On this page you will find answers to all questions submitted about the EETS Domain Statement Blankenburgverbinding.
Can you send us the estimate for the yearly income of the toll, if applicable including an estimate for the increase of the toll over the years as the A24/Blankenburgverbinding becomes more widely known and accepted?
The prognose of transport data for the A24/Blankenburgverbinding is as follows.
Base case 2015:
- 2025: 20,3 mln (‘60k per day‘)
- 2030: 21,9 mln (‘65k per day‘)
- 2035: 23,6 mln (‘70k per day‘)
Passages 2030 low tariff 91% and high tariff 9%.
Updated base case:
- 2025: 18,4 mln (‘55k per day‘)
- 2030: 20,0 mln (‘60k per day‘)
- 2035: 20,3 mln (‘60k per day‘)
Passages 2030 low tariff 93% en high tariff 7%.
Explanation:
- Forecast MLT 2030 is about 10% lower than WLO High 2030.
- Average WLO Low and High 2040 also results in lower use of the BBV.
- Correction results in slightly fewer vehicles in the high tariff category.
- This prognosis is only an estimate and is subject to uncertain factors. No rights can be derived from it.
You can find business case estimates in this presentation at Ternderned (at 'Documenten', 'Alle documenten'):
20230704 Report (EN and NL) and slides of presentation (EN) regarding Meeting EETS providers regarding Temporary Tolling 15 June 2023.pdf
What is the tariff for crossing the A24/Blankenburgverbinding? Could you also provide us with an estimated average income per truck per year?
- Cars, vans and motorcycles (under 3.500kg): € 1,45 per passage
- Trucks and other vehicles (above 3.500kg): € 8,70 per passage
You can find business case estimates in this presentation at Ternderned (at 'Documenten', 'Alle documenten'):
20230704 Report (EN and NL) and slides of presentation (EN) regarding Meeting EETS providers regarding Temporary Tolling 15 June 2023.pdf
Is the payment term daily after 28 days?
The payment term of 4 weeks starts for each Payment Claim individually (art. 33.3 EETS Domain Statement Blankenburgverbinding).
Are the timelines for bank guarantees not too short?
The timeline for the bank guarantee is mostly aligned with the Belgian kilometer charge scheme and is believed to be market-conform.
Is there a minimum amount for the bank guarantee?
As set out in Annex II to the Commission Implementing Regulation 2020/204, the bank guarantee may not exceed the average monthly toll transaction amount paid by the (E)ETS Provider for this toll domain. Therefore, no minimum bank guarantee is provided, as for small (E)ETS Providers this minimum could potentially be higher than their average monthly toll transaction amount.
Regarding the term for the implementation of changes: the envisaged period of three calendar months may, depending on the requirements, be too short. Other toll chargers may also require changes at the same time. Can this term be adjusted?
The period of three calendar months is market-conform and is the minimum term that will be applied by the toll charger. Moreover, if, in the opinion of the toll charger, a longer period is deemed necessary for the successful completion of the tests, the toll charger will apply a longer term than the three calendar months (art. 16.3 EETS Domain Statement Blankenburgverbinding).
Why are the quarterly reports required?
Quarterly reports are required for all (E)ETS Providers. This is a means to ensure quality and is necessary for accounting purposes.
Toll charges can be collected in various ways, for example by service providers on behalf and in the name of the toll collector. How should the temporary toll collection in this context be understood?
The toll is a retribution for use of the A24/Blankenburgverbinding. The toll charger does not assign road usage rights to (E)ETS Providers, nor do the (E)ETS Providers issue invoices in name of and on behalf of the toll charger. The (E)ETS Provider issues its invoice in its own name, as stated in art. 26.6 of the EETS Domain Statement Blankenburgverbinding.
Is it permitted for the (E)ETS provider to use subcontractors, particularly sales partners, either solely for payment mediation or in the supply chain of road usage rights?
The toll is a retribution for use of the A24/Blankenburgverbinding. The toll charger does not assign road usage rights to (E)ETS-providers, nor do the (E)ETS-providers issue invoices in name of and on behalf of the toll charger. The (E)ETS-provider issues its invoice in its own name, as stated in art. 26.6 of the EETS Domain Statement Blankenburgverbinding.
