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Administrador de Infraestructuras Ferroviarias

ADIF

Adif is the administrator of railway infrastructures in Spain.

Lobbying Activity

Meeting with Kai Tegethoff (Member of the European Parliament)

17 Sept 2025 · Rail Infrastructure

Response to Connecting Europe through high-speed rail

7 May 2025

ADIF, the Spanish Railways Infrastructure Manager, welcomes the upcoming Communication on Connecting Europe through High-Speed Rail. The targets to double HSR traffic by 2030 and triple it by 2050 are ambitious and necessary to meet EU climate, security, and competitiveness goals. Infrastructure Managers (IMs), as owners and operators of railway infrastructure, are essential partners in making this vision a reality. To ensure successful implementation, ADIF calls for a comprehensive framework addressing the following enablers: Avoiding islands: There are already three major high-speed rail national networks in Europe; linking them should be the first step in the creation of an European network. Interoperability and technical harmonization: Accelerated and harmonized deployment of ERTMS and technical standardization to overcome fragmentation. The EU must also recognize the importance of national projects with a strong cross-border impact and include them in funding priorities. Dialogue with stakeholders: Especially with railway actors and other modes of transport, promoting the visibility of communication and information exchange mechanisms from institutional, commercial, and technical perspectives. Funding:A long-term EU funding perspective, extending across multiple MFFs, is essential to give projects stability. Continued CEF grants should remain the backbone of support (particularly for cross-border links and ERTMS), prioritising cross-border links, critical missing links and bottlenecks, while avoiding narrow or artificial definitions. To reinforce financial sustainability, clearer guidance on PPPs, equity instruments and innovative tools like the EU Savings Market or green bonds is needed. EU co-funding should cover not only new HSR lines, but also the renewal and major upgrades of existing HSR infrastructure. Operational costs must be considered, with sufficient TAC flexibility for IMs to recover them under the user-pays principle. Implementation: Improve cross-border planning and coordination procedures and maintain an appropriate and stable legislative framework (especially in environmental and procurement matters). Strengthen governance (via TENtec, CINEA) to address long delivery times and rising costs is needed. Cross-border synchronization in corridors in necessary. Procurement framework: Ensure flexible mechanisms to adapt contracts to project needs (modifications, price revisions, etc.). Resilience and sustainability: Ensure that high-speed rail investments are climate-resilient, with a life-cycle approach and incentives for energy efficiency. The positive environmental impact of rail should be fully recognized in tax and state aid frameworks. Security and dual-use capabilities: Dual-use planning should be integrated in HSR network, ensuring that key corridors meet civil and defence mobility needs. Projects should integrate defence-related requirements, including accessibility and interoperability, volume and weight capacity, durability, defensibility, reparability. Infrastructure must be designed to withstand cyber and physical threats in a more challenging security environment. Energy: Collaboration in renewable energies and targeted investment to reduce dependence on non-clean sources. Workforce development: Address the labor shortage in the railway sector by supporting training and attracting new generations. Supply chain: Improve the growing imbalance between demand and the supply market in terms of planning and construction of railway projects, especially in areas such as signaling and telecommunications.
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Response to Technical specification for interoperability relating to the telematics subsystem of the rail system

