Impact Assessment of the revision of Regulation 445/2011 1st meeting of the WP for the revision of Regulation 445/2011 23 May 2017, Valenciennes
Impact Assessment Revision of Regulation 445/2011 Adopted Impact Assessment (IA) Methodology IMS procedure on IA (Annex 1 of MB Decision) - respects EC guidelines and ensures the application of the proportionality principle http://www.era.europa.eu/Document-Register/Documents/Annex%201%20Impact%20Assessment%20Procedure.pdf IA template (Annex 2 of MB Decision) - respects the EC guidelines and includes guidance for filling in each of the sections http://www.era.europa.eu/Document-Register/Documents/Annex%202%20Impact%20Assessment%20Template.pdf
Impact Assessment Revision of Regulation 445/2011 Recommendation on the revision of Regulation 445/2011 will be accompanied by an IA to inform decision-makers about options and consequences Full IA implying that impacts will as far as possible be quantified in monetary terms To support the IA work data will be collected at different stages
Impact Assessment Revision of Regulation 445/2011 IA problem statement: sections Problem and problem drivers Main assumptions Stakeholders affected Evidence and magnitude of the problem Baseline scenario Subsidiarity and proportionality
Impact Assessment Revision of Regulation 445/2011 Problem definition Problem Absence of a harmonised certification system for ECMs, maintenance providers and maintenance workshops dealing with locomotives and coaches (identical to Regulation 445/2011 for freight wagons) Main consequences Difficulties for RUs trying to: - Select an ECM which provides external maintenance services and corresponds to their exact needs - Ensure that the maintenance externally provided to locomotives and coaches is adequate (risks are controlled and operations are safe) Difficulties for ECMs and maintenance workshops having to deal with different requests for specific customer certifications
Impact Assessment Revision of Regulation 445/2011 Discussion at the 1st Working Party Understanding the problems experienced by stakeholders Consideration of current situation regarding: Outsourcing of maintenance for RUs Cost of certification for maintenance providers and ECMs
Impact Assessment Revision of Regulation 445/2011 Next steps for Impact Assessment An additional stage for data collection may be necessary (detailed questions to selected members of the WP) Determine problem statement, objectives and options Mid-July Assessment of impacts and comparison of options Mid-October (next WP meeting: 24-25 October) First draft of the report End of October Final draft version of the report for consultation of the WP 15 December
Impact Assessment Revision of Regulation 445/2011 List of questions Q1: What are the problems to be addressed by the revision of Regulation 445/2011, with reference to the current scope of the ECM scheme (freight wagons)? Q2: What are underlying causes of those problems? Q3: How important are these problems? (indications on the order of magnitude about the costs incurred by the problems)
Impact Assessment Revision of Regulation 445/2011 Q4: Regarding the issue of scope extension to other vehicles than freight wagons could you outline: The main problems due to the absence of a harmonised certification scheme for these vehicles currently encountered? The main causes/drivers of those problems? The importance of those problems (especially regarding costs incurred)?
Impact Assessment Revision of Regulation 445/2011 Q5: Could you provide information on the extent to which maintenance activities are outsourced in your country? Q6: Could you provide information on the typical certification costs concerning the current ECM certification scheme in your country? (“costs” could concern internal staff-related costs incurred in the preparation for certification + fees paid by an applicant to the certification body)
Impact Assessment Revision of Regulation 445/2011 Q7: Could you provide information on other costs concerning the current ECM scheme in your country, e.g. costs relating to surveillance assessments? (“costs” could concern internal staff-related costs incurred + fees paid to external bodies performing surveillance assessments) Q8: Do you have other relevant ideas and/or inputs for the work on the IA?