Is the (E)ETS-Provider allowed to use subcontractors, in particular sales partners, be it in the mere intermediation of payments (see above, a)) or in the supply chain of road use rights (see above, b)?
Both are allowed.
Are there any restrictions regarding the transfer of tolls (or user charges for road usage rights) or their use for debt collateralization?
If and in so far the question pertains to factoring, we can inform you that factoring is indeed permitted.
We assume that the EETS contract can only be terminated by toll charger for good cause. Termination for convenience is only possible by the (E)ETS Provider. Is this understanding, which corresponds to the European requirements, correct?
This understanding is correct.
Is there a timeline available indicating when the accreditation of (E)ETS Providers may start and when you expect the first (E)ETS Providers to begin offering their services?
The indicative timeline is that per 01-01-2024 all (E)ETS providers shall have the opportunity to register for interviews. The accreditation procedure itself can start on 01-02-2024. The start of services of (E)ETS providers can be immediately after the accreditation, but of course not before go-live of the tolling scheme.
Will all (E)ETS Providers go live at the same time?
(E)ETS Providers who are accredited before go live will be able to offer their services from the moment of go-live.
Can an EETS-Provider choose to apply for the A24/Blankenburgverbinding and then for the national GNSS system OR to apply for the national GNSS system first and then the A24/Blankenburgverbinding?
The EETS-directive does not dictate in which EETS domain the (E)ETS-providers must start first. As for the Dutch EETS domains, we will not impose any additional requirements in terms of entry into the Netherlands.
Is it still valid, that (E)ETS-Provider can either choose to apply for the A24/Blankenburg tunnel and then for the national GNSS system OR to apply for the national GNSS system and then need to add A24/Blankenburg tunnel latest 2 years after start as (E)ETS-Provider.
The EETS-directive does not dictate in which EETS domain the EETS providers must start first. As for the Dutch EETS domains, we will not impose any additional requirements in terms of entry into the Netherlands.
Are there any binding deadlines by when an (E)ETS Provider needs to finish the accreditation process?
There is no fixed end date before which the accreditation process must be completed. Of course, in order to provide services as from go-live, proof of accreditation needs to be obtained beforehand.
That being said, the EETS Domain Statement Blankenburgverbinding describes the process regarding the timelines which is high level as follows: the (E)ETS Provider delivers a test planning to the toll charger as part of the service plan and furthermore a detailed test plan as part of the test phase of the accreditation. The (E)ETS Provider and toll charger will together monitor the planning. Maintaining the foreseen timeline is relevant for the qualification whether or not a test is completed successfully.
How many (E)ETS Providers can be accredited by you in parallel, and will you have a First Come, First Serve principle for (E)ETS Providers applying for the Toll Domain?
RDW has the ambition to run the accreditation process for all the candidate (E)ETS Providers in parallel.
When will the A24/Blankenburgverbinding be opened for public?
The current planning is to open the A24/Blankenburgverbinding for public in Q4 2024.
Is it right that there will be only one section to be tolled (4km from entrance to exit of the tunnel)?
Yes, that is correct.
Will the same Main Service Provider be appointed for both the A24/Blankenburgverbinding and the ViA15?
When the ViA15 will be live, the appointed Main Service Provider for the A24/Blankenburgverbinding will also service as Main Service Provider for the EETS domain ViA15. At this moment, the go-live of the ViA15 is not yet determined.
Does the toll apply to all trucks above 3,5 tons? Can you confirm that there is no discount scheme implemented for truck Holders?
Toll charges are based on the maximum permissible weight of the vehicle (article 5 ‘Wet tijdelijke tolheffing A24/Blankenburgverbinding en ViA15’) and apply for national vehicles as well as foreign vehicles. The pricing is further specified in article 2 of the ‘Regeling tijdelijke tolheffing A24/Blankenburgverbinding en ViA15.’ Vehicles with a maximum permissible weight of 3.500 kilograms or more will be charged a fee of € 8,70 per passage. Military vehicles are exempted from toll charges. Furthermore, vehicles from the fire- and police department and certain ambulance services as well as hearses will also qualify for an exemption.
