Swiss Federal Railways
SBB
Represent the railway sector in Europe and the interest of Swiss Federal Railways.
ID: 25697628409-67
Lobbying Activity
Meeting with Johannes Hahn (Commissioner)
4 Mar 2020 · EC-CH Mutual Recognition Agreement
19 Dec 2019
The Swiss Federal Railways (SBB) believe 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). SBB emphasizes 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 - of which SBB is a member - has already illustrated the huge financial burden with concrete figures to the European Commission.
SBB 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.
Read full responseResponse to Rear aerodynamic devices according to the amended directive 96/53/EC on maximum weights and dimensions
12 Mar 2019
We would like to thank DG MOVE’s Road Unit 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 equipment 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 reflect 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 to answer any question you may have.
Read full responseResponse 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 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.
Read full responseResponse to Schedule for the rail infrastructure capacity allocation process
13 Apr 2017
Dear Sir or Madam
Thank you for the invitation to share our views on the draft timetabling rules as set out in Annex VII of Directive 2012/34/EU. We acknowledge the intention of the European Commission to better align the schedule for the timetabling and path allocation process with actual market needs. Unfortunately, the proposal does not meet this objective. For very densely used rail networks, like in Switzerland, it would even worsen the situation.
Our main concern
There is no need for two different deadlines. Based on the market requirements of the TTR project, after the deadline for annual requests, applicants are given the opportunity to submit requests for capacity, at any time. Therefore, we urge the Commission to avoid the creation of a rigid and unnecessary two-round application procedure. It would lead to more cancelations, more coordination effort and less efficiency.
Other issues
• Point 8: This amendment to Annex VII is out of scope as it deals with the access to service facilities, and not with the schedule for capacity allocation.
• Point 9: The last sentence should be deleted and replaced by the following: “Path details for passenger trains have to be available at least four months before the start of the TCS, for freight trains at least one month before the start of the TCR.”
• Article 2: This Decision shall apply from 1 July 2020 in time for the working timetable starting on 8 December 2022.
For more details, please, refer to the attached position paper.
Thank you in advance for revising the draft timetabling rules.
Michael Sünder
Read full response