NSBS (National Association of Bulgarian Freight Forwarders) made its own additional calculations and analysis for the amount of tolls for trucks and the accompanying economic changes. NSBS believes that, given that tolls are an element of public finances, to consider the possibility of tolls for heavy goods vehicles being lower than the envisaged 60% of the rate recommended by the state, and when the model works and is mastered by transport operators, forwarders and end users, to consider possible opportunities for increase.
In connection with the upcoming adoption of the amount of toll fees for trucks and the accompanying economic changes, the National Association of Bulgarian Freight Forwarders (NSBS) expresses the following opinion:
A World Bank report from October 2015 entitled Developing a Strategy and Business Model for the Implementation of the European Electronic Road Toll Service (EETS) Electronic Delivery System and Financial Planning shows that there are three scenarios to determine the amount of tolls, which are based on rates recommended by the state.
Scenario 1: an average of BGN 0.20 per km. (100% of recommended rate)
Scenario 2: an average of BGN 0.12 per km. (60% of the recommended rate)
Scenario 3: an average of BGN 0.26 per km. (130% of the recommended rate)
The report also states: Depending on the chosen scenario, however, annual revenues would vary between BGN 661 million and BGN 1,483 million from 2018 onwards. So in almost all cases, the system will break even within the first year.
In the report, it is striking that the analysis of the return on investment in the toll system and the played out possible scenarios, incl. and combinations between the rates and categories of roads for cars and trucks, are specifically targeted with a view to achieving a previously set financial goal, namely collecting additional revenues in the amount of BGN 400 million per year, without assessing how this additional financial burden would affect the business and inevitably the end user.
From the portal of the Council of Ministers in its part for public discussions, it is clear that according to the proposed Draft Decree of the Council of Ministers amending and supplementing the Regulations for the implementation of the Law on Roads, adopted by Decree No. 245 of the Council of Ministers of 2000 (published ., SG No. 98 of 2000) not a single statement, opinion, or proposal has been received from the business side. We assume that the release information of this project was not well publicized.
NSBS made its own additional calculations and analyses, which we present briefly below.
At the moment, for a truck over 12 tons and emission class EURO III, IV, V, EEV and higher, the monthly vignette fee is BGN 134. Under the proposed toll tax rates, the value of the current vignette fee would be distributed as kilometers on highways and category I and II roads as follows:
As can be seen from the table, choosing a scenario of 130% of the state recommended rates, a truck will be able to cover the distance of 515 km. (this is a one-way Kyustendil-Varna course) of the value of the current monthly vignette.
The table below shows the price parameters and the increase for carriers (in times) for the different options:
If the average scenario of 100% is accepted, the situation will be the worst for domestic carriers that travel only on the territory of Bulgaria and have an older vehicle fleet. With them, the cost of tolls will increase more than tenfold. An additional financial burden for carriers will be the purchase of on-board devices for charging the distance traveled, as well as the hardware and software support of these devices. The increase thus formed, according to all the laws of the market economy, should be paid by the end user of the transported goods. Otherwise, the burden on the carrier becomes overwhelming and a wave of bankruptcies of small and medium-sized companies in the industry will follow.
Our predictions are that the larger companies will hold this financial burden for a short period of time, eventually going bankrupt or monopolising the market. In any case, the final result will be detrimental, both for the competition in the market and for the final consumers of goods, as we foresee an increase in inflation in the country. As an additional negative effect on the entire economy of the country, we predict a sharp decrease in the competitiveness of Bulgarian goods, given the increase in their cost price after including transport costs.
We would like to point out that the average toll fee in the Federal Republic of Germany amounts to EUR 0.182 per km. It should be borne in mind that no toll is collected for the use of a large part of the road infrastructure, and only vehicles with a total weight of more than 7.5 tons pay a toll. At the same time, the amount of GDP per capita according to Eurostat data for 2018 in Germany amounts to 35,900 euros, and in Bulgaria - approximately 6,500 euros. Following the path of economic logic, the amount of the road tax in Bulgaria should be in proportion to the GDP per capita and, based on the German indicators, it should amount to an average of BGN 0.065 per km.
The official letter of NSBS can be seen here.
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