There is no discount scheme for Holders of trucks. Since the A24/Blankenburgverbinding is a different EETS Domain than the future Heavy Goods Vehicle Charge, the Holders of trucks will be exempted from the Heavy Goods Vehicle Charge during their passing of the A24/Blankenburgverbinding (and therefore, no double toll is due).
Is it correct that all EETS Domain Statements for national tolling, the A24/Blankenburgverbinding and VIA15 will be the same?
The EETS Domain Statement for Blankenburgverbinding and ViA15 will be mostly similar, for instance since both EETS-domains concern a toll charger dominant scenario and use the same technology (ANPR). Nevertheless, both EETS Domain Statements will of course be attuned to the different tolled sections.
The EETS Domain Statement for the heavy goods vehicle charge bears similarity to the EETS Domain Statement Blankenburgverbinding and EETS Domain Statement ViA15, but will be attuned to the dynamics of the heavy goods vehicle charge system, namely an EETS provider dominant scenario and the use of DSRC and GNSS technology (on-board equipment).
What is the timeline to find a Main Service Provider for A/24Blankenburg and Via 15 ? Will changes be made to the EETS Domain Statement after the Main Service Provider is awarded?
RDW has already awarded the Main Service Provider earlier in 2023.
While (major) changes to the EETS Domain Statement are not currently foreseen, the toll charger has the right at any time to amend one or more provisions of the EETS Domain Statement, as set out in articles 15 and 16 EETS Domain Statement Blankenburgverbinding.
How will Holders be enforced?
If no Service Agreement has been concluded for a passing vehicle and no payment directly to the toll charger has been made for the passage within a period of 72 hours, a payment reminder will be sent if name and address of the Holder of the vehicle are available. If payment is not made within the period set herein, a fine will be imposed on the Holder of the vehicle.
If the imposed fine is not paid, or if it is not possible to send a payment reminder, the license plate number of the vehicle will be placed on an alert list so that the vehicle can be stopped.
The (E)ETS Provider also offers its functionalities in third-party applications. For example, it is possible to pay for parking via the (E)ETS Provider in the application of a specific bank. Is it also allowed to collect toll fees through this method? The (E)ETS Provider is always clearly mentioned.
(E)ETS Providers are allowed to work with subcontractors and business partners or other third parties as long as all conditions from the EETS Domain Statement Blankenburgverbinding are met. For the sake of completeness, we note that this also includes the fact that a Service Agreement must always be concluded between the Toll Service Provider and the Holder.
If the country code for a license plate cannot be found (for example, due to a input error by the Holder), is it allowed to transmit the license plate without the country code?
It is mandatory to send the country code when registering a new contract for a license plate (Whitelist) or when terminating a contract for a license plate (Blacklist). If this is not present, an error message will be returned after delivery of the message. This can be read in the message specification document.
What is meant by the following sentence: "Changes to the customer list must be delivered to the toll collector immediately”? Is this, for example, within 500 ms?
The (E)ETS provider informs the toll charger through a whitelist/blacklist that it vouches for (or have withdrawn the guarantee for) the payment of passages for a license plate. The exchange of these lists is secured with certificates. The manner in which the (E)ETS provider itself guarantees the payment by the Contracted Holder to the (E)ETS provider (fuel card or otherwise) is at the discretion of the (E)ETS provider.
Receipt of billing data: Does the RDW send photos of license plates or transaction data?
The RDW sends transaction data, in the form of a BillingDetail.
On request of and with the consent of the Contracted Holder, the photos associated with a transaction can be requested.
What is the authorization procedure? Is it real-time authorization or based on batches?
The (E)ETS provider informs the toll charger through a Whitelist/Blacklist that, based on a Service Agreement, it guarantees (or has withdrawn the guarantee for) the payment of passages for a license plate. The exchange of these lists is secured with certificates. The manner in which the (E)ETS provider itself guarantees the payment by the Contracted Holder to the (E)ETS provider (fuel card or otherwise) is at the discretion of the (E)ETS provider.
