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Community of European Railway and Infrastructure Companies

CER

The Community of European Railway and Infrastructure Companies represents the interests of the European rail sector.

Lobbying Activity

Meeting with François Kalfon (Member of the European Parliament, Shadow rapporteur)

20 Jan 2026 · Mobilité militaire

Meeting with Lara Wolters (Member of the European Parliament)

15 Jan 2026 · Rail Ticketing

Meeting with Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen)

8 Jan 2026 · Military Mobility

Meeting with Daniel Boeshertz (Head of Unit Competition)

12 Dec 2025 · Exchange of views on the online rail ticketing market.

Meeting with Polona Gregorin (Head of Unit Climate Action)

27 Nov 2025 · Discussion on ticketing proposal MDMS/SDBT and ETS

European railways urge exemptions from digital fairness rules

24 Oct 2025
Topic — Proposed EU regulation tackling dark patterns, addictive design and unfair online practices.
Message — The organization requests clear exemptions for standard railway retail practices like automatic subscription renewals, discount displays, and promotional campaigns. They argue these transparent practices benefit customers and should not be regulated as problematic dark patterns.123
Why — This would preserve their current pricing and marketing practices without compliance costs.45
Impact — Consumers lose protections against practices like automatic renewals and targeted pricing strategies.67
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Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu), Francesco Corti (Cabinet of Executive Vice-President Roxana Mînzatu)

23 Oct 2025 · Train Drivers Directive and Erasmus+

Meeting with Yannis Maniatis (Member of the European Parliament) and Air France-KLM

13 Oct 2025 · Introductory meeting

European Rail Industry Seeks Priority Electricity Access and Safety Guarantees

9 Oct 2025
Topic — EU plan to increase electrification across energy sectors to achieve decarbonisation targets.
Message — The organization requests three key measures: mandatory compliance with EU railway safety regulations in all electrification policies, robust cybersecurity protections for critical rail infrastructure, and recognition of railways as priority electricity consumers during energy crises.123
Why — This would protect railways from electricity disruptions and reduce exposure to volatile energy prices.456
Impact — Other electricity consumers may face lower priority access during energy shortages or crises.7
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Meeting with Joachim Luecking (Head of Unit Mobility and Transport)

9 Oct 2025 · Military mobility package

Meeting with François Kalfon (Member of the European Parliament, Shadow rapporteur)

7 Oct 2025 · Mobilité militaire et grande vitesse ferroviaire

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

7 Oct 2025 · Current topics for the railway industry

Meeting with Joachim Luecking (Head of Unit Mobility and Transport)

30 Sept 2025 · Exchange of views on cross-border agreements between national safety authorities

Meeting with Andreas Schieder (Member of the European Parliament) and WIENER STADTWERKE GmbH and ÖBB-Holding AG

25 Sept 2025 · Lunchdebate

European rail industry opposes mandatory through-tickets for multi-operator journeys

19 Sept 2025
Topic — EU proposal to extend passenger rights protections to journeys combining separate tickets from different rail operators.
Message — CER opposes making through-tickets legally obligatory for all multi-operator journeys, arguing this would force operators to stop offering these trips due to prohibitive compensation costs. Instead, they propose a three-tier framework: separate tickets with no guarantees, combined tickets for international journeys with journey continuation based on existing industry agreements, and traditional through-tickets where commercially viable.123
Why — This would minimize their liability costs when disruptions occur on journey segments operated by other companies.45
Impact — Passengers combining separate tickets would lose automatic compensation and journey continuation rights when disruptions occur.6
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European rail industry demands level playing field for sustainable tourism

11 Sept 2025
Topic — Developing an EU strategy to boost sustainable tourism through greener transport and competitive growth.
Message — CER requests VAT exemptions for international rail and lower track access charges. They want polluter-pays pricing to ensure fair competition with airlines.12
Why — These reforms would lower operating costs and attract more short-haul air passengers.3
Impact — Aviation and road transport companies would face higher costs and lost market share.4
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CER demands EU prioritize rail in sustainable transport plan

4 Sept 2025
Topic — A strategic framework for public and private investments into sustainable transport fuels.
Message — CER calls for the STIP to prioritize rail investments due to its high energy efficiency and climate benefits. They request funding for digital tools, high-speed rail, and better port connections while ending subsidies for competing modes.123
Why — This proposal would improve rail's competitiveness by lowering energy costs and infrastructure charges.45
Impact — Aviation and road transport sectors would lose their current financial advantages from tax exemptions.67
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Meeting with Andreas Schieder (Member of the European Parliament) and Deutsche Bahn AG

3 Sept 2025 · Raillunch

Response to EU harmonised specifications for control-command and signalling

18 Jul 2025

CER welcomes the improvement of the TSI CCS and approves the proposed amendments provided the attached comments are taken into account. We are at the disposal of DG MOVE to discuss them.
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Meeting with Eric Von Breska (Director Mobility and Transport)

16 Jul 2025 · Exchange of views on High-Speed Rail, Ports, Military Mobility, Connecting Europe Facility

Meeting with Andreas Schieder (Member of the European Parliament)

16 Jul 2025 · Rail Breakfast

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

9 Jul 2025 · Shaping a new Team Europe approach towards LAC in order to increase the success rate of EU Railways industry on tenders on the region.

European rail group demands 30% market share in EU ports

2 Jul 2025
Topic — The EU Ports Strategy addresses security, competitiveness, and energy transition challenges in European ports.
Message — CER urges the EU to prioritize rail connectivity and set a minimum 30% rail market share target at ports. They propose expanding port rail infrastructure and lowering fees to make rail more competitive than road freight.123
Why — These policies would grow rail's market share and provide subsidies for terminal operations.45
Impact — Foreign investors face exclusion from port management to protect European strategic autonomy and security.67
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Meeting with Apostolos Tzitzikostas (Commissioner) and

1 Jul 2025 · Strategic Dialogue on the EU Port Strategy

Meeting with Andreas Schieder (Member of the European Parliament)

1 Jul 2025 · Exchange of views

European rail industry urges strategic status in EU AI strategy

4 Jun 2025
Topic — The consultation seeks to accelerate AI adoption and innovation across strategic European sectors.
Message — The sector asks the Commission to recognize rail as a strategic domain with high potential. They request expanded funding for public mobility providers and the creation of open data spaces.123
Why — Dedicated funding and infrastructure support would help rail operators modernize their management systems.45
Impact — Non-European technology companies may lose market share as the sector prioritizes strategic sovereignty.67
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Response to Connecting Europe through high-speed rail

8 May 2025

The Community of European Railway and Infrastructure Companies (CER) welcomes the initative Connecting Europe through High-Speed Rail and contributes to the call for evidence with the attached position paper, which reflects the vision, priorities, and recommendations of our members across Europe. High-speed rail (HSR) is transforming the way Europe moves. Fast, comfortable, and climate-friendly, HSR is becoming the first choice for many travellersbringing cities, people, and regions closer together. But HSR is more than just a transport solution: it is the backbone of integrated mobility, and a catalyst for building a better rail system and overall a more competitive Europe. CER position paper outlines the key steps needed to deliver a truly European HSR network that links all capitals and major cities. If implemented, HSR could carry over 54% of long-distance travellers by 2070, while boosting the role of conventional and regional rail. This shift would be a game-changer for Europes green and digital transition. To achieve this, CER calls for: Accelerated delivery of the TEN-T network, while completing it with the missing HSR links, as the foundation of European HSR success. A bold and reliable public funding strategy, including a dedicated EU budget envelope for the HSR master plan; Supportive financing models such as PPPs, RABs, and cross-financing mechanisms; Competitive and balanced track access charges that reflect route and infrastructure conditions; Full EU action on interoperability, ERTMS deployment, and seamless ticketing, supported by initiatives like the CER Ticketing Roadmap and Open Sales and Distribution Model (OSDM); A level playing field across transport modes, including fair taxation and pricing of externalities; With the right policy decisions and financial instruments, CER members are confident they can provide commercially viable high-speed services connecting all EU capitals and major cities.
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Meeting with Andreas Schieder (Member of the European Parliament)

6 May 2025 · Exchange of views

Meeting with Jens Gieseke (Member of the European Parliament) and Honeywell Europe NV and A-Gas International Ltd.

6 May 2025 · Austausch zu EU Politik

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur)

1 Apr 2025 · Railway capacity regulation

Meeting with Simonas Satunas (Cabinet of Commissioner Andrius Kubilius)

25 Mar 2025 · Military Mobility

Response to Technical specification for interoperability relating to the telematics subsystem of the rail system

14 Mar 2025

CER signed joint positions with EIM, UIP, ERFA and UIC, CIT on the revision of Telematics TSI / OSDM. The positions are attached. On the revision: ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool. As first output, an intermediate revision was included by amendment in TAF TSI in 2021. Nevertheless DG MOVE did not support the recommendations. Instead of granting an updated mandate to ERA, DG MOVE took over a large redrafting of the TAF/TAP TSI from mid-2023 with a completely new approach and without mandate. Since 2 years and after 7 versions of the Telematics TSI, the sector does not see any significant improvements with the new unjustified measures in particular: Change of nature of the TSI which is now more about making rail data public instead of exchanging or making available the information between the stakeholders; Very general wording and lack in details that lead to various interpretations and misunderstanding on how to implement; New structure of Act and Annex interconnected together, different of the usual and clear TSI structure, leading to difficulty to understand the requirements; From one version to the next, large modifications without concertation or new requirements not mature or even abolishment of requirements already implemented in TAF/TAP systems; Additional constraints put on the rail sector compared to all other modes (as freight on road); These issues concern all processes: RU/IM exchanges, freight services, retail and passenger services. That is due to the redrafting process of the TSI since mid-2023 where article 5 of the Interoperability Directive (drafting, adoption and review of TSIs) is no longer respected: ERAs role in drafting the content of the TSI has been taken over by DG MOVE; Modification of the scope without mandate; New or modified requirements without traceability via CRs and without justification of added value; No comprehensive discussion and study by the ERA working party with the experts of the sector and MSs; instead the EC Expert Group is used to discuss technical content that is not the aim (almost 10 EC EGs since mid-2023, that was never the case for other TSIs); No full impact assessment or cost-benefit analysis yet necessary considering the numerous modifications (the advisory note on impact was launched only very late in November 2024 that doesnt permit a correct assessment before vote planned in June 2025); No draft of a realistic and sustainable implementation plan without clear financing estimation and resources; Very late delivery of the Technical Documents, yet necessary to assess the specifications to implement and unclear approval process of the TDs for the vote planned in June 2025; Implementation deadlines planned to be defined in the RISC of June 2025 without involvement of the sector in charge to implement. Implementing this TSI EN07, for the requirements beyond the ERA TAF/TAP recommendations of 2022, is for the moment impossible based on the current wording which is very general and interpretable in different manners, without common understanding of what has to be deployed, without justification of benefit, without realistic and sustainable implementation plan and without clear financing estimation and resources. The redrafting in a more understandable and realistic manner, including shifting the non-mature requirements as open points, is necessary to allow a cost-efficient and business-efficient implementation. It is not too late to establish a common writing team between EC, ERA, MSs and sector to achieve this redrafting with the criteria of openness, consensus and transparency. The attachments describe in more details some main issues and proposals (list not exhaustive).
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Meeting with Jens Gieseke (Member of the European Parliament)

12 Mar 2025 · Austausch zu EU Politik

Meeting with Johan Danielsson (Member of the European Parliament)

12 Mar 2025 · ERTMS

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur)

12 Mar 2025 · Railway capacity regulation

Meeting with Herald Ruijters (Deputy Director-General Mobility and Transport)

19 Feb 2025 · Exchange of views on the future High-speed rail Communication

Meeting with Martine Kemp (Member of the European Parliament)

18 Feb 2025 · European Railway Infrastructure as Strategic Investment - Host of an event

Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Feb 2025 · Exchange of views with CER CEOs on the margins of the 18th European Railway award event.

Meeting with Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto)

23 Jan 2025 · High-speed rail in the future of EU transport sector, features of the rail sector, infrastructure financing and ticketing models, digitalisation of the rails service (ERTMS and FTRMCS).

Meeting with Joachim Luecking (Head of Unit Mobility and Transport)

21 Jan 2025 · Introductory meeting - new Head of Unit C4

Meeting with Pasquale Tridico (Member of the European Parliament)

17 Dec 2024 · Meeting with Direttore Esecutivo CER Ing. Mazzola

Meeting with Johan Danielsson (Member of the European Parliament)

17 Dec 2024 · Järnvägskapacitet och ERTMS

Meeting with Jens Gieseke (Member of the European Parliament, Rapporteur)

17 Dec 2024 · Multimodal Passenger Rights

Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas)

12 Dec 2024 · Courtesy Meeting for introduction

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur)

23 Oct 2024 · Railway capacity

Meeting with Lena Schilling (Member of the European Parliament)

23 Oct 2024 · Rail Policy and Investment in rail infrastructure

Meeting with Flavio Tosi (Member of the European Parliament, Rapporteur) and FERROVIE DELLO STATO ITALIANE S.p.A.

23 Oct 2024 · CTD

European Rail Body Demands Better Aviation Labels for Mode Comparison

22 Oct 2024
Topic — Methodology for a voluntary environmental labelling scheme for emissions from aviation flights.
Message — CER requests the label include non-CO2 climate impacts like nitrogen oxides and vapour trails. They demand consistency with broader EU methodology to allow direct comparisons with rail transport. The group also advocates for a classification-style logo rather than a simple certification seal.123
Why — Uniform comparison methods would help rail operators capture market share from high-emission flights.45
Impact — Airlines may lose customers if the full scope of their climate impact becomes visible.67
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Meeting with Rosa Serrano Sierra (Member of the European Parliament) and European Transport Workers' Federation and CLECAT - European association for forwarding, transport, logistic and Customs services

2 Oct 2024 · Priorities for European Commission 2024-2029

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

1 Oct 2024 · Speaker at a joint CER & Jacques Delors Institute event ‘On track for more than a single market’ to reflect on the future of railways

Response to Interim evaluation of the Connecting Europe Facility 2021-2027

23 Sept 2024

Please see attached document for full CER response. CER welcomes the opportunity to provide feedback to the call for evidence for an evaluation of Connecting Europe Facility 2014-2020 (CEF I). For rail, CEF is the key financing instrument for bridging missing links and removing bottlenecks on the TEN-T Core Network Corridors, thus increasing the competitiveness and market share of the European rail system. CEF funds are needed to complete the TEN-T network including the finalisation of major on-going TEN-T projects, and to support the digital transformation of rail operations, especially ERTMS on board and on track. CER would like to reiterate that both for CEF1 and CEF2, calls have been continuously oversubscribed, sometimes by a factor of up to five. This fact would be important to highlight in the evaluation and explore recommendations for the future CEF or a similar tool in the next Multi-annual financial framework (MFF). The rail sector calls for an increase of the new upcoming CEF to at least 100 billion. A bigger CEF, giving priority to infrastructure modernisation, will benefit both rail freight and rail passenger traffic, supporting projects aimed at developing accessibility and multimodality, including in the major stations located on the TEN-T Network. However, considering the substantial investment needs to complete the TEN-T Networks , this increase will not suffice to cover the investments needed to meet the EU ambitions for rail infrastructure, and therefore further efforts must be made to find additional EU funding budget lines. In particular for rail, specific priorities and hence budget lines as well as calls are necessary for rail technological upgrades for both infrastructure and rolling stock, especially for implementation, retrofitting and upgrading of ERTMS, FRMCS, and also for enabling other priorities such as TTR/DCM, DAC, and in general for enabling Automatic Train Operations. CER and its Members look forward to working closely with the European Commission and provide its input to public and targeted consultations of the evaluation.
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Response to Ex-post evaluation of the Connecting Europe Facility 2014-2020

