Position papers

GRB Position on the route compatibility check

This position paper sets out the Group of Representative Bodies’ (GRB) view on the general principles for the route compatibility check (RCC) before the use of authorised vehicles as outlined in Article 23 of the Interoperability Directive (EU) 2016/797. 


The Group of Representative Bodies asks the European Union Agency for Railways to adopt the RCC principles set out in this paper. The GRB asks for clear guidance documentation to be developed by the Agency for how the route compatibility process should be implemented in the day to day business where appropriate, either in a dedicated RCC application guide or in a section of existing guide documents.

The two concepts of technical compatibility with the network on one hand (article 21) and route compatibility on the other hand (article 23) as laid out in the interoperability directive shall be respected and kept separately. However, clear guidance is necessary to understand the content and responsibilities included and to ensure the route compatibility check performed by the railway undertaking is as easy, lean and straightforward as possible.

GRB-SFR Sector Vision for the Future of Reference Standards

The Group of Representative Bodies (GRB) and the CEN/CENELEC/ETSI Sector Forum Rail (SFR) published a position paper to set out the railway sector’s vision for how referenced standards within the Technical Specifications for Interoperability (TSIs) should be managed in the future. 

 

The proposal described in this paper aims to solve challenges faced in the sector today when applying TSIs and European standards during the conformity assessment process. The aim of the proposal is to introduce a process which allows the sector to benefit from regulatory stability while at the same time being able to apply the state-of-the-art standards.
The GRB and SFR asks the European Commission (EC) and the European Union Agency for Railways (ERA) to consider this position paper and to reflect on how the future regulatory framework for the railways can be adapted to work better for the sector and for society.

Joint position paper on the revision of the CT directive

Views of the Transport Sector on the revision of the Combined Transport Directive


Ahead of the European Commission High-level Conference on European Multimodal Freight Transport in Sofia on 20th March, UIP, along with 11 road and waterborne associations under the IAM Alliance, co-signed a position paper on the proposed revision of the Combined Transport Directive. For UIP, the new proposal of the CT Directive must pave the way for efficient intermodal and multimodal freight services offering level playing field for all modes of transport and promoting better the mode alternatives to suppliers, users and customers. You will find hereunder some of our proposals which we used to launch the Sector discussions and which we already sharedwith the Bulgarian Presidency and MEPs in Brussels.

We are greatly concerned that the new proposal does not guarantee more and new traffic between road and other modes of transport. Instead, it shows a positive discrimination of combined container transport, and creates additional administrative burden which will create extra costs for the Member States and the transport Sector.