Letters

Joint letter to the European Commission on funding CEN budget

Joint letter from the Group of Representative Bodies to the Commissioner in charge of Internal Market, Industry, Entrepreneurship and SMEs

Dear Ms BieĊ„kowska,

The Railway Sector is very active in supporting both the European Railway Agency and ‘CEN-CENELEC-ETSI’ for the development of the Interoperability and Safety regulations and the European technical standards.

When it comes to railway standardisation, it is the sector in its widest sense (railway undertakings, infrastructure managers, suppliers, users...) that invests a significant amount of time and effort (including its own experts) in standards development and the subsequent purchase of those standards and thereby covers about 95% of the total cost of standardisation works for rail in Europe.

Standardisation is a very important support for the internal market and also for business competitiveness. Rapid technological changes in our sector require a flexible, responsive and business-focussed standardisation system. This is essential to the competitiveness of rail not only in Europe but also on global markets and for that we want to promote initiatives that improve its efficiency.

New Approach Consultants employed by CEN_CENELEC are identified by the sector as a key contributor for the quality and efficiency of the standardisation process in our sector whilst helping to reduce the delivery time of the standards. Their work is complementary to that of the sector and they guarantee consistency between the voluntary standardisation structure and the regulatory framework managed by the European Railway Agency.

The availability of these New Approach Consultants was however interrupted during the first 7 months of 2014, and currently, we understand, the work on standardisation is again interrupted for an undefined period due to negotiations between CEN_CENELEC and your services on the budget for these New Approach Consultants.


Joint letter to the European Commission on the setting up of European Fund for Strategic Investments (EFSI)

Open letter on the Commission proposal for a Regulation establishing a European Fund for Strategic Investments

The undersigned stakeholder associations (CER, EBU, EFIP, EIM, ERFA, ESC, ESPO, ESO, INE, UIP, FEPORT, UIRR and UNIFE) highlight the important need for investment in transport infrastructure. In the TEN-T Guidelines, the European Parliament and Member States have agreed on a policy that is to guide decisions as to which transport projects should receive funding as a matter of priority. According to the 2011 Transport White Paper, more than EUR 1.5 trillion will be needed in the period 2010-2030 to develop transport infrastructure to match demand.1 Therefore, we strongly welcome the initiative of “An investment Plan for Europe” and are ready to support all efforts towards a renewed European economic boost through investments in key infrastructure projects.

Nonetheless, we would like to draw attention to three major concerns we have regarding the current proposal:

  • The EFSI budget will drastically limit the CEF envelope for grants.
  • Investments under EFSI will not follow the TEN-T priorities for funding of transport infrastructure and the prioritization as defined in the Corridor approach.
  • The money transferred to the EFSI is not ring-fenced for transport investments.

Of the EUR 8 bn that are to be taken out of the EU budget for the new guarantee fund, EUR 2.7 bn are to come from the transport envelope of the Connecting Europe Facility (CEF), in particular from the headings “Removing bottlenecks, enhancing rail interoperability, bridging missing links and improving cross-border sections”, “Ensuring sustainable and efficient transport systems” and “Optimising the integration and interconnection of transport modes and enhancing interoperability”. This means that the overall sum available for grant funding of transport projects (in non-cohesion countries) is cut by more than 18% by the EFSI proposal. The existing CEF envelopes for financial instruments and transport investments in cohesion countries remain untouched.

Joint letter to Italian National Safety Authority on NIB recommendations following Brixen accident

Joint letter from ASSOFERR and UIP to ANSF – Italian National Safety Authority

UIP, the International Association of Wagon Keepers and ECMs, shares your opinion that the derailment in Brixen and, in particular the results of the investigation process, are relevant and require thoughtful discussions at European level. However, having read the NIB report, we are very surprised about the conclusions and especially your requests towards RUs which are partly in contradiction with the ANSF requests in 2012 (12/07299 and 12/07875).
 

We reiterate our concerns that despite the entry into force of legislation 445/2011/EC on a system of certification of Entities in Charge of Maintenance for freight wagons, many National Safety Authorities still focus only on Railway Undertakings for ensuring safety. We are facing again a situation where a letter concerning “vehicle maintenance processes” is addressed to RUs without taking into account the existing ECM responsibilities (Art. 14 (a) of the Safety Directive)) and their defined role, i.e. ensuring “that the vehicles for which it is in charge of maintenance are in a safe state of running by means of a system of maintenance”. This may result again in non-manageable requests by RUs to ECMs, as the former may feel responsible (e.g. supported by the content of your letter) for a part of the safety processes they don’t need to manage and for which they have no information.