Sustainability-of-national-road-funding_2022.pdf

24th Jun 2026

Sustainability of national
road funding
Can existing national roads be repaired and
maintained to the desired standard and new roads
be built within the agreed timeframe when funding
is decreasing?

Report of the National Audit
Office to the Riigikogu , Tallinn, 12
September 2022

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 1
Sustainability of national road
funding
Can existing national roads be repaired and maintained to the
desired standard and new roads be built within the agreed
timeframe when funding is decreasing?
Summary of audit results
With decreasing funding, not all the objectives set for the
maintenance and development of national roads can be met. In a
situation where there is not enough money to meet the targets, the
Ministry of Economic Affairs and Communications (MEAC) must set
pr iorities that correspond to available funding or propose additional
funding options for road maintenance.
Figure. Approved funding for road maintenance and funding needs presented in the road
maintenance plan, € million

Source: National Audit Office on the basis of road maintenance plans 1
The decrease in funding for road maintenance increases the risk that
existing roads cannot be repaired and maintained to the extent that
road quality and road safety do not deteriorate in the near future.
The roughness of roads has improved steadily over the past decade, with
the biggest improvements on main roads, which have been reconstructed
and built using EU funds. In the years to come, the funds allocated in the
budget are significantly smaller than is needed to m aintain the roads in
their current state. This increases the risk that road quality will start to
deteriorate.
It is not realistic to complete the Trans -European Transport Network
(TEN -T) by the agreed deadline. Estonia has made a commitment to the
European Union to upgrade the roads of the European core road network
1 The years 2022 –2025 are given on the basis of the financial plan of the Road
Maintenance Plan 2022 –2025, excluding VAT. The National Audit Office added 20%
VAT to create a better comparison. The funding needs are presented in the last approved
or 2021 –2030 RMP.

Sustainability of national road funding
2 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
to the requirements of the TEN -T Regulation by 2030. The Government
of the Republic of Estonia wants to finance the development of roads
only with the support of European Union funds, but the money allocated
to Estonia for the construction of roads is not enough to meet its
commitments.
As funding is decreasing and prices are rising, the MEAC and the
Government of the Republic must decide on the priorities of road
maintenance. The national strategy documents set out a number of
objectives for maintaining and developing the quality of national roads
and improving road safety, but there is not enough money to meet these
objectives and no long -term plan to secure funding. In a situ ation where
funding is decreasing and construction prices are soaring, it is necessary
to step up control over ri sing costs, ensure a transparent selection of sites
and decide which investments to make and in what order.
Recommendation of the National Audit Office to the Minister of Economic
Affairs and Infrastructure:
■ Identify the financing opportunities (including long -term) and needs
for public roads in conjunction with rail development plans, taking
into account the current situation, and then set priorities that
correspond to the opportunities.
Response of the Minister of Economic Affairs and Infrastructure:
According to the minister, different financing options have been mapped
out in the road maintenance plan for national roads and the action plan for
the development of public railway infrastructure. The priorities and
objectives for both rail and road maint enance are reflected in the
Transport Competitiveness and Mobility Programme and correspond to
the possibilities of the state budget strategy. The minister confirmed that
both long -term loans and the use of the public -private partnership model
have been an alysed and proposals have been made to the Government of
the Republic.

Main recommendations

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 3
Contents
Overview of the sector 4
Strategic framework for road development and preservation 5
As funding is decreasing and prices are rising, the state must decide on the priorities of road maintenance 7
The strategy papers set a number of objectives for the condition of national roads, but
there are problems in achieving them 7
Achieving the condition and development goals of national roads with the agreed funding is
impossible 11
There are no plans to use non -state budget funds to meet the TEN -T road development
commitments 16
The methodology for selecting road maintenance projects is in place, but selection has not been
transparent 21
The Transport Administration has guidelines and a methodology for selecting road
maintenance projects 21
The selection of projects is not always sufficiently justified 22
The costs of maintaining national roads are rising constantly, but supervision of the increase in costs is
weak 24
Supervision of amendments to maintenance contracts is weak 24
The cost of maintenance contracts increases also due to the increase in the volume of
periodic maintenance and repair work 27
The volume of the works to be ordered is not clear when the procurements of maintenance
contracts are carried out, and the unit prices in maintenance contracts differ significantly 29
Characteristics of audit 36
Audit objective 36
Assessment criteria 36
Annex A. Sample of public contracts for sites of development and preservation measures 40

Sustainability of national road funding
4 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Overview of the sector
1. In the Estonian road network, roads are divided into national roads,
local roads and private and forest roads. This audit focuses on national
roads, the total length of which in early 2022 was 16,662 km. 2 The
development and maintenance of national roads is in the area of
responsibility of the Ministry of Economic Affairs and Communications
(MEAC).
2. 1,605 km (9.5%) of national roads are main roads, 2,408 km (14.2%)
are basic roads, 12,515 km (73.9%) are secondary roads and other
national roads and 134 km (0.8%) are ramps and connecting roads (see
also Figure 1).
Figure 1. Estonian network of national roads

Source: Transport Administration
3. Restoration and development measures are distinguished in road
maintenance . The subdivision of preservation of the road network
includes the following road maintenance works:
■ road maintenance;
■ repair of gravel roads;
■ preservation repairs of paved roads to maintain the condition of
the surface, generally by surfacing;
2 The total length of national roads including light traffic roads and temporary ice roads is
17,020 km.
Road maintenance – activities
related to national roads,
including construction, repair,
maintenance, etc.
Source: Road Traffic Act § 1 1, https://www.riigiteataja.ee/akt/122032022 004
Main road Basic road Secondary and other national roads

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 5
■ restoration repairs of paved roads, the purpose of which is to
renew the surface by either overlaying or milling and resurfacing;
■ repair of bridges;
■ reconstruction of paved roads, the purpose of which is to replace
the road embankment or all or part of the road surface road,
together with the replacement or repair of the facilities belonging
to the road and the improvement of road safety, including the
reconstruction of intersections, etc.
4. The sub -division on road network development in the road
maintenance plan includes construction sites and their preparation,
upgrading of infrastructure for smart transport systems, implementation
of the action plan to mitigate the harmful effects of environmental noise,
reconstruction of accident blackspots, construction of gr avel road
surfacing as part of the Dust -free Estonian Roads by 2030 programme
and construction of infrastructure that promotes more sustainable
mobility.
Strategic framework for road development and preservation
5. The state’s most important long -term directions have been agreed in
the development strategy Estonia 2035 3. More detailed road maintenance
planning starts with the development plan in which the long -term
objectives for national roads are set. In the current Transport and Mobility
Development Plan 2021 –2035 4, the main objectives for the development
of roads are the development of TEN -T roads (see also Figure 2), the
reduction of road deaths and covering gravel roads with dust -free
surfaces.
3 Estonia 2035, adopted by the Riigikogu on 12.05.2021, available at
https://valitsus.ee/strateegia -eesti -2035 -arengukavad -ja-planeering/strateegia/materjalid . 4 Transport and Mobility Development Plan 2021 –2030, adopted by the Government of
the Republic and submitted to the Riigikogu on 10.06.2021, available at
https://www.mkm.ee/transport -ja-liikuvus/transpordi -tulevik .
Road maintenance plan – the
document that is the basis for
funding the activities related to
the maintenance of national
roads, including construction,
repair, maintenance, etc.
Source: Road Traffic Act § 1 1, https://www.riigiteataja.ee/akt/122032022 004
How is the maintenance of
national roads planned?

TEN -T roads – roads belonging to
the Trans -European Transport
Network. The list of TEN -T roads is
set in Regulation No 1315/2013 of
the European Parliament and of
the Council. 1,291 km of national
roads in Estonia are TEN -T roads.

Sustainability of national road funding
6 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Figure 2. The core and comprehensive network of the Trans -European road network (TEN -T)
in Estonia

Source: National Audit Office based on the TEN -T Regulation 5

6. According to the Road Traffic Act, the MEAC prepares the road
maintenance plan considering the possibilities offered by the state budget
and the state budget strategy (SBS), and submits it to the Government of
the Republic for adoption.
7. The money required for funding roads and the main development
projects to be implemented by 2030 have been established in the latest
RMP 6 approved by the Government of the Republic on 12.12.2020.
8. During the audit, the National Audit Office investigated the state’s
objectives in preserving and developing public roads. The National Audit
Office also analysed whether a financing plan is in place and whether
sufficient funds have been allocated for the achie vement of the objectives
(see Chapter I of the report).
9. In addition, the National Audit Office checked whether the money
allocated to road maintenance from the state budget is used economically.
For this purpose, the National Audit Office analysed the activities of the
Transport Administration in the use of fun ds planned for the
implementation of preservation and development measures, including the
conclusion and amendment of maintenance contracts. The results of the
analysis are presented in the second chapter of the report.
5 The interactive map of the European Commission’s trans -European network, including
roads, is available at https://ec.europa.eu/transport/infrastructure/tentec/tentec –
portal/map/maps.html . 6 Road Maintenance Plan 2021 –2030, approved by the Government of the Republic on
10.12.2020, available at https://www.transpordiamet.ee/maanteed -veeteed -ohuruum/tee –
ehitus/teehoiukava .
What did the National Audit
Office audit ?

