” in the annexes.
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Response to Maximum dimensions and weights in national and international traffic for certain road vehicles circulating within Union

2 Feb 2022

ASECAP, European Association of toll motorways, tunnels and bridges operators and their members toll road infrastructure Companies welcome the initiative of codification of the provisions on maximum weight and dimensions in traffic but would like to make some observations and comments. The ASECAP and its members think that this proposal for a Directive should be limited to codification work and does not make any changes as regards the provisions relating to the maximum weight and the dimensions of heavy goods vehicles. An increase in the maximum weight and the dimensions of heavy goods vehicles would have a direct and significant impact on the infrastructure of the motorway network and may have also impact on road safety. Motorway built in Europe are designed to meet the existing standards of weights and dimension. They are not designed for longer and heavier vehicles. The basis for national and European regulations and therefore also for the infrastructure planning and building is Directive 96/53/EC which sets out the maximum allowable vehicle loading dimensions in national and international road transport in the EU. Any further increase in the maximum weight and the dimensions of heavy goods vehicles would lead to several problematic pitfalls, including: 1. Negative effects on bridges. Bearing structure have to be massively reinforced due to the higher loads but also to maintain the current safety standard. The acceleration and accentuation of fatigue phenomena on pavements and structures, with repeated passage of stresses at high sized limits, lead to potential long-term degradation that is difficult to estimate. 2. Negative effect on tunnels. Several European countries have territorial characteristics (Alpine regions etc..) that consequently lead to remarkably high proportion of tunnels. Increasing the maximum authorized truck dimension also increasing high risk of fires (proportionally to the cargo which is carried). This requires massive structural changes to the tunnel not sized for mega truck. The safety installations and the estimation of the potential for danger would thus have to be completely reassessed. 3. This would increase road safety risks, by increasing visibility problems for other users, in particular in insertion curves and ramps, or by masking signs, and would limit the possibilities of drawdown and insertion. 4. The psychological impact to light vehicles’ drivers behavior should not be underestimated. 5. Access/capacity limit to rest areas and parking lots: as it is mandatory to conform to driving periods and rest obligations, the increase of the maximum weight and the dimensions of heavy goods vehicles would cause serious difficulties in terms of secure parking capacity. 6. Difficulties on links between primary and secondary roads (ie,: junctions, roundabouts), applicable regulation and parameters for road constructions refer to “standard vehicles” which are currently in use. For all these reasons, ASECAP has strong reservations about any increase in the maximum weight and the dimensions of heavy goods vehicles in the current state of knowledge. ASECAP is the European Association of Operators of Toll Road Infrastructures across 20 member countries representing 135 companies employing more than 50.000 direct jobs and 200.000 indirect jobs. They operate, maintain, manage a network of more than 86.000 km with a long-term vision that ensures highest quality standards to make the road infrastructure safest thank to the user/payer principle providing sustainable financing. ASECAP members are shouldering their responsibility as mobility providers linking inter-urban and metropolitan areas, playing a major role by moving people for their daily trips to go to work, schools, hospital....
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Response to Revision of the specifications for EU-wide real-time traffic information services (Delegated Regulation 2015/962)

9 Nov 2021

Data sharing to enhance real time information in term of traffic, services is of high importance for road operators. ASECAP members provide to their grantor the requested data to enhance road safety. Additional data aiming at improving citizens experiences as well as information on alternative fuel location are of high importance too. In view of the consultation, ASECAP would like to raise attention to the fact that furniture and access to data should satisfy the following two points: - The control of the quality of the information throughout its production, from the source to the final form in which it is delivered to the user, the traveller, or the carrier of goods. - The homogeneity of the security and information services on all journeys made on the Trans-European transport network. - Control of the quality of traffic information: - The quality of information is measured by its ability to improve safety by avoiding accidents and to optimise traffic both for light and heavy vehicles. The risk of information contrary to the measures taken by road operators must be prevented. - Among the essential information for safety, there is the alert on incident (accidents, breakdown, construction site, object on the road, special weather conditions,...), and alerts on traffic management, such as speed limits, overtaking bans on heavy goods vehicles….. - Essential information for network optimisation includes calculations of real times travel time in congestion situations, route management measures that are adapted to the capacities of road networks and considering the time needed to return to normal after an accident situation…. - To foster the use of clean vehicles, customers may have all relevant and right information Traffic safety and optimization require that information be qualified and comply with road operators' management measures when it is produced. Poor quality information might be against the general objectives of safety and traffic flow as well as mobility services. A qualification of the data from the source to the final production must be introduced to check the reliability of the information provided. This requires compliance with rules to be defined throughout the production chain, involving the various stakeholders as well as responsibilities of parties disseminating information. The question of the production cost and qualification/ check of traffic & service information: The production of quality information has a cost that includes the cost of collecting data at the source, processing large amounts of data, creating information adapted to drivers, as well as the media for editing, disseminating, and receiving data. National Access Point (NAP) The consultation of the provision of the Delegated regulation supplementing Directive 2010/40/EU is making a specific emphasis on the NAP to foster its deployment by members states. ASECAP would like to recall that the cost must be recognised within an open market for traffic information and mobility services, combining where appropriate at one stage or another in the production chain, both: - a public policy (information paid by the public budget) - a private policy (information paid by the user to allow a return on investment of producers). An obligation to provide free of charge is a hindrance if the responsibility for its financing is not ensured simultaneously In conclusion, ASECAP would like to highlight the following points: - New organisational models will be required involving the different stakeholders the one providing mobility data and information on services and the ones who will be using them to make business - As road operators, there are sensitive data that require specific processing and cannot be shared - There should be clear rules on how the data will be put at disposal - Clear rules on who will access data - - Responsibility of each stakeholder will also need to be defined and clarified
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