23 Sept 2024

Please see attached full response of CER. CER welcomes the opportunity to provide feedback to the call for evidence for an evaluation of Connecting Europe Facility 2014-2020 (CEF I). For rail, CEF is the key financing instrument for bridging missing links and removing bottlenecks on the TEN-T Core Network Corridors, thus increasing the competitiveness and market share of the European rail system. CEF funds are needed to complete the TEN-T network including the finalisation of major on-going TEN-T projects, and to support the digital transformation of rail operations, especially ERTMS on board and on track. CER would like to reiterate that both for CEF1 and CEF2, calls have been continuously oversubscribed, sometimes by a factor of up to five. This fact would be important to highlight in the evaluation and explore recommendations for the future CEF or a similar tool in the next Multi-annual financial framework (MFF). The rail sector calls for an increase of the new upcoming CEF to at least 100 billion. A bigger CEF, giving priority to infrastructure modernisation, will benefit both rail freight and rail passenger traffic, supporting projects aimed at developing accessibility and multimodality, including in the major stations located on the TEN-T Network. However, considering the substantial investment needs to complete the TEN-T Networks , this increase will not suffice to cover the investments needed to meet the EU ambitions for rail infrastructure, and therefore further efforts must be made to find additional EU funding budget lines. In particular for rail, specific priorities and hence budget lines as well as calls are necessary for rail technological upgrades for both infrastructure and rolling stock, especially for implementation, retrofitting and upgrading of ERTMS, FRMCS, and also for enabling other priorities such as TTR/DCM, DAC, and in general for enabling Automatic Train Operations. CER and its Members look forward to working closely with the European Commission and provide its input to public and targeted consultations of the evaluation.
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Meeting with Andreas Schieder (Member of the European Parliament)

17 Sept 2024 · Exchange of Views on Transport Policy

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

10 Jun 2024 · - Funding for rail in next MFF - Digitalisation - Military mobility

Response to Block exemption regulation on the application of Articles 93 and 108 of the Treaty to State aid for the land transport sector

2 Apr 2024

CER, the Community of European Railway and Infrastructure Companies, thanks the European Commission for the opportunity to provide evidence for the impact assessment of the new Transport Block Exemption Regulation (TBER). The railway sector has long advocated for a block exemption regulation for transport, a sector where a block exemption is necessary to enable it to meet the targets set by the Green Deal and at the same time feasible due to a consistent and abundant Commission practice. The TBER will considerably simplify and streamline the granting of aid while decreasing the administrative burden for Member States wishing to support rail. Most importantly it will make it possible to avoid the time lag between notification, Commission decision and actual availability of the financial resources to beneficiary undertakings. Ultimately, the TBER will be a key element to enable the railway sector to fulfil the Green Deal objectives. Please refer to the attached position for CER's full reply.
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Shadow rapporteur) and Ryanair Holdings and

2 Apr 2024 · Stakeholder Meetings on Passenger Mobility Package

Response to Revision of fees and charges of the European Union Agency for Railways

28 Mar 2024

The railway sector stakeholders represented here collectively by CER, AERRL, ALLRAIL, EIM, ERFA, UIP, UIRR and UNIFE - do not like to see any cost increase for the sector which we regard as a major challenge for the competitiveness of the European rail sector. The increase especially the mechanism of average workload - should be offset against the efficiency improvements promised with the 4th railway package. Especially since the railway stakeholders face corresponding costs within their own companies and from their contractors. While we acknowledge an overall cost increase in the limits of inflation, which is currently 2,8 % in 02/2024, for the sake of transparency we request that the method of calculation of these costs is made publicly available by the Agency . The new fixed fee of 26500 Euro proposed under Art 3(3)a and item 4 in table B of the Annex (Submission to and processing by the Agency of an application for a decision authorising a vehicle type - freight wagons when the area of use is whole Union) actually exceeds their experienced costs under the currently hourly rate method. We also recall that the fees for a wagon type authorisation under the 3RP were also significantly lower than today under the 4RP. Given the objective of the European Commission to boost the efficiency, sustainability and competitiveness rail freight services across the European Union, we recommend to lower the fees & charges for freight wagons either via a revised fixed fee proposal or keeping the hourly rate method for the type authorisation. The wording for Art 2(2)h and item 8 in table B of the Annex (Processing of notifications, including decisions of the Agency in accordance with Article 16(4) of Implementing Regulation (EU) 2018/545) needs to be refined. It shall be made clear that the amount of 3.710 is a lump sum for all notifications of a type of vehicles and not for individual vehicles. This would lead to enormous costs otherwise In addition, the 3.710 are just the experiences of an applicant when exchanging information according with Article 16(4) with the German NSA significantly higher than the range between 600 to maximum 1.200 . We do not support the possibility for NSAs to delay their input and ERA to issue an invoice without the associated NSA costs proposed under Art 5(3). Allowing NSAs to recover costs directly with the applicants at an undefined time passes the administrative burden over to the applicants and contradicts the principle of one OSS application one invoice as established when drafting of (EU) 2018/764. The new 20 calendar days period for the NSAs to provide their cost statements to the ERA should be sufficient and the second half of the proposed Art 5(3) should be deleted. The new Art 5(1) also gives ERA 60 days rather than 30 to solve this. The fixed fees for conformity to type (CTT) authorisations found in item 1 in table B of the Annex have now undergone two indexations, standing at 11,6% higher than those established by (EU) 2021/1903. We believe these fixed fees need to be recalibrated to reflect the efficiency gains in the CTT process reported by the Agency in subsequent years and quality improvements of the applications following 3 more years of experience. It is understood that the hours required to process the CTT applications are now lower than in 2021 and as such the fees should also be adjusted to reflect this and incentivise continued improvement in the processes. If we add up all the cost elements for vehicle authorisation and registrations on a case-by-case basis, we conclude that the accelerated roll-out of European Rail Traffic Management System (ERTMS) both on the side of Infrastructure Manager and Railway Undertakings as well as the Digital Automatic Coupler (DAC) is at risk. We recommend addressing the issues of vehicle and trackside authorisation in the framework of the accelerated ERTMS rollout and DAC deployment.
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Meeting with Nicolas Schmit (Commissioner) and

6 Mar 2024 · Labour and skills shortages, the EU's social targets, the European Pillar of Social Rights Action Plan

Rail Industry Seeks Limits on New Multimodal Passenger Rights Obligations

27 Feb 2024
Topic — EU proposal to strengthen passenger protections for journeys combining multiple transport modes.
Message — The organization requests clearer definitions of responsibilities, arguing intermediaries should bear more obligations while carriers face excessive burdens. They seek exclusions for local and regional services, longer reimbursement periods, and language limits on claim forms. They emphasize infrastructure and digitalization must be prioritized over regulatory requirements.12345
Why — This would reduce compliance costs and administrative burdens from language requirements and shortened deadlines.67
Impact — Passengers lose stronger protections when connections are missed and streamlined cross-border claim processes.89
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Meeting with Maroš Šefčovič (Executive Vice-President) and UNIFE

29 Jan 2024 · Railway

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur)

23 Jan 2024 · Rail capacity proposal

Meeting with Dominique Riquet (Member of the European Parliament, Shadow rapporteur)

17 Jan 2024 · Politique des transports

Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur) and UIRR, International Union for Road-Rail Combined Transport

17 Jan 2024 · Weights and dimensions directive

Meeting with Nicola Danti (Member of the European Parliament, Shadow rapporteur) and FedEx Express BE BV

12 Jan 2024 · CountEmissionsEU

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

6 Dec 2023 · Speech on combined transports at high level meeting of Rail Freight CEOs

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and FERROVIE DELLO STATO ITALIANE S.p.A. and

29 Nov 2023 · Rail Capacity proposal

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Société nationale SNCF and SNCF Connect

28 Nov 2023 · Rail Capacity proposal

Response to Revision of the Union Customs Code

7 Nov 2023

The Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for the opportunity to provide our views on the Proposal for a Regulation of the European Parliament and of the Council establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013. Please find attached the CER Position paper titled "Revision of the Union Customs Code," which contains our remarks on the text of the Proposal.
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Response to Count your transport emissions: CountEmissions EU

31 Oct 2023

CER is glad to see carbon accounting on the European decision making agenda thanks to the legislative proposal for the 'CountEmissionsEU' Regulation. For decades CER has been calling for the full implementation of the polluter pays and user pays principles in the transport sector. CountEmissionsEU should be an enabler to internalise greenhouse gas (GHG) emissions from transport. With a common reference method, calculation tool and credible databases, CountEmissionsEU should provide clear information on GHG emissions to transport users, consumers and service providers to guide them towards more efficient choices that can reduce their emissions. CER calls for higher amibition from the EU co-legislators through mandatory application of CountEmissionsEU, including the whole mobility sector in its scope, and guidance on its use cases such as mandatory carbon labelling of transport services.
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Meeting with Magda Kopczynska (Director-General Mobility and Transport)

25 Oct 2023 · 1. Weight and Dimensions 2. Combined Transport 3. Rail capacity 4. MDMS 5. Revision of Rail State Aid Guidelines 6. ERTMS

Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

24 Oct 2023 · Weights and dimensions directive

Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur) and UIRR, International Union for Road-Rail Combined Transport

24 Oct 2023 · Rail Forum Event on Greening Transport Package

Meeting with Liliane Karlinger (Cabinet of Executive Vice-President Margrethe Vestager)

25 Jul 2023 · MDMS

Response to Mandate for France regarding agreement on the safety and interoperability requirements within the Channel Tunnel

24 Jul 2023

The Community of European Railway and Infrastructure Companies (CER aisbl) role is to represent the interests of its members on the EU policy-making scene, in particular to support an improved business and regulatory environment for European railway undertakings and railway infrastructure managers. In agreement with our partner organisations EIM and ERFA, please find hereunder our common statement: The Community of European Railway and Infrastructure Companies (CER aisbl), the European Association of Rail Infrastructure Managers (EIM aisbl) and the European Rail Freight Association (ERFA asbl) bringing together close to 100 European railway undertakings, their national associations, vehicle leasing companies as well as rail infrastructure managers support the proposal for a decision of the European Parliament and the Council empowering the French Republic to negotiate, sign and conclude an international agreement on the safety and interoperability requirements within the Channel Fixed Link (2023/0192 (COD)). CER, EIM, and ERFA call on all parties to find pragmatic arrangements ensuring safe, interoperable and free movement of trains from the European Union to the United Kingdom through the single, complex engineering structure that is the Channel Fixed Link. CER, EIM, and ERFA encourage the French Republic to work out a sound agreement for a coherent railway safety and interoperability framework under the conditions described in Article 2 of the aforementioned legal act. CER, EIM, and ERFA note that the guarantees provided by the agreement will be of special importance in the context of increasing exchanges between the EU and the United Kingdom.
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Meeting with Carlo Fidanza (Member of the European Parliament)

11 Jul 2023 · Railway situation in Italy

Meeting with Kurt Vandenberghe (Director-General Climate Action)

6 Jul 2023 · FF55

Response to Revision of the specifications for EU-wide Multimodal Travel Information Services (Delegated Regulation 2017/1926)

28 Jun 2023

CER Members welcome the revision of the Delegated Regulation (EU) 2017/1926 on EU-wide multimodal travel information services. Within CER membership improving services based on more data ranks among the highest priorities, as it enables us to strive for the provision of efficient and appealing transportation options and services to our valued customers. CER members have shown their commitment to seamless ticketing by 2025 with the adoption and implementation of the CER Ticketing Roadmap, where one of the main commitments is to develop a European real time data service for better informing passengers. Our position is outlined in the attached document.
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Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

27 Jun 2023 · Multimodale Buchungsplattform, Train Drivers Directive, TEN-V

Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

6 Jun 2023 · Rail

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

Community of European Railway and Infrastructure Companies (CER) welcomes the opportunity to comment on the amended EU taxonomy on climate change. Please find our comments related to the transport sector.
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Meeting with Isabel García Muñoz (Member of the European Parliament, Shadow rapporteur)

19 Apr 2023 · TEN-T Revision

Meeting with Maria Grapini (Member of the European Parliament)

18 Apr 2023 · Multi-Modal Digital Mobility Services

European rail industry seeks flexibility in EU passenger reimbursement form design

5 Apr 2023
Topic — New EU regulation standardizing forms for rail passenger reimbursement and compensation requests.
Message — The organization requests railway undertakings be allowed to use their own forms alongside the standard form, maintain more generous compensation schemes, and receive responses in their working languages. They argue the standard form needs technical modifications to distinguish reimbursement from compensation and accommodate through-tickets.1234
Why — This would allow them to promote better compensation schemes and avoid costly website changes.56
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

30 Mar 2023 · Meeting on MDMS

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and

16 Mar 2023 · CMRD6

Meeting with Maria Grapini (Member of the European Parliament)

2 Mar 2023 · Multimodal Digital Mobility Services Initiative

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament) and UNIFE

31 Jan 2023 · Railway Award

Meeting with Izaskun Bilbao Barandica (Member of the European Parliament) and UNIFE

31 Jan 2023 · European Railway Award Ceremony

Response to Revision of technical specification for interoperability relating to the ‘control-command and signalling’ subsystems

26 Jan 2023

The Community of European Railway and Infrastructure Companies (CER aisbl) shares the overall strategic and ambitious goals of the revised CCS TSI. However, in order to ensure an efficient, swift and sustainable deployment of ERTMS, it is important that the new requirements are pragmatic and reasonable: it is to be avoided imposing long-term requirements on trains with a remaining life time of 10 or 15 years as it unnecessarily increases the costs without any benefit. We call that tailor-made solutions are allowed and that the most stringent requirements are applied to newly developed trains only. This leitmotif should guide the in-depth discussions with the sector in expert groups to be soon organised before finalising the CCS TSI. CER underlines that full alignment between the CCS TSI, the OPE TSI and RINF on the one hand and the CCS TSI, the LOC&PAS TSI and the WAG TSI on the other hand remains necessary. CER and our sector partner UNIFE (railway supply industry) continue to be committed in supporting the European Commission and RISC members to help find solutions on the remaining critical points that are acceptable for all, both for the decision makers and the railway sector stakeholders.
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Response to Revision of seven Technical Specifications for rail Interoperability: LOC&PAS, WAG, INF, ENE, NOI, PRM and RINF

26 Jan 2023

The Community of European Railway and Infrastructure Companies (CER aisbl) appreciates all efforts that have been made in a collective manner to produce the big TSI 2023 package (comprising both the Mega Pack as well as the CCS & OPE TSIs. CER would particularly like to highlight the efforts and achievements of the European Union Agency for Railways (ERA). CER suggests a set of amendments to the Mega Pack in the attached document. Some comments recommend corrections, others precision and the remaining part of comments is of editorial nature. Although the ERATV act and the OPE TSI are out of scope of the EC consultation, CER suggests some amendments as ERATV and OPE TSI are closely linked to the TSIs of the TSI Mega Pack. CER strongly recommends to have a holistic look at the RINF act, the OPE TSI and the CCS TSI. As theses acts are heavily interrelated and the TSI requirements interlinked, it is therefore essential to have the full and final picture of all texts combined before an opinion can be given. CER encourages the European Commission to pay attention to ensure the correct referencing of standards in the TSI. Various suggestions are made in the attached document. The CER comments in the attachment are not referring to the documents uploaded for the 02/2023 RISC meeting but to the 12/2022 EC documents for public consultation. CER continues to be committed in supporting the European Commission and RISC members to help find solutions on the remaining critical points that are acceptable for all, both for the decision makers and the railway sector stakeholders.
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CER Seeks Long-Term Cyber Support for Railway Infrastructure

19 Jan 2023
Topic — New EU legislation setting mandatory cybersecurity standards for digital products and services.
Message — CER requests that vulnerability support lasts over five years to match railway lifespans. They want better alignment between general and sector rules to prevent security gaps. They seek clearer product categories to ensure standard parts remain usable.123
Why — Rail companies would benefit from guaranteed security maintenance for their long-lasting infrastructure assets.4
Impact — Technology suppliers would face higher costs for providing security updates over much longer periods.5
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Meeting with Ismail Ertug (Member of the European Parliament)

