Facilitating the interoperability of trains within the different European national networks and supporting the current trend towards the complete liberalisation of the railway market are the two major directions on which international rail associations and bodies are focusing their attention. A recent interim report elaborated by the European Railway Agency (ERA) provides an analysis of the current situation of the rolling stock mutual recognition process, so that railway transport operators would become aware of the aspects that need to be approached in order to improve the authorisation processes and maximise mutual recognition opportunities. The problems raised will be considered in the future “steps to follow” on the best practices for vehicle authorisation.
The revision of the Directive on Interoperability, 57/2008, aims at rendering a clearer process of vehicle authorisation for placing in service (PIS) as well as the consideration of different particularities, such as new vehicles, upgraded vehicles, types of vehicles, vehicles under TSI regime or vehicles under national rules, vehicles authorised to run on Trans-European networks (TEN-T), vehicles authorised to run on non-TEN-T networks, vehicles authorised to run on national networks or on various networks in the Member States and additional authorisations.
Other important objectives of the Directive revision are reducing bureaucratic barriers, simplifying the process of vehicle authorisation for placing in service, as well as the application, if possible, of the mutual recognition principle when a vehicle has already been authorised for placing in service in a Member State. It is very important that other Member States should not appeal to national rules in order to impose useless and redundant verifications, except for the situation in which they are strictly necessary to check the technical consistency of the vehicle with the relevant network. To reach these objectives, it is very important to share experience and know-how on the vehicle certification process and to identify a list of problems that need to be considered in order to facilitate the application of the revised Directive.
This interim report shows the conclusions of the authorisation for placing in service, based on information from EU-25, Norway and Switzerland. Present and future processes have been analysed by ERA with the cooperation of the national safety authorities (NSA), as well as sector authorities. “Liberalisation, interoperability and the free traffic of railway vehicles are common points of the same strategy”, declared Mauro Moretti in 2009, when he took over CER’s presidency. The questionnaire elaborated by ERA revealed an increase in the number of vehicle authorisations for placing in service during 2004-Q 2 of 2009. With the help of the organisations from the railway sector, the Community of European Railway and Infrastructure Companies (CER) and the Union of European Railway Industries (UNIFE), ERA was able to estimate the following data for 2016. During 2010-2016, the number of authorised vehicles is expected to grow globally by 1.2% per year. The number of vehicles manufactured according to their type is very low, with an average of 44 vehicles per class, while the interface of the authorisation process is complex and different from one state to another, shows ERA’s interim report published in April.
Bilateral meetings between ERA and the National Railway Safety Authorities (supported by sector organisations) and the result of the study, clearly show that processes, tasks and responsibilities vary based on a series of reasons. One of these reasons refers to the checking bodies having limited or multiple roles (Notified or Designated Bodies); a second reason is the difference between the national legal frameworks in what concerns the placing in service of vehicles. ERA has studied the mutual recognition of vehicles with other transport modes, such as air, maritime or road. By comparison, even if legislation, market players and processes are different in this aspect, the principle of mutual recognition of approved types, certifications, checking bodies is widely established for air, road and maritime (within EU or internationally) but is in its infancy for rail, shows the report published by ERA. The same bilateral meetings between the Agency and safety authorities have revealed several activities that drive additional costs, such as on-board Control Command Signalling (CCS) for the modification of existing and/or the additional vehicles for their placing in service. The cost section also includes electro-magnetic compatibility, running dynamics and pantographs. ERA will carry out further investigation to identify other parameters that are believed to generate additional costs.
Legal incongruities in Member States generate further costs in industry
ERA collected further data based on CER’s support (the responses to this survey came from less than 10% of CER members). The data collected covered the period 2010 – 2013 and is based on expected deliveries of all types of vehicles to be placed into service by the responding railway company. UNIFE provided data covering 19 countries in the European railway area. The data come predominantly from railway manufacturers and are based on several selective criteria for the period 2008-2016, as follows: 2008-2010, a list of projects will be elaborated based on member information, bank information and consultancy studies; the period 2011-2013 will include medium-term forecasts based on projected volumes, while during 2014-2016, long-term forecasts will be elaborated based on projected volumes.
“The European railway sector appreciates the mutual recognition principle and the technical harmonisation of rolling stock, as well as the establishment of clear deadlines and criteria based on which the authorisations are released, including the ‘automated authorisation’ procedure. CER also welcomes the provisions concerning the type of vehicles and the necessity of a reference document where national rules will be carefully and frequently arranged”, Libor Lochman, CER Deputy Executive Director, said on the occasion of the European Parliament’s vote for the interoperability Directive.
“Significant progress in the field is expected generated, on the one side by the harmonisation of safety certificates for railway companies and the introduction of the Joint Safety Methods and on the other side by the amendments brought to the Interoperability Directive that will impose the mutual recognition of national rules for vehicle authorisation for placing in service”, former European commissioner for transport, Antonio Tajani, commented on the revision of the Interoperability Directive.
Current requirements for vehicle authorisation can be found in a series of written documents, while others are still “unwritten”, to a certain extent unofficial, the Member State in cause deciding whether to observe these requirements or not.
This creates uncertainty for the applicants. According to ERA’s interim report, it is intended that this will be resolved by the establishment of a Reference Document which will collate and make public all the national requirements for vehicle authorisation whatever their documentary origin.
Constant changes in the legal framework (new national legislation, amendment of European Directives, entry into force or revision of TSIs, new EC Decisions, etc.) result in a learning process for all actors and additional costs for the industry. New organisations with new roles and responsibilities, new documentation and new processes need to be managed. During transition to European standards this leads to discontinuity, uncertainty and cost for the railway sector. These directions represent some of the concerns expressed by railway market players in the study conducted by ERA and then rendered in the Agency’s report. It is clear that there are significant differences in interpretation of core parts of the Directives among the Member States, such as the concept of “authorisation to place into service”, which is differently understood. Also, the scope of authorisation is different among Member States, the threshold of releasing a new authorisation is differently interpreted, as well as the threshold for a new authorisation, ERA believes. The Agency will carry on its studies and research work together with its partners so far, work groups and Member States. A final report will be published in the fall of 2010.
by Elena Ilie
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