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Region Västra Götaland

VGR

Region Västra Götaland has the responsibility, according to Swedish law, for Regional development in Västra Götaland.

Lobbying Activity

Response to Requirements for Artificial Intelligence

5 Jul 2021

AI has the potential to contribute significantly in several areas such as increased economic growth as well as solutions to environmental and social challenges. There are examples of AI enabling better diagnoses of diseases, reducing traffic accidents, streamlining industrial production, developing new drugs, and shortening red tape. At the same time, the risks of AI need to be considered. It is therefore positive that the proposal uses a risk-based approach to create a structured division between different types of AI systems and its use. As in the reply to the Public Consultation on the White Paper on AI, Region Västra Götaland highlights that the development and the use of AI need to be guided by norms and ethical principles and be based on the principle of human rights. The overall goal should be sustainable AI, meaning that AI applications should be ethical, secure, reliable, and transparent. Ethical and safety considerations cannot be an afterthought in AI applications but must be an integral part of the early design work. The use of AI has the potential to create significant benefits in several areas through increased economic growth as well as solutions to environmental and societal challenges. It is therefore important that there is a balance between the consideration of risk on the one hand and development and innovation on the other. Thus, it is central that the proposal highlights the use of so-called regulatory sandboxes. It is an important part in promoting innovation and streamline regulatory compliance for future AI systems. Test and experimental environments, as well as regulatory sandboxes, are central to the development of reliable AI. For AI to contribute with desired effects, data needs to be made available. It is with the help of large amounts of data that AI can be used, for example, in healthcare diagnoses and contribute to preventive health. A prerequisite is the possibility to share and use data in a secured manner. Furthermore, data needs to be of high quality. In the proposal, parts of the activities under regional responsibility falls under areas of possible high-risk AI applications. It is therefore important that the right conditions are created to ensure that the public administrations have the right tools to make an adequate risk assessment of often complex AI value chains. It is of great importance that the consequences of the proposal for both public and private activities are analysed in detail. The possible increased administrative burden for regions and municipalities also needs to be analysed. Furthermore, digital skills and competences are key factors. A prerequisite for sustainable introduction and application of trusted AI systems is the understanding and commitment to AI development. The need for digital skills is growing but there is simultaneously a shortage of digital skills and excellence in many parts of the EU, for example in Sweden. This is a challenge, not least for the development of AI. The proposal for a new AI regulation can be expected to further increase the need for digital competence in various businesses and industries. Resources need to be invested in skills development in both public and private sectors. Investments in lifelong learning, efforts to attract international talent and improved measures to match the supply and demand in the labour market are needed in the EU. Region Västra Götaland therefore welcomes the European Commission's new coordinated plan on AI. It is important to work strategically on measures for skills supply, digital skills and increased investment, and to make use of the already existing structures at local, regional, national and European level. Regions have long experience of supporting and collaborating with actors in different ecosystems and infrastructures at regional level. These already existing forms of cooperation and ecosystems should be considered in the future work in the field of digitalisation and AI.
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

