Proposal for regulation(s) revising Regulation (EU) 913/2010 of the European Parliament and of the Council of 22 September 2010 concerning a European rail network for competitive freight and introducing measures to better manage and coordinate international rail traffic, including through new rules for capacity allocation in the rail sector
Date: 2022-10-04
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: common transport policy



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Factual summary report on the public consultation on on the impact assessment for the initiative on international freight and passenger transport – increasing the share of rail traffic



This document only provides a factual summary. A later synopsis report as an annex to a staff working document will provide a more detailed overview of the consultation activities.


Disclaimer: the views presented in this factual summary report are not the views of the European Commission but those of the stakeholders that participated in this public consultation. The report cannot in any circumstances be regarded as the official position of the Commission or its services.



1.Introduction


The public consultation opened on 30 March 2022 and closed on 22 June 2022. The total number of responses submitted was 123. The objective of the consultation was to gather the views and receive feedback from stakeholders and the general public on the most important problems facing cross-border rail and the measures to address them. The focus of the questionnaire was on rail infrastructure capacity and traffic management, digitalisation of some rail-related services and improving rail’s performance in combined freight transport. Cross-border rail is predominantly freight, so a number of questions addressed this particular market segment and its specificities (including its performance in combined transport). The consultation addressed problems and measures that involve the rail freight corridors, established under Regulation (EU) 913/2010 concerning a European rail network for competitive freight. The consultation contained questions on passenger services as well, with a focus on cross-border traffic.


The factual summary report provides an overview of the number of responses, some characteristics of the respondents as well as some of their views and concerns.


2.Contributors


A total of 123 responses to the questionnaire were received. The responses covered a variety of stakeholder groups, as shown in the table below.


The highest rate of responses came from business (companies 34, associations 13), citizens (31 EU and 1 non-EU) and public authorities (27).


Table 1 
                     Classification of respondents per stakeholder group according to type of organisation





Stakeholder category




Number of responses




% of responses






Academic/research institution




0




0.0%






Business association




13




10.6%






Company/business organisation




34




27.6%






EU citizen




31




25.2%






Non-EU citizen




1




0.8%






Consumer organisation




2




1.6%






Environmental organisation




1




0.8%






Non-governmental organisation (NGO)




7




5.7%






Public authority




27




22.0%






Trade union




2




1.6%






Other




5




4.1%






Total




123




100.0%






More than two-thirds of respondents are linked to rail in a professional capacity.


Table 2 – Classification of respondents per stakeholder group according to their relationship with rail





Stakeholder category




Number of responses




% of responses






Citizens




22




17.9%






Ministries, regulatory bodies, national safety authorities and other public authorities




19




15.4%






Umbrella organisations and associations representing the rail stakeholders




16




13.0%






Other (please specify)




15




12.2%






Rail infrastructure managers and allocation bodies




11




8.9%






Rail regulatory body




11




8.9%






Railway undertaking providing freight services




9




7.3%






Railway undertaking providing passenger services




6




4.9%






Non-governmental organisations (not specialising in rail transport) and civil society




5




4.1%






Terminal owners and operators




3




2.4%






Transport operators of other modes (e.g., road hauliers)




2




1.6%






Logistics services providers, freight forwarders and transport organisers




2




1.6%






Multimodal operators (MTOs)




1




0.8%






Industry and commerce




1




0.8%






Research and academia




0




0.0%






Total




123




100.0%






The geographical distribution of responses showed respondents residing in, or organisations based in, 20 Member States. Further 10 responses were received from Norway, Switzerland, Turkey and the United Kingdom and 2 responses did not provide information on the country of origin. Germany, Belgium, France and Sweden provided the highest numbers of responses (a total of 57 responses between them, or 47 % of all the responses).





Figure 1 
                     Distribution of the responses by country of origin
1









Responses from legal entities included 42 responses from large organisations (i.e., with 250 or more employees), 18 from micro organisations (i.e., between 1 and 9 employees), 17 from medium organisations (i.e., between 50 and 249 employees) and 13 from small organisations (i.e., between 10 and 49 employees). Some 33 respondents did not provide information on the size of their organisation.