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 7
As funding is decreasing and prices are rising, the state
must decide on the priorities of road maintenance
10. The National Audit Office clarified the objectives set in the strategy
documents for the development and preservation of public roads and
checked whether funds for the achievement of the objectives have been
allocated in the state budget documents.
The strategy papers set a number of objectives for the condition of national
roads, but there are problems in achieving them
11. The National Audit Office assumed that specific and measurable
objectives have been set for the preservation and development of public
roads and that the milestones have been met.
12. The main objective of road preservation and improvement is to
preserve the condition of the national roads. In the previous Transport
Development Plan, the condition was measured according to the
proportion of roads that were in a very good, good, satisfac tory or poor
condition, the approach taken in the new programme for the
implementation of the Transport and Mobility Development Plan is to use
the International Roughness Index (IRI) to measure the condition of
national roads. The lower the IRI, the smoot her the road.
13. IRI is measured on paved roads, which account for approximately
three quarters of all national roads.
14. Roughness has improved steadily over the last fifteen years (see also
Figure 3). The condition of the main roads (see also Figure 1) has
improved the most and their roughness is ca 0.9 mm/m. It has been
possible to use European Union funds for the reconstruction and
construction of main roads.
15. The situation is worse on secondary roads, i.e. 74% of national roads,
where the average roughness is 2.93, i.e. the condition of the road surface
is satisfactory.
7 Read more about road surface roughness and the meaning of measurement intervals
here: https://teed.ee/teenused/katsetamine -ja-mootmine/mootmine/iri/ .
What are the objectives of the
preservation of national
roads?
Did you know that
According to AS Teede
Tehnokeskus, the current
roughness of secondary roads
indicates that the road surface is
relatively uneven , i.e. although
speeds can generally be close to
the maximum permitted, the road
surface should be observed when
driving. 7

Sustainability of national road funding
8 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Figure 3. Annual average annual roughness on national roads 2005 –2021, mm/m
Source: National Audit Office according to the road register
16. Estonia has made a commitment to the European Union to construct
the roads of the TEN -T core road network according to the requirements
of Regulation by 2030. The Tallinn -Pärnu -Ikla and Tallinn -Tartu -Võru –
Luhamaa roads belong to the TEN -T core network in E stonia (see also
Figure 2).
17. The main requirements the TEN -T core network roads must meet in
2030, according to the Regulation, are as follows:
■ there are separate carriageways for each direction of traffic,
separated by a dividing strip not intended for traffic or, in
exceptional cases, by other means;
■ crossings with other roads, railways, footpaths, cycle paths and
tramways are grade -separated;
■ they do not serve properties adjacent to the road.
18. The TEN -T comprehensive network (see also Figure 2) has to be
completed in line with the requirements of the Regulation by 2050. The
following requirements apply to the comprehensive network:
■ access to the road is via grade -separated or regulated
intersections;
■ stopping and parking on the carriageway is prohibited;
■ there is no level crossing of the road and a tramway or railway.
19. Today, 30% of the Tallinn -Tartu -Võru -Luhamaa road and 21% of the
Tallinn -Pärnu -Ikla road are TEN -T compliant. 42% of the Tallinn -Narva
road that is part of the TEN -T comprehensive network is TEN -T
compliant.
20. The target to make all gravel roads used by at least 50 cars per day
dust -free by 2030 is also set in the Transport and Mobility Development
Plan.
2,32
Main road
0,90
4,32
Basic roads
2,93
3,81
Secondary roads
1,78
0
0,5
1
1,5
2
2,5
3
3,5
4
4,5
5
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
What are the objectives of the
development of national
roads?

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 9
21. In addition, the target for 2025 8 is to reduce the three -year average
number of road deaths to forty 9. The target for 2021 was 48 road deaths
as a three -year average, but the three -year average of road deaths in 2021
was 55. 10
22. According to the Performance Report, the decrease in the number of
road deaths has been more than twice as slow as needed to meet the
targets set in the road safety programme.
23. According to the MEAC, this is due to the fact that the actions are
funded from the budget of the institution responsible for the actions 11.
Often, however, the activities related to the road safety programme are
not a priority for the Transport Administration and other authorities. This
means that a large part of the actions is not implemented. For example,
62% of the actions foreseen for 2021 were fully implemented, 18% were
partially implemented and 20% were not implemented, according to the
MEAC.
24. According to the MEAC, to achieve the road safety objectives, the
implementation of the road safety programme must be considered
important at the level of the Government of the Republic, and the state
budget strategy must provide for targeted funding of critical measures of
the ro ad safety programme.
25. According to the expert opinion of AS Teede Tehnokeskus of 2019 12
on the funds needed for the preservation of national roads, the optimal
amount required for the preservation of roads per year is €193 million 13.
In other words, it would be necessary to allocate such an amount every
year to ensure that the level of all roads of heavy traffic is at least
satisfactory and to improve the general condition of the road network.
26. Given the exceptionally high overall inflation in the near future (see
Figure 4), this amount is likely to be higher now.
8 Road Safety Programme 2016 –2025, approved by Order No 54 of the Government of
the Republic on 16.02.2017, available at
https://www.transpordiamet.ee/liiklusohutusprogramm . 9 The baseline in 2014 was 82 road deaths as the three -year average. 10 Transport Performance Report 2021, approved by the order of the Minister of Economic
Affairs and Infrastructure issued on 30.05.2022. 11 Ministries, agencies (including the Transport Administration and the Police and Border
Guard Board) or local authorities are responsible for the activities of the road safety
programme for the period 2016 –2025. 12 Strategic Analysis of the Funding Needed for Maintenance of National Roads 2019 –
2048, 2019, available: https://transpordiamet.ee/media/3141/download . 13 All amounts in the report are shown inclusive of VAT unless otherwise stated.
How much will the
achievement of the national
road targets cost?
AS Teede Tehnokeskus – company
providing engineering services in
the area of road infrastructure.
The company operates in an open
market and has no direct
contracts with the state. In
addition to Estonia, services are
also provided in Latvia, Lithuania
and Germany.

Sustainability of national road funding
10 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Figure 4. Total inflation in Estonia since 2000
Source: Euro area statistics
27. In addition to the preservation of roads, there are also the costs
required for developing them, including building new roads and thus
improving the road network.
28. According to the explanatory memorandum of Estonia’s position on
the amendment of the TEN -T Regulation 14, the estimated cost of making
the core and comprehensive network comply with the requirements of the
current Regulation is €4 billion.
29. The explanatory memorandum also sets out the expected funding
needs up to 2050 by works:
■ construction of 354 km of 2+2 roads – €1.6 billion;
■ reconstruction of 215 km of existing 2+2 and 2+1 roads to make
them comply with requirements – € 200 to 400 million;
■ reconstruction of 725 km of the 1+1 roads of the existing TEN -T
network to make them comply with the requirements of TEN -T,
i.e. 2+1 roads – €2 billion;
■ maintenance costs of TEN -T 2+2 and 2+1 roads – €2.5 million
per year.
30. However, according to the explanatory memorandum, the
requirements established for TEN -T roads will become stricter with the
new regulation. According to the draft, the roads of the comprehensive
network would also have to meet the same requirements as the roads of
the core network, which would mean that the cost of building the roads
would also rise to €6 billion 15 (see also points 73 –89).
14 Explanatory memorandum to the decision of the Government of the Republic ‘The
positions of Estonia on the Regulation of the European Parliament and of the Council of
on Union guidelines for the development of the trans -European transport network,
amending Regulations (EU) 2021/1153 and (EU) No 913/2010 and repealing Regulation
(EU) No 1315/2013 and the Communication from the Commission to the European
Parliament and the Council on the extension of the trans -European transport network
(TEN -T) to neighbourin g third countries’, approved on 02.06.2022. 15 The amounts given in the explanatory memorandum do not include VAT.
Did you know that
At the end of 2021, there were 176 km
of four -lane TEN -T core network roads
in Estonia. Of these, 97 km have
been built after the restoration of
independence.
This means that so far, an average of
3.2 km of four -lane roads per year have
been built. In order to build 354 km
of four -lane roads by 2050, the
pace of construction should be
12.6 km/year.
Source: Four -lane roads would save centuries of time for Estonians every year. Ärileht , 08.10.2021.
The Estonian Infra Construction
Association pointed out in an
interview with the National Audit
Office that the fastest pace so far
has been 9 km/year .
May 2022 Estonia : 20.1%

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 11
31. Thus, the amount that should be allocated for the achievement of the
objectives of TEN -T roads by 2050 should be €142.8 –214.3 million per
year on average.
32. In addition to the development of TEN -T roads, the construction of a
dust -free surface on gravel roads must also be financed from the budget
of the development measures. In 2020, €20.5 million was spent on paving
200 km of gravel roads.
33. Thus, a dust -free surface should be built on another ca 1,800 km of
gravel roads 16 by 2030, which amounts to approximately 200 km per
year, i.e. €20.5 million per year without considering inflation and price
increases.
34. The National Audit Office found that clear and measurable objectives
for both the preservation and development of public roads have been set
in strategy documents.
35. The preservation goal has been met so far, but there are problems in
meeting the road safety goal and potentially also in constructing a dust –
free surface on gravel roads.
Achieving the condition and development goals of national roads with the
agreed funding is impossible
36. The National Audit Office assumed that there is a long -term
financing plan in place for the maintenance of public roads, including the
money needed.
37. Long -term funding needs for road investments are foreseen in the
road maintenance plan. However, this does not guarantee the existence of
the funds, as the actual funding is decided by the state budget strategy for
four years and, more precisely, by the st ate budget once a year.
38. According to the Ministry of Finance and the Government Office, the
road maintenance plan is outdated and not in line with activity -based
budgeting or the strategic planning framework.
39. Although ministries can present their opinions on the RMP at the
drafting stage, the state budget and the state budget strategy are approved
before the RMP, when the overall amounts of funding are fixed, without
any discussion of other possible options of the RMP at the level of
ministers.
40. The latest approved RMP, i.e. the one made for 2021 –2030 also
contradicts the SBS for 2022 –2025. According to the Transport
Administration, the SBS and the RMP are not aligned, as the MEAC
expects to receive more money during the preparation of the SBS for
2023 –2026, and therefore the Ministry did not want the government to
approve the RMP with reduced funding.
16 Whilst there are more than 4,000 kilometres of gravel roads among national roads in
total, a little over half of them are used by fewer than 50 cars a day. Road Maintenance
Plan 2021 –2030, approved by the Government of the Republic on 10.12.2020, availabl e at
https://www.transpordiamet.ee/maanteed -veeteed -ohuruum/tee -ehitus/teehoiukava .
What did the National Audit
Office find?
How is the funding of national
roads planned?