31 Mar 2021

Ensuring a green and digital transformation The green and digital transformation of the EU is a massive undertaking. The possibility of supporting the digital and green transition in the region through public funding will be crucial to create incentives for change and to include the entire territory in the transition, to ensure that no one is left behind. Region Västra Götaland is in the forefront regarding both digitalisation and electrification and therefore stresses the importance of a legislation which allows for high ambitions regarding technical requirements and allows the region to drive the green transition forward by creating incentives for changed behaviour and patterns. Supporting technological development It is necessary to introduce amendments and updates of the relevant provisions of the GBER in relation to the rules on State aid for broadband infrastructures. Many of our societal challenges depend on support from the ongoing digitalisation. Future-proofed and robust communication solutions increase companies' competitiveness, streamline public operations, and create solutions for a fossil-free society. Region Västra Götaland shares the high ambitions and support the development of the digital infrastructure needed for EU to achieve its goal of becoming a leading force in using the opportunities of digitalisation. To ensure this transformation, Region Västra Götaland highlights the importance of ensuring that all areas and people have access to the best existing technological level of broadband networks. Otherwise residents and businesses in sparsely populated areas risk to be left with old and non-robust technology without the possibility of upgrading to a more modern connection, due to lack of market solutions available. It is of great importance that the definition and interpretation of Next Generation Access (NGA) is updated to keep up with technological developments. Today's interpretation of the NGA means that speeds as low as 30 Mbps can be included. To promote digital transformation only technologies that can handle 1 Gbit/s should be defined as NGA today, and when needed the definition in the regulation should be changed automatically in line with technological developments, to ensure that the EU is on the forefront. Furthermore, it should be clarified that the speeds requirements are symmetrical, i.e. applies to both uploading and downloading. It is obsolete to have lower upload speed requirements than downloading. Symmetric speed requirements have been part of the regional broadband strategy of Region Västra Götaland since 2015. Supporting charging infrastructure for electric vehicles To achieve the goals of the Green Deal a systemic approach is needed for an electrification of the society. A fair and well-developed system is key to drive the transition forward. Regions should be allowed to accelerate the electrification of the transport system throughout the regions, where commercial market solutions are not available. Fast charging infrastructure along the regional road network and in smaller, cities, towns, and sparsely populated areas is key to transform the entire region and not only the big cities and main roads. It is not profitable for operator to invest in areas outside of the cities, consequently public investments are needed to ensure geographical coverage and a fast transformation of the entire transport system. Ensuring public block charging infrastructure in areas with many rental housings is another important focus area, to create incentives for electric vehicles. According to studies made by Region Västra Götaland block charging ventures are not profitable for commercial actors today. Without charging possibilities close to home for people in apartments there will be low incentives for the public to change to an electric vehicle. Hence public support will be needed for both charging points and the distribution grid to promote and drive a fast transformation.
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Response to EU strategy for sustainable textiles

1 Feb 2021

Region Västra Götaland welcomes the high ambitions of the European Green Deal and share the general outline of the commissions view of the textile sector. However, even if the effects of the pandemic have indeed created new challenges, the core challenges persist. The use of primary resources, linear business models and lack of traceability remains clear indicators of a sector with a profound need of modernisation. Region Västra Götaland has been at the centre of Swedish textile production since early industrialisation, and we are presently the most prominent textile cluster in Sweden with triple helix structures for production, design and materials. From our perspective the general direction of the roadmap is positive, but we have some concern regarding the examples used to achieve sustainability and resilience of the EU textile sector. For example: • Targets for reuse and recycling are welcome but can alone at best contribute to extending the linear market model. • Ensuring uptake of secondary raw materials without even stronger corresponding efforts in the design and product development will have a very limited impact In our view circularity is not a waste issue and a circular economy will not emerge even if these targets would be met with a significant margin. Over 80 % of the environmental impact from clothing is in place before reaching the consumer. It is therefore a key factor to focus on production, design and business models. Many major brands have already started the transition and it is of utmost importance that European legislation aim to create a stable base for circular business models and incentivise this shift instead of modifying the linear market model. In this context we propose: • The legislation should prioritise design and product development focused on extending the lifetime of the product and aiming towards circularity and resource efficiency. • The legislation should include all aspects of circularity rather than making minor adjustments of some aspects of linear business models. • Definitions and international standards should be developed for circular design • Traceability should be transparent and relevant data on materials and substances of concern should be accessible for producers, retailers as well as consumers. • The regulation on energy efficiency labelling has been a remarkable success. A similar scheme for textiles could both incentivise producers and improve consumer awareness. • The role of extended producer responsibility should primarily promote prevention of waste and stimulate reuse rather than only focus on collection of waste textiles.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