3.Responses to the public consultation 


Not all respondents replied to all questions. There was a high response rate, both on questions on problems and solutions (possible measures), but some respondents responded on many occasions with ‘No opinion / I don’t know’.


The Commission services received 18 written contributions. In fact, 20 respondents uploaded documents, mostly position papers, but some papers were uploaded more than once, as they were common positions of several associations.


The Commission services received 1 late reply by email and corrections to 1 reply.


3.1 Responses to the questions on problems for cross-border rail 


Overall, the majority of respondents agreed that the problems identified in the questionnaire are constraining the growth of cross-border rail freight.


The questions were multiple choice, allowing respondents to agree or disagree with each answer.


Question 10: What are the main challenges that need to be addressed to achieve the goals set by the European Commission for rail freight transport?


(a) The higher prices of rail freight services compared to other modes of transport


(b) The poor performance of rail freight transport services compared to other modes of transport (lower speed, lack of reliability, poor integration with other modes of transport, etc.)


(c) Insufficient availability of scheduled rail freight services, notably for multimodal transport (e.g., lack of connections offered, insufficient frequency)


(d) The limited growth potential of rail freight transport services due to lack of capacity on the rail network to accommodate additional traffic



Overall, respondents who expressed opinion on this question, confirmed that all challenges are important. The information below provides an overview of the opinions on the individual challenges listed in the question.




Out of the 123 responses received, 82 (66.7%) expressed an opinion. Of those 58 agree (18 strongly agree) that the higher prices of rail freight services compared to other modes of transport is one of the main challenges that need to be addressed to achieve the goals set by the European Commission for rail freight transport. 24 (29.3%) respondents disagree or strongly disagree with the statement, mostly companies (business organisation) suggesting that other challenges are more important than pricing of rail freight services.






























97 (78.9%) respoondents expressed views on the poor performance of rail freight transport services. A large part (65%) agrees that the poor performance of rail freight transport services compared to other modes of transport is one of the main challenges that need to be addressed. 17 respondents (17.5%) disagree (4 strongly). Company/business organisation (mostly railway undertakings) express strongest doubts about rail freight’s performance being an issue, but even companies overall agree performance is a challenge.

























85 (69.1%) respondents provide an opinion on insufficient availability of scheduled rail freight services, notably for multimodal transport (e.g., lack of connections offered, insufficient frequency). Among the opinions provided 68 (80%) agree (23 strongly) that this is a chellenge and only 17 (20%) disagree. A minority of companies and EU citizens are the ones disagreeing, 


93 (75.6%) respondents provide an opinion on the lack of capacity on the rail network to accommodate additional traffic. A big majority of those (77 or 82.8%) agree (44 respondents strongly agree) that capacity is a major challenge that needs to be addressed. Only 12 (12.9%) and 4 (4.3%) respondents (mostly EU citizens and company/business organisations), respectively disagree or strongly disagree.


























Respondents also provided comments to question 10.


In relation to the higher prices, the respondents (business, associations, companies, trade unions) highlight the need for all external costs to be internalised for all modes of transport and the ‘polluter pays’ principle should be fully implemented.


In relation to poor performances, respondents (public authorities) highlighted punctuality (reliability of scheduled arrival time), flexibility and reaction time to customers’ needs. In particular, respondents highlight the urgency to tackle the lack of reliability, the lower speed and the poor integration with other modes. Furthermore, they argue that the poor performance of rail freight transport are not only due to infrastructure related problems, as delays occur also in the composition of freight trains.


In relation to the insufficient availability of scheduled rail freight services, respondents (business association) believe that today the sectors struggle from a lack of good international connections.


In relation to the lack of capacity, respondents (business associations) highlighted different elements of it. Some pointed out the different situation with most European countries having the problem, but a few exceptions in some Central and Eastern European Member States where capacity may still be abundant. 