Sustainability of national road funding
12 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
41. For example, for the year 2025, the MEAC requested almost €271
million in addition to the budget. 17 However, the government did not
approve the budget increase the MEAC had hoped for and instead, the
decision made with the SBS for 2022 –2025 was to cut funding for road
maintenance (see also Figure 6).
42. The National Audit Office has highlighted the problem of a lack of
long -term funding also in several previous audit reports. For example, in
the overview of public investment published in 2020, the National Audit
Office found that there is no nationwide vi ew of investment management
that goes beyond four years. 18
43. In overview, the National Audit Office pointed out that a cross –
sectoral investment plan covering a longer period would help areas of
government to prepare projects over a longer period of time and would
give greater assurance that it would be possible to obtain funds for the
implementation of the investment, as the preparation of a road
construction project alone often takes more than five years, plus the time
needed for construction.
44. According to the Ministry of Finance, road maintenance is not the
only area that needs long -term planning. The Ministry of Finance
confirmed to the National Audit Office that it has also prepared a plan to
improve the efficiency of investments, but the Gov ernment of the
Republic has not yet discussed it.
45. The analysis of the National Audit Office showed that in the years
2020 –2022, the money allocated for maintaining the state of the roads has
remained below the funding level found by the company AS Teede
Tehnokeskus. According to the financial plan of the RMP for 2022 –
2025 19, funding will remain below this level also in the following years
(see also Figure 5). Whilst the amount of funding to be allocated for road
preservation in 2022 is still €141.8 million, it will drop to €80.9 million
by 2025.
17 According to the general rule, the funding for each measure of the additional year of the
state budget strategy is automatically the same as the funding for the previous year.
Ministries can submit additional requests to increase funding. 18 Overview of the National Audit Office “Investment planning and management in
ministries, larger state -owned companies, hospitals and universities”, published on
06.02.2020, available at https://www.riigikontroll.ee/tabid/206/Audit/2497/language/et –
EE/Default.aspx . 19 “Investment plan for 2022 –2025 that corresponds to the funding opportunities of the
SBS”, Transport Administration 2022, available at
https://www.transpordiamet.ee/maanteed -veeteed -ohuruum/tee -ehitus/teehoiukava .
Did you know that
■ Preparations for the construction
of the Kose -Võõbu 2+2 road,
including planning and
design, took 10 years and the
whole project took 13 years.
■ The design of the Võõbu -Mäo 2+2
will take ca 15 years according
to estimates.
Source: Priit Sauk, Director General of the Road Administration: You cannot build a motorway fast. Kesknädal , 19.09.2019 https://kesknadal.ee/2019/09/19/maanteeameti -peadirektor -priit -sauk -kiirteed -kiiresti – valmis -ei-ehita/
Is funding available to meet
the objectives set for road
maintenance?

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 13
Figure 5. Funding for road preservation measures 2020 –2025, € million*
* The years 2022 –2025 are given on the basis of the financial plan of the RMP 2022 –2025, excluding VAT. The National Audit Office added 20% VAT to create a better comparison.
Source: National Audit Office on the basis of RMPs
46. However, despite the sub -optimal level of funding for road
preservation, the roughness of roads has improved steadily (see also
Figure 3). According to the Transport Administration, this is due to the
fact that, whilst funding is insufficient, they have targeted resources to
areas where they create the most benefit for the network as a whol e. For
example, the Administration has prioritised resurfacing and levelling
courses, which has an impact on the roughness of roads.
47. The Administration adds that cheaper measures have sometimes been
used, which were not foreseen in the model of AS Teede Tehnokeskus.
48. Also, in the context of limited funding, the Transport Administration
has deliberately left out some of the items of the reconstruction measure
and has preferred cheaper works that increase driving comfort. The
Administration explained that if a few short sections in a very poor
condition appear in the road network, and a large number of sections in a
satisfactory condition are being improved at the same time, then the
average according to the measure is progress.
49. At the same time, the Transport Administration added that these short
sections in a very poor condition require increasing investment as their
condition continues to deteriorate.
50. The Transport Administration also explained that the condition of
roads cannot be judged by their roughness alone, as it is also indicated by,
for example, rut depth, defects and load -bearing capacity.
51. The condition of roads is also shown by the ‘repair debt’, i.e. the
investment the state should make to bring road sections that are in a poor
condition or do not comply with requirements up to a good standard.
52. AS Teede Tehnokeskus estimated the repair debt for 2019 at €689
million, which according to the Estonian Infra Construction Association 20
20 Construction News, “Infra Association: national road repair debt will continue to grow
in 2022”, 17.12.2021, available at
https://www.ehitusuudised.ee/uudised/2021/12/17/taristuliit -riigiteede -remondivolg –
kasvab -ka-2022 -aastal.
144,2 150,2 118,2 118,9 86,3 67,4
0
20
40
60
80
100
120
140
160
180
200
2020 2021 2022 2023 2024 2025
€193 million

Sustainability of national road funding
14 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
will increase further as a result of insufficient funding for road
maintenance.
53. The Transport Administration admitted in an interview with the
National Audit Office that in 2025, the defects in roads will probably be
such that more money than planned should be allocated for their repair
(resurfacing).
54. In addition to preservation measures, development measures are also
funded from the road maintenance plan. Following the logic of road
maintenance, funding should be allocated in this order – preservation first
and development if possible.
55. At the same time, the SBS for 2022 –2025 allocates just over €125
million in total for road preservation and development for 2025 (see also
Figure 6).
Figure 6. Funding for road maintenance 2014 –2025, € million*
* The years 2022 –2025 are given on the basis of the financial plan of the RMP 2022 –2025, excluding VAT. The National Audit Office added 20% VAT to create a better comparison. In the period 2014 -2020, road maintenance funding also included the administrativ e costs of the Road Administration. Administrative costs have not been included since 2021, when the Transport Administration was established.
Source: National Audit Office on the basis of RMPs
56. For example, less than €5 million per year is planned for the
construction of dust -free surfacing on gravel roads in 2022 –2023, and the
level of funding for road maintenance planned for 2024 –2025 does not
allow for the construction of surfacing on gravel r oads.
57. The latest approved RMP for 2021 –2030 also includes the estimate of
the Transport Administration of how much money is needed to
implement the objectives of the preservation and development of state
roads. Figure 7 shows the difference between the total roa d maintenance
funding needs estimated by the Transport Administration and the funding
approved in the state budget strategy.
238,1
325,7
104,6
125,5
100,0
150,0
200,0
250,0
300,0
350,0
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
Is funding available to meet
the objectives set for road
development?
In comparison:
the construction procurement for
the 9.6 km Pärnu -Uulu section
alone is expected to cost €30
million.
Source: The construction of the Pärnu -Uulu 2+2 section will cost €30 million. ERR, 14.06.2022. https://www.err.ee/1608629629/parnu – uulu -2-2-loigu -ehitus -laheb -maksma -30- miljonit -eurot

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 15
Figure 7. Funding for road maintenance until 2025 and need for funding from 2026 –2030, €
million*
* The years 2022 –2025 are given on the basis of the financial plan of the RMP 2022 –2025, excluding VAT. The National Audit Office added 20% VAT to create a better comparison. In the period 2014 -2020, road maintenance funding also included the administrative costs of the Road Administration. Administrative costs have not been included since 2021, when the Transport Administration was established. The funding for road maintenance also includes funding from the Cohesion Fund for the period 2021 –2025, which is not included in the funding needs. Source: National Audit Office on the basis of RMPs

58. Since even before the cut, funding for road maintenance was not
sufficient in the opinion of the MEAC 21, the cut in funding will,
according to the Ministry, lead to both a sharp deterioration in the
condition of roads and high unemployment in the road maintenance
sector. According to the Transport Administration, the deterioration of
bridges is also a probl em.
59. According to the MEAC, road safety and environmental requirements
cannot be met either. For example, according to the Transport
Administration, the operating budget was cut, which reduced funding for
road marking, outdoor toilets and waste management.
60. It must also be kept in mind that the Russian -Ukrainian war has also
made the construction, repair and maintenance of roads more expensive
because of the cost of raw materials. In particular, the prices of fuel,
bitumen and metal have risen.
61. The final impact of the war on road development and maintenance
plans and maintenance contracts is not known, but the Transport Agency
estimates that in 2022 it will cost around €15 million to compensate
contractors for bitumen price increases and around € 5 million to
compensate for other material price increases. 22
62. At the same time, the Transport Administration has been actively
preparing projects. According to the Administration, 326.6 km of roads
concerning the three larger main roads are being or planned to be
21 Transport Performance Report 2021, approved by the order of the Minister of Economic
Affairs and Infrastructure issued on 30.05.2022. 22 Ain Alvela “Builders: you get 15 –20% less than last year for the same money“, June
2022, available at https://ehitusest.ee/uudis/2022/06/13/ehitajad -sama -raha -eest -saab –
mullusest -15-20-vahem/ .
325,7 278,2 209,3 209,3
493,7
517,4
507,8
479,3
487,2
483
0,0
100,0
200,0
300,0
400,0
500,0
600,0
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
How much money is spent on
preparing projects?