18 Jan 2023 · TEN-T

Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur)

17 Jan 2023 · TEN-T

Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

17 Jan 2023 · TEN-T

Meeting with Isabel García Muñoz (Member of the European Parliament, Shadow rapporteur)

17 Jan 2023 · TEN-T Revision

Meeting with Ciarán Cuffe (Member of the European Parliament) and eu travel tech and

13 Jan 2023 · Passenger rights

Response to Import Control System 2 (ICS2) and guarantor’s undertakings used for transit

29 Dec 2022

Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for the opportunity to respond to this public consultation on the Commission Implementing Regulation amending Implementing Regulation (EU) 2015/2447 as regards the provision of information for entry summary declarations and risk analysis for security and safety purposes at entry of goods, and adding Ukraine to the list of countries in the guarantors undertakings for transit (hereinafter Implementing Regulation). CER brings together railway undertakings, their national associations as well as infrastructure managers and vehicle leasing companies, representing 73% of the rail network length, 76% of the rail freight business and about 92% of rail passenger operations in EU, EFTA and EU accession countries. As with the deployment of release 3 of ICS2 the submission of entry summary declarations through the ICS2 system for goods entering the customs territory of the Union by rail will become obligatory, the Implementing Regulation proposes the necessary amendments to the text of the Implementing Regulation (EU) 2015/2447. CER would like to propose a number of additions to the current version of the text of the Implementing Regulation. Please kindly find these proposed amendments elaborated in the attached document.
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Response to European Disability Card

21 Dec 2022

Railway companies are continuously keen to improve the travel experience of people with reduced mobility or passengers with disabilities. That is why CER Members are ready to recognize a potential EU wide European Disability Card, provided existing Public Service compensations apply for national citizens and agreed by the competent authorities no matter if they travel on domestic or international routes. CER has also invited in the past Member States to accept the principle of extending their national compensation schemes to the holders of disability cards issued by another Member State under equivalent conditions. In addition, CER invites the European institutions to develop a European disability card acceptable in all member states as soon as possible. The European disability card makes it easier for passengers with disabilities to claim their rights under the European Passenger Rights Regulation 2021/782 and would support the implementation of the CER Ticketing Roadmap. Informing the passengers concerned of their rights is also an important element. One of the concerns deals with the way in which the card is issued. A European card should not call into question the existence of different national cards. In the same way, it will be necessary to clarify compatibility: for example, some national cards define different levels of disability; the European card will have to be compatible. For this purpose, a uniform and at the same time forgery-proof means of identification (compatible with UIC Standard IRS 90918.9 to enable an exchange via ETCD) is needed throughout Europe, which is made available to passengers with disabilities. Finally, a single-format verification mechanism for checking purchase rights must be guaranteed. For example, through the implementation of an interoperable number to verify that the passenger has an active status. CER members are delivering transport services for persons with disabilities and are active in the field of assistive technology such as developing accessible apps, ticket-distribution and websites. European railway undertakings and infrastructure managers work internally and cooperate internationally continuously to improve the travel experience of people with reduced mobility or passengers with disabilities. Since 2010 representatives from most of the main railway companies in Europe meet regularly to exchange best practices and to discuss accessibility issues and PRM policies within the UIC PASSAGE group of experts. As a result, a web-based tool (PRM Assistance Booking Tool) was created 10 years ago and has been used successfully since then to facilitate booking of assistance services for PRM for international journeys through Europe when autonomous mobility is not possible CER members are engaged in an active and continuous dialogue with passengers with disabilities and their national and European federations. For instance, railways generally develop TSI/PRM4-compliant equipment (e.g. ticketing machines, vocalisation of screens announcing departures in stations, orientation tools for visually impaired people, etc.) in close cooperation with organisations representing passengers with disabilities. We believe it is important that railways are involved early in the development of new policy actions related to transport and accessibility. Rail services are by far more accessible than they were in the past and many passengers with disabilities are able to take the trains without assistance. Billions of euros are being invested to continue removing barriers in stations and on trains over the next decade like purchasing step-free access coaches and adopting platforms, in order to facilitate the travel experience of passengers with disabilities and passengers with reduced mobility and this, despite the scarce resources available. The legislative framework implemented in recent years introduced major improvements in order to make rail services more accessible than they were in the past.
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

The Community of European Railway and Infrastructure Companies (CER) welcomes the opportunity to comment on the roadmap for an evaluation of the Polluter Pays Principle (PPP). Implementation of the PPP was introduced by the Organisation for Economic Co-operation and Development (OECD) 50 years ago as an economic principle for allocating the costs of pollution. For transport the PPP is not a new idea since economists proposed PPP to internalise transport's so called external effects (such as air and water pollution, traffic noise etc). The PPP is granted a legal status in the EU with the Treaty on the Functioning of the EU and for more than two decades various Transport White Papers introduced the internalisation of external costs as an objective. In December 2020, the EU Sustainable and Smart Mobility Strategy recognised the limited progress in implementing PPP in transport despite longstanding policy commitments for fair and efficient pricing in transport. The Commission once again stated that the PPP and 'user pays principles' need to be implemented without delay in all transport modes. According to the EC figures, the environment-related external costs alone amount to 388 billion each year. EU society will be better off when PPP is applied. The PPP is to remove the obstacles hindering the uptake of green technologies in transport and enable the utilisation of the most sustainable transport modes with lower externalities. The European railways, which comply with the PPP principle better than any other motorised transport mode, both for passengers and freight, recommends the application of user-pays and PPP in transport: marginal social cost pricing both for infrastructure wear and tear and for externalities like accidents, air pollution, climate change, noise and congestion. The EC must pursue both sector-specific regulatory and economy-wide market-based measures to deliver smart and fair pricing across all transport modes. The revision of the Eurovignette Directive for example only made very small progress in implementing PPP in road. This is why with the Fit for 55 package, the EU Emissions Trading System reform must set rules for addressing emissions from aviation, maritime and road. On the other hand policy coherency must be achieved with energy taxation rules by removing the mandatory exemption of aviation and maritime. PPP is not only important for EUs sustainability agenda but also to help with the global challenges on energy. CER will contribute to the regulatory fitness evaluation of the PPP and ready to provide input to the forthcoming support study on collecting evidence for mapping of the current application of the PPP. References: http://cer.be/publications/latest-publications/finance-europes-economic-recovery-with-user-and-polluter-pays-principles http://cer.be/publications/latest-publications/decarbonisation-eu-transport-requires-fair-and-transparent http://cer.be/publications/latest-publications/commission-study-results-suggest-greater-role-european-railways
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Response to Revision of Operation Technical Specification for rail Interoperability

8 Dec 2022

The Community of European Railway and Infrastructure Companies (CER aisbl) takes note of the efforts made in the framework of the OPE TSI revision to achieve a step-by step harmonisation of operational rules across the European Union. Nonetheless, before the System Pillar can take over to further pave the way to this full harmonisation based on this OPE TSI, some major elements need to be put right: Infrastructure parameters, rules and their registers CER noticed that there is a wrong understanding of the data flow from RINF to the route book and generally about the rule book The content of the route book is safety relevant both in normal and degraded operation. This information partly constitutes the drivers route knowledge. Today the RU develops the route book based on the information coming from the IM via RINF and other sources ( the so called technical parameters ). Additionally, the RU adds some information about specific local procedures coming from IM or RU needs for normal and degraded mode. This information is not part of RINF, but essential for operational safety. RINF can be the basis for the route book, but an automatic workflow would lead to unmanageable safety risks. Inevitably, the route book is much more than only RINF parameters. It is not realistic that RINF content, availability and IT-security will in in the near future be sufficient for the entire RCC and Route Book needs. The rule book is a description of requirements for all the routes worked and the rolling stock used on those routes according to the situations of normal operation, degraded operation and in emergency situations which the driver may encounter. There are no rules in RINF. RINF is the tool for describing the static railway network characteristics and capabilities. In the attachment, CER suggests amendments to the draft text of the OPE TSI. Radio based communication The re-naming of re-labelling of Level 2 and Level 3 merging to Level R is questioned. Although the merge of both levels makes sense from a technical point of view as 95% of the functions are identical a re-naming would lead to huge administrative burden. The costs for changing all documents, manuals, training-material etc. and the knowledge-update of the staff are expected to be high without any financial benefit. CER recommends refraining from a renaming. CER encourages the EC to continue the discussions on the OPE TSI revision in order to reach a sound text taking into account the mutually agreed findings of the discussion between the regulator and the concerned sector stakeholders.
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Response to Creation of the Common European Mobility Data Space

6 Dec 2022

CER, Community of European Railways, and EIM welcomes the Mobility Data Space initiative to facilitate data sharing in the mobility sector. Our position is expressed in more detail in the attachment. We would like to point out that given the challenges, in order to ensure that the benefits of a Mobility Data Space outweigh its risks, CER and EIM believe that the implementation should incorporate of the following foundational principles: Data sovereignty: Data providers and users should be able to determine the terms and conditions of their transaction agreements. We should safeguard sensitive data and ensure it remains under its owner's control. Existing legislation such as the Trade Secrets Protection Directive already contributes to protecting sensitive information. Sharing transport data based on voluntary and FRAND contracts should enable the emergence of additional innovative solutions generated through co-creation. The data sovereignty principle has already been recognised in similar initiatives such as the French Mobility, transport and tourism Data Space EONA-X and the German Mobility Data Space . The list of data categories to be made available must be limited to what is strictly necessary, to those already available in Open Data and must be precise in terms of the date of collection of the data, their nature, completeness, quality and relevance. Standardisation and interoperability: Data spaces should be supported through cloud infrastructure based on the principles of (cyber)security, interoperability and data portability. The future European Mobility Data Space must be easy to use and compatible with existing data spaces or digital ecosystems, e.g. Gaia-X, and data spaces from other sectors. Businesses should face no additional administrative burden or costs, including for the use of the data space itself and the value created from data sharing should remain with the users. The formats and standards for making data available can lead to a significant workload and costs if they are far removed from the uses of the company producing the data. Flexibility must therefore be left to data producers on this point. Data reciprocity: The forced provision of business data could hamper the competitiveness of European businesses by increasing the power of a few large companies at the expense of smaller players such as SMEs. Currently, rail infrastructure managers and railway undertakings have many reciprocal data-sharing obligations, while nothing similar exists for other users of these data. A level playing field is not enough when it comes to comparing market incumbents with the increasingly direct customer interactions and potential intermediates. Data quality: For railway undertakings and infrastructure managers, data quality is more important than data quantity. If the available data is not usable, the amount of that data, no matter how large, does not serve the purpose. Regarding the current legislation, CER and EIM believe that the available harmonised data standards referenced in the existing legislation is sufficient. Furthermore, for the purpose of traffic management, the interoperable bilateral exchange as specified in TAF and TAP TSI remains the optimal way for the rail infrastructure managers to get and to share data.
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Ismail Ertug (Member of the European Parliament)

11 Oct 2022 · TEN-T

Meeting with Marco Campomenosi (Member of the European Parliament)

10 Oct 2022 · Meeting with Alberto Mazzola, CER

Meeting with Dorien Rookmaker (Member of the European Parliament)

4 Oct 2022 · Revision of TEN-T

European rail sector warns pesticide ban jeopardises track safety

16 Sept 2022
Topic — Proposed EU regulation to reduce pesticide risks and promote alternative pest management.
Message — The industry asks the Commission to integrate sector-specific needs into the new regulation. They argue that banning plant protection products in sensitive areas would make track maintenance impossible.12
Why — Exemptions would allow rail managers to maintain safety without using unproven alternative methods.3
Impact — Environmental groups lose protections as chemical use continues in designated sensitive zones.4
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CER urges customs reform to prioritize green rail transport

14 Sept 2022
Topic — The EU is revising customs rules to address e-commerce and data analytics.
Message — CER wants the reform to provide strong incentives for modal shift to rail. They suggest making it as easy as possible to fulfill customs obligations.12
Why — Reducing administrative burdens would lower operational costs and prevent supply chain delays.3
Impact — The road transport sector loses market share as freight shifts to rail.4
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Response to Union guidelines for the development of the TEN-T network amended proposal

19 Jul 2022

1. CER welcomes the extension of European Transport Corridors to Ukraine and the Republic of Moldova. Increasing the transport connections through European Transport Corridors to additional countries boosts environmentally friendly rail transport for people and goods. Extending the European Transport Corridors should be done in a way where countries, regions and cities which are currently on these European Transport Corridors are not affected in a negative way, i.e. they should not lose their status on an ETC due to a redrawing of the maps. 2. The extension of the Corridors to Ukraine and Moldova will also need the fulfillment of technical, regulatory and administrative requirements. The European Commission should verify the ability of Ukraine and Moldova as “recently accepted EU candidate countries”, both Member States and national railway Stakeholders, to bear the costs of the above mentioned requirements. 3. Since European and Eurasian rail traffic, including with countries not sanctioned, is negatively impacted by the current developments, it would be important to support European infrastructure that helps to increase rail freight. 4. Interoperability is a goal CER shares with the Commission, however we believe that the migration to the standard gauge should only be considered after a proper cost-benefit analysis looking, among the others, to options to migrate parts of the network, such as core and/or comprehensive, and to the financial and operative costs that such options would entail. On the other hand, the possible migration to the standard gauge would have a major impact not only in the relevant lines, but also on terminals, stations, depots and maintenance facilities, private sidings, port rail infrastructure, traffic control, etc. and would have a major impact on the rolling stock which would have to be adapted to standard gauge at a very high cost. The operations and activity would suffer significantly during the long period of migration with a very big impact on business and revenues. Furthermore, if only part of the network (the European Transport Corridors) was migrated to standard gauge, it would no longer be interoperable with the rest of the network with the original gauge, particularly for freight transport. That would mean that the problem would be transferred from the borders to the interior of the network with a different gauge, which would lose capillarity. 5. Extra funding from the European institutions should be a prerequisite for both extending the ETCs to more Countries and for even considering the migration to the standard gauge. The planned funding for each Member States should not be touched. 6. We would like to highlight that rail infrastructure is planned long term and plays an important part in reaching the goals of the European Green Deal and the Sustainable and Smart Mobility strategy. Any changes to the maps should consider the long-term effects, which will not be reversed easily. 7. Any new proposal aimed to amend the current Union guidelines for the development of the trans-European transport network proposal should be considered and eventually shaped after a proper cost-benefit analysis.
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Meeting with Dominique Riquet (Member of the European Parliament) and European Sea Ports Organisation and AEROSPACE VALLEY

20 Jun 2022 · Infrastructures de transport

Meeting with Ismail Ertug (Member of the European Parliament)

15 Jun 2022 · Employability in the railway sector

Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur)

8 Jun 2022 · TEN-T

Meeting with Karolin Braunsberger-Reinhold (Member of the European Parliament, Shadow rapporteur)

7 Jun 2022 · Action plan to boost long distance and cross border passenger rail

Meeting with Peter Liese (Member of the European Parliament, Rapporteur)

18 May 2022 · ETS Revision

Response to A New European Innovation Agenda

10 May 2022

Rail has already demonstrated that it can safely transport goods and passengers in the most environmentally friendly manner, thanks to technology and innovation. It has also demonstrated it can simultaneously create value and industrial jobs throughout Europe, exporting goods produced in our factories, and help preserve our planet for future generations. Rail is an essential part of the European landscape, culture and way of living. However, European rail is currently confronted with major challenges - to preserve jobs, to maintain industrial and technological leadership, and to deliver growth to European citizens, since it needs to confront the arrival of new players strongly supported by their Governments to innovate and to be more and more competitive. From a demand side, rail has to accommodate a further increase in mobility, has to become more attractive to our citizens, needs to be more flexible and interrelate more with other transport modes. In order to meet these constrains, research and innovation is the way to transform the railway system and make it more attractive, comfortable and affordable. For the benefit of the youngest, we must accelerate the arrival of digital technologies, artificial intelligence, automated and autonomous trains, and more solutions. The Community of European Railway and Infrastructure Companies (CER aisbl) fully supports the European Commission’s initiative “New European Innovation Agenda” and particularly supports the outlined (intended) achievements of this initiative. CER believes that that all research and innovation initiatives shall be strongly connected to “regulation and standardisation” as well as the “financing and funding” aspects. New approaches to regulation that can keep pace with, and enable innovation in, new and rapidly evolving fields are fully supported. The railway sector acknowledges the challenge of developing and retaining talents in Europe and encourages the European Commission to undertake initiatives aiming to facilitate an entrepreneurial mind-set and skills, promote inclusion and gender balance, support female entrepreneurship and encourage cooperation between research organisations and industry. CER is happy to see that the EC will contribute with this activity to a robust innovation ecosystem for the future of Europe including its railway system. CER supports the EC initiative and sees this as a contribution to a strong European research and innovation ecosystem supporting a vital and competitive European economy and innovative transport system.
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Meeting with Annalisa Tardino (Member of the European Parliament, Rapporteur)

