Position papers

GRB Position Paper on ERA Linguistic Arrangements

A clear linguistic regime is essential for the Agency in the design of its processes for its new tasks, more particularly in the way all the actors involved in the processes will coordinate to ensure that these processes are efficient, consistent and safe to the benefit of all these actors.
In the absence of a specific Board decision, the linguistic regime of the Community applies also to the European Union Agency for Railways i.e. Regulation 1/1958 ‘determining the languages to be used by the European Economic Community’.
The regulation foresees that :

  1. The official languages of the Institutions shall be the 24 EU Member States languages.
  2. Documents which a Member State or a person subject to the jurisdiction of a Member State sends to institutions of the Community may be drafted in any one of the official languages selected by the sender. The reply shall be drafted in the same language.
  3. Regulations and other documents (including the OJ) of general application shall be drafted in the official languages.
  4. The institutions may stipulate in their rules of procedure which of the languages are to be used in specific cases.

Based on all the inputs collected in the different workshops and the discussions within the Management and Executive Boards (June and September 2016), the Agency made a proposal for linguistic arrangements in four articles. In the light of the vote during the 40th meeting of the Agency’s Management Board, the Group of Representative Bodies (GRB) hands over a Position Paper on “Linguistic Arrangements” where it agrees only partially to the European Union Agency for Railways’ proposaland the outlined key principles.
GRB fully underlines the general need to make railways and the sector more efficient and to reduce costs. A sound approach to the linguistic arrangements (with preferably one reference language only) will contribute to cost reduction, efficiency and clarity. The 4th Railway Package’s Technical Pillar paves the way to cheaper and more efficient processes. This goal shall not be endangered by complicated language provisions and linguistic arrangements that hamper lean processes and inevitably let costs explode in the end.
In GRB’s opinion all meetings including the meetings of the Management and the Executive Board and the NSA, NIB and NRB plenaries organised by the Agency shall be in English. Exceptionally and upon special written request the NSA and NIB plenaries could be organized additionally in French and German as the two other reference working languages except if other common working language(s) can be agreed between all involved participants to the meetings. All documents shall be in English.

UIP position paper on wagon performance

Provision of Vehicle Performance Data

UIP regularly points out the high importance of vehicle performance data for Wagon Keepers and ECMs around Europe. It has previously formalised its general demand on vehicle performance data in its Position Paper on a European Strategy for an Efficient Exchange of Rolling Stock Data in Rail Freight (July 2013). UIP still believes that complete vehicle performance data in high quality is an important input to assure compliance of ECMs with highest standards of vehicle maintenance and to improve efficiency of vehicle maintenance systems.

Although legal requirements within both the TSI (TSI OPE and the ECM Regulation exist, today’s legal framework falls short of saying clearly which data should be exchanged and how. The attempts to use a contractual basis (such as the GCU) to ensure that all parties involved in the maintenance process exchange relevant information have failed due to complex authorization discussions over data access rights, a lack of standards for data quality and formats and a fear of loss of proprietary information related to traffic patterns. Only very few Railway Undertakings deliver vehicle performance data to Wagon Keepers/ECMs, and those who do, take no responsibility for data quality and completeness.

Furthermore, since 2012 and following the recommendations of the EC Task Force on Telematics Applications, limited progress has been made towards achieving a common European solution for the mileage calculation for Rolling Stock (see recommendation 12 of 08/57-DV61EN01, handled at RISC53).

UIP believes that the time has come to demand a revision of the legislation applying to data exchange in order to achieve a coherent and full territorial coverage of performance (input) data exchange for freight vehicles.
This paper formulates the following demands for the provision of vehicle performance data and addresses the European Commission, Rail Safety Authorities and Sector Organisations.

UIP position paper on noise reduction

The International Union of Wagon Keepers (UIP) recognises that noise is the most significant environmental burden of rail that affects not only society, but also the performance and perspectives of the whole railway system around Europe. With that in mind, UIP fully understands and supports the objective of reducing rail freight noise, but calls for a unified approach on Noise reduction at European level.

This position paper stresses the importance to carefully consider the impact of any future EU legislation and both future and existing national rail noise abatement programmes on transaction, operational and maintenance costs for the rail freight sector. Despite the fact that the level of concerns with regard to rail noise actually differs amongst the Member States, if we want to see a reduction of noise emissions in rail, without jeopardising further rail freight competitiveness and efficient cross border traffic, UIP asks for appropriate funding, suitable incentive schemes and harmonised implementation across Europe in order to promote the retrofitting of the existing wagons fleet.