Sustainability of national road funding
16 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
designed in 2022. Most of the preliminary projects will be completed in
2022 –2023.
63. In 2020 –2021, €2.73 million was spent on the design of development
measures, and €4.97 million is planned for 2022 –2024.
64. However, with declining funding and rising prices, it is not certain
when the projects will reach the construction stage. There is a risk that
some of the money spent on design will be wasted, as completed projects
become outdated and expire fast.
65. Projects expire within a few years for several reasons. For example, a
building permit granted for a preliminary or main project is valid for five
years, and approvals of the main project with third parties (e.g. utility
network owners) generally expire within a year.
There are no plans to use non -state budget funds to meet the TEN -T road
development commitments
66. According to the Action Plan of the Government of the Republic for
2021 –2023 23, the plan is to finance TEN -T roads from the European
Union Cohesion Fund.
67. However, the MEAC knows from the Programme for Cohesion
Policy Funds 2021 –2027 and the draft partnership agreement that €159
million will be allocated to public roads during the financial period 2021 –
2027.
68. The Ministry of Finance admits that the financial capacity for the
construction of four -lane roads in Estonia is low under the current SBS
and that PPPs are the only non -budgetary alternative for the construction
of four -lane TEN -T roads.
69. To achieve the objectives of the Action Plan of the Government of
the Republic for 2019 –2023, the feasibility of PPP transactions was
analysed and it was concluded that PPPs can be implemented on the basis
of the legislation in force in Estonia.
70. However, the option of using PPPs was abandoned with the change
of government in 2021, as PPPs are costly for the state in the long term.
71. The MEAC assured the National Audit Office that no additional
transport taxation measures are planned in the coming years in addition to
the road user charge introduced in 2018, which applies to all lorries over
3.5 tons.
72. The Ministry also says there are no plans to borrow money to cover
the increase in road maintenance costs.
23 Action Plan of the Government of the Republic for 2021 –2023, available at
https://www.valitsus.ee/valitsuse -eesmargid -ja-tegevused/valitsemise –
alused/tegevusprogramm .
Has the MEAC considered
other ways to finance
development projects?
Did you know that
the Libatse -Nurme project alone
(21.6 km) is estimated to cost
€105 million.
PPP – Public -Private Partnership

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 17
73. As EU regulations are directly applicable, the Estonian state cannot
directly withdraw from the construction of TEN -T roads.
74. However, under the current TEN -T Regulation, Estonia can apply to
the European Commission for a derogation from the provisions of the
Regulation if the investments in infrastructure cannot be justified on the
grounds of socio -economic cost -effectiveness.
75. For example, the Ministry of Economic Affairs and Communications
has requested a derogation for the Uulu -Ikla and Ülenurme -Võru –
Luhamaa sections, which are part of the core network, citing low traffic
volumes.
76. Whilst the TEN -T Regulation does not explicitly state what the traffic
volumes should be for a project to be considered socio -economically
cost -effective, the new draft TEN -T Regulation provides that an
exception may be made in particular if the traffic vo lumes are below
10,000 cars per day. 24
77. Based on this, the MEAC would have grounds to request a derogation
for a large part of the TEN -T roads. The areas where the annual average
daily traffic volumes are 10,000 cars or more are shown in red in Figure
8.
78. According to the cost -benefit analysis of the Rõmeda -Haljala 2+2
road commissioned by the Transport Administration in 2010, and the
Administration’s subsequent preliminary cost -benefit calculations, the
cost -benefit limit for the 2+2 road is generally a tr affic volume of more
than 6,000 cars per day (shown in blue in Figure 8).
79. However, it should be kept in mind that TEN -T roads must also meet
all the requirements of the Regulation (see also from point 17), which
means that their construction is generally more expensive than that of
ordinary roads.
24 Proposal: Regulation of the European Parliament and of the Council on Union
guidelines for the development of the trans -European transport network, amending
Regulation (EU) 2021/1153 and Regulation (EU) No 913/2010 and repealing Regulation
(EU) 1315/2013, Strasbourg, 14.12.2021.
Is it possible for the Estonian
state to withdraw from its
commitment to the European
Union to build TEN -T roads?

Sustainability of national road funding
18 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Figure 8. Annual average daily traffic volume in Estonia in 2021

Source: National Audit Office according to the traffic volume data of the road register
AKÖL – annual average daily traffic volume cars/day
80. Although the addition of the Rail Baltic railway connection will have
an impact on the reduction of passenger and freight traffic on the Tallinn –
Pärnu road, both the MEAC and the Transport Administration estimate
that traffic on national roads will neverth eless continue to increase in the
future.
81. In order to assess the impact of the added railway on roads, the
Transport Administration commissioned a Via Baltica traffic forecast,
which was completed in 2017. It shows that after the Rail Baltic railway
is taken in use, traffic on Via Baltica will nev ertheless increase 1.7 times
in 20 years. However, the situation for passenger and freight traffic has
changed since the outbreak of the Russia -Ukraine war.
82. The Transport Administration has requested funding to create a
mobility model covering all modes of transport: rail, road, water and air.
So far, however, funding for the mobility model has not been found due
to budget cuts.
83. The National Audit Office finds that the state does not have a long –
term and stable financing plan for the development and preservation of
state roads that considers realistic financing possibilities. Although the
Transport Administration has highlighted the long -term funding needs for
road maintenance in the road maintenance plan, in practice this does not
What did the National Audit
Office find and what does it
recommend?

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 19
mean that the activities and projects set out in the plan will actually be
funded.
84. Also, the RMP is approved after the state budget and the state budget
strategy, in accordance with the overall amounts set out therein. This also
means that, although the RMP is approved by the Government of the
Republic, it is not substantively discussed.
85. The National Audit Office find that achieving the objectives of the
preservation, safety and development of roads – including the
commitment to the EU to complete the TEN -T core network by 2030 –
with the planned funding is not realistic.
86. Due to underfunding and price increases, the National Audit Office
also estimates that there is a risk that the condition and drivability of
national roads will deteriorate in the near future.
87. Nor has the state agreed on alternative financing for public roads,
such as the use of PPPs or the establishment of additional taxes. It is
therefore unlikely that the state will be able to fully meet its own targets
and its commitments to the European Uni on.
88. Consequently, the National Audit Office believes that the MEAC and
the Government of the Republic of Estonia should think more broadly
about the priorities in the field of road maintenance and what can be
implemented with the existing funding or where the missing funding can
be found. In the opinion of the National Audit Office, it is also
unreasonable to proceed with the preparation of projects that are not
selected as a priority.
89. Recommendations of the National Audit Office to the Minister of
Economic Affairs and Infrastructure:
■ Initiate an amendment to the Road Traffic Act in such a manner
that the road maintenance plan does not have to be approved by
the Government of the Republic and include it in the Transport
and Mobility Development Plan, in order to better ensure the
planni ng of the state’s various transport networks and the
monitoring of development trends and project implementation.
■ Until the Road Traffic Act stipulates that the road maintenance
plan must be approved by the Government of the Republic,
submit
o to the Government of the Republic regularly an overview of
the implementation of the road maintenance plan, including
the timeliness of the sites and their adherence to the budget;
o all construction and reconstruction projects to the road
maintenance plan.
■ Analyse how to avoid the deterioration of the condition of the
current national road network by reallocating funds between the
measures in the road maintenance plan, where necessary .

Sustainability of national road funding
20 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
■ Identify the financing opportunities (including long -term) and
needs for public roads, taking into account the current situation,
and then set priorities that correspond to the opportunities.
■ Take into account the actual funding possibilities and the real
need for road construction when ordering design. Avoid spending
money on the preparation of projects that cannot be carried out
with the approved funding and do not need to be fully built.
Response of the Minister of Economic Affairs and Infrastructure: We
will consider implementing the proposal. However, we would like to
point out that the Transport and Mobility Development Plan is a long –
term sectoral development document approved by the Riigikogu. The
Transport Competitiveness and Mobility Programme, w hich sets targets
for the quality of transport services within the limits of funding
possibilities, can be seen as the operational programme of the Transport
and Mobility Development Plan. The road maintenance plan, which takes
funding options into account , is also a more detailed implementation plan
than the programme, which highlights, among other things, longer
funding needs as set out in the Transport and Mobility Development Plan
2021 –2035, which the programme does not include.
The road maintenance plan is, among other things, a document for
monitoring the implementation of the objectives of the Action
Programme of the Government of the Republic, playing an important role
in aspects of national security, regional policy implement ation and
environmental protection, thus influencing not only the Ministry of
Economic Affairs and Infrastructure but also the functioning of other
sectors.
The road maintenance plan is submitted to the Government of the
Republic for approval, usually once a year. An overview of the
implementation of the road maintenance plan so far, the main concerns
and possible solutions will be given with the approval of t he new plan.
The road maintenance plan to be presented in 2022 will outline the
construction and reconstruction projects for the whole road maintenance
period. The Ministry is certainly ready to submit to the Government of
the Republic various overviews to gether with the information requested
by the Government of the Republic.
This analysis will be carried out every year in when the road maintenance
plan is updated, taking into account the volume of funds allocated to road
maintenance. The road maintenance plan is prepared according to the
principle of ‘preserve first, then deve lop’ in order of priority –
maintenance, preservation and then development.
The maintenance of national roads is financed on the basis of the Road
Traffic Act, according to which the amount of funding for road
maintenance is set out in the state budget strategy and in the state budget
for each financial year, which includes variou s sources of funding. In
addition, under the Railways Act, the Government of the Republic
approves an action plan to guide the development of the public railway
infrastructure, with the aim of providing sustainable funding for the
maintenance, renewal and development of the infrastructure needed to
meet future mobility needs. Under the State Budget Act, a four -year
budget strategy is drawn up, including sectoral programmes. The