4 May 2022 · Meeting with CER

Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail

4 Apr 2022

In view of the European Green Deal and the European Commission’s goal to reach climate-neutrality by 2050, efficient and optimized capacity management is key to ensure the modal shift to rail. Rail is the backbone of sustainable movement of goods, businesses and people, and fundamental for sustainable and connected economy in the EU. CER welcomes the opportunity to provide feedback to the call for evidence for an Impact Assessment expressing the intended revision of the RFC Regulation. The RFC Regulation relies on Rail Freight Corridors to promote rail freight traffic in a more efficient way throughout Europe. However, more than eight years after the start of the operational use of the Rail Freight Corridors, rail freight market share has not increased. We welcome that the Commission’s initiative aims to create the conditions necessary to help the rail sector to improve rail infrastructure capacity and traffic management, covering all types of rail traffic, and to improve the multimodal integration of rail freight services. We also appreciate the consideration of existing initiatives from the sector for the design of policy options, such as the Timetable Redesign Project (TTR), the electronic exchange of estimated times of arrival, digitalization of planning, operating and monitoring railway infrastructure and of rail transport services. We welcome the fact that three policy options are being studied, and we look forward to seeing more details and research prior to our further elaboration. We are happy to share our Position Papers on the revision of the RFC Regulation and TimeTableRedesign (TTR) for Smart Capacity Management, as well as CER Position on Action plan to boost long-distance and cross-border passenger rail.  CER proposes to replace the Corridor One-Stop-Shop (C-OSS) by a “Corridor Account Manager” (CoAM) who will use the skills developed in the last years in terms of international customer management. The CoAM would support RUs and coordinate IMs in offering harmonized international capacity in line with customer needs, while the operational business dealing with concrete train paths allocation will be tackled by the IMs.  TTR needs a sound legal basis applied to the entire European network as early as possible, and no later than the end of 2022, so as not to endanger the Europe-wide implementation of TTR. For the success of TTR and its timely implementation, RFC Regulation shall not reopen the 4th Railway Package, unless the ongoing evaluation will conclude it is not legally possible to establish robust legal basis for TTR without changes to the main body of Directive 2012/34. In the latter case, the changes to the text of the Directive 2012/34 should be of a very targeted nature, i.e. strictly limited to enabling the TTR project, as otherwise the railway sector will be destabilized by such a frequent change of the EU legal framework.  CER asks the European Commission to tackle EU-wide harmonized TCR planning processes (including common timelines, inter-IM coordination and alternative rail paths) as foreseen within the framework of the TTR project, and to urge Member States to comply with funding their IMs on a multiannual basis to ensure precise and stable planning of capacity restrictions on the network.  CER believes that commercial conditions should incentivize an infrastructure use that maximizes the rail capacity use.  A Union-level entity overseeing the optimisation of cross-border rail traffic and coordination mechanisms should not have more than a monitoring and guiding role, and always with respect to the Infrastructure Manager's individual autonomy and responsibility on capacity and traffic management. It should aim to identify best practices of cross-border coordination facilitating international pathway allocation and disruption management. However, further roles of this entity are under discussions in the sector and will be further investigated in the consultation process.
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Meeting with Jakop G. Dalunde (Member of the European Parliament) and Deutsche Bahn AG and Potsdam-Institut für Klimafolgenforschung

16 Mar 2022 · Speaker: Rail and Fit for 55

Meeting with Peter Liese (Member of the European Parliament, Rapporteur)

16 Mar 2022 · ETS Revision

Response to Evaluation and revision of the Weights and Dimensions Directive

14 Feb 2022

In 2008, the world reached the peak of conventional oil production (IEA – 2018 World Energy Outlook). It is now estimated that the peak of absolute oil production has already been reached or is on the verge to be reached this year. CO2 emission is therefore not the only challenge we will have to face in the coming decades. Energy shortage will in fact become the most immediate challenge for the transport sector and the industry at large as from this year as rapid decrease of oil output will not be fully compensated by the take up of renewable energies neither in the short nor medium term. Rail is 6 times more energy-efficient than road. Competition between modes is therefore no more an option. Cooperation, coordination and solidarity between modes will be the way forward if we want to be able to transport the same amount of goods with less energy. Innovation promoting competition between modes should give the way to innovation that allow modes to complement each other. With this in mind, rail is willing to continue to give a hand to road. For now 3 decades, railways have innovated to accommodate trucks, trailers, containers and swap-bodies, by creating new types of wagons (e.g.: pocket wagons) and new transhipment technics (horizontal). These investments are capital-intensive and can only be amortised over long periods (beyond 30 years), whereas trucks&trailers write-off periods are closer to 10 years. It is therefore essential that road now makes a step towards rail. While improving the intrinsic performance of road transport, truck manufacturers must make sure that any truck-trailer coming out of the manufacturing line are compatible with rail, as rail-based multimodal transport chains are undeniably the most efficient way to save energy overall. Their use will also have to be carefully organised. Therefore it is paramount… 1. that Public authorities set strict rules on the type of road vehicles that are allowed on the European market, in terms of weights, dimensions, derogations to dimensions (e.g. protruding devices), shapes, designs, resistance to air pressure, to make sure that they are compatible with rail transport and promote rail-road interoperability. 2. That Public Authorities set strict rules on the characteristic needed for such vehicles to be transferred easily, quickly and cost-efficiently on and off wagons (promoting operational agility & compatibility between modes). These should include a cranability requirement. 3. That rules are set on road vehicles combinations to be allowed on the market in order to optimise the use of both trucks and wagons capacity (certain trailers dimensions indeed do not allow to optimize wagon capacity). 4. That rules are set on the usage of certain combinations. For example, modular trucks should not be used outside intermodal operations. Conversely, if used for intermodal operations, they may optimise the transport chain. If used for long-distance road transport, they may simply cannibalise more energy-efficient rail-based transport chains: intermodal transport (of which combined transport), single wagonload and full-train business. See Frauenhoffer Institute 2011 Study on the “Effects of the Introduction of LHVs on Combined Road-Rail Transport and Single Wagonload Rail Freight Traffic” available here: https://www.cer.be/publications/brochures-studies-and-reports/study-effects-introduction-lhvs-combined-road-rail. 5. Lastly, in the age of multimodality, the Weights & Dimensions Directive is no more to be considered a mere road directive. It is a directive for all modes, because it is of concern to all modes. Its revision must be conducted hand-in-hand with the revision of the whole multimodal framework of which the revision of the Combined Transport Directive is the 2nd pillar. See CER Position on the Combined Transport IIA of September 2021 on: http://cer.be/publications/latest-publications/cer-position-revision-combined-transport-directive.
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Response to Regulation on train drivers’ certification

8 Feb 2022

The Community of European Railway and Infrastructure Companies (CER) welcomes the upcoming revision of the Train Drivers Directive (2007/59/EC), scheduled for Q4 2022, as per the Action Plan of the Sustainable and Smart Mobility Strategy. Since its entry into force, the Directive which aimed to improve and facilitate the mobility of train drivers across the EU rail network as well as to make it easier for employers to assign train drivers to operations in various Member States is enabling a more harmonised system of licences and certifications across the region, showing a move in the right direction. The Directive starts to address, but does not solve, completely, the problem of fragmentation regarding licences and complementary certificates. In order for the framework to deploy its full potential, further harmonization is needed regarding certain aspects (e.g. what are the training criteria for the Licence of train drivers). For instance, to enhance the harmonisation process, it would be advisable to enrich the contents of the licence related to the security of the system, rather than focusing on the content of the licence exclusively on administrative aspects and rules. In addition, the different types of fragmentation can be due to the various interpretations at national level which suggests the need for clearer definitions and criteria at European level. An appropriate level of adaptation to national specificities and realities is also needed, so finding the right balance is key. Furthermore, CER regrets the administrative procedures that a company must follow for the issuance and maintenance of complementary certificates as they can be extremely complex. It is important to underline that the additional administrative burdens stemming from the Directive affect several entities (NSA, employers, drivers) and put the railway sector at a significant competitive disadvantage compared to other modes of transport. The current rules have led to increased costs for companies, so decreasing the administrative burden of the Directive should be a priority in the revision process. Digitalisation can be seen as a solution to achieve this (i.e. digitalisation of the complementary certificate and/or licences would help reduce administrative burden). Overall, in view of being more efficient, technological developments can help with the process of reducing costs. CER notes that since the original drafting of the Directive, technological developments have come a long way and changed the way we work. The new Directive should consider the new challenges of digitalization, for example provide the possibility of experimental use of tools (for language requirements), and consider them, when possible. Furthermore, any more binding form of legislation should be assessed against a cost-benefit analysis and taking into consideration the impact on rail competitiveness vis-à-vis other modes that are subject to less binding requirements. CER believes that a clarification of the existing requirements would be a sufficient and beneficial step towards a clearer and more efficient system. CER is willing to continue the dialogue with the European Commission during the evaluation and revision process. While consulting all interested stakeholders, the European Commission should acknowledge the specialised input and expertise from CER and its members since the Directive stems from a previous agreement from social partners. Sector representatives should be closely associated to and consulted throughout the process. To conclude, CER and its members support a revision of the Directive so that it better reflects the evolution of the sector since the text was last revised. Harmonisation shall be pursued in those areas where it brings added value to the activities of railway companies.
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Rail industry urges stability in passenger rights rules

17 Jan 2022
Topic — EU review of passenger rights framework for travel disruptions and multimodal ticketing.
Message — The organization requests that new passenger rights initiatives do not interfere with current investment plans and the recently adopted rail regulation. They caution against changes to multimodal ticketing provisions that could disrupt ongoing progress in through-tickets and distribution systems.123
Why — This would protect their investment cycles and allow them to continue implementing existing rules.45
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Response to Count your transport emissions: CountEmissions EU

17 Dec 2021

Driving the transition to zero-emission mobility as required by the EU Green Deal will only be possible by placing the right incentives to transport users. Achieving the 90% greenhouse gas emission reduction in the transport sector by 2050 requires a basket of measures that include a robust carbon pricing, taxation, infrastructure charging and CO2 standards for vehicles complemented by financial incentives to develop cleaner mobility. According to the EU Sustainable and Smart Mobility Strategy, the Commission plans to establish a European framework for the harmonised measurement of transport and logistics greenhouse gas emissions by 2022. CER, therefore, welcomes the initiative called CountEmissions EU, which should be applicable to all transport modes avoiding greenwashing. It will offer the EU citizens the tools to make sustainable choices in order to facilitate a shift to the most energy efficient and sustainable transport solutions, strengthening the EU Green Deal by accelerating zero-emission mobility. This European harmonised carbon footprint tool should follow the energy-efficiency first principle and ideally lead to energy-efficiency labelling of transport services and in the long run contribute to the polluter pays principle by including a pricing dimension. CER proposals are found in the attached position paper.
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European Rail Operators Urge Sector-Led Digital Ticketing Solutions

2 Nov 2021
Topic — The EU initiative seeks to improve multimodal travel planning and ticketing across borders.
Message — CER insists that sector-led ticketing models should be the starting point for regulations. They oppose mandatory ticket re-selling and demand that data sharing remains strictly voluntary.123
Why — This protects rail operators' pricing autonomy and reduces potential new administrative burdens.45
Impact — Digital platforms lose the power to become market gatekeepers through unregulated data aggregation.67
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Response to Revision of the State aid Railway Guidelines

28 Oct 2021

The Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for this opportunity to provide our views on the Inception Impact Assessment for Revision of the Community Guidelines on State aid for railway undertakings. Please find attached the CER Position paper Rail transport – revision of State aid guidelines: Inception Impact Assessment.
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Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

20 Oct 2021 · TEN-T Regulation

Meeting with Isabel García Muñoz (Member of the European Parliament, Shadow rapporteur)

6 Oct 2021 · TEN-T Revision

Response to Revision of ERA Fees & Charges

15 Sept 2021

The Community of European Railway and Infrastructure Companies read the promising recitals of the Commission Implementing Regulation (EU) 2018/764 with great hope that this piece of legislation, together with the other elements of the 4th Railway Package, is paving the way to a competitive European railway sector whilst lifting administrative and financial burden from the railway sector. The revised 2021 recitals are the summary of a disappointing development in this respect and manifest wrong previous assumptions and decisions. The part that fees and charges payable to the Agency should not result in the imposition of unnecessary financial burden on companies and should not jeopardise the competitiveness of the European railway sector has been deleted for good reasons as this goal cannot be accomplished with the present draft of the revised above-mentioned legal act. We are surprised to see an increase of the hourly rate from 130€ to 235€, meaning an increase of 80%. As this is far above the inflation rate, we must assume that the 2017 calculation of the hourly rate was a mistake and that advice on the hourly rate for the Agency from the well experienced national safety authorities has not been taken into account in this period. This increase of the hourly rate shall be balanced with a corresponding increase of the quality of the tasks to be performed by the Agency, mainly through a significant reduction of the delay for the proper processing of the different applications. We are astonished that the applicant has to pay for the use of the OSS IT tool on top of the amount made up by the hourly rate x working hours spent. This should normally be covered in the indirect costs. We regret the significant budget cut for the Agency and acknowledge the considerable maintenance and development costs for the OSS tool but we cannot accept that this deficit shall now be closed by the applicants. We are happy to see that a 20% reduction of the total amount due for an application shall apply for micro, small or medium-sized enterprises. Nonetheless, this “relief measure” will not help the sector as the major cost drivers are not tackled here. In particular the cost for conformity to type of all vehicles and the cost for freight wagon authorisation are major costs drivers. Under the 3rd RP, costs for the authorisation for a single freight wagon in the Netherlands was 5-6 k€, for the same authorisation under 4th RP: 12-20 k€. As conformity to type did not exist under the 3rd RP, the cost for the vehicle registration was approximately only 70 € per vehicle, passenger or freight alike. Under the 4th RP, C2T and registration cost between 120 and 1570 €. With the revised Commission Implementing Regulation it will become even more expensive. The increase of fees and charges for authorisation and C2T of freight vehicles are endangering the competitiveness of the freight sector. Additional fees, the erroneous concept of C2T for all vehicles increase costs directly (fees and charges), increase costs indirectly (stand still times of vehicles waiting for C2T) and will significantly hamper upgrade and renewal of rolling stock incl. the ETCS on-board retrofitting and hence ERTMS deployment. If no cost cap is specified for ERTMS TS approval, ERA should issue the cost estimation for free at the beginning of ERTMS TS procedure. It shall be made clear in the Regulation that the fee for the use of the OSS is only charged once for the entire procedure. Clarity is needed in which situation which fee for revoking is charged and what the costs for the withdrawal of submitted application by the applicant are. CER believes in the central role of ERA, supports its important work and acknowledges that the costs of the European Union Agency for Railways must be covered but we do not accept that the European railway sector now has to pay alone for wrong decisions being taken by the European institutions in the past years.
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Response to Revision of Combined Transport Directive

