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LOHR INDUSTRIE

LOHR est un groupe privé français, spécialiste mondial depuis plus de 50 ans dans la conception, la fabrication et la commercialisation de systèmes de transports de biens.

Lobbying Activity

Response to Revision of Combined Transport Directive

2 Feb 2024

Combined transport has played a pivotal role in the development of rail freight volumes over the past 30 years. However, the untapped potential for Combined Transport remains massive. If done properly, updating the CT Directive can definitely help unleash this potential, thereby achieving modal shift. We therefore welcome the overall aims of the proposed directive and the toolbox of measures which are designed to promote the further development of CT across the EU. Measures like the week-end-driving is welcome even though its impact will probably be limited. It is already in force in some Member States and did not lead to major modal shift. The retention of Article 4 allowing for cabotage operations will be more impactful but not sufficient in itself. However, parts of the Commission proposal must be improved on 3 aspects: 1.Article 1c.2a foresees that a combined transport operation shall meet the following conditions: (a) except for operations referred to in point (b), the operation produces at least 40% less external costs than the alternative unimodal road transport operation. It is important that current Combined Transport operations be protected in any revision to the directive to avoid ineligibility of some flows, which would give rise to a reverse modal shift. The overall gap of 40% of reduction of external costs will be increasingly difficult, if not impossible, to achieve in the near future. A blending with distance thresholds should be envisaged that would still favor long distance transport for non-road modes and in particular rail as the most environmental-friendly mode.2.ISO6346 refers to the identification and marking of containers and EN13044 refers to the identification and marking of swap bodies and semi-trailers. These standards are applicable to containers, swapbodies and craneable semi-trailers. However, the vast majority of semi-trailers used in the road market do not conform to these standards. This has given rise to the development of systems such as Horizontal Loading or Loading Baskets, which allow the transportation of unmarked, uncodified semi-trailers. By promoting the use of these technologies, Lohr has been able to grow the CT market and achieve modal shift to rail, and we therefore fail to understand why the application of these standards will become mandatory. Rather than opening the market to more potential customers, this requirement will act as a new barrier to entry. We support the application of EN13044-1 to intermodal units, to allow the identification of all semi-trailers used in CT traffic but by a set deadline, given that the vast majority of non-craneable units are currently not identified. However, the imposition of EN13044-3 to all semi-trailers potentially used in CT operations would be counterproductive and will act as a new barrier to entry, and is therefore inacceptable to Lohr industrie.3.Part II of the Annex lists support measures to increase the upgrade or uptake of technologies improving the efficiency of intermodal transport operations. Out of 7 examples of measures, 3 aim at promoting craneabiliy of semi-trailers (paragraphs (b), (c) and g)). No measure is listed to actually handle non-craneable rolling stock which constitutes the vast majority of the semi-trailer fleet. Bearing in mind that craneable semi-trailers account for just 10% of the market, such a list of examples would have a negative impact on the road fleet and industrial companies that have invested in research and development of horizontal technologies. A focus on terminals with vertical technology is therefore discriminatory and unacceptable to Lohr industrie. We suggest to add further examples in the Annex to promote horizontal transshipment: reinforcing the aid for acquiring rolling stock and terminals adapted to non-craneable semi-trailers and reducing track access charges for rail rolling stock able to to sustain combined transport traffic even when the wind is strong.
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Response to Evaluation and revision of the Weights and Dimensions Directive

21 Feb 2022

Every year in Europe more than 270 000 semi-trailers have been transferred from road to rail thanks to the MODALOHR system. This corresponds to a saving of more than 245 million kilometres of road journeys. The European Commission is planning to amend the Weights and Dimensions Directives, and in particular to increase the authorised length of semi-trailers from 13.6m to 14.92m or even 15.25m. The undeniable advantages in economic, energy, environmental and societal terms for the road will probably lead to a generalisation of these dimensions in the road fleet within the next 5 years (average renewal cycle for semi-trailers). BUT BEWARE OF THE DANGER OF DEATH FOR COMBINED RAIL AND ROAD TRANSPORT! THE INCREASE IN LENGTH MUST NOT BE ACHIEVED WITHOUT 100% OF THE SEMITRAILER FLEET REMAINING COMPATIBLE WITH A MODAL SHIFT. Creating a new "intermodal unit" standard like the current "cranable" semi-trailers, incorporating these provisions and restrictions, is not a solution either. This would restrict the fleet eligible for modal shift, especially as these units would not be competitive on the road, which will account for more than 80% of the kilometres travelled even in the medium term. There is currently no technical solution available for a wagon that is compatible with the new lengths and, above all, without performance restrictions for the semi-trailer. These "new" wagons, even if they existed, would only replace the existing fleet after one or more decades, with massive costs. The existing rolling motorway fleet would be good for scrap, the terminals would have to be redesigned or even dismantled. Worth reminding: Each journey of a semi-trailer on a combined transport train brings an economic, energy, environmental and societal advantage considerably greater than that brought by the extra length on the road for the same journey. Every year in Europe more than 270 000 semi-trailers have been transferred from road to rail thanks to the MODALOHR system. This corresponds to a saving of more than 245 million kilometres of road journeys.
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