Some respondents (public authorities, business associations, citizens) provided suggestions on measures, referring to measures part of the Timetable Redesign Project. 


Respondents (public authorities, business associations, companies, citizens) identified priority rules for the allocation of existing capacity as an area requiring action. 


Finally, the need for new infrastructure (new tracks, switches, passing loops, lines) and upgrading signalling and control technology were also identified as a challenge (a business association).


In terms of other challenges, business associations widely agree on the lack of technical interoperability, the lack of harmonisation of national rules and procedures for rail, the lack of a level playing field with other modes, as well as, the lack of financing for the necessary infrastructure.





Question 11: What are the main challenges that need to be addressed to achieve the goals set by the European Commission for high-speed passenger rail transport?


The number of respondents expressing an opinion in favour or against the replies varied between 81 (65.9%) and 91 (74%) out of the 123 respondents to the survey.




Question 12: What are the main problems causing poor performance of cross-border rail freight transport?


(a) Poor performance of railway undertakings (lack of respect of the timetable resulting in poor punctuality, poor organisation of cross-border operations, insufficient preparations for disruptions and incidents, lack of coordination with other transport modes, etc.)


(b) Poor services provided by infrastructure managers and allocation bodies (train paths not being in line with railway undertakings’ requests, poor coordination of train paths across borders, outdated processes and IT tools, etc.)


(c) Low priority for cross-border rail freight services in planning and operations compared to domestic and passenger traffic, e.g., when allocating capacity or when dispatching trains in case of delays, etc.


(d) Insufficient integration of rail freight services in multimodal transport chains (time lost or delays incurred in terminals, no door-to-door tracking and tracing and estimated time of arrival, etc.)


80 (65.0%) respondents provide an opinion whether the performance of railway undertakings is causing poor performance of rail freight. Among the respondents providing an opinion, 54 respondents agree (40.0% agree and 27.5% strongly agree). 26 (32.5%) respondents either disagree or strongly disagree with the aforementioned statement. In relative terms disagreement comes from consumer organizations and business associations. 2 infrastructure managers disagree with this statement and 3 agree. Some railway undertakings also express agreement that they are responsible for the poor performance, while others disagree. Clients of rail freight services mostly agree with the statement, as do public authorities, with some exceptions.

























85 (69.1%) respondents express an opinion on the quality of services provided by infrastructure managers being a challenge. 68 (80.0%) respondents agree (34) or strongly agree (34) with this statement, whilst only 17 (20.0%) disagree (13) or strongly disagree (4). The ones disagreeing with the statement are mostly infrastructure managers.


























Only 76 (61.8%) respondents provide an opinion on the prioritisation of rail freight. Among those providing an opinion, a big majority of 63 (82.9%) agree or strongly agree with this statement, whilst only 13 (17.1%) disagree or strongly disagree, with only a couple of citizens disagreeing that the low priority of rail freight is a challenge.




























79 (64.2%) provide an opinion whether the integration of rail freight in multimodal transport chains is a challenge. A large portion (68 – 86.1%) agrees or strongly agrees and only 11 (13.9%) disagree that this is an issue. 


Respondents provided further details on their replies in the comments section.


In relation to the poor performance of railway undertakings, some (public authorities) disagree, argue that there is sufficient competition in the market for international rail freight to ensure reasonably efficient behaviour by the railway undertakings. Other respondents (public authorities) point out that, although international paths are defined as a result of railway undertakings’ capacity requests during the capacity allocation process, it appears that railway undertakings do not always have full knowledge of the train composition and the related transit times at border stations (due, for instance, to the presence of particular types of wagons in the train composition or specific freight typologies) and do not have sufficient certainty of their business needs. This results in repeated requests for rescheduling of paths, due to changes in the demand for transport coming from their customers.