10 Sept 2021

CER SUPPORTS the Commission’s objective and approach... CER welcomes the launch of the work on the revision of the Combined Transport Directive and the draft roadmap which the Commission published on 19 August 2021 outlining its intended actions until a legislative proposal comes out in Q4 2022. More specifically, CER supports the intention of the Commission to explore the option of extending the current scope of the directive, from Intermodal-Loading-Units-(ILUs)-based Combined Transport to all intermodal and multimodal transport that promise to save on externalities when evaluated against road-only transport. Indeed, multiple intermodal solutions exists that rely on various transhipment techniques other than sole ILU-based techniques. From this point of view, CER looks forward to the results of the study that the Commission is currently carrying out on transhipment techniques. Also, some unimodal solutions (like block trains and, above all, single wagonload transport) provide environmentally-performing end-to-end logistic solutions compared to road-only solutions. CER also supports the three options which the Commission intends to explore and assess, beyond the option of keeping the status quo (Option 1), i.e.: - Option 2 : Extension of the scope to all intermodal or multimodal transport operations (as described above). - Option 3: Option 2 plus an additional requirement of regular transport system analysis to assess the efficiency of the support measures chosen by the Member States. - Option 4: Option 3&4 plus a range of mandatory support measures (to be explored during the assessment phase). CER SUGGESTION: Further explore ways to enhance trucks and trailers interoperability with other modes... In its draft roadmap, the Commission underlines the need to revise the CT Directive in an integrated approach with other regulations including the directive which governs the use of trucks and trailers (the Weights and Dimensions Directive 96/53/EC). CER would like to recommend to extend the reflection to the type approval of future trucks and trailers to be put on the market according to the Masses & Dimensions Regulation 1230/2012. Indeed, the promotion of intermodality is not only a matter of organisational and financial incentive but also a matter of technical compatibility between modes. If intermodality is to become the future of transport, then it is crucial to make sure that trucks and trailers are designed to be rail-interoperable by default. To this end, solutions may be developed which may not necessarily be legislation-based to enhance the “Interoperability of Trucks & Trailers with Other Modes”. CER is ready to share its views on the enhancement of rail-road interoperability as a way to support intermodality.
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Response to Addressing distortions caused by foreign subsidies

16 Jul 2021

Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for the opportunity to respond to this public consultation on Proposal for Regulation on foreign subsidies distorting the internal market. Please find CER reply to the public consultation attached.
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Response to RoHS deleting exemptions for mercury in double-capped linear fluorescent lamps for general lighting purposes

13 Jul 2021

The Community of European Railway and Infrastructure Companies (CER aisbl) takes note of the European Commission proposals not to renew the RoHS exemptions addressing CFL-integrated and non-integrated lamps and double-capped linear fluorescent lamps for general lighting purposes [1(g), 1(a)-(e), and 2(a)(1)-(5)]. The CER members are committed to use eco-friendly components in the railway system. Nonetheless, due to the size and complexity of our industry, we need sufficient time to upgrade vehicles and the infrastructure in order to comply with any kind of regulation and standardisation. A sound transition to other product types and technologies needs time and a proper planning. The future availability of these exact same product types has also already been addressed by the 2019 EU Ecodesign regulation for light sources and separate control gears [EU 2019/2020]. Under this regulation the EU Member States and the European Commission decided on the need to maintain some of these product types on the EU market and set out a clear timetable to phase out others. CER urges the European Commission to avoid market confusion by aligning the timeline of the exemptions with that of Ecodesign to set out a single clear timetable for the future of each of these product types. In the absence of such an alignment, we ask the European Commission to publish and widely disseminate a statement, after the adoption of the delegated directives amending RoHS Annex III. This is needed to indicate which timeline takes precedence for each of these product types: that of RoHS or that of Ecodesign? Manufacturers of these product types across the world and their users in Europe need to have a clear understanding of the net effect of the body of EU law (both Ecodesign and RoHS) on the availability of these product types on the EU market over the next few years. The Community of European Railway and Infrastructure Companies (CER aisbl) shares the position of LightingEurope.
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Response to RoHS exemption 6

13 Jul 2021

The Community of European Railway and Infrastructure Companies (CER aisbl) takes note of the European Commission proposals not to renew the RoHS exemptions addressing CFL-integrated and non-integrated lamps and double-capped linear fluorescent lamps for general lighting purposes [1(g), 1(a)-(e), and 2(a)(1)-(5)]. The CER members are committed to use eco-friendly components in the railway system. Nonetheless, due to the size and complexity of our industry, we need sufficient time to upgrade vehicles and the infrastructure in order to comply with any kind of regulation and standardisation. A sound transition to other product types and technologies needs time and a proper planning. The future availability of these exact same product types has also already been addressed by the 2019 EU Ecodesign regulation for light sources and separate control gears [EU 2019/2020]. Under this regulation the EU Member States and the European Commission decided on the need to maintain some of these product types on the EU market and set out a clear timetable to phase out others. CER urges the European Commission to avoid market confusion by aligning the timeline of the exemptions with that of Ecodesign to set out a single clear timetable for the future of each of these product types. In the absence of such an alignment, we ask the European Commission to publish and widely disseminate a statement, after the adoption of the delegated directives amending RoHS Annex III. This is needed to indicate which timeline takes precedence for each of these product types: that of RoHS or that of Ecodesign? Manufacturers of these product types across the world and their users in Europe need to have a clear understanding of the net effect of the body of EU law (both Ecodesign and RoHS) on the availability of these product types on the EU market over the next few years. The Community of European Railway and Infrastructure Companies (CER aisbl) shares the position of LightingEurope.
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Response to Electrical equipment – Revoking exemptions for mercury in single capped (compact) fluorescent lamps for general purposes

13 Jul 2021

The Community of European Railway and Infrastructure Companies (CER aisbl) takes note of the European Commission proposals not to renew the RoHS exemptions addressing CFL-integrated and non-integrated lamps and double-capped linear fluorescent lamps for general lighting purposes [1(g), 1(a)-(e), and 2(a)(1)-(5)]. The CER members are committed to use eco-friendly components in the railway system. Nonetheless, due to the size and complexity of our industry, we need sufficient time to upgrade vehicles and the infrastructure in order to comply with any kind of regulation and standardisation. A sound transition to other product types and technologies needs time and a proper planning. The future availability of these exact same product types has also already been addressed by the 2019 EU Ecodesign regulation for light sources and separate control gears [EU 2019/2020]. Under this regulation the EU Member States and the European Commission decided on the need to maintain some of these product types on the EU market and set out a clear timetable to phase out others. CER urges the European Commission to avoid market confusion by aligning the timeline of the exemptions with that of Ecodesign to set out a single clear timetable for the future of each of these product types. In the absence of such an alignment, we ask the European Commission to publish and widely disseminate a statement, after the adoption of the delegated directives amending RoHS Annex III. This is needed to indicate which timeline takes precedence for each of these product types: that of RoHS or that of Ecodesign? Manufacturers of these product types across the world and their users in Europe need to have a clear understanding of the net effect of the body of EU law (both Ecodesign and RoHS) on the availability of these product types on the EU market over the next few years. The Community of European Railway and Infrastructure Companies (CER aisbl) shares the position of LightingEurope.
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Response to Standardisation Strategy

7 Jul 2021

The Community of European Railway and Infrastructure Companies (CER aisbl) supports this initiative of the European Commission and underlines the strategic and economic importance of having well-prepared standards available to the railway community. Business-led standards provide a real potential for cost reduction, the creation of new business models or an increase in competition and greater opportunity for system effectiveness and efficiency. CER thoughts on improving European standardisation: - Work with CEN, CENELEC (and ETSI) and the NSBs to streamline their rules, review and optimise the digital tools (digital meetings and methods) to reduce the costs of standardisation for companies and increase the involvement of experts from the railway operating community. - Establish a high-level dialogue between the railway sector and ESOs and NSBs. This would be achieved by creating an efficient standing mechanism to systematically facilitate technical cross-fertilisation amongst TCs in the 3 ESOs and include, at all levels, bodies active in the preparation and publication of railway standards or standard-like products (such as the UIC). - Raise the profile of Sector Forum Rail (SFR-JPCR). SFR should be tasked with coordinating exchanges between EU railway stakeholders, NSBs and the relevant ESO Technical Committee (TC) chairs, alerting them on specific items that are crucial for the EU railway sector. - The railway operating community shall work with the European Commission (EC) and the European Union Agency for Railways (ERA) so as to ensure that there is formal recognition of the foundational assets that have been created by the railway operating community and on which much of the railway system of today has been built. This needs to be seen as part of the EU standardisation system and defended alongside the ESO products during international commercial negotiations with third countries in order to avoid undermining the business interests of the railways. - Create a systemic, structural link with innovation (Europe’s Rail JU and other innovation programmes…) to facilitate the preparation of standards much earlier in the innovation process. CER thoughts on improving International Standardisation: - The railway operating community will work with ISO and IEC to streamline their rules, review and optimise the digital tools (digital meetings and methods) to reduce the costs of standardisation for companies and increase the involvement of experts from the railway operating community. - Establish an SFR coordination mechanism with ISO and IEC and their relevant TCs so as to ensure that the business interests of the railway are fully understood and taken into account in order to avoid duplication, maximise opportunity, minimise cost and enable the proposition of New Work Item Proposals (NWIP)s by the railways for the railways
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Response to A Drone Strategy 2.0 for Europe

1 Jul 2021

The Community of European Railway and Infrastructure Companies (CER) very much appreciates this European Commission initiative on drones. CER welcomes amendments to the current regulation on the operation of unmanned aircraft as this market is tremendously developing fast. We welcome to further develop and probably restrict certain drone operations and encourage the European institutions to assess the previous and current regulation(s) in force (Commission Implementing Regulation (EU) 2019/947 of 24 May 2019 on the rules and procedures for the operation of unmanned aircraft) and propose necessary amendments taking into account the return of experience or restrictions that did not show the expected effects. We believe that it is of utmost importance to involve the drone users in the regulatory process in order to ensure the return of experience of the particular domain being appropriately and comprehensively taken into account. A general survey (or similar means) in each participating Member State of the Union might help to fully understand the market, its needs and problems. We understand from the road-map that "this exercise will consist both in an online public consultation as well as targeted stakeholder consultations in the context of a preparatory study to be launched in Q2 2021" and that "a "Synopsis Report" will be published there after the consultations are completed." We recommend that this "Synopsis Report" shall include a study on drones with different areas of application across the Union and in particular in and around the transport sector. CER acknowledges that "the EU needs to ensure the safe and efficient development of a drone ecosystem, addressing other related societal concerns such as safety, security, privacy and environmental protection while simultaneously ensuring a sustainable economic environment for the European drone industry to grow." We suggest to examine both the opportunities and the challenges and balance the needs of all involved actors for creating an innovative, sustainable, economically strong and safe Europe.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Community of European Railway and Infrastructure Companies (CER) welcome the opportunity to provide feedback on the draft EU Taxonomy Article 8 Delegated Act. CER supports harmonisation of the non-financial information reporting rules at the EU level on taxonomy-related disclosures. European railways are prominently included in the EU taxonomy on climate change and see an added-value of better disclosures in the overall sustainable finance framework. The sector has an experience in providing non-financial information and ready to work with the European Commission to align reporting approaches. CER is also reviewing the Commission proposal on the New Corporate Sustainability Reporting Directive (CSRD) and will contribute with more detailed proposals in the near future. Please refer to the attached document for CER's clarification requests.
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

21 May 2021 · Meeting to discuss the state of play of rail files.

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

30 Apr 2021 · State aid issues of relevance for the rail sector

Meeting with Johannes Hahn (Commissioner)

26 Apr 2021 · EU action on post pandemic recovery and resilience, opportunities for the railway sector

Meeting with Adina-Ioana Vălean (Commissioner)

23 Mar 2021 · Meeting President

Response to Evaluation of the European Union Agency for Railways (ERA)

18 Mar 2021

The Community of European Railway and Infrastructure Companies (CER) appreciates and fully supports this EC initiative of a "fitness check" for the European Union Agency for Railways (ERA). ERA is a pivotal player and an important interlocutor for the European railway actors. A well functioning and efficient Agency is one of the prerequisites for a vital, high-preforming and competitive European railway sector. CER fully supports the assessment criteria outlined in the document (Evaluation of the EU Agency for Railways - Ares(2021)1555088 - 01/03/2021): • Effectiveness • Relevance • Efficiency • EU added value • Coherence of the Agency’s regulatory framework itself, and the coherence of this framework with other relevant EU policies. Particular attention in the framework of the assessment/ evaluation shall be given to: • ERA's budget (need for sufficient budget to carry out the tasks of the SPD comprehensively) • ERA's staff (need to attract and have skilled staff for the upcoming challenges (SSC, VA, ERTMS TS AP) Applications, Digital Railways, Next TSI Revision, System Pillar) • Digitalisation [Digitalisation at ERA and ERA in a digitalised (railway) world] (need to cope with the challenges of a digital railway system) • Preparedness for a changing railway world (Hyperloop, Railway target system, Interface Rail/Road) CER is committed to actively contribute to this activity ("Evaluation of the EU Agency for Railways") at European level as a representative body and as a partner of the European Union Agency for Railways in the framework of consultations/ providing RoE and interviews etc..
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Response to Revision of the NIS Directive

17 Mar 2021

The Community of European Railway and Infrastructure Companies (CER aisbl) supports the overall intention of the proposed NIS-2 Directive. In our opinion it is fully justified that the EU and the entities in the critical sectors pay more attention to and harmonise the efforts for cyber security. This is necessary as both the dependency of the critical entities on digital services and products as well as the associated cyber threat increase rapidly . As indicated in the impact assessment, costs incurred by entities for cyber security will increase considerably due to the introduction of the NIS-2. The cost increase is estimated 12% for entities already appointed as critical entities under the current NIS Directive and 22% for newly appointed critical entities. A number of sectors concerned by the NIS Directive still are dealing with the consequences of the current COVID crisis. For the rail transport sector it is foreseen that it will take a considerable time before this sector will have recovered from the negative financial impact of the crisis. Due to this reason the implementation of the NIS-2 Directive has to be accompanied with substantial financial supporting measures from the EU for the entities operating in this sector. We believe that it is important that the new NIS regulation will include some mandatory minimum demands/requirements, that all actors in the specific sectors must fulfill. We need to be able to measure a cyber security baseline across county border. It will increase the cyber security in the whole sector and will make it easier to do tenders, supply change and procurement. Detailed CER comments are provided in the attached document.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

17 Mar 2021 · RFF

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

1 Mar 2021 · Rail and the European Green Deal

Meeting with Celine Gauer (Head of Task Force Secretariat-General)

22 Feb 2021 · RRF

Meeting with Elisa Ferreira (Commissioner)

19 Feb 2021 · To discuss the role of rail in the transition of the European transport system in line with the objectives of the European Green Deal and the investment in the rail sector, cohesion policy in the post-COVID recovery.