14 Mar 2025

Adif welcomes and considers positive the initiative to increase the share of rail transport that digitalization can bring. In addition, it should be mentioned that we are working, as other stakeholders, for a long time on the implementation of the current TAP/TAF TSI regulations. We would like to take the opportunity of the Public Consultation to present our comments. It is necessary to highlight that in 2022 the ERA presented his recommendation, with the involvement of the sector, but the Commission did not consider. The Commission has presented a new proposal (after 7 version) without considering important recommendations from the sector. Therefore, the draft maintains several measures that are not supported by most of the stakeholders. Although it is a recurrent complaint that has been communicated, it is reminded that the Commission's proposal exceeds the mandate, especially about data sharing.In agreement with what has been discussed in the meetings of the sector's representative groups, in particular with EIM, 4 major risks are observed arising from this text if they are not corrected: Risk of non-compliance The implementation deadlines are not realistic and consistent, and many concepts of the new measures are still vague and proposed solutions lack maturity. Risk of discouraging the sector The proposal represents a paradigm change not only affecting the investment done by sector in the implementation of current TAF/TAP TSI; also due to new system requirements (including API/Web Services). Risk of paralysis of investment: in connection with the above risk, it is possible that stakeholders may be predisposed to a paralysis or at least a deceleration of investments due to uncertainty. Also take in mind the possibility to loss the previous/current investment. Risk of financially overburdening the sector: It is estimated that the costs derived from the regulation would be significant. Although they cannot be accurately assessed because not all the requirements and concept are clearly identified and explained. Risk of reversed modal shift: As IM we cannot forget that due to the above-mentioned risks, we are worried that a reduction of traffic in our network could impact our business. In that sense, to make public the rail operator traffic data could transfer the transport from rail to another mode. While in the current TSI´s TAP and TAF it was defined and understandable WHO should send WHAT MESSAGE to WHOM, in the draft of the new regulation terms such as "share", "make available" or "grant access" are frequently used, which is unclear, confusing and impossible to comply with without clear and detailed instructions. In line with this, the proposal to create new actors (rail facilities operators), and is not clearly define the link and processes among them, which is fundamental to establish a flow of the information (goal of the telematic). Make data publicly available could be not in line with SERA Directive, due to the IM must guarantee the confidentiality of the information. SERA directive gives obligations to the infrastructure managers for providing services and charging fees to railway undertakings. Data can be part of the minimum access package and package 2 and 4 (this information is for the RU according to Annex 2, not for all entities and free). In the draft TSI Telematics there are obligations to provide data free of charge. This contradicts the SERA directive. We wish to raise the article 20 about the National Coordination Point. The infrastructure manager should not be appointed and not assume these responsibilities. IM does not have the legal competences or power to deal with this. IM could be a station manager / railway service facilities operator, so could be a conflict of interest. Also, implies additional resources. In summary, the TSI Telematics should give realistic implementation and should be aligned with other European legislation. For rail specially with SERA and future Capacity Regulation
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Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail

17 Nov 2023

We appreciate the commitment made by the Commission to improve and make rail transport more competitive. The proposal aims to harmonize the criteria on capacity allocation, but also and not less important, to another basic activity of the rail such as traffic management, proposing for this activity also a standard framework especially in the case of incidents affecting cross-border services. We agree and positively valued the new role of the infrastructure manager. It is right to value and strengthen its role, since one of the characteristics of the rail infrastructure manager is to be an entity with the ability to integrate and coordinate the interests of the different stakeholders involved in the rail transport chain. Integration of interests that also allows the railway network to be managed in the most efficient way. Especially in the case of shortage or congestion, with the criterion of non-discrimination in access to the infrastructure being a key element. It is therefore a challenge for the infrastructure manager to collaborate in making rail transport more efficient, collaborating in achieving the objectives of the European Green Deal and the Sustainable and Smart Mobility Strategy, However, the Commission's proposal creates a more complex governance scenario, and should be cautious to avoid causing inefficiencies, especially in the capacity allocation processes and in the relationships between all the players in the Railway System. In this sense, among other points, it is necessary to clarify the legal nature and responsibilities of the future ENIM, which is a key actor in the new governance model. We do not consider necessary incorporate others new European entities different of those already included in the proposal, such as a kind of an EuroControl for rail. In the attached document you will find in detail some points that we consider of relevance and that if taken into account, in our opinion on certain articles of the proposal that we understand that if considered would result in an improvement of the railway system. However, We would like to briefly anticipate the following points: 1. Methods for allocating capacity: Different methods for allocating capacity should be used in accordance with the infrastructure manager necessities. Not all of them should be considered as a right for the RUs. Rolling Plan method for capacity allocation needs further development and definition. 2. Priority criteria: The socio-economic criteria must be, on one hand, flexible enough to adapt to different national realities and, on the other hand, capable of assigning non-discriminatory priorities within the same market segment. 3. Compensations: We think there is not a complete definition of what compensation is, and what can be considered a modification of capacity rights. So as result, this can lead not just to economic losses but legal claims. 4. Regulatory oversight: We expected greater involvement and role of the ENRRB in order to prevent discrepancies in the interpretation of the European framework by different national regulators. Could a decision taken by ENIM be accepted by some national regulators but challenged by others? 5. Economic equilibrium test: We would like to introduce a reference in the text to the entry of new applicants in the market when a PSO traffic exists. This reference should include the mandatory deadlines for guaranteeing legal certainty for all parties involved: Applicant shall inform IM and Regulator at least 18 months before the entry into force of the working timetable and the regulator must make a decision on economic balance before the end of the deadline for receipt of capacity requests 6. IT Tools: IMs has IT systems for capacity and traffic management. Their substitution should be made only after a CBA and investments should be protected. Harmonization can be achieve with coordination and data exchanges according to TSIs, avoiding adding complexity and additional cost.
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