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 21
priorities and objectives for rail and road maintenance are reflected in the
Transport Competitiveness and Mobility Programme and correspond to
the possibilities of the budget strategy. Long -term road infrastructure
objectives and infrastructure priorities are set out in the Transport and
Mobility Development Plan 2021 –2035, which, among other things,
addresses all modes of transport and their interactions. Different
financing options have been mapped out in the road maintenance plan for
national roads and the action plan for the development of public railway
infrastructure. The Ministry of Economic Affairs and Communications,
the Transport Administration and AS Eesti Raudtee are actively involved
in EU targeted assistance programmes to improve railways, roa d
maintenance and road safety (e.g. ITS, military mobility, etc.). Among
other things, both long -term loans and the use of the public -private
partnership model have been analysed and proposals have been made to
the Government of the Republic.
The methodology for selecting road maintenance projects
is in place, but selection has not been transparent
90. The National Audit Office assumed that the projects that receive
funding from the state budget are the ones that most need to be
implemented. This means that the Transport Administration has
developed a methodology for selecting the road sections that need repairs
the most and has implemented this methodology in practice.
91. The National Audit Office also assumed that the data used in the
analyses were complete, timely and relevant, and that they were collected
according to established methodologies.
The Transport Administration has guidelines and a methodology for selecting
road maintenance projects
92. According to the Road Traffic Act, the Ministry of Economic Affairs
and Communications is responsible for the preparation of road
maintenance plans. The financial plan of the RMP and the list of
construction and reconstruction projects are prepared by the Transport
Administration during the drafting of the RMP.
93. The Transport Administration collects various data on the condition
and usability of roads, including data on road roughness , traffic volumes
and defects.
94. The analysis of the data of the road register by the National Audit
Office showed that the data are collected according to the established
guidelines and are largely both timely and relevant.
95. The National Audit Office ordered a data analysis from Positium OÜ,
a research company of the University of Tartu, to assess the quality of the
traffic volume data of the Transport Administration.
96. Traffic volumes are one of the main criteria for selecting both
preservation and development projects. Data on traffic volumes also
influence maintenance contracts.
How is it decided which
projects will be funded?

Sustainability of national road funding
22 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
97. Comparing the results of the analysis with the traffic volume data of
the Traffic Register, the National Audit Office concluded that the traffic
volume data of the Transport Administration are largely correct and
reflect the real traffic on national roads.
98. Positium OÜ also confirmed to the National Audit Office that the
differences between the mobile positioning data and the traffic volume
data are acceptable and the discrepancies can be explained by the
differences between the two measurement methods – the number of
vehicles on the road is measured in the case of traffic volumes and mobile
positioning measures the number of all people, including, for example,
pedestrians.
The selection of projects is not always sufficiently justified
99. Based on the data collected, the Transport Administration analyses
the need for road section repairs in the Estonian Pavement Management
System (EPMS).
100. Based on the ranking, the person responsible for each repair measure
puts together an investment plan for the measure and submits it, with the
justifications, to the road maintenance plan working group of the
Transport Administration for discussion.
101. The working group approves the prepared measure -based investment
plans and submits them to the management for decision. However, the
management does not see the analysis or justification of the choices of
items and approves the plans as a whole. This means that the
management does not know how many projects have been removed from
the list and why, and what the need for repairs of these projects was like
(see also Figure 10).
Figure 10. Process for selecting sites to be funded from the repair measures of the Transport Administration

Source: National Audit Office on the basis of the documents and explanations of the Transport Administration
102. The National Audit Office analysed the list of the repair measures of
the RMP for 2018 –2022 and the EPMS analyses on which they were
based to determine whether the selection of RMP sites was justified and
transparent.
103. However, the analysis showed that the process of drawing up the lists
of the road maintenance plan for 2018 –2022 was not transparent.
104. Although the EPMS analyses of all repair measures had been carried
out in accordance with the applicable guidelines, the Transport
Administration did not document how the sites were selected from the
ranking of the analysis to the RMP list. This means that it was not
entirely clear why some of the sites identified in the analysis as being in
greater need of repair were excluded from the RMP list, while those
lower down the EPMS ranking were funded under the RMP.
How does the Transport
Administration select
projects?
Working group discusses
Road condition
data
Ranking of sites Management approves
List of sites EMPS analysis
RMP list

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 23
105. In an interview with the National Audit Office, the Transport
Administration pointed out that an object may be excluded from the RMP
list, for example, because a decision is made in favour of another repair
measure or postponing the commissioning of the ob ject. In addition to
condition, other important factors in the selection of sites include the
proximity of another site, the availability of human resources, the time
needed for preparation and land acquisition, political guidelines, etc.
106. At the same time, the Transport Administration also sent the National
Audit Office an analysis table of the reconstruction measure that was the
basis for the RMP for 2021 –2030, which contains a much more thorough
explanation as to why each site should or s hould not be financed under
the RMP.
107. Although the Transport Administration has improved the analysis
table of the reconstruction measure, the National Audit Office did not
analyse all of the analysis tables and RPM lists that were the basis for the
RMP for 2021 –2030 and cannot confirm that th e Administration now
adequately justifies all RMP investments.
108. The analysis of the National Audit Office also showed that the
reconstruction projects included as an annex to the RMP for 2018 –2022
should not have been taken on as a priority according to the EPMS
analysis. However, according to the Transport Administrat ion, the road
sections that are eligible for the EU Cohesion Fund are specified in the
annex to the RMP.
109. According to the Road Traffic Act, the RMP should contain lists of
all construction and reconstruction projects.
110. However, only road construction projects are included in the RMP for
2021 –2030. According to the Transport Administration, the TEN -T road
projects are included in the annex to the RMP because they are the only
ones that are likely to receive funding from t he Cohesion Fund, and the
requirement to submit projects applying for funding in a road
maintenance plan arises from the regulation that regulates the
implementation of the Fund 25.
111. According to the Administration, there are no more reconstruction
projects in the last RMP because there is no hope of obtaining external
funding for them.
112. The National Audit Office finds that despite the existence of
guidance materials and methodologies; there is no assurance that the
projects financed from the state budget are the ones that most need to be
implemented. The audit showed that the selection of projects for the RMP
for 2018 –2022 has not been transparent and the Transport Administration
was a lso unable to explain to the National Audit Office why some of the
projects at the bottom of the EPMS ranking list were included in the RMP
list, whilst the projects ranked higher, i.e. the projects in a worse
condition, were excluded.
25 § 6 (1) of Minister of Economic Affairs and Infrastructure Regulation No 85
“Development of transport infrastructure in 2014 –2020”, entered into force on
10.10.2014, available at RT I, 07.10.2014, 16 .
What did the National Audit
Office find and what does it
recommend?

Sustainability of national road funding
24 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
113. At the same time, the National Audit Office is of the opinion that the
data on the condition of the roads collected in the road register is accurate
and up -to-date.
114. Recommendation of the National Audit Office to the Director
General of the Transport Administration: ensure that the agreed
dataset and methodology for the selection of sites for the road
maintenance plan are actually used and that the selection of sites is
documented and transparent at every stage.
Response of the Director General of the Transport Administration:
We confirm that the Transport Administration uses the agreed dataset and
methodologies for the selection of sites for the road maintenance plan.
We agree with the observation that the documentation of decisions needs
to be improved. Therefore, we will revi ew the methodologies for the
selection of sites of all measures and will update the process of obtaining
lists from the ranking in those methodologies where this part is missing or
unclearly described, with a deadline of 01.08.2023. As a quicker measure
for the improvement of documentation, we will add additional
justifications to the lists of sites to be approved as of 01.08.2022 if the
procedure for the selection of sites is not described clearly enough.
The costs of maintaining national roads are rising
constantly, but supervision of the increase in costs is
weak
115. The National Audit Office also investigated the use of budgetary
funds during the audit. For this purpose, the National Audit Office
analysed the effective ness of maintenance contracts, their amendment and
the amendment of major development and preservation contracts.
Supervision of amendments to maintenance contracts is weak
116. The National Audit Office assumed that the development,
preservation and maintenance contracts concluded by the Transport
Administration would be amended only in justified cases and that a clear
division of roles and responsibilities has been established f or their
amendment.
117. The sample of development and preservation sites analysed by the
National Audit Office (see Annex A) revealed that contracts are rarely
amended. The Transport Administration explained that contracts are
mainly amended when it is necessary to correct errors in a project. In a
few cases, the term of the contract is also changed, or an amendment is
made if the person named in the contract changes, for example, the
representative of one of the parties or the roadmaster.
118. Increases in the cost of procurements under development and
maintenance measures that remain under than €100,000 are approved by
the head of the regional unit of the infrastructure construction and
maintenance department of the Transport Administration.
119. If the cost of a project increases by more than €100,000 or if the
tenders exceed 30% of the expected cost when the procurement is
How are contracts amended?

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 25
opened, the increase will be approved by the road maintenance plan
working group of the Transport Administration.
120. Whilst the responsibility of the working group of the Transport
Administration is described in the working group’s rules, the
responsibility of the Administration’s regional managers for the
amendment of contracts is not. The Transport Administration expla ined
that the responsibility of the managers of regional units in amending
contracts is governed by the Public Procurement Act and the extent of the
reserve provided for in the contract. In general, the reserve is 15% of the
total cost of the contract.
121. Maintenance contracts are generally amended when the price of the
contract is adjusted once a year in line with changes in the consumer
price index and when there are changes in the road network. The
Transport Administration changes the volume of the contr acts when a
new road is added to the maintenance, a road is taken off the national
road network or the Administration raises the condition level of an
existing road.
122. The input for changing condition levels comes from the results of the
measurement of traffic volume. According to the statutes of the Transport
Administration 26, the Administration carries out traffic counts on national
roads and publishes the results on its website and in the road register in
the first quarter.
123. Amendments to the maintenance contracts are approved and signed
by the regional manager of the Transport Administration.
124. The cost of maintenance contracts increases almost every year,
mainly due to the indexation of maintenance contracts with the consumer
price index, the increase in condition levels due to the increase in traffic
volumes, and changes in the road network as new junctions, collector
roads, light roads, etc. are built.
125. The Transport Administration explained that maintenance contracts
can become more expensive when one contract expires and the terms of
the new contract are stricter compared to the previous one.
126. On the one hand, the increase in condition levels brings greater
driving comfort and safety, but the maintenance contracts analysed by the
National Audit Office also show that maintenance contracts have become
increasingly costly for the state.
127. Using the Lääne -Viru contract as an example, the cost of a contract
year can increase by up to 37% compared to the original contract – while
the amount that had to be paid for a contract year in the period
01.11.2017 –31.10.2018 was €1.97 million, the amoun t that had to be paid
for a contract year in 01.11.2021 -31.10.2022 was €2.7 million (see also
Figure 11).
26 Minister of Economic Affairs and Infrastructure Regulation No 82 “Statutes of the
Transport Administration” of 03.12.2020, RT I, 09.12.2020, 1 .
Condition level – the level of the
requirement a road must meet.
Condition levels vary according to
road type, traffic volumes and
season. The level requirements
established for each type of road
are approved by the Regulation of
the Minister of Economic Affairs
and Infr astructure.
Source: Minister of Economic Affairs and Infrastructure Regulation No 92 “Requirements for the condition of roads” of 14.07.2015, RT I, 15.07.2015, 13
What is causes the increases
in the cost of maintenance
contracts?