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

16 Feb 2021 · Meeting to discuss the European Year of Rail future events.

Response to Legislative framework for the governance of common European data spaces

3 Feb 2021

CER believes that data and digitalisation provide new opportunities throughout logistics and mobility systems, and for EU citizens and businesses. Moreover, efforts to digitalise the transport sector will also contribute to achieving the EU Green Deal objectives. Nevertheless, we are acutely aware of the challenges to be overcome to unlock the potential of the data economy, including: Stakeholders’ lack of trust that data will be used in line with or even without contractual agreements, given the unequal bargaining power between the parties. • The lack of economic incentives, including concerns over competitiveness and protection of commercial interests. • The risk of misappropriation of data by third parties, resulting in potential consumer protection and liability issues. • A lack of legal clarity surrounding the governance of data access and use (including co-created data, such as from the Internet of Things) and re-use/re-distribution. • A lack of understanding of the total costs associated with data generation, data processing, storage, and distribution. Given these challenges, steps must be taken to ensure equal opportunities for all business partners in the digital economy. To this end, a fair and transparent governance structure for business-to-business (B2B) data is needed. We are calling on data governance that explicitly sets out the following principles for the provision of B2B data: i. The voluntary provision of data: The forced provision of business data could hamper the competitiveness of European businesses by increasing the power of a few large companies at the expense of smaller players such as SMEs. B2B data exchange should continue to rely on voluntary contractual agreements, as this is a flexible and efficient option. This principle should apply to all companies, whether public or private, operating a purely commercial service or under a public service contract and regardless of their ownership structure. ii. Responsible actors: The obligations and liability of data aggregators should be clearly defined at the EU level and the rights of data generators explicitly recognised. In particular, the collection, storage, processing, sharing, use, re-use, access, and security of data should be clearly defined in B2B contracts. This can boost the trust and mitigate concerns of data misappropriation. iii. Standardisation and interoperability: The lack of commonly agreed interoperable and multimodal specifications at the EU level, for example, for APIs or data formats, is an issue that makes interoperability between platforms difficult and increases the risk of lock-in with platforms. The standardisation efforts must factor in the economic and operational realities of transport companies and not represent an excessive burden. In this respect, initiatives like the delegated acts under the ITS Directive are useful for establishing certain standards for the transport sector as a whole. Data spaces should be supported through cloud infrastructure based on the principles of security, interoperability, and data portability. iv. Boost skill development to boost competitiveness: Innovation and technology in the transport sector should be underpinned by a strong focus on skills. Skills need to be upgraded to take full advantage of the opportunities provided by databased business models. To achieve the full potential of digital transformation and more competitiveness of the EU, businesses need incentives to upskill their talent in critical areas such as artificial intelligence (AI), machine learning (ML), and cloud computing. v. Financial support: the impact on the industry of the transition to a digital economy should not be underestimated, as the fixed costs are high and the margins are low. In order to embrace digitalisation, the transport sector requires legal and regulatory clarity but also financial support, including for small- and medium-sized enterprises.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

1 Feb 2021 · Covid-19, European Year of Rail

Meeting with Adina-Ioana Vălean (Commissioner) and UNIFE

25 Jan 2021 · Perticipation of the Commissioner to the European Railway award ceremony

Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

18 Dec 2020

CER welcomes the opportunity to provide feedback to the Inception Impact Assessment expressing the intended revision of the Regulation on Union Guidelines for the development of the trans-European transport network (TEN-T). Transport infrastructure policy at EU level is essential for the coordination of important transport projects, the overall development of cross-border and regional infrastructure as well as cohesion and social inclusion. It is an important enabler for the European economic growth and provides opportunities for jobs. Please see attached the response of CER to the Inception Impact Assessment on the revision of the Regulation on Union Guidelines for the development of the trans-European transport network (TEN-T).
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Response to Certain aspects of railway safety and connectivity

9 Dec 2020

The Community of European Railway and Infrastructure Companies (CER aisbl) welcomes the European Commission’s regulation proposal. The regulation, if adopted, will effectively ensure continuity of operations in the Channel Tunnel on 1 January 2021 by extending the validity of the infrastructure manager’s safety authorisation by two months on the one hand and the validity of operators’ licences and safety certificates by nine months on the other hand. Given the strategic importance of the Tunnel for the EU economy, the stability of the Channel Fixed Link’s regulatory and safety regime is crucial. The regulation is necessary for two main reasons: - It will leave more time for France to negotiate with the UK an additional protocol to the Treaty of Canterbury that would preserve the unified safety framework of the Channel fixed link, and would enable the mutual recognition of licences and certificates in the Tunnel. France did not receive the EU mandate to open these negotiations until October 2020. - It will leave more time for the Tunnel’s infrastructure manager and operators to prepare for a scenario in which the Franco-British negotiations fail to deliver a solution. We believe that it is in the interest of all parties to reach an agreement preserving the unified regulatory and safety regime of the Channel Tunnel.
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Response to Revision of the Intelligent Transport Systems Directive

19 Nov 2020

CER welcomes the opportunity to respond to this roadmap consultation for the Revision of the Directive on intelligent transport systems (ITS). Please find attached CER response to the consultation, which we ask the Commission to kindly consider. CER members represent 92% of rail passenger operations in EU, EFTA and EU accession countries. Our members are delivering transport services and are active in the field of ticket-distribution and multimodal offerings. Railways will play a major role in delivering the objectives of the upcoming EU smart and sustainable mobility strategy and should be the backbone for multimodal, low-carbon transport systems. Multimodal journey offers already available in the EU and the rail sector is committed to offer market-driven door-2-door solutions for the customer and to become an actor to facilitate sustainable multimodal mobility. In context of the ITS Revision, the existing ITS Directive laid out the recently implemented Delegated Regulation 2017/1926 on Multimodal Travel Information Systems (MMTIS). The MMTIS Delegated Regulation is of particular interest to our members.
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Response to Union of Equality: European Disability Rights Strategy

12 Nov 2020

CER members represent 92% of rail passenger operations in EU, EFTA and EU accession countries. Our members are delivering transport services for persons with disabilities and active in the field of assistive technology such as developing accessible apps, ticket-distribution and websites. We have already commented on the public consultation to evaluate the EU Disability Strategy 2010-2020. Kindly note that our responses are solely taken from the perspective of railways as passenger service operators and not from a viewpoint as an employer. The roadmap explicitly makes reference to mobility and “free movement of persons can be facilitated by continuous strengthening of accessibility and passenger rights legislation to guarantee access to transport at all levels” under Item B on the aims and objectives. CER provides relevant points in the attached position.
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Response to Amendment of Directive (EU) 2016/798 on railway safety as regards the application of safety rules in the Channel Tunnel

1 Oct 2020

The 4th Railway Package’s Technical Pillar was adopted with the ambitious goal of facilitating the applications for vehicle authorisation and safety certification, with the European Union Agency for Railways (ERA) playing a central role in these processes and being the one-stop-shop for all applicants. The upcoming withdrawal of the United Kingdom from the European Union creates particular challenges for railway undertakings offering services through the Channel Tunnel from the United Kingdom to France and beyond. The Community of European Railway and Infrastructure Companies (CER aisbl) believes that in times of political uncertainty, the respective roles and responsibilities of the entities granting safety certifications for the “areas of operation” in the United Kingdom, the Channel Tunnel and France should be stable and reliable for the applicants. As the Channel Tunnel is structurally and operationally a single piece of railway infrastructure, we recommend that a single safety authority responsible for the whole Channel Tunnel is maintained. Due to the fact that on a small part of the European railway network between the United Kingdom and France, three areas of operation require multiple applications for safety certificates, requiring complex applications based on vast safety management systems, we recommend to maintain, as much as possible, the status quo regarding the entities granting safety certification for the above described areas of operation for the sake of safety, legal certainty and business continuity. Having two separate regulatory regimes for the Channel Tunnel would negatively impact the existing high level of safety and create an additional administrative burden. CER fully supports the attached position paper of our member Eurostar International Limited and calls the European Commission as well as the United Kingdom to make all efforts in order to find a pragmatic solution that allows continuing smooth railway travel between the United Kingdom and the European Union in future without a burden for the railway sector or endangering its competitiveness.
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Meeting with Carlo Fidanza (Member of the European Parliament)

2 Sept 2020 · Focus on TRAN files

Response to Advance Information on Air Passengers

17 Jul 2020

CER members represent 92% of rail passenger operations in EU, EFTA and EU accession countries. Our members are operating inter alia international rail passenger services including stops at third countries. The EU and the railway sector have been working for many years on facilitating cross-border rail transport by improving rail interoperability, investing resources into rail infrastructure and creating a common market for rail services. Any security-measures and requirement which impact seamless cross-border rail travelling must be of proven added-value and be proportionate to the level of security gains desired. In the context of the consultation, the rail sector is therefore concerned about the roadmap’s policy option to expand the data collection as to include other modes of transport. The existing Directives has been prepared and implemented for the air sector only, and a possible scope extension to other modes of transport shall take into account all the specificities, negative consequences and particular needs of each mode. A thorough and holistic impact assessment is important in order to mitigate the potential operational and economic impacts of such legislative measures. In our attachment (attached pdf-document: CER response_roadmap consultation API Directive_17072020) we elaborate key concerns of the railways on the roadmap, which we ask the Commission to duly take into account.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

3 Jul 2020 · Discussion on rail transport and the economic recovery

Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

3 Jun 2020 · Meeting to discuss the subject of RAIL

Response to Evaluation of the Commission Notice on market definition in EU competition law

14 May 2020

Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for the opportunity to respond to the Evaluation Roadmap of the Commission Notice on the definition of relevant market for the purposes of Community competition law (hereinafter ‘Notice’). As definition of the relevant market is a starting point in any type of competition analysis, and both rail freight and passenger services markets in the EU are opened to competition, the definition of relevant market and the present evaluation of the Notice are of a great importance for CER members. CER notices the necessity of the revision of the Notice in the light of the many economic and market changes that have occurred since its adoption in 1997 – more than 22 years ago. Undoubtedly, the present evaluation will allow the Commission to conduct a comprehensive assessment of these developments to later reflect them in the updated text of the Notice. In this regard, CER would like to ask the Commission to carry out an in-depth assessment and carefully take into consideration the impact that the revision of the Notice and the possible new approaches towards the definition of the relevant market would have both on the railway services, as well as on the supply sector.
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Meeting with Frans Timmermans (Executive Vice-President) and UNIFE and ALLIANCE OF RAIL NEW ENTRANTS

14 May 2020 · Recovery and Green Deal in Transport

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

21 Apr 2020 · Impact of Coronavirus crisis on the rail sector and road to recovery

Response to Revision of the Energy Tax Directive

23 Mar 2020

As CER has stated before, the ETD's existing mandatory energy tax exemptions for aviation and maritime shipping (Art. 14(1) (b) and (c)) have a negative impact on the environment and on the level playing field with rail. They should be removed. The optional tax exemption in Art. 15(1)(e) for energy products and electricity used for goods and passenger transport by rail, metro, tram and trolley bus should be maintained to allow incentivising the use of these environmentally friendly modes of transport. From 2023 at the latest, in case a member state chooses to continue exempting aviation or maritime shipping, it should be obliged to also exempt rail, a competing transport mode, from energy tax. The dedicated ETD public consultation planned for this spring should also allow businesses to respond, in addition to the stakeholders listed in the latest roadmap. Given the climate emergency and the delay already incurred since the ETD public consultation in 2018, the Commission should publish its proposal for a revised ETD as soon as possible and in any case by the target date June 2021.
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Meeting with Frans Timmermans (Executive Vice-President)

19 Feb 2020 · Green Deal and the rail sector

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

10 Feb 2020 · Preparation of an upcoming meeting of the Executive Vice President

Meeting with Dara Murphy (Cabinet of Commissioner Mariya Gabriel)

27 Jan 2020 · European Green Deal

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

10 Jan 2020 · Contribution of railways to the Green Deal

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

10 Jan 2020 · Railways

Response to Rules for rail vehicle extension of area of use and specifications on standards and transition under Union requirements

13 Dec 2019

The Community of European Railway and Infrastructure Companies (CER) believes that good provisions were defined by the European Commission to facilitate an extension of the area of use for railway vehicles without unnecessary bureaucratic burden. Nevertheless, we believe that the requirements in the draft legal text “COMMISSION IMPLEMENTING REGULATION (EU) …/... of XXX amending Commission Regulations (EU) No 321/2013, (EU) No 1299/2014, (EU) No 1300/2014, (EU) No 1301/2014, (EU) No 1302/2014, (EU) No 1303/2014, (EU) No 1304/2014 and (EU) 2016/919 as regards the extension of the area of use, the transition phase and applicable standards” regarding • the EC type or design examination certificate and • the extension of the area of use in the CCS domain are not appropriate and will lead to significant additional and unnecessary costs for the railway operating community. Inevitably, such financial burden will have a negative impact on the competitiveness of the railway operating community (in particular railway undertakings). CER emphasises that the technical pillar is designed to boost the competitiveness of the railway sector by significantly reducing costs and administrative burden for railway undertakings wishing to operate across Europe. The EC type or design examination certificate in Annex I and II (LOC&PAS and WAG TSI) The defined end of the validity period of the new EC type or design examination certificate is critical for RUs as they will lose the flexibility they have today (e.g. issue of release orders of a framework contract). In the long term, this might lead to unnecessary changes of the fleet and hence unnecessary costs. It might as well lead to more diversity in the fleet and problems with obsolescence of spare parts. CER has already illustrated the huge financial burden with concrete figures to the European Commission. CER suggests the following (re-)wording: “The validity period of additional EC types or design examination certificates shall be limited to 7 years (LOC&PAS) / 10 years (WAG), without exceeding 7 years (LOC&PAS) / 10 years (WAG) after the end of the validity period of the original EC type or design examination certificate” The extension of the area of use regarding the Control Command and Signalling (CCS) domain For the extension of the area of use for a vehicle, the technical compatibility between the vehicle and the network that forms the new part of the area of use (articles 21 and 23 of the Interoperability Directive and article 39 of PA VA) applies exclusively. Therefore, it is our understanding, that there shall be no compulsory ETCS retrofit in case of the extension of the area of use. With the new Interoperability Directive, the PA VA, and the CCS TSI in force, we believe that the legal framework is fully sufficient, there is no need for such additional provisions and recommend refraining from such amendment of the legal provision in force. In this light, we reiterate our message that the technical pillar is designed to significantly reduce costs and administrative burden for railway undertakings.
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Meeting with Jean-Eric Paquet (Director-General Research and Innovation) and UNIFE and EUROPEAN RAIL INFRASTRUCTURE MANAGERS

4 Sept 2019 · Joint meeting CER-EIM-UNIFE to discuss future of transportation in Horizon Europe

Response to System of certification of entities in charge of maintenance of vehicles in the railway sector

14 Mar 2019

The Community of European Railway and Infrastructure Companies (CER) acknowledges the intensive discussion on the ECM scope extension but believes that the current draft is not yet mature enough and will be a burden for the European railway sector. CER underlines the following principles: 1. ECMs should be covered by a mandatory certification scheme applicable for all vehicle but exemptions/derogations should remain possible for vehicle out of the scope of the interoperability/safety directive and rail road vehicles. There shall be two options for this certification, either through: a.) the SSC of a railway undertaking or the safety authorisation of an infrastructure manager with the possibility to subcontract ECM functions 2, 3 or 4, or b.) the certification by a certification body. 2. The scope of any mandatory certification should be limited to ECM function 1 (management of maintenance) 3. Provisions on safety critical component as proposed in the draft will only increase administrative burden and should therefore be deleted or thoroughly revised. CER believes that a harmonised and stable “short list” of safety critical components is the preferred option in order to facilitate harmonisation and interoperability. We suggest to use the JNS process for enhancing the aforesaid list instead of following a less coordinated process.
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Response to Rear aerodynamic devices according to the amended directive 96/53/EC on maximum weights and dimensions

