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Cross Acceptance CER Expectations

Cross Acceptance CER Expectations. ERA Seminar, Lille, 17.11.2010. Libor Lochman. Involvement of CER members in the authorisation processes. RUs: customer of a manufacturer applying for authorisation or Applicant for authorisation

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Cross Acceptance CER Expectations

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  1. Cross Acceptance CER Expectations ERA Seminar, Lille, 17.11.2010 Libor Lochman

  2. Involvement of CER members in the authorisation processes • RUs: • customer of a manufacturer applying for authorisation or • Applicant for authorisation • Concerned about current prohibitive cost and time for vehicle authorisation, which are affected by current differing national processes and non-transparent rules • IMs: • Currently making efforts to provide rules for technical compatibility between vehicles and the network • Sometimes involved in testing • Concerned about reliability and impact (wear) of vehicles running on its network

  3. Current problems with XA • The classification of national rules in advance of projects not always available; the first applicant has to carry more cost and risk than subsequent applicants • In some authorization process our members face practical problems to apply the limits related to re-checking. • Some NoBo Certificates are considered to be more trustworthy than others, hence some are re-checked by NSAs • A vehicle type authorisation and a common approach for modifications requiring re-authorisation is not available

  4. The way forward • To issue a recommendation, based on the works of the ERA on cross-acceptance, for the systematic use of TSI requirements in place of the National Notified Technical Rules, each time they cover the same parameter or hazard. • To identify what are the possible legal obstacles to the application of such recommendations on a European level as well as (if applicable) on national level • To issue a recommendation for the implementation of a “platform authorisation” concept

  5. DV29 – the step in the right direction General • CER strongly supports the idea to provide a common understanding amongst the Member States and the stakeholders. DV29 provides a good basis for a common understanding. • CER supports the basic principles outlined in DV29 • separation of authorization from operation/maintenance • rules-based approach • limit to re-checks

  6. DV29 – proposals for an improvement • In order to prevent further diverging interpretations of Dir 2008/57 and of DV29, we would propose the incorporation of a process flowchart for first and additional authorizations clarifying the sequence, maximum duration, input and output, tools, roles and responsibilities related to each step • Clarification on requirements to related modifications of authorized vehicles • Time limits for the full implementation of the new regime, especially the tools: • Completion of National Notified Rules including improved classification • Completion of Registers: RINF and ERATV

  7. Further options • ERA mapping the national rules to hazards and vehicle functions • Systematic analysis of national rules for the closure of TSI open points • ERA role in NSA auditing to guarantee comparable authorisation processes • Reduction of the on-track testing (CER would contribute to the on-track testing study by reviewing and completing the already collected information)

  8. CER vision • Lower approvals costs and time • Faster introduction of new train designs • Less on track testing in individual countries • Less barriers imposed by IMs to new train introductions • Easier fleet cascades - moving around and between countries after first delivery

  9. Libor Lochman CER Deputy Executive Director Tel: +32 2 213 08 82Email: libor.lochman@cer.be  For further information, visit our website: www.cer.be  Thank you for your attention!

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