Sustainability of national road funding
26 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Figure 11. Increase in the cost of maintenance contracts by the contracts of 4 regions, €
million

Source: National Audit Office on the basis of maintenance contracts
128. Due to a significant increase in the consumer price index in 2022, the
existing contracts will be more expensive for the Transport
Administration than originally planned. The change in the index in 2022
compared to the previous year is 4.6%. According to t he Transport
Administration, the cost of maintenance contracts will increase by €4
million in 2022 due to the consumer price index.
129. The increase in the cost of existing contracts was affected the most by
the amendment to the regulation “Requirements for the condition of
roads” 27 made in 2018, as a result of which all roads on which more than
1,000 cars drive per day on average have the highest level, i.e. condition
level 3. Preventive 3+ de -icing is separately paid for in addition to this.
130. Although the Transport Administration receives the traffic volume
data on which the road condition levels are based at the end of every
March, some contracts show that the condition levels have been changed
up to four times a year.
131. The Transport Administration has no procedure for the amendment of
contracts on the basis of new traffic data. The Administration explained
that it is common practice that contract amendments are made as and
when necessary.
132. Decisions to change the condition levels are taken independently by
each region of the Transport Administration. Whilst the regulation lays
down rules on the condition level a road must meet depending on the
traffic volume, the Administration says that in addition to the traffic
volume, it also takes into account the proportion of heavy goods traffic
and the need to ensure the comprehensive condition level of the road.
27 Minister of Economic Affairs and Infrastructure Regulation No 92 “Requirements for
the condition of roads” of 14.07.2015, RT I, 15.07.2015, 13 .
2,7
3,1
2,2
2,8
2,0
2,7
1,6
2,1
1,5
1,7
1,9
2,1
2,3
2,5
2,7
2,9
3,1
3,3
Pärnu Põlva Lääne-Viru Keila
Did you know that
road maintenance is divided into
routine and periodic maintenance.
Routine maintenance is further
divided into summer and winter
maintenance . The maintenance
contracts also include
preservation repairs based on unit
prices.
Source: RMP 2021 –2030

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 27
133. The National Audit Office found that the roles and responsibilities for
amending contracts in the Transport Administration have been defined,
with the regional managers having greater responsibility. However, the
audit showed that the Administration’s supe rvision of amendments to
maintenance contracts is weak, there are no financial limits on
amendments to maintenance contracts, and the Administration needs
clearer rules on how often and for what reasons contracts can be
amended.
134. Recommendations of the National Audit Office to the Director
General of the Transport Administration:
■ Establish the thresholds within the scope of which the decision in
the case of an increase in the cost of a maintenance contract is
made by a regional manager and when the price increases must
be discussed in the road management plan working group of the
Transport Administration.
■ Establish a common procedure for changing condition levels for
all regions, based on traffic volume data.
Response of the Director General of the Transport Administration:
We will make the changes in the processes from 01.01.2023.
We will establish a single procedure in 2023 at the latest. In addition to
traffic volumes, we also take into account other criteria that are relevant
for the determination of condition levels.
The cost of maintenance contracts increases also due to the increase in the
volume of periodic maintenance and repair work
135. The National Audit Office assumed that a procedure for ordering
additional periodic and repair work had been agreed and is followed.
136. In order to ensure the condition of the roads, the maintenance
contracts foresee, in addition to the routine maintenance works, periodic
maintenance works and repair works, which are added to the contract
every year as necessary. This, in turn, increases the cost of road
maintenance.
137. The biggest changes in periodic maintenance are related to the
increase in the volume of dust control.
138. For example, while the Saare maintenance contract foresaw 44 km of
dust control works at the time it was concluded, a total of 66 km of dust
control works were ordered in 2021.
139. Also, the volume of ordered dust control work has increased every
year according to the Pärnu contract. Whilst 100 km of dust control
works were initially ordered, 137 km have been ordered in 2022
according to the contract.
140. Although the maintenance contracts state that the contracting
authority and the road maintenance contractor review the performance of
the periodic maintenance planned for the year on an ongoing basis and
enter the composition, volumes, locations and deadli nes of these works in
What did the National Audit
Office find and what does it
recommend?
Periodic maintenance – additional
performance of maintenance
work not included in routine
maintenance, such as resurfacing,
dust control, installation of traffic
signs and cleaning of the road
area. Repair work – replacement of part
of a road with an equivalent, e.g.
repair of gravel surface,
construction of new culverts,
construction of side ditches. Source: Transport Administration

Sustainability of national road funding
28 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
a record, the Transport Administration says that no record is usually
prepared about this.
141. According to the regional representatives of the Administration,
periodic maintenance is agreed on an ongoing basis by email and, once
the work has been carried out, a periodic maintenance record is prepared,
indicating the work that was carried out, its l ocation and volume.
142. The analysis of four maintenance contracts (Põlva, Keila, Lääne -Viru
and Pärnu) by the National Audit Office also showed that more work was
done than set forth in the contract. Records of the added works were
prepared after the works were carried out.
143. The maintenance contract of Põlva County for the period
01.10.2020 –30.09.2021 stated that dust control will be performed on 202
km, but according to the record prepared in September 2021, the work
was performed on 213 km.
144. The Transport Administration explained that in 2017 –2019, the
objective of the Administration was to join the dust control sections and
this significantly increased the volume of work. The decision on which
sections would be joined was made during the cont ract period, and it was
not possible to know before the procurement how many extra kilometres
would be added.
145. The Administration added that larger volumes in the records are due
to the need that emerged in a specific situation, such as repeated
complaints from citizens or the joining of two dust -free sections. In
addition, volumes increase when non -traditional HGV traffic spoils the
dust control and it must be redone.
146. The analysis of the National Audit Office showed that, contracts also
become more expensive when repair works are added. For example, the
amendment to the Põlva contract increased the cost of repair works in
2020 by €157,215 (excluding VAT) due to the emer gency works related
to the wear layer of gravel roads on six gravel roads covering 68,267 m 2.
Initially, repair works on 100 m² were provided in the contract.
147. Additional repair works have also been ordered in other regions, for
example, an amendment to the Võru maintenance contract in 2020
increased the cost of repairs by 75%, or €67,378. 28
148. The National Audit Office also drew attention to the addition of large
volumes of repair works in its 2012 audit “Road maintenance and
supervision of road maintenance”. At the time, the predecessor of the
Transport Administration, the Road Administration, replied that it was
considering excluding preservation repairs from maintenance contracts.
The Transport Administration explained that large -scale works, such as
resurfacing of a few tens of kilometres and major repairs of gravel roads,
have been excluded from the contracts.
149. However, an analysis of the maintenance contracts showed that
preservation repair works are still included in the existing contracts and
that there are no procedures on how and within which financial limits
28 The amount set for repair works in the initial contract was €89,318.
What did the National Audit
Office find and what does it
recommend?

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 29
periodic works and repairs are ordered within the scope of maintenance
contracts.
150. The Transport Administration explained that the repairs included in
the maintenance contracts are small -scale and without them, it is not
possible to guarantee the condition requirements, and that separate
procurements will be announced for repairing frost damage and cracks,
and marking.
151. However, the analysis of the National Audit Office showed that it is
not possible to get an overview of the roads on which additional repairs
are carried out and the criteria according to which these roads have been
selected. For example, in the case of th e Põlva and Võru contracts, the
volume of repair works was increased significantly, but in neither case
does the amendment to the contract state on which sections and for what
reasons it was necessary to carry out such a volume of repair works, it is
only stated that the volume of emergency works on gravel roads,
including repair works, will be increased.
152. The National Audit Office also drew attention to the same problem in
its 2012 audit “Road maintenance and supervision of road maintenance”,
where it highlighted that the contracts do not contain information on the
condition and repair needs of roads.
153. Recommendation of the National Audit Office to the Director
General of the Transport Administration: establish clear rules within
the Transport Administration on how, within which financial limits and
on the basis of which data additional works within the scope of
maintenance contracts are decided upon, and record additional works
with justifications befo re the works are carried out.
Response of the Director General of the Transport Administration:
We will prepare and establish the rules by the end of Q1 2023 at the
latest.
The volume of the works to be ordered is not clear when the procurements of
maintenance contracts are carried out, and the unit prices in maintenance
contracts differ significantly
154. The National Audit Office assumed that maintenance contracts are
amended only in justified cases, the volume of work to be carried out is
known before the contract is signed and the unit prices in maintenance
contracts do not differ significantly.
155. An analysis of the effective ness of public contracts showed that
maintenance contracts are amended either within one to two months after
the start of the first year of the contract or even before the start of the first
year of the contract.
156. In most cases, the contract is amended on the grounds that the overall
length and condition levels of the roads to be maintained have changed.
157. For example, in the case of the Keila contract, the first amendment
entered into force before the start of the first contract year. The reason
given in the amendment to the contract was that the total length and
condition levels of the roads to be maintain ed in the Keila road
Is the volume of maintenance
to be ordered clear in
procurement?