11 Mar 2019

We would like to thank DG MOVE’s Road Unit (and Frederik RASMUSSEN) for their efforts: 1. To take into account the railway requirements to ensure the intermodal compatibility of aerodynamic devices (notably the 2600mm maximum width limit); 2. To have voiced the railways’ concerns to DG GROW with respect to type approval requirements; 3. To have striven to a synchronisation of DG MOVE’s and DG GROW’s respective implementing acts in the very spirit of “better regulation”; 4. To have launched the present consultation prior to the meeting of the Committee on Road Transport (CRT) on 1 April 2019 where we understand that this implementing act may be voted upon. Furthermore, we would like to make the following comments: 1. We understand that DG GROW decided to postpone the adoption to its Implementing Act on “Type Approval” to the next legislative term. In the same spirit of “better regulation” as has prevailed so far on DG MOVE’s side, we believe and hope that DG MOVE will kindly consider the possibility to postpone its own CRT Committee vote in order to ensure maximum synchronisation with DG GROW’s TCMV Committee (now postponed) vote. 2. Indeed, the DG GROW's implementing text as it stands today still requires major improvements on “Type Approval requirements” to ensure intermodal compatibility. These necessary improvements may have a significant impact on DG MOVE’s implementing act related to “Conditions of Use”. 3. Based on the current status of DG GROW’s implementing act, we are already in a position to recommend the following amendments to the DG MOVE’s text: 3a. In order to make sure that transport units are made perfectly compatible with intermodal transport, truck drivers should make all the necessary checks before or while the transfer to the other mode takes place. Therefore, in order to mirror a similar amendment proposed on DG GROW’s implementing act, please consider REPLACING ARTICLE3 §3a BY THE FOLLOWING TEXT: “In preparation of an intermodal transport, i.e. before or while transport units (tractors, trailers, semi-trailers, containers, swap-bodies or any combination of them) are transferred to another mode of transport (rail, maritime or inland waterways), all types of devices and equipment (including those listed in Appendix 1 of Regulation 1230/2014) shall be in the closed position in such a way that they do not protrude at all outside the vehicle permissible outermost dimensions as set out in Regulation 1230/2014.” 3b. In order to make sure that Trailers & Semi-Trailers (as well as, preventively, any other types of units which could be fitted with various devices and equipement in the future) are in the scope of 96/53, a broad definition of “Intermodal Transport” should be added to ARTICLE 2. Therefore we suggest to add the following paragraph to ARTICLE 2: “(d) For the purpose of this regulation, an “Intermodal Transport” means the transport of one or more transport units (containers, swap bodies, tractors, trailers, semi-trailers, etc… or any combination of these) where the unit(s) concerned use(s) road on at least one leg of the journey and rail or inland waterway or maritime services on at least one other leg of the journey.” This also reflects a similar amendment that we suggested to DG GROW’s Implementing Act on Type Approval. 4. Please note that we may have further comments or suggestions for improvements once we know more about the final text of DG GROW’s Implementing Act on “Type Approval”. We thank you in advance for taking into account the railways’ suggestions to ensure full compatibility of the trucks and trailers of the future with intermodal transport and remain at your disposal shoud you have any question.
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Response to Evaluation of the 2011 White Paper on Transport

7 Mar 2019

Transport White Paper, adopted by the European Commission in March 2011, provided a comprehensive strategy and vision for tomorrow’s transport in Europe. In 2016, Community of European Railway and Infrastructure Companies (CER) contributed to the implementation report of the Transport White Paper. CER believes that the modal shift targets of the 2011 Transport White Paper are central to the delivery of Europe’s overall goals of cutting greenhouse gas emissions, achieving energy security, and relieving congestion. Decarbonisation of the transport sector remains both a challenge and an opportunity. CER would like to draw attention to the European Environment Agency data that show the greenhouse gas emissions (GHG) gap between the transport sector and the 2011 Transport White Paper’s target. Emissions in the transport sector are constantly increasing since 2014 and that the EU will fail to achieve the transport GHG target as set by the 7th Environmental Action Programme. Both the European and the global approach addressing climate change have changed a lot since 2011. We need to act now to accelerate transport decarbonisation. In November 2018 the European Commission adopted its climate vision for 2050. In December 2018 Member States published their draft national climate and energy action plans. Building on EU’s obligations under the Paris Agreement, the European transport sector needs to prepare for achieving climate neutrality by mid-century. Rail sector is embracing the challenge of transport decarbonisation by leading the way to climate-neutral mobility in Europe. See attached CER Fact Sheet on climate. CER requests transport sector to be higher agenda in the European Union strategy. 2011 Transport White Paper should match the overall 2050 objectives with a clear roadmap for short term actions. Against that background, CER welcomes the timely evaluation of the 2011 Transport White Paper. CER agrees with the proposed evaluation roadmap and is ready to support the Commission with providing inputs at all levels.
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Response to Type-approval requirements for elongated cabs and rear flaps for trucks/trailers

22 Feb 2019

Add recital: “To ensure COMPATIBILITY with INTERMODAL TRANSPORT as per Dir.96/53 - Art.8b-3(c) the respective railway regulation in force shall be used as reference” 6 additional conditions MUST be added to text apart from max length limits (trailer +200mm; cab +800mm) CONDITION 1: When retracted/folded devices must RESIST AIR PRESSURE under RAIL OPERATING CONDITIONS, eg crossing in tunnels (notably with High Speed trains), lateral winds… To prevent potential dramatic accidents ANNEX I must be completed especially Parts A, B (§ 1.3.1.2.4), C (§ 1.3.1.2.4), D (§ 1.4.1.2.4) where values mentioned are insufficient A provision shall be added that “Aerodynamic load cases and a calculation method to derive them shall be agreed upon. Prototypes’ tests shall be performed ‘in situ’ in various rail-operating conditions, the results of which shall be used to define requirements on structural strength”. Such ‘in situ’ tests are foreseen in the EU-funded AEROFLEX project but they are not sufficient as they will cover only a small variety of rail operating conditions! Reference shall be made to existing regulations, notably TSI WAG (Reg. 321/2013 as revised by RISC Committee on 31/01/19 – See Appendices). See sections 4.2.2.2 & 6.2.2.1 referring to Chapters 5-6-7 of EN 12663-2:2010 as mandatory standards regarding structural requirements of railway vehicles (e.g. see 7.8.1.5-Stresses caused by trains passing). The aerodynamic load cases shall account for pressure changes generated by passenger trains operating in open air and in tunnels as defined in TSI LOC&PAS (Reg. 1302/2014 as revised by RISC Committee on 31/01/19) § 4.2.6.2.2+6.2.3.14 and 4.2.6.2.3+6.2.3.15 referring to EN 14067-4:2013 and EN 14067-5:2006 CONDITION 2: The TOTAL WIDTH of Trucks&Trailers (including devices) must not exceed 2600mm ANNEX I to be amended esp. Part A + Part B (§ 1.3.1.1&1.3.1.2) + Part C (§ 1.3.1.1&1.3.1.2) + Part D (§ 1.4.1.1&1.4.1.2): Add to clause “in a such a way that the maximum authorised width of the vehicle [] is not exceeded by more than 25mm on each side of the vehicle” the following text “and remains within the limit of 2600mm permissible on rail (as part of an intermodal transport)” CONDITION 3: The LOWEST POINT of devices from the ground MUST BE ABOVE 830mm Amend ANNEX I Part A + Part B (§ 1.3.1.1&1.3.1.2) + Part C (§ 1.3.1.1& 1.3.1.2) + Part D (§ 1.4.1.1&1.4.1.2): add to clause “the maximum authorised length of the vehicle is not exceeded by more than 200 mm” the following text: “over a height of 830mm from the ground when the trailer's or semitrailer's suspension is in the lower or deflated position; the maximum authorised length of the vehicle is not exceeded at all, below a height of 830mm from the ground when the trailer's or semitrailer's suspension is in the lower or deflated position” CONDITION 4: TOLERANCES for devices to be excluded from the determination of outermost dimensions are DANGEROUS! Future technological innovation should precisely be applied to avoid the protrusion of devices rather than to multiply protuberances leading to a multitude of derogations and consequently hazards in a rail-operating context. Too many exceptions to the rule kill the rule. Appendix 1 Tables I, II and III cannot be tolerated. Instead, a provision shall be added that: “All devices fitted on trucks and trailers shall not be allowed to protrude (at the minimum when folded/retracted) so as not to cause any hazard during rail transport nor any changes in rail operating conditions” CONDITION 5: Safety criteria regarding LOCKING must be detailed ANNEX I to be amended, esp. Part A + Part B (presumably § 1.3.1.2.2) + Part C (presumably § 1.3.1.2.2) + Part D (presumably § 1.4.1.2.2): Add provisions on safety criteria (to be “type-approved) including LOCKING in both FOLDED & unfolded positions CONDITION 6: The surface of aerodynamic devices shall be non-reflecting to avoid false alarms of profile measuring systems
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Meeting with Themis Christophidou (Director-General Education, Youth, Sport and Culture)

20 Feb 2019 · Speech at General Assemnly

Response to Inventory of assets for railway infrastructure related to persons with reduced mobility (PRM)

19 Nov 2018

The Community of European Railway and Infrastructure Companies (CER), together with its partner, the European Rail Infrastructure Managers (EIM) (forming the European railway operating community), very much appreciates the joint efforts made to shape the IMPLEMENTING REGULATION - Railway networks — disabled access (inventory of accessibility infrastructure). CER and its partner EIM would like to draw the European Commission’s particular attention to the following issues: 1. It’s not clear how long the entity in charge of collecting and providing data will have time for it. According to this proposal to the PRM TSI on Inventory of Assets the amended article 7a bullet (1) each MS shall decide which entities are in charge nine months after EIF. Bullet (2) states that MS can ask for extension. But (4) states that collection shall be finalised within 36 months after EIF, leaving no space to collect data or set up conversion if the MS has notified an extension. CER/EIM recommend: If the MS has notified an extension for determining the entities the end date of collecting data has to be postponed for at least the same period of time. 2. The amended article 7a bullet (3) of this proposal to the PRM TSI on Inventory of Assets states “For each station, there shall be an entity responsible for exchanging the accessibility data”. The minimum structure and content of data to be collected for the inventory of assets (former appendix O) contains data fields concerning assets where different owner of the assets might exist. Hence the entity in charge of collecting, maintaining and exchanging the accessibility data might not have a juridical basis to receive the data and might have problems to receive data in case of updating of the assets and the responsibility of the entity concerning the correct data is not clear. The station management has shared responsibilities and this is not reflected in this proposal. 3. The bullet (1, last sentence) of this proposal to the Annex of the PRM TSI on Inventory of Assets states: “Where relevant that description is complemented by the information regarding the stations' state of conformity to this TSI.” In consequence the content of the former Appendix O has to be amended to indicate the version of the TSI. This leads to adapt the IT-Tools 4. The minimum structure and content of data to be collected for the inventory of assets (former appendix O) were defined by ERA (by the working party) is not satisfying at all: a. The experience of the testing phase concerning the Bilbomatica Software and the content of former Appendix O (Data to be collected for the Inventories of Assets for Infrastructure) resulting in extensive comments from CER/EIM is not reflected. Without the update of this structure and content (data to be collected for IoA) the MSs would agree to something they do not know exactly. It could happen that small changes in structure and content would lead to increase the effort of data collection in a significant way. b. The final results of structure and content (the former Appendix O) have to be implemented in the Bilbomatica software tool which was built on an old basis of former appendix O. c. Technical solutions are not in place neither the conversion tool nor the manual collecting tool. None of the IM and RU of CER/EIM could finally confirm the technical solutions works properly. d. Concerning b) and c): To adapt the IT-tools requires a long period of time. And in the end there is not enough time to collect data within the fixed period of 36 month.
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Response to Detailed rules on unmanned aircrafts

5 Nov 2018

The Community of European Railway and Infrastructure Companies (CER) acknowledges the intense work done to prepare drone regulations but expresses expectation for simplified regime for drone operations supporting rail operations and concerns that railway environment will get appropriate protection. A workshop on the use of drone within or next to railway infrastructures would help to agree on remaining tuning to be done in regulations and challenges to be fixed by normative documents.  Legal acts should enable drone service for rail but also protect railway. CER notes that the regulatory package does not yet simplify use of drone for railway purpose. Generic railway operation scenarios and harmonized principles for LUC could be appropriate tools but should now be developped in order to simplify mission authorisations. The draft legal acts do not define specific protection of the railway system. There are still some specific risks when flying next to railway infrastructures. In general, open category could be open for missions above railway infrastructure only if they comply with a minimum safety distance to railway tracks. Authorities’ responsibility to prevent and sanction breach of no-drone-zones remains to be clarified and reporting channels defined. Fully automated, pilot-less UAS should be recognized by the act. As we understand, a human pilot or operator is required. The regulation should remain technological-agnostic. Some requirements should be reviewed to keep technical flexibilities (e.g. the wingspan criterion in UAS.SPEC.020 seem to impose unreasonable disadvantages on fixed-wing UAS; conformity with the kinetic impact energy threshold through technical modifications such as parachutes has to be possible requirement of V2V communication in a certain frequency band).
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Response to Review of ecodesign requirements for lighting products

31 Oct 2018

The Community of European Railway and Infrastructure Companies (CER) appreciates the involvement and consultation of the sector stakeholders in the framework of the consultation of the „Review of ecodesign requirements for lighting products”. The Community of European Railway and Infrastructure Companies (CER) is fully committed to develop a sustainable and energy efficient railway system by deploying energy efficient measures and energy efficient products. However, the European railway sector is concerned about the envisaged ban of the placing on the market of fluorescent tube T8 lamps in the European Union by 2021 as such a short transition period is not consistent with the sustainability goals of the railway sector. The European railway sector fears that it would go against the intended energy savings and reduction of emissions while causing an important economic burden to the railway sector. The fluorescent lamp T8 is widely used as the most common lighting system in European railway rolling stock and infrastructure (e.g. stations, terminals or workshops) and many other sectors. In order to meet the needed lighting performance, specific requirements and legal obligations when replacing T8 by LED, mechanical and/or modifications or even a complete replacement of the installation will be necessary before the end of its useful life cycle in many cases. This would result in reduced energy efficiency, increased consumption of resources and extra cost. We appreciate the exemption for railway rolling stock and signalling. Nevertheless, we underline that for shunting yards and stations (platforms) no equivalent substitution product for replacing the current lamps in the existing lightning systems is available that fulfills all legal requirements and railway specific technical specifications. (in particular light intensity and avoiding the effect of glaring) The European railway sector supports a ban of T8 lamps if the transition period is sufficient to allow for a replacement of the lighting installation at its end of life or for bringing them together with other modifications of the fixed installation or vehicles. Therefore, the European railway sector asks for postponing the ban until 2030.
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Meeting with Violeta Bulc (Commissioner) and

18 Sept 2018 · Speech at Innotrans Opening ceremony and visit to stands, Commissioner Bulc as key note speaker at the Rail Leaders` Summit

Response to Revision of language requirements for train drivers to allow pilots exploring alternative options

20 Jul 2018

CER welcomes the European Commission’s pragmatic approach to open up the possibility to test alternative options to the current language requirements set out in Directive 2007/59/EC, while ensuring an equivalent level of safety. It is necessary to better define the language requirement in the Directive, in order to: - Limit the language requirement to what is necessary for safe operations; - Avoid any unnecessary regulatory burden that hamper the ability of railways to offer a reliable service and compete with a much less regulated road sector. CER members are interested to put forward pilot projects. In order to be effective, the procedure set out in the Commission’s proposal and supporting the deployment of pilot projects should be: - Centred on the overarching need to guarantee the same level of safety; - Crystal-clear about the role and responsibilities of every concerned actor; - Aimed at identifying the scope of the clarification and/or revision of the current language competence requirements in the framework of planned general revision of the Directive. With this input paper CER is suggesting concrete amendments to the Commission’s proposal in order to support achieving these objectives. CER and CER members are willing to contribute to the definition of the framework for pilot projects, and to their successful implementation.
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Response to MFF: 9th Framework Programme for Research and Innovation and Rules for Participation and Dissemination

16 Jul 2018

The Community of European Railway and Infrastructure Companies (CER) acknowledges the efforts of the European institutions for establishing Horizon Europe – the Framework Programme for Research and Innovation and laying down its rules for participation and dissemination. CER believes that a significantly larger adequate budget is needed in particular for railway research (Pillar II – ‘Global Challenges and Industrial Competiveness’ including “Mobility”). The budgeting must be coherent with the scope and depth of the rail research programme including provisions that ensure the achievement of the envisaged TRL. In Horizon 2020 only 7% of the transport budget was allocated to railway research. CER believes that this is insufficient. Shift2Rail showed that the committed stakeholders of the Joint Undertaking (manufacturers and the railway operating community) were able to invest and carry out the work. The amount was well spent. More results could be achieved with additional resources. CER calls to put in place appropriate mechanisms to facilitate the dissemination and adoption of results in particular by the railway operating community incl. additional available European funding instruments.
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Response to Multiannual Financial Framework: Specific Programme implementing the 9th Framework Programme for Research and Innovation

