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Ing. Miroslav Haltuf

H-Comp Consulting

Cílem činnosti je rozvíjet a podporovat zapojení veřejných i soukromých organizací do evropských aktivit a projektů souvisejících s dopravou a logistikou.

Lobbying Activity

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

12 Mar 2025

Considering the nature of this regulation (TSI), this draft regulation (published as ST16EN07) should, if possible, include all general features of such regulation, as well as sector-specific features, and also features which are not or cannot be included in another legal document. Such legal document should include the legislative framework it is based on, linkage to other regulations for directly related matters or anything it is based on. What is essential for the correct usage of the regulation as a legal document in its full extent is that it is legally precise and technically accurate It should also unequivocally define terms relevant to the entire scope of the regulation, the meaning of those terms, and the use within its context. A document of this type should in no way define or modify neither legal, nor technical parameters of processes, activities, or outputs not relevant to the regulation. The draft does not fulfil this condition. On the contrary, it contains a number of duplicate definitions which already exist in other documents of an equivalent legal form and these definitions are often at odds or are open to significantly different interpretation. This makes interoperability in the rail system much more difficult and thus as a whole it is more costly and less competitive. Specific examples of this in the attachment. The ongoing discussions leading up to this draft version resulted in a decline in quality of the document rather than improving it. I believe that a draft Regulation, and specifically a version of it just before the approval process, should not contain references to (at the time of its approval process) unfinished documents or legal/technical texts, or those at odds with processes allowed by any legislation in force. Examples again in attachment. Annexes of the regulation should be drafted in the same spirit as the core text. I am supporting full and immediate integration of OSDM and change the actual Telematics TSI-Architecture, at least maintain OSDM topics in the Telematics TSI revision as appropriate compromise draft "open point" before B5 is finalized. The following issues are key: - The title of the Implementing Act - Article 1: interoperable data sharing - All recitals and provisions including data related references, definitions and requirements because it might facilitate the approval process if: - the words for interoperability of data sharing in rail transport are deleted in the title - Data sharing is deleted in all recitals and provisions - ERA recommendations of the 2022 result of the ERA Revision WPs from 2018 to 2021 (if relevant as modified until March 2023) for entering in force is reconsidered The European Commission will grant a new mandate to ERA to draft the revised TSI according to IOD article 5 with a scope extended to the additional requirements in Telematics TSI EN07 Final Summary: Early 2022, after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474), ERA published the TAF/TAP Recommendations. An intermediate revision was included as the first output by an amendment of TAF TSI in 2021. After two years and seven versions of the Telematics TSI, I do not see any significant progress in the draft, or more specifically progress towards a desired improvement in the draft Regulation. That seems to be 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. A full impact assessment or a cost-benefit analysis, which is necessary considering the numerous modifications, is missing. For context, the advisory note on impact was launched only very late in November 2024 and it doesnt allow a proper assessment before the vote planned in June 2025. There are plans to define the implementation deadlines in the RISC of June 2025 without involvement of the entire sector, which is actually in charge of the implementation.
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Response to European Partnership for transforming Europe’s rail system

6 Aug 2019

Since 2013, I have been involved in processes related to Shift2Rail Joint Undertaking under Horizon 2020. The current Shift2Rail Joint Undertaking (JU) is satisfying in its working, but since the beginning of its operation, I have identified many negative aspects, which cause difficulties in financing of the JU, approval of founding and associated members, and in administration of projects. Regarding financing of the current JU, annual financing seems to be an obstacle. Multi-annual financing would be more efficient. As mentioned in the commission document PART-2019-350970V1, it is true that the lack of competitiveness and attractiveness of rail services in comparison with other modes and the lack of appropriate integration of freight. The upcoming partnership needs to address this. Slow deployment and limited market uptake of innovative solutions are caused by the absence of synergies with other funding instruments in the current Shift2Rail regulation. The new partnership has to be strongly connected with CEF, ESFI, and other funds in order to increase market uptake of innovative solutions. Partnerships in HORIZON EUROPE must be more open and transparent, especially for Central and Eastern European countries in order to eliminate the feeling of those member states' authorities that partnerships are "closed clubs" of select companies and research institutions. I personally (and as the representative of the Czech Republic in Shift2Rail SRG) strongly recommend "Option 2" - institutionalised partnership. Significant changes in the rules for members would be necessary. This would include simplification of administrative processes and financing, e.g. by using the lump sum method, which would lead to further motivation of CEEC countries to get involved. The principle that projects are financed only once (in all framework programmes) has to be an essential part of the new methodology in HORIZON EUROPE partnerships. The shortest possible time between result demonstration and implementation must be guaranteed. Focus on innovative potential of all members within the partnerships is key to ensure the success of partnerships. To achieve this goal, there needs to be a major change in governance, rules of procedures, and associated membership should not be automatically for the entire duration of the partnership. Contents of the partnerships need to change from vertical structure (IPs) to matrix structure and calls for projects within partnerships should be approved before publishing by all stakeholders.
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