How do you handle duplicate transactions? This can occur if two (E)ETS providers have the same license plate in their records.
If several Service Agreements have been concluded for the same license plate, the last agreement that came into force will be used. See also Article 8e, second paragraph of the ‘Wet tijdelijke tolheffing Blankenburgverbinding en ViA15'.
Is a separate Service Agreement required between the (E)ETS provider and the Holders for the A24/Blankenburgverbinding, or can this be included in the existing Terms & Conditions of the (E)ETS provider?
A Service Agreement must be concluded between the (E)ETS Provider of and the Holder, the content of which must comply with the provisions of Article 8b, 3 ‘Wet tijdelijke tolheffing Blankenburgverbinding en ViA15’. Also article 26 EETS Domain Statement Blankenburgverbinding is relevant in this respect, where e.g. is stated that the Service Agreement cannot be active before go live. There are no further additional requirements on how the Service Agreement with the Holders should be established.
Will the toll rate for the A24/Blankenburgverbinding also be differentiated based on the CO2 class of vehicles?
As explained in the note from the Minister of Infrastructure and Water Management dated 11 October 2023, no differentiation of the toll rate according to CO2 class is envisaged for the time being.
Will the toll charges be subject to VAT?
No, the toll charges are considered a tax and are thus not subject to VAT.
Are there any estimations regarding the number of potential EETS customers? You previously shared the assumption that 13% of trucks would be foreign. We would like to know how many of the 87% of the local trucks are also driving out of your country.
Estimations are challenging since the Blankenburgverbinding is not yet live. Approximately 10% of the vehicles crossing the Blankenburgverbinding are estimated to be heavy vehicles. The latest estimates were shared on the page: Q&A: EETS Domain Statement Blankenburgverbinding.
While the heavy vehicles in the Netherlands are mostly local (national) trucks, a study which was conducted for the future Heavy Goods Vehicle Charge suggests that around one third of these local trucks regularly cross the border.
In addition to this, we have also published facts and figures regarding the Eurovignette in the Netherlands, which can help to estimate a business case for EETS providers. These facts and figures can be found on page 72 in this presentation at Ternderned (at 'Documenten', 'Alle documenten'):
20230704 Report (EN and NL) and slides of presentation (EN) regarding Meeting EETS providers regarding Temporary Tolling 15 June 2023.pdf
Can the required bank guarantee be substituted with an Escrow account?
The bank guarantee is mandatory for every (E)ETS Provider in the EETS Domain Blankenburgverbinding.
Is our understanding correct that in the future there will be three separate Dutch EETS domains: Blankenburgverbinding, ViA15 and the nation-wide Heavy Goods Vehicle Charge? If you apply for one of these EETS domains, will you also have to apply for the other EETS domains in the Netherlands?
The Blankenburgverbinding, the ViA15 and the nation-wide Heavy Goods Vehicle Charge will indeed be three separate EETS domains. As per Article 5 of the EETS Directive (directive 2019/520), EETS providers are required to conclude contracts covering all EETS domains in a given Member State within the 24 months following the conclusion of the first contract in that Member State. This will also apply to The Netherlands.
Disclaimer
This "Q&A: EETS Domain Statement Blankenburgverbinding" is solely intended to provide clarification or explanation regarding the EETS Domain Statement Blankenburgverbinding and/or its annexes. No legal rights can be derived from this.
The toll charger has reserved the right to group and answer similar or identical questions together, and not to answer the following questions:
- Questions submitted after the submission deadline.
- Questions that go beyond mere clarification or explanation of the EETS Domain Statement Blankenburgverbinding and, for example, are aimed at initiating negotiations.
- Questions for which an interested (candidate) (E)ETS provider indicates or suggests that they should be treated confidentially and are therefore not to be disclosed publicly.
The toll charger’s responses are formulated in both Dutch and English on this website. As with the EETS Domain Statement Blankenburgverbinding itself, Dutch-language answers shall prevail over a translation thereof into any other language.