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

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.

UNIFE Members 70 Full Members 15 National Associations

Introduction Overview of UNIFE presentation: 1. Current situation 2. Major problems 3. European manufacturers needs 4. Expectations

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

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

Current situation Railway sector is going through a very complex period in terms of placing in service of railways vehicles Opening of railways International transport market and Equipment procurement markets A fast increasing need for international placing in service Pressure on prices and design of platform standard rolling stock Enforcement of NSA powers The publication of NNTR in the 27 Member States

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

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

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: 1. 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 2. 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

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

UNIFE requests 1. Immediate extension of scope of the rolling stock TSIs 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 Notwithstanding the identification by NSA of possible new specific cases All vehicles placed in service in Europe are never designed only for TEN operations but also for off TEN 3. Automatic extension to the whole interoperable network of authorisations delivered on the basis of TSI compliance 2. Elimination of all unnecessary NNTR

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: 1. Systematic use of TSI requirements in place of the National Notified Technical Rules, each time they cover the same parameter or hazard 2. Elimination of all unnecessarily National Technical Rules: reduce the number of National Rules to duly identified national specific cases

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

Platform authorisation To solve the problem of furhter authorisations in EU country: 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 1.Mechanism for authorization of variation of type 2.Recognition of ISA assessment between Member States

Conclusions UNIFE has high expectations from X-A unit in supporting and work for the achievements of the following points: 1. Clarify the correlation between TSI and CSM 2. Systematic use of TSI requirements in place of the NNTR, each time they cover the same parameter or hazard 3. Elimination of all unnecessarily NNTRs and reduction to duly identified national specific cases 4. Immediate extension of already delivered TEN authorisation 5. Recommendation for Platform Authorisation

Thank you for your attention!