20 Apr 2021 · Sustainable and smart mobility policy orientation with a focus on road safety action plan, ITS and TEN-T revision proposals.

Meeting with Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

20 Apr 2021 · transport

Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

16 Dec 2020

ASECAP is glad for the opportunity to express its views on the proposed Inception Impact Assessment document and provide some recommendations. ▪ We strongly agree on the 3 main problems identified in the paper: i) the insufficient effectiveness of TEN-T to stimulate zero and low emission transport; ii) the lack of preparedness of the TEN-T for the digital transition in transport; iii) the insufficient resilience of the TEN-T infrastructure. ▪ We also agree on most of the measures proposed to face these problems, however, the text does not take into account the funding mechanisms needed to implement those measures and reach the desired goals. ▪ Important investments are still needed to offer a safe, reliable, multimodal and sustainable transportation system, especially in periurban and urban growing areas. ▪ We believe that the source of funding should be sustainable in time, and as such it should be encouraged (to not burden future generations with debt repayments) and ideally come from road users, that benefit from the infrastructure and generate externalities. ▪ Tolling/charging is not only a mechanism to finance the needed investments on road infrastructure (to build, enlarge and make resilient the EU road network and adapt it to the digitalisation and green evolutions) but it is also a key mechanism to manage the traffic demand, boosting the transition to cleaner, safer, connected and automated vehicles and to place the right incentives to our mobility. ▪ Provisions related to CO2 emission class with reduction charging and possibly free charging for the electrical vehicle have to ensure that the relevant part of the cost allocated to this vehicle (the infrastructure costs) are covered. It will not solve traffic congestion nor remove cars or truck from the road. Lower toll rates for electric vehicles can be applied on high density area and can be part of an integrated urban pricing policy including new elements easing sustainable accesses to cities: managed lanes, high occupancy vehicles lanes, dissuasive parking, carpooling, bus rapid transit, etc. • We are convinced that the development of a sustainable Trans-European Transport Network (TEN-T) should considerer the mobility chain and the associated services in their entirety linking territories and answering to urban mobility needs. • We would like to recall that earmarked tolling has allowed the development of efficient safe road infrastructure with high-level of services, long-term optimization, proper maintenance and investments. These infrastructures achieve the best level of quality, safety and protection of the environment and biodiversity, based on user/payer principle which is a sustainable financing scheme. • More investments for mobility are needed as European cities are increasing in size and the population. Time for commuting, congestion, air pollution and noise are increasing everywhere in Europe. To face those challenges, toll road infrastructure operators are ready to invest to boost new mobility schemes and contribute to decarbonization of road transport to reach the target of carbon-free emission by 2050. Investors can act in long-term liaison between administrations to ensure the pursuit of sustainable goals through long term public-private partnerships. A transparent mechanism with an entity bearing and managing most of the risks, having an economic incentive to ensure that infrastructure, is resilient. This sustainable mechanism can be transferred to future generations in the same or better conditions. It has already been tested by concession models public or private and should be encouraged in compliance with the regulation.
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Response to Revision of the Intelligent Transport Systems Directive

