Plasser & Theurer
Plasser & Theurer is a private Company, specialised in development and manufacturing of machines for railway track maintenance and construction.
ID: 795628730580-67
Lobbying Activity
27 Jan 2023
More than 2 years ago in the first draft of the revised L&P TSI 2022, instead of the former 4 categories, 3 categories with substantially changed content were defined. A category (C) was newly defined, which concerns all Special Vehicles (SVs); i.e. vehicles that do not cover commercial traffic. Why is this separate category necessary? Because not all requirements of this L&P TSI for conventional rolling stock can apply to special vehicles. Therefore, some exemptions were already described for OTMs in the existing L&P TSI 2014. In nearly all chapters of the proposed revision the term OTM has been changed to Special Vehicle, only the main chapter 4 and its appendices have not been changed. Without the definitions of the different categories of SVs in 2.2.2, inconsistency and confusion is created later in the TSI (e.g. 2.3.1, 4.1.3, chapter 4, 7.1.1.3, appendix C) where OTMs and IIVs are then referenced. CR384 provided updates to the LOC&PAS clauses 2.2.2, 2.3.1, 4.1.3, 7.1.1.3 and Appendix C.4. The sole purpose of CR384 was to bring better consistency between the TSI, Interoperability Directive and EN 14033-1. The overall goal of the clarification is to make the application of the TSI clearer and therefore facilitate its use for SVs. Alternatively the TSI should only reference SVs and therefore all references to OTMs/IIVs etc. in the text should be changed to SV as a whole, as considered by DG MOVE in the SV meeting held 29.11.22. The new addition of clause 7.1.1.3(1) to make the TSI LOC&PAS mandatory for OTMs cannot be accepted and must be deleted. This added clause cannot be supported at such a late stage without previous consultation or detailed impact assessment on the business of SV manufacturers and construction companies. Experience today shows TSI application to OTMs requires higher efforts and therefore costs than authorisation via NNTRs. SVs are typical made in low quantities, therefore any additional unnecessary costs must be avoided to not jeopardize the business case for customers which cannot spread the authorisation costs across a fleet of vehicles. A significant percentage of OTMs today remain authorised under only NNTRs (the majority for many companies) due to their special configurations and complexity. In addition, when a SV is authorised only for one MS with these specific NNTRs a significant later extension of the area of use to another MS would then require the application of the TSI. This would have a major impact on the 1st vehicle type authorisation. Under no circumstances should this revision of this TSI result in a worse position of SVs compared to conventional rolling stock due to old exemptions that have been taken over (e.g. Appendix C.3 the 50.000 km clause not only for conical profiles but for all existing profiles in use).
Read full response26 Jan 2023
For us, as a manufacturer of special vehicles, the obligation to equip our machines with ETCS has a serious impact on our business. Especially for our customers, mainly medium sized construction companies, a fundamental change within such a narrow timeframe is not acceptable. Basically, special vehicles are built to work and driving on the rail network is only a means to an end. In order not to prevent the abolishment of the Class B system and thus to go hand in hand with the target of the EC, special vehicles also have the possibility of being transported passively to the desired place of operation without necessarily having to be equipped with ETCS. Considering a cost-benefit analysis and the underlying transition phases and the accompanying multi-year planning, we see the current version as too ambitious and would propose the following adaptation to CCS TSI Annex I 7.4.2.1, 7.4.2.2, Annex B - Table B1 - lines 2 (points 7.4.2.1 and 7.4.3) and 3 (point 7.4.2.2) as described more in detail in the attachment.
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