Position papers

UIP position paper on data exchange

Position Paper on a European Strategy for an Efficient Exchange of Rolling Stock Data in Rail Freight

 

UIP generally supports the goals expressed by the European Commission concerning the development of a Single European Railway Area, especially removing administrative and technical barriers and developing easy and common procedures at European level. This is particularly critical and important when it comes to the question of registers.

Following the work of the ERA Task Force on Telematics Applications and in parallel to the discussions on the TAF revision, it became evident that due to the existence of numerous registers for Rolling Stock, there is a need for a register architecture at European level. Most recently at the RISC66 held on January 23 and 24, 2013 in Brussels, Mr. Patrizio Grillo of DG MOVE reminded of the importance of the registers and invited the sector to consider alternative and best scenarios for each register.
UIP sees this as an opportune time to make public its views and recommendations on “how operational databases such as RSRD² could fulfill the sector’s needs for operational data and how such databases could interact with the registers” (as mentioned in DV61EN01 – Recommendation 5, presented and discussed at RISC63).

In the following position paper, UIP presents a recommendation for an efficient, low-cost solution to registers dedicated to Rolling Stock Data. This Position Paper is addressed to the European Commission with the aim to have it taken into account in the preparation of the new ERA Working Party on vehicle registers which is to be launched in September 2013.

Joint position paper on noise abatement and Swiss ban

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.



 

Joint position paper on a new role for the European Railway Agency (ERA)

CER, UNIFE, ERFA and UIP position on the Future role of ERA

 

One of the key targets of European transport policy is to achieve a Single European Railway Area. For this purpose four key objectives shall be pursued:
• Promoting the development of effective rail infrastructure;
• Establishing an attractive and genuinely open rail market;
• Removing administrative and technical barriers and developing easy and common (Member States neutral) procedures on European level;
• And ensuring a level playing field with other transport modes

In this context, CER and UNIFE call for setting the strategic target of aiming at achieving the single European railway area by incrementally establishing a single European railway vehicle authorisation. The Regulation establishing a European Railway Agency [(EC) No 881/2004] should be correspondingly amended. This is perfectly in line with the Commission objective of removing administrative and technical barriers, whilst contributing to establishing an attractive and open rail market.

In the first place however there is a strong need for the European Commission to push Member States to effectively transpose the Safety & Interoperability directives.
Two decades after the decision to revitalise European rail transport, and more than a decade after the publication of the first Directive on the Interoperability of the European railway system, the legal framework of the European railways has been deeply transformed.

In spite of this, we still face problems based on the gap between theory (the legal framework) and practice (diverging application by Member States).

Thus, in spite of the implementation of a basic legislative framework for the interoperability and safety of the European railway system, interoperability is still far from being achieved and measures have to be taken to reach this objective sooner, with all actors acting in a harmonised way.

It can be expected that a harmonised system will be reached step-by-step together with an increase in the quality and quantity of specifications as well as of the scope of application – while nevertheless taking into consideration economic realities. Interoperability is – to a large extent – “cross acceptance” and a “single process for placing into service of vehicles”. When looking at existing and long-lasting infrastructure subsystem/constituents, they will not meet the specifications for interoperability for another decade or even more - until they are renewed or upgraded.

A single European railway area cannot therefore be achieved without developing ERA’s role and without accelerated application of the TSIs through the extension of their geographic scope and the consequent reduction in national rules, coupled with more effective ERA engagement with the National Safety Authorities and the Member States.