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Izba Gospodarcza Transportu Lądowego

IGTL

Izba Gospodarcza Transportu Lądowego (Land Transport Chamber of Commerce) jest organizacją samorządu gospodarczego działającą od 1995r.

Lobbying Activity

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

18 Mar 2019

According to art. 15 the transitional period for certification for an entity in charge of maintenance for vehicles other than freight wagons is de facto one year from the date of entry into force of the proposed regulation, because only certification issued before that date remains valid. For large passenger RUs the deadline will probably prove to be too short. The new obligations for maintanance system will require money and deep changes to the internal procedure. It is proposed to lenghten the transition period even up to 4 years.
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Response to Streamlining the implementation of the Trans-European Transport Network (TEN-T)

9 Jul 2018

The proposed regulation project is very far going into the national law and procedure as regards the planning and execution of infrastructure investments. However, it is week in definitions section and does not give any details on implementation. The new regulation leads to integration of all administrative and legal areas such as spatial planning, environmental issues, public consultation, location or building permits within the operation of OSS. There is a risk that a conflict of competences might occur among different authorities and offices responsible for the above mentioned domains. The regulation is blind as the tendering issues are concerned. For large projects some sequencing and splitting into LOTs is a common practice in order to properly use the market potential (design, supply, execution), especially introducing smaller companies into the process, which proved beneficial for the sake of competition. Moreover “design & build” is often utilized and within the process different administrative decisions are being obtained continuously as the design is advancing. The transition periods are totally unrealistic, as the regulation is revolutionary. The evidence of positive impact on streamlining the implementation of TEN-T infrastructure projects is not convincing at all.
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Response to Economic Equilibrium Test for national rail regulatory bodies

18 May 2018

Remarks from Land Transport Chamber of Commerce in the file attached
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Response to Requirements for a safety management system for railway undertakings and infrastructure managers

21 Sept 2017

The file enclosed contains remarks raised by members of the Land Transport Chamber of Commerce.
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Response to Practical arrangements for the rail vehicle authorisation process

29 Aug 2017

Having in mind that in the art. 1 (Subject matter and scope) there is no provision regarding exemptions from art. 21 of the Directive 797/2016, it is proposed to add the following "This Regulation applies without prejudice to Article 21(16 and 17) of the Directive (EU) 2016/797"
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Response to Access to service facilities and rail-related services

17 Aug 2017

Remarks raised by the members of the chamber in the file attached
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