In relation to the poor services of infrastructure managers and allocation bodies, respondents (public authorities) highlight the presence of poor coordination in traffic management operations between national control centres and the insufficient exchange of real-time information between neighbouring infrastructure managers. Others (business associations, companies) argue that rail freight transport is hampered by low speed as some Member States do not maintain their existing network properly. In particular, the poor infrastructure quality, partly due to the fact that the infrastructure manager mostly depends on state funding, influences the quality of services and explains the current modal share of rail. Some (business association) point out that there is no clear understanding of how decisions are taken regarding capacity allocation by infrastructure managers in cases of delays or works. In general respondents (company, business association) highlight that the infrastructure managers manage quite smoothly the planning phase, with problems mostly occurring during the operations phase.


In relation to the low priority for cross-border rail freight services, a respondent (company) argues rail freight (national/international) is often at a disadvantage in regards to passenger traffic in the daily operations. In fact, international commuting trains are often prioritised, whereas freight ones have to be planned around that predefined schedule.


In relation to the insufficient integration of rail freight services in multimodal transport chains, respondents (public authority) highlight that there is a lack of actors/logistics companies that offer comprehensive multimodal transport, across the entire transport chain (i.e., rail, road, terminals and ports). A respondent (company) states that insufficient integration of rail freight services in multimodal transport chains is mainly due to a non-transparent and inconsistent data exchange/communication.


In terms of other challenges, respondents believe that these relate to the lack of interoperability and separation of breaking up of integrated rail companies (trade union), non-harmonised and inconsistent national safety rules and national commercial conditions (public authority). Respondents (companies, business associations) also highlight achievement (Contingency Management handbooks for both infrastructure managers and railway undertakings, TTR and Digital Capacity Management, virtual European Traffic Management, ETA project and translation tools etc.), but note there are still challenges in implementing these solutions on a European scale, including the issue of persisting high congestion and the consequential high interference between trains. Interoperability issues and ERTMS are also highlighted. Poor coordination (or high number) of temporary capacity restrictions is another challenge. Some respondents (business association) highlight that the current capacity planning does not take into consideration rail freight operators’ needs for flexibility in booking capacity. There is a need for a possibility of long-term path allocation (as introduced by pre-arranged train paths), but also planning not fitting the annual schedule for timetables.



Question 13: What are the main problems with the services provided by rail infrastructure managers and allocation bodies to the operators of cross-border rail freight services?


The number of respondents expressing an opinion in favour or against the replies varied between 70 (56.9%) and 86 (69.9%) out of the 123 respondents to the survey.



Some respondents added comments to their replies.


The current national approach to infrastructure management, which focuses primarily on passenger traffic, usually leads to a situation whereby the needs of international rail freight are not being sufficiently addressed across a number of points, which respondents widely argue are all captured properly by the list of problems identified in the question.


In relation to the insufficient infrastructure capacity available for short-term capacity, a public authority agrees that high-capacity utilisation on certain routes makes it sometimes difficult to meet short-term capacity needs.


In relation to the performance of IT tools, respondents (public authorities) point out that IT tools are in place only at national level and not really for cross border management. In this regard, the problem relates to the fact that some infrastructure managers currently use IT tools that cannot communicate with other systems. Others (public authorities again) argue that the appropriate IT tools are actually in place, but that the actual problem relates to lack of EU-wide harmonisation and obligation to use them appropriately and correctly.


In relation to the coordination between infrastructure managers, respondents (business associations, companies, public authorities) argue that the planning of works and capacity restrictions has to improve, in particular in terms of international coordination, involving infrastructure managers, where trains can be rerouted. The varying priorities and rules between different infrastructure managers both in terms of planning and operation create problems for freight traffic. In particular, despite the many efforts on both sides of the border, the aforementioned cooperation lacks better communication both between distinct infrastructure managers/path allocation authorities and between them and railway undertakings. 