EU Taxonomy – feedback on Draft Delegated Regulation Region Västra Götaland considers climate mitigation and the transition to a sustainable society as some of the most important challenges of our time. We are working with a multitude of tools out of which some goes significantly further than EU legislation such as set targets for decreasing consumption driven emissions from our citizens, a CO2 budget for the region to stay in line with the targets of the Paris agreement and we are to be a fossil-independent region 2030. In this context Region Västra Götaland is positive towards the Taxonomy as a tool to define and promote sustainable activities and welcomes all proportional and effective ways of achieving long term sustainability. We do however have a few concerns with the current draft proposal: • In its current form, and in the absence of pragmatic usability guidance, the total burden of the Taxonomy structure is too high - in terms of excessively demanding criteria requirements, a non-proportional administrative burden and the non-consideration of regional contexts. This conflicts with the aims of the Delegated Act: to ”ensure usability and proportionality” and to be ”easy for economic operators and investors to use”. • Even if it could be considered motivated for a financial regulation that defines sustainability to have environmental requirements that are stricter than presently implemented legislation the choice of criteria should not contribute to the administrative burden unless if the effect on climate mitigation can be considered substantial and proportional. • We know that new technologies will play an important role in decarbonizing society, but these are not necessarily included in the list. The lack of technology-neutrality introduces a risk to hamper innovation. • Region Västra Götaland is responsible for public transportation within our territory and even if a great majority of travelled kilometers already is zero emission, we do have a significant part of public transportation that is regional and presently cannot be electrified. We are concerned that a definition that lack of technology-neutrality and focus on a single point of measurement (tail pipe emissions) could lower or remove incentives for alternative fuels that from a well to wheel perspective would give a significant GHG savings until viable options for zero emission regional traffic is available.
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Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

15 Dec 2020

Completion of the network The Region Västra Götaland stresses the importance of the designated core network corridors and its strategic importance. The regulation is vital in promoting the free circulation of goods, services and citizens throughout the EU. TEN-T should therefore adhere to the strategic direction adopted in 2013 regarding the completion of the core network by 2030 and the emphasis on cross-border infrastructure. Eliminating bottlenecks should also remain a key objective in the revised regulation. From road to rail The technical requirements in the regulation imposed on the rail networks are not enough to enable moving freight and passenger traffic from road to rail and between sustainable forms of transport. The regulation needs to facilitate the move of a greater part of the transportation of freight from road to rail by strengthening and developing rail infrastructure. Measures to improve the rail competitiveness in comparison with road transport should therefore have high priority in the regulation and special importance should be given to sections where bottlenecks create an obstacle to a move to more sustainable mobility. Generally, single-track sections allow lower line speed, lower frequencies, longer travel time due to waiting times and are less resilient in case of disturbances, which is decreasing rail competitiveness to road transports. Requirements such as double track infrastructure should be included in the requirements for completion in bottleneck sections. The railway infrastructure must also be integrated to other modes of transportation such as maritime transport. A greater focus on the Core Ports is needed as better integrated ports will lead to reduced congestion. This as the freight load is then shared by multiple transportation networks rather than burdening only one mode of transportation. Thus, to make rail more competitive the regulation must focus more on railway capacity standards, bottlenecks and intermodality. Alternative fuels The regulation must also support the fundamental transformation of the road transport system and should to a greater extent includeinnovative solutions that are aligned with the priorities of the Green Deal. The regulation should include a technology neutrality approach by supporting all available technologies with market potential and ensure that the standards are the same across Europe. To allow for this transformation it is of greatest importance that the EU focuses on an accelerated roll-out of charging stations of alternative fuels. A main concern for the development is the interoperability of alternative fuels in an international context; i.e. functioning payment systems. Digitalisation The regulation needs to support the fundamental transformation of the transport system and better use the opportunities of digitalisation. It is in the core network and the major nodes that there are prerequisites for developing and implementing new digitization solutions, such as intermodality. A greater focus on research and innovation on cyber security will be important in order to guarantee safety in an increasingly digitalised and interconnected European transport system. New standards and techniques need to be incorporated into the TEN-T networks as they are established. Resilience The regulation is an important tool to ensure freedom of movement and cross border mobility in the EU. From a regional and local perspective, it is a vital instrument to guarantee a cross border perspective at the national level, which normally tends to prioritise national infrastructure perspectives. The cross-border perspective needs to be given high importance. Diversification of available traffic modes is important to handle a crisis. To be more resilient the regulation also needs a comprehensive infrastructure planning method considering the actual and potential transport flows across regional and national borders.
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