18 Nov 2020

On October 8th, the European Commission has launched a consultation in the provision of the ITS Directive revision focusing on the impact assessment. ASECAP members have been very much committed to implement the ITS Directive and would like to take the opportunity of this consultation to submit some comments and suggestions. For more than two decades, motorway companies have been strongly involved in ITS, simply because our prime objective as toll motorway operators has always been to provide our customers the best mobility service, consisting in a safe, comfortable and uncongested travel on the motorways we operate. Continuous investments have enabled the deployment of services matching the evolution of mobility and minimising the impact of the infrastructure on the environment : real time traffic information services, on board devices (application on smartphones, VMS.), travel time, dynamic speed limit regulation adjusting, in real time, speed according to traffic density traffic, hard shoulder running, dedicated lane for bus, car sharing. European wide interoperable ETC system, etc.). These are few examples which are now common to all drivers. ASECAP members have been strongly involved in ITS deployment projects in CEF corridor with support of European funding allowing to have a common platform to exchanges knowledges and experiences (EASYWAY, EU EIP platform). Common deployment guidelines have been issues and a common data exchange with DATEX 2 standard allowing robust cross border cooperation between road operators allowing cross border traffic management plan. Important achievement has been made and should be recognized. ASECAP members will continue their commitment to reach vision Zero accident and congestion free urban network. In vue of the consultation, ASECAP would like to raise the following recommendations: • New organisational models will be required involving the different stakeholders providing mobility services by adapting the road infrastructure to multimodal mobility options connected to other transport mode operated by metropolitan transport organisation • A common European framework will have to be implemented for the definition and development of new traffic management concepts, which will have to be based on European services homogeneity and interoperability. In this respect, common standards will have to be developed and implemented; and clear and stable legal framework will have to be established. European Commission should create a clear regulatory framework that assures that the current C-ITS installations as well as V2I connectivity will be able to communicate with future solutions and that all C-ITS stations will be interoperable with each other. • Encourage large-scale testing and deployment in a harmonised way. • Enhance quality and performance of communication network. • Interference free - coexistence with ITS safety related applications and road charging. • Data -sharing, security, crucial aspects behind the deployment of digitalization. • Develop standards in full coherence of the principle of technological neutrality & and proven efficiency. • The existing infrastructures will require to be upgraded, adapted & modernized. For this purpose, a specific framework to compensate to the existing road operators for these new investments should be defined. • User/pay principle with earmarked tolling allows the development of an efficient safe road infrastructure with high-level of services, long-term optimization, proper maintenance and investments without public budget. The European Commission should consider the roll-out of electronic road charging for the revision of the ITS directive: to have clear standards and specifications to ease the market-entry of new technologies whilst preventing fragmentation; to leave the market decide on technical solutions while integrating the interoperability and compatibility aspects.
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Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

7 Feb 2019

ASECAP represents European Road Operators and maintains 50,000km of toll-roads. Road Operators are responsible for road maintenance, road safety and traffic flow on significant parts of Europe’s motorways. ASECAP members deploy cooperative ITS (C-ITS) to improve road safety and traffic efficiency. ASECAP members want to make sure that C-ITS and electronic road charging systems can co-exist without harmful radio interference. ASECAP will observe updates so that the Delegated Act, even in future, assures that coexistence. ASECAP members are technology neutral regarding C-ITS as far as investments are safeguarded, as well as the coherence with markets developments. They therefore welcome the review mechanism in the Delegated Act. It assures a fast track mechanism into the C-ITS framework for new and mature technologies that must follow the same standardization process and guarantee backwards compatibility. The Delegated Act gives a clear guidance on interoperability so that the evolution of C-ITS is possible. Innovation of new C-ITS services for automated driving requires a stable C-ITS communication environment which the Delegated Act provides. Link: ASECAP Position Paper on the C-ITS Delegated Act: http://asecap.com/official-positions.html?download=335:asecap-position-on-the-c-its-delegated-act
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Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

3 Oct 2018 · Road safety

Meeting with Alisa Tiganj (Cabinet of Commissioner Violeta Bulc)

15 Mar 2018 · interview

Meeting with Alisa Tiganj (Cabinet of Commissioner Violeta Bulc)

15 Dec 2017 · road safety

Meeting with Bodo Lehmann (Digital Economy)

18 Oct 2016 · connected and automated driving

Meeting with Bodo Lehmann (Digital Economy)

18 Oct 2016 · connected and automated driving

Meeting with Henrik Hololei (Director-General Mobility and Transport)

25 Jan 2016 · Regional European Electronic Toll Service (REETS)

Meeting with Violeta Bulc (Commissioner) and

14 Apr 2015 · Meeting Commissioner Bulc