In relation to the lack of sufficient alternative routes or capacity of available routes, one respondent (business organisation) believe that this, together with a general lack of capacity, represents one of the major issues for freight traffic, especially as the number of TCRs will only increase in the coming decades. The lack of sufficient alternative routes can sometimes be a problem, but the main problem is infrastructure managers do not reserve and protect capacity for freight services, based on internationally harmonised capacity models. One respondent (citizen) states that alternative infrastructure capacity is often there, but that the problem often resides in railway undertaking not being able to use it, for lack of drivers or lack of interoperability, arguing that for this reason contingency plans for railway undertakings are needed.


In terms of other problems, a respondent (citizen) highlights that the different national processes, including the deadlines for draft capacity offers, final offers remain one important problem, especially for cross border traffic. Respondents (business association, citizen, companies) point out that in some countries even if the deadlines are harmonised, there is no real incentive for the infrastructure manager to deliver the offers on time and in good quality. Transparent key performance indicators for infrastructure managers and financial incentives to avoid disruptions are missing.





Question 14: What are the main problems with the services provided by the infrastructure managers / allocation bodies to the operators of cross-border passenger rail services?


The number of respondents expressing an opinion in favour or against the replies varied between 60 (48.8%) and 84 (68,3%) out of the 123 respondents to the survey.




Measures to address the problems



Question 15: Infrastructure managers can prepare plans for the utilisation of capacity on the rail network, covering an adequate partitioning of capacity between different rail services (national, cross-border, passenger, freight, etc.), events with a large impact on available capacity, such as infrastructure works, or contingency plans for major disruptions. Should these plans be aligned at EU level and how should this be done?


117 (over 95%) respondents expressed their views, with 17 choosing to formulate their own reply. Out of the respondents providing an opinion, the majority (54) argues that alignment should be supported by a governance set up at the level of transport corridors covering the main trade and transport flows in the EU. On the other hand, one EU citizen believes that there is no need to align plans across Member States and 22 respondents state that alignment should be supported by bilateral processes, involving only the infrastructure managers concerned. Finally, 23 think that alignment should be supported by a single EU entity responsible for the entire network of strategic lines in Europe. It seems important to note that the responses are generally similarly distributed within each stakeholder category with a statistically meaningful number of respondents.







































Respondents also provided comments. A business associations suggests that the alignment should not only include infrastructure managers but also relevant private stakeholders such as terminal operators, shippers, freight forwarders and rail freight companies. In particular a public authority warns that if alignment is not supported by a well-defined governance structure, whether bilateral or centralised, there is a risk that the coordination of capacity utilization could be unduly influenced by individual Member States, infrastructure managers, or commercial initiatives. Furthermore, in relation to passenger services, a company warns that overlapping structures should be avoided. Finally, a public authority encourages the European Commission to make sure that regardless of the policy option chosen transparency and the principles of a competitive market must be ensured. 


In relation to bilateral processes, opponents believe it has failed, where supporters suggest that this is a less bureaucratic and pragmatic approach. Deficiencies are due to incomplete implementation of EU legislation. 


In relation to transport corridors, opponents believe that the corridor structure only add complexity, undermining railways competitiveness. Supporters see it as the optimum level for cooperation.


In relation to a single EU entity, some supporters bring forward the principle of subsidiarity: making overall strategic decisions at the European level, but keeping implementation on the ground at the national level. Some (companies, citizens) note that an EU entity responsible for the whole European network management would be too bureaucratic. A business association points out that Member States would not agree to this.


Some respondents (public authority, business association) advocate for bilateral/multilateral cooperation on planning, supervised by an international leading entity, where railway undertakings and other stakeholders can escalate unresolved problems. The entity must have the decision-making power of last resort, and enforce the alignment. The entity also must have expertise knowledge to issue the final decisions in timeframe needed by the market.



Question 16: Rail infrastructure capacity is limited and some lines and nodes are congested with traffic. Infrastructure managers must choose between conflicting capacity requests on such lines. The socio-economic and environmental benefits of passenger and freight traffic differ depending on the specific situation. Should there be rules at EU level that define how capacity should be split between different types of traffic (national, regional, cross-border, passenger, freight, etc.)?


