16 Jul 2018

The Community of European Railway and Infrastructure Companies (CER) acknowledges the efforts of the European institutions to establish the specific programme implementing Horizon Europe – the Framework Programme for Research and Innovation. In particular we support a strong focus on Pillar II – ‘Global Challenges and Industrial Competiveness’ including “Mobility”. The European railway sector is willing to further contribute to sustainable mobility and railway networks being clean, safe, smart, secure, silent, reliable and affordable, offering a seamless integrated door-to-door service. CER supports any effort to further develop and shape rail technologies and operations for a high-capacity, silent, interoperable, and automated railway system. CER believes that a significantly adequate budget is needed in particular for railway research.
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Response to Economic Equilibrium Test for national rail regulatory bodies

18 May 2018

During the past months the Community of European Railways and Infrastructure Companies (CER) presented in several meetings with the European Commission and other stakeholders concerns of the Railway sector regarding the Draft Implementing Regulation on the Economic Equilibrium Test proposed by the European Commission (DG MOVE). In November 2017 CER produced a position paper underlining all of the points that required attention in the 2nd Draft of the Implementing Regulation released by the European Commission in September 2017. Since then the Draft of the Implementing Regulation was to some extend adjusted with the final text being published and opened for feedback on 20 April 2018. CER welcomes the opportunity to reply to this public consultation and reiterate certain issues on the position paper attached.
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Meeting with Violeta Bulc (Commissioner) and

20 Feb 2018 · Meeting with Mr Fritzsons, CEO of CER & CER Management Committee

Response to Review of ecodesign requirements for lighting products

5 Feb 2018

The Community of European Railway and Infrastructure Companies (CER), the European Railway Infrastructure Managers (EIM), the Association of the European rail manufacturing industry (UNIFE), the International Union of Wagon Keepers (UIP), the European Passenger Train and Traction Operating Lessors' Association (EPTTOLA) and the International Association of Public Transport (UITP) – hereinafter referred to as “the European railway sector” - are fully committed to develop a sustainable and energy efficient railway system by deploying energy efficient measures and energy efficient products. However, the European railway sector is concerned about the envisaged ban of the placing on the market of fluorescent tube T8 lamps in the European Union by 2020 as such a short transition period is not consistent with the sustainability goals of the railway sector. The European railway sector fears that it would go against the intended energy savings and reduction of emissions while causing an important economic burden to the railway sector. The fluorescent lamp T8 is widely used as the most common lighting system in European railway rolling stock and infrastructure (e.g. stations, terminals or workshops) and many other sectors. In order to meet the needed lighting performance, specific requirements and legal obligations when replacing T8 by LED, mechanical and/or modifications or even a complete replacement of the installation will be necessary before the end of its useful life cycle in many cases. This would result in reduced energy efficiency, increased consumption of resources and extra cost. The European railway sector supports a ban of T8 lamps if the transition period is sufficient to allow for a replacement of the lighting installation at its end of life or for bringing them together with other modifications of the fixed installation or vehicles. Therefore, the European railway sector asks for postponing the ban until 2030.
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Response to Fees and charges payable to the European Union Agency for Railways

16 Jan 2018

The CER comments fall into - a PART A with editorial comments and - a PART B with comments on the content PART A - Editorial Comments: ==> 1st editorial comment (Recitals 9 & 10) Change "fees" to "fees and charges" in recitals (9) & (10) ==> 2nd editorial comment (Article 2.2) The reference to the delegated act referred to in Article 6(1)(f) of Directive (EU) 2016/798 shall be replaced by the reference to the delegated act referred to in Article 6(2) of Directive (EU) 2016/798. ==> 3rd editorial comment (Article 3.2) In article 3.2 add the correct reference in which legal document the referenced article Article 80(3) can be found. Proposal (“Regulation (EU) 2016/796”) ==> 4th editorial comment (Article 8.1) Change the reference in article 8.1 from Article "4" to Article "3" ==> 5th editorial comment (Article 8.2 & 8.3) Article 4 does not cover fixed rates applied by the NSA. The reference shall be deleted or changed. ==> 6th editorial comment (Article 8.5) Add a reference to Article 19 Paragraph 3 of Regulation (EU) No 1271/2013 in Article 8.5 "5. The Commission shall, on the basis of the financial results and forecasts of the Agency, revise the range of the hourly rate, if necessary, [ADD: "in accordance with Article 19 Paragraph 3 of Regulation (EU) No 1271/2013"]" -------------------------------------------------------------------------------------------------------------- PART B - Comments on the content: ==> 1st content comment (Recital 4) Add "A working group involving the railway sector and the NSAs, should specify the costs’ perimeter on a yearly basis, in particular for the translation costs." ==> 2nd content comment (Recital 8) Change "non-binding estimate" to "firm quotation" This will ensure predictability of the fees & charges. ==> 3rd content comment (Article 2.2) The relation should be clarified with the ERTMS guidelines on pre-authorisation as there it was indicated that the initial procedure is free of charge. ==> 4th content comment (Article 3.2.) DELETE “staff training related to single safety certification, vehicle authorisations, and decisions for approval by the department in charge of the application. “from the list of indirect costs as they are not accountable in this context. Staff training is already covered in the Agency’s budget. See “ERA's budget and establishment plan 2018” ==> 5th content comment (Article 4.2.) DELETE “by more than 15 %” as any exceedance needs to be justified.
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Response to Rules of procedure of the Board(s) of Appeal of the European Union Agency for Railways

16 Jan 2018

PART A - Editorial Comments ==> 1st editorial comment (Article 15) In Article 15.4 and 15.5 the references need to be corrected In Article 15.4 change from "in point (a) of paragraph 1" to "in point (a) of paragraph 2" In Article 15.5 change from "in point (b), (c), (d) and (e) of paragraph 2" to "in point (b), (c), (d) of paragraph 2" ==> 2nd editorial comment (Article 14.2) Change "chairman" to "chairperson" and make it gender-neutral --------------------------------------------------------------------------------------------------------------- PART B - Comments on the content ==> 1st content comment (Article 1.1) Add "from the list referred to in point (a) of Article 55 (3) of Regulation (EU) 2016/796." ==> 2nd content comment (Article 1.1) Change to "Their term of office shall be limited to 4 years and may be renewed once." ==> 3rd content comment (Article 2.1) Change from "Where the Chairperson of the Board of Appeal considers..." to "Where the Board of Appeal considers..." ==> 4th content comment (Article 4.1) The Chairperson shall designate [ADD: "a member of the Board of Appeal to act"] as rapporteur for each case. ==> 5th content comment (Article 5.1) Change "by one of the other members" to "by an alternate" ==> 6th content comment (Article 13) If the Appeal does not comply with the requirements set out in points (a), (b) and (c) of paragraph ( MAKE THE CORRECT REFERENCE HERE - REPLACE "PARAGRAPH "3" by "PARAGRAPH "2"] of this Article, the Registrar shall prescribe a reasonable period [ADD "not exceeding [5] working days"] within which the appellant is to comply with them. The Registrar shall fix such period only once. During that period, time shall not run for the purposes of calculating the time-limit set out in Articles 58 and 62 of Regulation (EU) 2016/796. ==> 7th content comment (Article 27) Fully align Article 27 of the Commission Implementing Regulation with the ERA Regulation Article 62. "The Agency shall take its final decision in compliance with the findings of the Board of Appeal" Proposal for Article 27.1: "The Executive Director shall issue its decision following the findings of the Board of Appeal [...]" ==> 8th content comment (Article 41) Delete "hear the witness" This is inappropriate for witnesses. Witnesses will most likely be requested by a party (for instance an employee of a RU), so it cannot per se be ruled out that there is some personal interest in the outcome of the case. These matters are better dealt with the principle of free consideration of evidence, which should apply to the Board of Appeals too.
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Response to Evaluation of the General Union Environment Action Programme to 2020 (7th EAP)

4 Dec 2017

CER welcomes the opportunity to contribute to the evaluation of the General Union Environment Action Programme to 2020 (7th EAP). CER has already provided input to the recently published European Parliamentary Research Service's study on the ‘mid-term review of the implementation of the 7th EAP and will be willing to take part in the stakeholder consultation that will be launched in 2018. For what the railway sector is concerned, CER would like to underline that transport emissions are problematic to achieve priority objectives 2 and 3 of the 7th EAP. Without additional new sub objectives it will not be possible to reverse the trend. CER would like to draw attention to the European Environment Agency data, that show the greenhouse gas emissions gap between the transport sector and the 2011 Transport White Paper’s target. Transport’s greenhouse gas emissions are increasing since 2014. CER is requesting transport sector to be higher agenda in the EAP. A necessary step is to confirm in legislation of the Transport White Paper 2011 target for greenhouse gas emission reduction.
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Response to Noise differentiated track access charges schemes

23 Nov 2017

CER welcomes the opportunity to contribute to the evaluation of the implementation of the existing NDTAC schemes in Europe. Evaluation roadmap published by the Commission on 27 October is timely due to the ongoing limited revision of the TSI Noise, which clearly shows that the availability of public funding is not consistent with the policy goals that are currently being addressed by the decision makers. The railway sector is committed to tackle the noise at the source by accelerating freight wagon retrofitting across all member states in order to achieve a public acceptance of rail freight transport. As agreed by the high-level conference on reducing rail freight noise that was organized by CER on 3 May, targeted public funding is a fundamental precondition for speedy retrofitting actions in Europe. The railway sector clearly has a preference for a direct funding of wagon owners/keepers covering both the investment and the higher operational costs to incentivize retrofitting. This is already reflected in the successful uptake of the CEF budget for retrofitting. CEF funds (with higher budget and co-funding) and direct state funding, should possibly be complemented by NDTAC schemes. CER notes that number of retrofitted wagons are significantly increasing per year and these wagons are widely used in the networks with NDTAC. It is therefore possible to state that NDTAC is effective in terms of noise reduction. Diversity of membership in CER will help to bring detailed input from infrastructure managers and freight operators on the implementation of the NDTAC schemes. While it is necessary to investigate those member states (Austria, Germany and the Netherlands) with NDTAC schemes, CER suggests achieving a comprehensive approach in the assessment by adding the Swiss NDTAC system to the evaluation - in particular for the target stakeholder and expert consultations and / or expert group. Although the Swiss NDTAC system is not based on Directive 2012/34/EU, it is in line with the systems in Germany and in the Netherlands, and furthermore the oldest NDTAC system in Europe (since 2002). Therefore, it would be worth taking into account the Swiss experience, too. SBB Infrastructure and the Federal Office of Transport declare their willingness to participate in the evaluation to an appropriate extent.
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Meeting with Maroš Šefčovič (Vice-President) and

6 Nov 2017 · 2nd Mobility Package

Meeting with Henrik Hololei (Director-General Mobility and Transport)

19 Oct 2017 · MFF, Shift2Rail

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

17 Oct 2017 · Meeting with Mr Fritzson and Mr Lochman

Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

11 Oct 2017 · MFF and the future of transport financing

Response to Access to service facilities and rail-related services

17 Aug 2017

The Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for the opportunity to provide feedback to this draft implementing regulation. CER brings together more than 70 railway undertakings, their national associations as well as infrastructure managers and vehicle leasing companies. The membership is made up of long-established bodies, new entrants and both private and public enterprises, representing 73% of the rail network length, 80% of the rail freight business and about 96% of rail passenger operations in EU, EFTA and EU accession countries. Please find attached CER`s Answer to this Public Consultation.
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Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

18 May 2017 · Mobility package

Meeting with Alisa Tiganj (Cabinet of Commissioner Violeta Bulc)

12 May 2017 · rail security and passengers rights

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič) and Transport and Environment (European Federation for Transport and Environment) and Tesla Motors Netherlands B.V.

27 Apr 2017 · Road tollling

Response to Schedule for the rail infrastructure capacity allocation process

14 Apr 2017

The members of CER and EIM fully understand the importance of making the capacity allocation process more open and transparent. For this reason, RNE and FTE, supported by ERFA, launched the project ‘Redesign of International Timetabling (TTR)’, which aims to create exactly that: a more flexible and reliable timetabling process which responds to the needs of the market, with improved commitment to the international timetabling process, and with greater efficiency in terms of capacities and resources, leading to a better use of the existing track capacity. CER and EIM are therefore ready to support the European Commission in designing a process which ensures more predictability for the railway undertaking and flexibility for the infrastructure managers, while taking into account the operational concerns of all stakeholders involved, and which fully reflects the main elements of TTR. The sector has, however, identified a few elements in the Commission proposal which are incompatible with TTR. The main aim of the attached CER/EIM position paper is to highlight those elements and to propose an alternative wording which would be compatible with TTR. In the latest draft of the Delegated Act, the Commission still proposes setting up a two rounds application period. This is justified with the need to give applicants the chance to submit late requests for capacity to be incorporated in the annual working timetable. CER and EIM members believe, however, that such a system will be too rigid, increase the administrative and operational burdens of all stakeholders, and will not deliver the desired goal. In line with the rolling calendar approach of TTR, the sector proposes that capacity requests be made at any time after the annual deadline should be taken into account by the infrastructure manager. Furthermore, to avoid any possible discrimination, there should only be one common rule for all infrastructure managers. CER and EIM support the goal of giving applicants a chance to prepare and adapt to temporary capacity restrictions (TCRs) in due time. In this regard, we urge the Commission to take into account the TTR project, which defines three types of TCR impact clusters on applicants and outlines the timeline and obligations associated with these clusters. All members of CER and EIM fully support the TTR Project, into which the sector has invested considerable time, effort and recourses over the last years. The TTR technical input reflects the experience made by the sector, as requested in Article 43 of Directive 2012/34/EU. In the attached EIM/CER joint position paper, we have built our proposal on the basis of the latest update of the TTR/TCRs project, which was amended by the project manager after conducting trial runs. Finally, CER and EIM understand the Commission’s goal to have the new provisions adopted on time for the Timetable 2019. We believe, however, that the proposal contains several provisions which warrant a derogation from the rule proposed by the Commission i.e. that the act enters into force on the twentieth day following its publication. EIM and CER call on the Commission to foresee a transition period for the application of the Act, which would give the sector enough time to adapt to the new rules and to meet all the timelines required by Annex VII (e.g. x-24, X-18, X-12). Therefore, we suggest that the annex becomes effective 2 1/2 years before the working timetable where the rules have to be applied for the first time.
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Meeting with Silvio Mascagna (Cabinet of Commissioner Julian King)

27 Mar 2017 · Rail security

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

2 Dec 2016 · Preparation of joint event

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen), Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen) and VR-Group Plc

16 Nov 2016 · Investment plan / railways

Meeting with Violeta Bulc (Commissioner) and

20 Oct 2016 · InterRail

Meeting with Henrik Hololei (Director-General Mobility and Transport)

20 Oct 2016 · Rail Passenger Rights Regulation

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

19 Oct 2016 · Energy Union

Meeting with Henrik Hololei (Director-General Mobility and Transport)

26 May 2016 · Freight CEO Task Force, 4th railway package

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

15 Apr 2016 · Commission’s road transport initiatives

Meeting with Violeta Bulc (Commissioner) and

16 Feb 2016 · Meeting board of Community of European Railway and Infrastructure Companies (CER)

Meeting with Violeta Bulc (Commissioner) and

16 Feb 2016 · Meeting Freight CEOs Task Force on pending transport issues

Meeting with Matthias Ruete (Director-General Migration and Home Affairs)

15 Feb 2016 · Rail Transport Security

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and UITP - International Association of Public Transport and

29 Sept 2015 · Metal Theft

Meeting with Matthias Ruete (Director-General Migration and Home Affairs)

29 Sept 2015 · Rail Transport, Passenger Security

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

2 Sept 2015 · On train to COP21 – Paris

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

23 Apr 2015 · Meeting with CER

Meeting with Desiree Oen (Cabinet of Commissioner Violeta Bulc)

24 Feb 2015 · Transporting goods from Asia to the EU - what role for intermodality

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc), Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

6 Feb 2015 · ITS