Sustainability of national road funding
30 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
maintenance area of Harju County had changed, and consequently the
cost of maintenance had also changed.
158. The price for one period of this contract increased by €30,689 before
the start of the first year, bringing the total maintenance cost to
€1,611,353. The change increased the total length of the maintenance of
paved roads by ca 20 km.
159. The maintenance contract of the Ida -Viru maintenance area was
signed at the end of April 2021, but the amendment that came into force
in September increased the length of the roads to be maintained by 11
km.
160. The Transport Administration explained that the road network
changes a lot during the procurement process and the status of the roads
has to be aligned with the road register in the contract.
161. The first amendment to the Lääne -Viru contract was signed a week
after the start of the first year of the contract. The reason given in the
contract was that rubber bollards had been installed on a 6.5 km section
of the road, which required additional main tenance, as the contracting
authority had not foreseen the extent of the impact of the installed
bollards on road maintenance.
162. The National Audit Office finds, however, that such a cost should be
foreseeable for the Transport Administration as a body dealing with road
maintenance on a daily basis, as the rubber bollards were installed in the
same year when the public contract was awarded. In the opinion of the
National Audit Office, there should also be no situations where the
contract is amended before the start of the first maintenance period due to
changes in the length of the roads to be maintained, as this information
should b e clear before the procurement is announced.
163. It is stated in the 2012 audit of the National Audit Office “Road
maintenance and supervision of road maintenance” that the prices per
kilometre of routine maintenance obtained through procurement vary by
almost two times between regions.
164. An analysis of the unit prices of the four maintenance contracts
showed that the situation is the same also in the case of effective
contracts. For example, in the Lääne -Viru contract for the period
01.11.2021 –31.10.2022, the unit price for condition level 3 (single
carriageway sections) is €1,978.34, while in the Põlva contract, the unit
price for the same condition level is €958.58 euros cheaper, i.e.
€1,019.52.
165. The Transport Administration explained that the main emphasis
during the preparation of a tender is on the final cost and the contracting
authority cannot control how the planned profit is distributed between the
expenditure budget lines
166. The unit prices of repair work s also differ considerably. For example,
while the cost of cleaning 5 km of ditches in Ida -Viru County is €15,000
per year, the state pays €4,000 per year to have the same quantity of
ditches cleaned in Järva County.
Are the unit prices of
maintenance contracts
comparable?

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 31
167. The problem has also been highlighted in the study commissioned for
the preparation of the Mobility Development Plan, which recognised the
lack of a database of infrastructure unit prices that could be used for cost
forecasting. 29
168. The Transport Administration explained that it has compiled a more
detailed database of maintenance prices, and that the cost per kilometre of
maintenance is published on its website. According to the Administration,
unit prices are obtained because of procurement and differences in unit
prices between regions depend on volumes, the existing roads, regional
specificities.
169. In order to reduce the impact of unreasonable unit prices, the
Transport Administration has taken several measures, such as a more
detailed description of the technical specifications in procurement, a
review of the ratio between routine and periodic maintenance, and the
selection of the best tenderer based on quality in addition to price.
170. In conclusion, the National Audit Office considers that the
supervision of the performance of maintenance contracts in the Transport
Administration in relation to the increase in expenditure has been weak,
and the responsibility for the expenditure has bee n placed on the regional
managers of the Administration, who do not have to justify the increase
in expenditure.
171. The audit showed that the justification and the volumes of repair and
periodic maintenance works are not fixed with the contractor in advance
and are only revealed when the works are received, which does not allow
the National Audit Office to assess whethe r the works were justified and
whether the contractor performed the works in the required volume. Also,
the volume of the work to be ordered is not always clear before the
maintenance contract is signed, and the unit prices in maintenance
contracts sometim es differ multiple times.
172. Recommendations of the National Audit Office to the Director
General of the Transport Administration:
■ set thresholds for the cost of additional repair work ordered under
maintenance contracts, above which a new procurement must be
organised for ordering work.
■ Establish a database of unit prices in the area of infrastructure to
better forecast road maintenance costs and exclude tenders that
are too cheap.
Response of the Director General of the Transport Administration:
We will prepare and set limits on the cost of additional repairs ordered
under maintenance contracts by 01.01.2023 at the latest.
The Transport Administration has a database of the unit prices of
maintenance contracts, on the basis of which forecast budgets are
calculated. The Transport Administration will continue to compile and
29 Baseline study of the Organisation for Economic Co -operation and Development
(OECD) for the Estonian Transport and Mobility Development Plan 2020, available at
https://www.mkm.ee/media/6871/download .
What did the National Audit
Office find and what does it
recommend?

Sustainability of national road funding
32 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
update the database on unit prices and will clarify whether the data can be
processed and analysed more efficiently.

/digitally signed/
Ines Metsalu -Nurminen
Director of Audit, Audit Department

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 33
Recommendations of National Audit Office and responses of the auditee
On the basis of the audit, the National Audit Office made various recommendations to the Ministry of
Economic Affairs and Communications, and the Transport Administration. The Minister sent his
responses to the recommendations made by the National Audit Of fice on 11.08.2022 and the Director
General of the Administration on 28.07.2022.
Recommendations of the National Audit
Office
Responses of auditees
■ Funding for national roads
■ 89. Recommendations to the Minister of Economic Affairs and Infrastructure:
■ Initiate an amendment to the Road Traffic Act in such a manner that the road maintenance plan does not have to be approved by the Government of the Republic and include it in the Transport and Mobility Development Plan, in order to better ensure the planni ng of the state’s various transport networks and the monitoring of development trends and project implementation.
■ Until the Road Traffic Act stipulates that the road maintenance plan must be approved by the Government of the Republic, submit
– to the Government of the Republic regularly an overview of the implementation of the road maintenance plan, including the timeliness of the sites and their adherence to the budget;
– all construction and reconstruction projects to the road maintenance plan.
■ Analyse how to avoid the deterioration of the condition of the current national road network by reallocating funds between the measures in the road maintenance plan, where necessary.
■ Identify the financing opportunities (including long -term) and needs for public roads in conjunction with rail development plans, taking into account the current situation, and then set priorities that correspond to the opportunities.
■ Take into account the actual funding possibilities and the real need for road construction when ordering design. Avoid spending money on the preparation of projects that cannot be carried out with the approved funding and do not need to be fully built.
(points 36 –88)

Response of the Minister of Economic Affairs and Infrastructure: We will consider implementing the proposal. However, we would like to point out that the Transport and Mobility Development Plan is a long -term sectoral development document approved by the Riigikogu. The Transport Competitiveness and Mobility Programme, which sets targets for the quality of transport services within the limits of funding possibilities, can be seen as the operational programme of the Transport and Mobility Development Plan. The road maintenance plan, which takes funding options into account, is also a more detailed implementation plan than the programme, which highlights, among other things, longer funding needs as set out in the Transport and Mobility Development Plan 2021 –203 5, which the programme does not include. The road maintenance plan is, among other things, a document for monitoring the implementation of the objectives of the Action Programme of the Government of the Republic, playing an important role in aspects of nat ional security, regional policy implementation and environmental protection, thus influencing not only the Ministry of Economic Affairs and Infrastructure but also the functioning of other sectors.
The road maintenance plan is submitted to the Government of the Republic for approval, usually once a year. An overview of the implementation of the road maintenance plan so far, the main concerns and possible solutions will be given with the approval of t he new plan. The road maintenance plan to be presented in 2022 will outline the construction and reconstruction projects for the whole road maintenance period. The Ministry is certainly ready to submit to the Government of the Republic various overviews to gether with the information requested by the Government of the Republic.
This analysis will be carried out every year in when the road maintenance plan is updated, taking into account the volume of funds allocated to road maintenance. The road maintenance plan is prepared according to the principle of ‘preserve first, then deve lop’ in order of priority – maintenance, preservation and then development.
The maintenance of national roads is financed on the basis of the Road Traffic Act, according to which the amount of funding for road maintenance is set out in the state budget strategy and in the state budget for each financial year, which includes variou s sources of funding. In addition, under the Railways Act, the Government of the Republic approves an action plan to guide the development of the public railway infrastructure, with the aim of providing sustainable funding for the maintenance, renewal and development of the infrastructure needed to meet future mobility needs. Under the State Budget Act, a four -year budget strategy is drawn up, including sectoral programmes. The priorities and objectives for rail and road maintenance are reflected in the Tra nsport Competitiveness and Mobility Programme and correspond to the possibilities of the budget strategy. Long -term road infrastructure objectives and infrastructure priorities are set out in the Transport and Mobility Development Plan 2021 –2035, which, am ong other things, addresses all modes of transport and their interactions. Different financing options have been mapped out in the road maintenance plan for national roads and the action plan for the development of public railway infrastructure. The Minist ry of Economic Affairs and Communications, the Transport Administration and AS Eesti Raudtee are actively involved in EU targeted assistance programmes to improve railways, road maintenance and road safety (e.g. ITS, military mobility). Among other things, both long -term loans and the use of the public -private partnership model have been analysed and proposals have been made to the Government of the Republic.
■ Project selection
■ 114. Recommendation to the Director General of the Transport Administration: ensure that the agreed dataset and methodology for the

Response of the Director General of the Transport Administration: We confirm that the Transport Administration uses the agreed dataset and methodologies for the selection of sites for the road maintenance plan. We

Sustainability of national road funding
34 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Recommendations of the National Audit
Office
Responses of auditees
selection of sites for the road maintenance plan are actually used and that the selection of sites is documented and transparent at every stage.
(points 99 –113)
agree with the observation that the documentation of decisions needs to be improved. Therefore, we will review the methodologies for the selection of sites of all measures and will update the process of obtaining lists from the ranking in those methodologi es where this part is missing or unclearly described, with a deadline of 01.08.2023. As a quicker measure for the improvement of documentation, we will add additional justifications to the lists of sites to be approved as of 01.08.2022 if the procedure for the selection of sites is not described clearly enough.