Question 17: On certain congested lines, a major share of capacity is currently allocated to regional or national passenger trains. If cross-border rail freight traffic is to be developed, the number of passenger trains might need to be reduced in some cases. In case harmonised EU rules on the prioritisation of different types of rail traffic are introduced, how detailed should they be, what should they include and at what level?































Question 18: Managing capacity and operations for cross-border traffic requires close coordination and cooperation, covering infrastructure works restricting infrastructure availability, changes to the timetable after capacity allocation, etc. Currently, 11 rail freight corridors support this coordination and provide 11 one-stop shops for cross-border traffic. The evaluation of Regulation (EU) 913/2010 concluded that this set up has not resulted in sufficient harmonisation at EU level and that co-existence of 11 one-stop shops does not always match the needs of cross-border rail operators. Should there be a single entity at EU level to support the coordination between infrastructure managers and what should its functions be?


Between 85 (69.1%) and 96 (78%) of the respondents expressed clear preference for one of the options provided. As far as the stakeholder categories are concerned, the distribution of responses shows similar patterns between the groups of respondents.




Respondents provided comments. A business association argues that the current corridor approach brought little benefits and has not solved the problems due to the artificial split between passenger/freight, national/international or corridor/non-corridor traffic. Since many trains or their connections do not originate or end on the corridors a comprehensive approach considering the full network as one entity is required. In this regard, some respondents (business associations, public authorities) believe that the coordination between rail freight corridors could be further improved and harmonised without creating another level of governance, which would involve several challenges related to the EU legal framework such as the applicable law in case of conflict and issues related to liability. The fact that the problem relates to the nationally orientated and not coordinated decision-making, implies that there is no need for a great bureaucratic and centralised entity which is in charge of planning and operation. Furthermore, others (business association) expect that the Timetable Redesign Project will be rolled out successfully and will become mandatory across Europe, also in this case implying that there is no need for an entity at the EU level. In this regard, some (public authority) argue that it is paramount to produce clearer rules as an entity at EU level can never compensate for the lack of adequate rules. Finally, others (public authority) highlight the importance of keeping the subsidiarity principle and creating binding obligation for IMs to work together on the cross-border level.


Some stakeholders indicated lack of enforcement mechanism that would guarantee that infrastructure managers work together, as the experience of the last two decades shows that this does not work on a voluntary basis (public authorities).


Lack of compliance with EU law was also identified as an issue. 


A respondent (a rail business association) suggested the creation of Corridor Account Managers, a new role for the one-stop shop managers in the rail freight corridors. The operational business dealing with concrete train paths allocation would be left to the IMs who would coordinate through their IT tools interfaced to the central TTR IT Landscape. These managers would support and coordinate IMs in offering harmonized international capacity in line with customer needs. In this context, national processes and procedures which are relevant for international capacity planning and allocation should be harmonised towards TTR in order to ensure a real international approach.


In relation to the possibility of having a single entity at EU level, the respondent argues that a Union-level entity overseeing the optimisation of cross-border rail traffic and coordination mechanisms should not have more than a monitoring and guiding role, and always with respect to the infrastructure manager's individual autonomy and responsibility on capacity and traffic management. It should aim to identify best practices of cross-border coordination facilitating international pathway allocation and disruption management. However, further roles of this entity are under discussions in the sector. 


On the one-stop-shop, some respondents (business association, citizens) argue that the Commission should consider a Eurocontrol for rail, which would have ‘subsidiarity’ over national decisions on the corridor. On the other hand, some (member of the RFC governance) believe that one-stop shops should be closer geographically to the train runs and that they could be kept at corridor level. On a similar note a business association expresses little confidence that an EU-level single entity could function efficiently as a one-stop-shop. Considering the current levels of digitalisation and communication of most national infrastructure managers, very large capacity would be required for operators of cross-border services to implement such an approach. A rail company suggests that a single entity could provide support mechanisms to the allocation at either corridor level or by the individual infrastructure managers.


