Cross-Acceptance: UNIFE expectations

1. Cross-Acceptance: UNIFE expectations Alice Polo Safety and Certification Manager

2. What is UNIFE ? • Full members: 70 of the largest and medium-sized companies in the rail supply sector • Associated members: 18 National Associations, representing almost 1,000 suppliers of railway equipment UNIFE represents the European rail supply industry • Based in Brussels since 1992, 22 permanent employees • A trusted partner of the European institutions in all matters related to rail and transport • UNIFE members have an 80% market share in Europe and supply more than 50% of the worldwide production of rail equipment and services.

3. UNIFEMembers • 70 Full Members • 15 National Associations

4. Introduction Overview of UNIFE presentation: • Current situation • Major problems • European manufacturers needs • Expectations

5. X-A activities • UNIFE welcomes very much the activities realised so far by ERA in the framework of Cross-Acceptance, in particular: • Common reference for • non-TSI conform • vehicles in Europe • 1. The New annex VII of • Interoperability Directive Good Starting point BUT • 2. The reference • document • Collection of all National • Technical Rules • Overview of today situation • and foster harmonisation • of certification procedures • 3. The report on • authorisation process • DV29!

6. Authorisation Process Strong need for a quick fix of the difficulties still applicable to the authorisation process (cost and time) Authorisation process is seen by UNIFE as the most urgent problem to be solved for the interoperability and the competitiveness of the European rail system The railway sector simply cannot afford being subject to differing national interpretations of European rules nor months-long delays before being able to introduce appeals

7. UNIFE needs • Simplification and transparency of authorisation processes URGENT NEEDS • A quick move towards a true European wide vehicle authorisation, on the basis of the recast Interoperability Directive 2008/57/EC

8. Current situation Today’s authorisation for putting in service a vehicle in Europe is the final outcome of 3 apparently multiplicative processes: • 3. Comprehensive risk analysis of the change brought by the introduction of the new vehicle, notwithstanding the compliance of it with all relevant TSI’s and Notified National Technical Rules • 2. Assessment of conformity with the whole set of NNTR • 1. Assessment of conformity with all relevant TSI’s Certification/Authorisation process too much time and cost consuming (1 to 5 Million Euros)

9. Authorisation and CSM • Next steps toward the solution is the transposition of ID according to DV29, but the application of CSM shall be further clarified! • ERA X-A should: • Investigate in detail the way in which CSM on risk assessment are understood and applied by the main European National Safety Authorities for the authorisation of new vehicles • Map the hazards covered by the conformity to all published TSI or NNTR, which by definition should not be subject to any additional risk assessment

10. 1. Extension of the • geographical scope • of the TSIs • 2. Authorisation for TEN • also validd off TEN • First Type • Authorisation • Further Authorisation • in other EU countries • Platform • authorisation

11. UNIFE requests • The related works can only lead to the identification of a few additional specific cases or operation cases justifying partial possible relaxations of the requirements 1. Immediate extension of scope of the rolling stock TSI’s 2. Elimination of all unnecessary NNTR Notwithstanding the identification by NSA of possible new specific cases 3. Automatic extension to the whole “interoperable network” of authorisations delivered on the basis of TSI compliance • All vehicles placed in service in Europe are never designed only for TEN operations but also for off TEN

12. TSI and NNTRs • Reference list is the tool for the comparison of NNTR and TSI requirements  Thanks ERA for the very good achievement in collecting all the NNTRs! This is the starting point for: • Systematic use of TSI requirements in place of the National Notified Technical Rules, each time they cover the same parameter or hazard • Elimination of all unnecessarily National Technical Rules: reduce the number of National Rules to duly identified national specific cases

13. Insufficiencies of the notion of type authorisation Type Authorisation (in ID) Only concerns authorisations for fleets of strictly identical vehicles, having to cross borders on a European international corridor Need for a real European authorisation for rolling stock, including ERTMS onboard equipment A European-wide type authorisation should be delivered at the outcome of the first authorisation of a vehicle type by one NSA

14. Platform authorisation To solve the problem of furhter authorisations in EU country: Mechanism for authorization of variation of type Recognition of ISA assessment between Member States Platform Authorisation This would drastically simplify the authorisation of a vehicle in a 2nd member state, when another vehicle based on the same technical “platform” has already been authorised in a 1st member state ERATV should support the traceability between different versions, i.e. platform evolutions

15. Conclusions UNIFE has high expectations from X-A unit in supporting and work for the achievements of the following points: • Clarify the correlation between TSI and CSM • Systematic use of TSI requirements in place of the NNTR, each time they cover the same parameter or hazard • Elimination of all unnecessarily NNTRs and reduction to duly identified national specific cases • Immediate extension of already delivered TEN authorisation • Recommendation for Platform Authorisation

16. Thank you for your attention!