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 35
■ Supervision of amendments to maintenance
contracts
■ 134. Recommendations to the Director General of the Transport Administration:
■ Establish the thresholds within the scope of which the decision in the case of an increase in the cost of a maintenance contract is made by a regional manager and when the price increases must be discussed in the road management plan working group of the Transport Administration.
■ Establish a common procedure for changing condition levels for all regions, based on traffic volume data.
(points 116 –133)

Response of the Director General of the Transport Administration: We will make the changes in the processes from 01.01.2023.
We will establish a single procedure in 2023 at the latest. In addition to traffic volumes, we also take into account other criteria that are relevant for the determination of condition levels.
■ Increase in the cost of maintenance contracts
■ 153. Recommendation to the Director General of the Transport Administration: establish clear rules within the Transport Administration on how, within which financial limits and on the basis of which data additional works within the scope of maintenance contracts are decided upon, and record additional works with justifications befo re the works are carried out.
(points 135 –133)

Response of the Director General of the Transport Administration: We will prepare and establish the rules by the end of Q1 2023 at the latest.
■ Volume of maintenance contracts
■ 172. Recommendations to the Director General of the Transport Administration:
■ Set thresholds for the cost of additional repair work ordered under maintenance contracts, above which a new procurement must be organised for ordering work.
■ Establish a database of unit prices in the area of infrastructure to better forecast road maintenance costs and exclude tenders that are too cheap.
(points 154 –171)

Response of the Director General of the Transport Administration: We will prepare and set limits on the cost of additional repairs ordered under maintenance contracts by 01.01.2023 at the latest.
The Transport Administration has a database of the unit prices of maintenance contracts, on the basis of which forecast budgets are calculated. The Transport Administration will continue to compile and update the database on unit prices and will clarify wh ether the data can be processed and analysed more efficiently.

Sustainability of national road funding
36 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Characteristics of audit
Audit objective
The aim of the audit was to find out whether, in a situation of decreasing funding for road development
and maintenance under the RMP and the SBS, the quality of existing national roads can be maintained
while meeting international commitments and building new TEN -T roads at the same time.
Assessment criteria
The National Audit Office is of the opinion that the funding model is effective if the development plans
and other strategic documents for maintaining and improving the quality of national roads (including the
SBS, the state budget and the SBS) reflect the objectives of maintaining and improving the quality of
national roads and there is stable and sufficient funding to achieve the objectives. In addition, the rules for
the preparation of the RMP and the management of changes, including roles and responsibi lities, must be
agreed.
The National Audit Office finds that the management of contract amendments by the Transport
Administration is effective if the Administration accepts the amendment of the public contracts for
development and major preservation projects only in justified ca ses, while respecting the limits set by the
Public Procurement Act; and if procedural rules have been agreed for informing decision -makers if the
RMP projects become more expensive or falls behind the agreed schedule.
According to the National Audit Office, the objectives set for the preservation and development of
national roads have been achieved and are achievable if the quality of national roads has not deteriorated
or will not deteriorate in the coming years for an y type of road, and the projects of the Trans -European
Transport Network have been implemented on schedule and the construction objectives are feasible.
Scope and focus of audit
The audited institutions were the Ministry of Economic Affairs and Communications, the Ministry of
Finance, the Government Office and the Transport Administration. In addition, a contract was signed with
OÜ Positium, which analysed traffic volumes on Eston ian national roads using mobile positioning data.
The result of the work done by Positium is the dataset of annual average daily traffic volume on the entire
Estonian road network.
Table 1. People interviewed in the course of the audit
Agency Interviewed
Ministry of Economic Affairs and Communications Julia Bergštein, Head of Road Division
Transport Administration Erki Ernits, Head of Mobility Planning Department
Mehis Leigri, Head of Infrastructure Asset Management Department
Martin Lengi, Director of Mobility Planning Division
Urve Õis, Senior Budgeting and Strategy Expert
Janar Tükk, Head of Road Infrastructure Construction and Maintenance Department
Janno Sammul, Head of Design Department
Jaan Tarmak, Head of Road Infrastructure Development and Standards Department
Jaan Ingermaa, Asset Management Expert at Road Infrastructure Asset Management Department

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 37
Elmar Aruja, Principal Analyst at Road Infrastructure Asset Management Division
Erkki Vaheoja, Head of Road Management Department
Government Office Triin Reisner, Advisor at the Strategy Unit of the Government Office
Ministry of Finance Rando Kängsepp, Advisor at Strategy Division
Tallinn University of Technology Ain Kendra, Road Engineering and Geodesy Research Group
Estonian Infra Construction Association Sven Pertens, Chairman of the Management Board
AS Teede Tehnokeskus Taivo Möll, Director
Stanislav Metlitski, Head of Intelligent Transport Systems and Road Information Systems Department
Marek Truu, Head of Development and Research Department

The following documents were analysed during the audit:
■ EU TEN -T Regulation, its draft amendment and the positions of Estonia on the draft amendment;
■ sectoral legislation and its explanatory memoranda, in particular the Road Traffic Act;
■ sectoral development plans, programmes and action plans and their performance reports;
■ Estonian state budgets and state budget strategies, and their explanatory memoranda;
■ approved road maintenance plans and lists of sites of development and preservation measures since
2014;
■ Action Programme of the Government of the Republic 2011 –2015, 2016 –2019 (including
amendment), 2019 –2023, 2021 –2023;
■ Data from the Ministry of Finance and the Ministry of Economic Affairs and Communications on
road maintenance funding since 2014;
■ Strategic Analysis of National Roads in 2011, AS Teede Tehnokeskus, 2011;
■ strategic Analysis of the Funding Needed for Maintenance of National Roads 2019 –2048, AS Teede
Tehnokeskus 2019;
■ Memos of the joint meetings of the Ministry of Transport and the Ministry of Economic Affairs and
Communications in 2021;
■ Records of the investment committee of the Transport Administration;
■ Rules and regulations of the working groups of the Transport Administration;
■ Methodologies of the Transport Administration for selection of sites for preservation measures;
■ Road Register Data 2006 –2021;
■ ISKE Audit Report of the Road Register, FocusIT, 2019;
■ output tables from the analysis of the selection of preservation measures in the EPMS, which was the
basis for the Road Maintenance Plan for 2018 –2022;
■ effective maintenance contracts and their amendments;

Sustainability of national road funding
38 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
■ Reports and records of routine and periodic maintenance and repairs in Võru, Põlva, Pärnu and Keila
maintenance areas;
■ Reports of road maintenance audits of the supreme audit institutions of Baltic and Scandinavian
countries;
■ survey of the National Audit Office on road maintenance funding among the supreme audit
institutions of Baltic and Scandinavian countries (Latvia, Lithuania, Finland, Sweden and Norway).
Time of completion of audit
The audit activities were carried out from November 2021 to April 2022.
Audit team
The audit team consisted of Audit Manager Silver Jakobson and auditors Kristiina Visnapuu, Silja
Einberg and Meeli Saksing.
Contact information
Further information on the audit is available from the Communication Unit of the National Audit Office
telephone: +372 640 0704 or +372 640 0777; email: [email protected]
An electronic copy of the audit report (PDF) is available online at www.riigikontroll.ee .
A summary of the audit report is also available in English.
The number of the audit report in the record management system of the National Audit Office is 80086.
The postal address of the National Audit Office is:
Kiriku 2/4
15013 TALLINN
Telephone: +372 640 0700
[email protected]

Sustainability of national road funding
Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022 39
Previous audits of the National Audit Office in the area of financing and
maintenance of state roads
03.02.2012 – Road maintenance and supervision of road maintenance
22.11.2013 – Renovation of main national roads
30.11.2017 – Financing public functions from European Union support

All reports are available on the website of the National Audit Office at www.riigikontroll.ee

Sustainability of national road funding
40 Report of the National Audit Office to the Riigikogu, Tallinn, 12 September 2022
Annex A. Sample of public contracts for sites of development and preservation
measures
The National Audit Office selected a random sample of sites costing more than 1 million in 2014 –2020 to
analyse the costs and changes in the public contracts for sites of development and preservation measures.
This included making sure that the sites did n ot all end up in the same region, and that sites completed in
different years were included.
Road
No
Measu
re
Name of
road
Initial
starting
kilometre
Initial end
kilometre Year Type of work
Owner
supervis
ion
Contract
or
3 Preserva tion Jõhvi -Tartu – Valga 109.60 118.97 2015 Reconstruction of paved road
Teede insenerid OÜ YIT Infra Eesti AS
11412 Preserva tion Liikva – Rannamõisa 0.00 5.16 2020 Reconstruction of paved road Lindvill OÜ Trev -2 Grupp AS
43 Preserva tion
Aovere – Kallaste – Omedu 30.72 40.80 2017 Reconstruction of paved road Sweco Projekt AS Trev -2 Grupp AS
2 Develop ment
Tallinn -Tartu – Võru – Luhamaa 188.55 191.50 2015
Construction of a completely new paved road
Taalri Varahaldu se AS Nordecon AS
11 Develop ment Tallinna ringtee 0.65 2.87 2018
Construction of a completely new paved road
P.P. Ehitusjärelevalve OÜ Nordecon AS
5 Develop ment
Pärnu Rakvere – Sõmeru 74.70 75.60 2015
Construction of a completely new paved road
Teehoiu Partnerid OÜ YIT Infra Eesti AS