A company highlights the fact that there is already an entity at EU level responsible for developing a harmonised framework – ERA. In particular, a public authority argues that a new entity based on RailNetEurope’s current role should not be entrusted with the development of common rules, as these, differently from procedures and IT Tools, should be developed independently of stakeholders. 


Question 19: In case of complaints, railway undertakings can revert to national rail regulatory bodies. However, national regulatory bodies cannot address issues outside the national territory. Under current EU law, regulator bodies are required to cooperate with each other on cross-border traffic. However, there are indications that decisions by national regulatory bodies are not always consistent with each other. How to ensure that regulatory supervision of rail infrastructure managers takes adequately into account the needs and requirements of cross-border traffic?


The replies are summarised by the graph below.































Respondents provided comments.


Some (companies, public authorities) prefer a special European layer, as national regulatory bodies can align decision only to certain extent. There is a need for a European legal framework.


One public authority argues that current provisions, and in particular Article 57(2) of Directive 2012/34/EU, are sufficient.



Question 20: Rail freight often covers only part of door-to-door freight transport operations, such that goods need to be transhipped to other modes of transport (ships, trucks, etc.). What are the best measures to increase the efficiency and performance, e.g. in terms of punctuality, reliability and speed, in multimodal transport chains involving rail?



The number of respondents expressing an opinion in favour or against the replies varied between 69 (56.1%) and 91 (74%) out of the 123 respondents. As far as the stakeholder categories are concerned, the distribution of responses shows similar patterns between the groups of respondents.





Question 21: Digitalisation and automation have a huge potential to make rail and multimodal transport more efficient and competitive. EU laws define frameworks and concepts for digital information exchange between the stakeholders involved. However, deployment of these frameworks takes time and there are no strict implementation deadlines. Should there be deadlines to accelerate the deployment of digital services supporting rail transport and logistics?


99 (80.5%) out of 123 give a definitive reply, whereas a total of 24 (19.5%) either does not have an opinion on the matter (16), has provided no response (3) or has provided a comment with a different option (5). Out of the respondents providing an opinion, the majority (50) believes that there should be deadlines to guide digitalisation, which are legally binding to accelerate the deployment of digital services supporting rail transport and logistics. 36 respondents prefer only indicative deadlines. 13 respondents think that there is no need to require digitalisation of services via EU law (the only trade union responding, as well as some citizens, a public authority, some companies and some business associations). 


Comments focused on concerns on costs for digitalisation, challenges, lack of harmonisation of data exchange processes, difficulties for SMEs, differences between the level of digitalisation in Member States, 


The lack of effective enforcement of agreed deadlines for digitalisation was also raised.


One trade union argues that digital and automated technologies can support the modal shift, but they also have a strong impacts on the working conditions and health and safety at the workplace. Their introduction should be gradual and must always be accompanied by the involvement of railway workers and their representatives at every step of the process. Stricter deadlines for implementation could be detrimental to the health and safety of railway workers and rail users.



Question 22: Should there be greater ambition to harmonise European traffic management? If so, which aspects should be covered by such harmonisation?


Between 98 (79.7) and 103 (83.7%) of the respondents expressed an opinion in favour or against one of the replies provided. 







Question 23: Improving performance requires a good understanding of current performance and its limitations. Performance monitoring is also an essential prerequisite to improving the efficiency and customer-orientation of rail (freight) services. According to the Commission’s proposal for the revision of the TEN-T Guidelines, European Coordinators will monitor administrative, operational and interoperability aspects of passenger and freight traffic and services along corridors. Is there a need to further strengthen performance monitoring for rail (freight) transport services?


Between 82 (66.7%) and 86 (66.9%) of the respondents expressed an opinion in favour or against one of the replies provided. 




Respondents provided comments and suggestions for specific elements that should be subject to monitoring. One respondent (railway undertaking) suggests additional actions are needed, e.g. financial incentive for infrastructure managers to avoid late planning of works and line closures and changes to paths after allocation. 







(1)
 
                        There are no operational railway networks in Cyprus and Malta.