CER – UIP – ERFA comments on the consultation - Swiss federal law on railway noise
CER, UIP and ERFA understand and support the intention of the Swiss government to reduce the problem of railway noise and speed up the processes of retrofitting the old and noisy brake block types of freight wagons. However, the measure foreseen (de facto ban of cast-iron brake blocks by January 1st 2020) in the draft law would cause severe problems for the European single market and will create intermodal as well as intra-modal distortion of competition.
CER, UIP and ERFA strongly believe that noise reduction measures should respect the single market. The ban of cast iron brake blocks as foreseen by the federal law from 2020 on would be a barrier to the single market.
Contrary to what is stated in the explanatory note of the Swiss Federal Office for Transport (BAV), it is unlikely that enough wagons and type of wagons (i.e. non-Swiss) will be equipped with composite brake blocks by 2020 in order to compose trains within, to, from and through Switzerland containing silent wagons only. Given the high percentage of non-Swiss wagons (50%) used today for the supply of Swiss shippers (import, export, internal) or running in transit through the country, the actual amount of wagons complying with the provisions laid down in the TSI Noise, the potential capacity of the manufacturing industry for new wagons and the difficult economic situation in general and of rail freight operators in particular it is even too optimistic to expect that the number of new wagons reaches 100 000 in 2020 (only 50% of the amount assumed by the BAV).
Furthermore it will not be economically possible for current foreign wagons to be retrofitted in time. In fact, it will prevent the majority of European wagons to be operated within, to, from or through Switzerland. As a result, rail freight traffic through or within Switzerland will most likely be negatively affected, with a massive impact not only on customers and foreign undertakings but also on Swiss railway companies which operate trains and foreign wagons.