Besides endorsing the content of the paper that has been co-signed by 22 organizations representing different industries of the logistics chain, FEPORT would like to underline in this paper a number of key items for private terminal operators.
FEPORT members believe that an efficient, sustainable and resilient logistics sector is dependent on a good cooperation between industry parties (B2B) but also on relevant decisions and coordinated actions initiated by EU regulators and broadly enforced by Member States.
We hope that the Estonian presidency’s focus on “digital transport” will anticipate on some of the key topics of the 2018 multimodal year and that the work will hopefully materialize into recommendations to the benefit of the whole logistics chain.
FEPORT is committed to working constructively with the Estonian Presidency as well as European institutions towards real progress on these topics.
Objective of Digitalisation
The objective of digitalisation needs to be to improve the efficiency and reliability of the logistics chain. Therefore, digitalisation should not be viewed as an end in itself, but rather a means to an end, namely greater efficiency and reliability. This should be achieved via enhancing the seamless flow of data across the supply chain and between actors, as well as ensuring that the reporting once principle is implemented.
Interoperability and Open Standards
First and foremost, from our industry perspective, we consider that efforts should be concentrated to facilitate interoperability in the supply chain. Ultimately, this can only be achieved through widespread use of open standards in logistics. Open Standards are a format that allows for the free, widespread sharing of data, prevents lock-in and other artificial barriers to interoperability and are free of any extensions that may hamper interoperability.
With respect to B2G (Business to Government) or B2A (Business to Administration) communications, we would highly recommend that, in line with the Estonian Presidency priorities, the European Commission works towards ensuring that all relevant ICT systems are based upon open standards. This will lead to the various systems communicating within the supply chain to share information without hindrance. It will also remove technical barriers to the reporting once principle, as national systems will be able to re-use data between Member States.
Besides its coordinating role among Member States, the European Commission can, through its agencies such as INEA also support logistics operators, including terminal operators, who are innovating and developing ICT systems to increase their efficiency and incorporate the use of open standards in their ICT systems.
Funding programmes such as Motorways of the Sea should be adapted to have an increased focus on logistics and assist operators interested in incorporating interoperable solutions into their respective operations. Prioritization for such projects will assist in the private sectors transition to widespread use of open standards.
FEPORT relies on the Estonian Presidency to strongly promote the use of open standards in B2G and G2G communication and to invite the Commission to lay the framework for technical and financial programmes which would support the development of interoperable systems by businesses.
The Digital Transport and Logistics Forum should be supported in its current work, especially in regards to interoperability in supply and logistics chains.
Harmonization of Data and Single Windows
There is an urgent need to recognize that harmonisation is a primary objective and that it should work on a maximum data set, given that minimum data sets, and subsequent requests for further data, remove all advantages and benefits of harmonisation. The actual system data is being submitted to, be it a National Single Window or a European Single Window, is secondary.
The Commission’s proposed revision of Directive 2010/65 on Reporting Formalities should act as a catalyst for rethinking the role of Maritime Single Windows as envisaged in the Directive. Single Windows should be part of a larger vision for the entire logistics chain that allow for the re-use of data throughout the logistics chain. Single Windows could work on a push pull basis, with access rights being granted to trusted actors – such as AEO certified operators, which would allow operators to access information of use to their operations.
FEPORT recommends that work on a revision to the Reporting Formalities Directive focuses on true data harmonisation and the creation of a maritime logistics single window.
The logistics sector is a global sector in which data moves not only between Member States, but also between continents. There is a need to ensure that all access points are secure given that the integrity of information is only as secure as its weakest link. Therefore, the EU needs to be adopting a global position to cyber security.
Within the Maritime Safety Committee of the IMO, the issue of cyber security is becoming more prevalent. For instance, there has recently been amendments tabled to include cyber risks as an operational risk within the ISM Code (International Management Code for the Safe Operation of Ships and for Pollution Prevention). Regardless of where this issue of cyber security is addressed within IMO, it is clear that there is a new ambition to address this topic at global level.
FEPORT recommends that IMO’s Maritime Safety Committee ambition to address the issue of cybersecurity is supported by the EU and that the European Commission deploys efforts to make sure that third countries are also mobilized on this issue.
Regarding possible legislative proposals for the wider logistics chain, there is a need for consultation with industry to identify the risks and threats that exist, and what form possible solutions could take