Europaudvalget 2024-25
EUU Alm.del Bilag 79
Offentligt
Reducing costs in the Single European Rail Area
Challenge
An integrated, standardized, competitive, digital, and automated railway is a crucial part of the European
transport network for passengers and for freight. However, the cost of managing and developing railway
infrastructure is reaching unsustainable levels, and in Denmark the associated infrastructure cost of moving a
person one kilometre is currently 10-25 times higher for railways than for roads. At the same time, ongoing
electrification of cars and heavy-duty vehicles makes road transport greener. As rail becomes more expensive
and road becomes greener, it is increasingly difficult to justify the considerable national and regional
investments required by railway infrastructure from a socio-economic point of view.
If we allow bureaucratic requirements, high barriers of entry, and expensive technologies to inhibit
competition and increase infrastructure costs, while passenger numbers and freight loads remain miniscule
vis-á-vis other modes of transport, railways will increasingly lose relevance. To keep railways competitive in
such an environment, we need
before anything else
to initiate an extensive assessment of the EU railway
acquis with the aim of simplifying it and identifying ways to reduce costs.
What drives costs?
One example of high costs is the approval processes for changes to rolling stock and infrastructure. The need
for complicated approval mechanisms and independent assessments
sometimes several assessments
increases complexity and drives up costs far beyond the direct costs associated with the paperwork. A recent
example is the fitment of Danish trains with ETCS, where more people at the infrastructure manager,
Banedanmark, were employed to keep track of procedures and paperwork than to actually work on installing
the ETCS equipment in the trains.
In the road sector, many companies enter the market, ensuring high competition and lower prices on both
infrastructure projects and the transport of goods and passengers. In rail, however, complicated rules and
procedures inhibit new players from entering. A profoundly high level of competence and sector knowledge
is required from new entrants. This is a significant market barrier, that effectively blocks healthy competition.
The prime example in Denmark is the market for ERTMS. Before the rollout of ERTMS, many companies were
able to participate in signal-related public tenders. Today, only a few players are qualified, and long-term
maintenance contracts in effect create monopolies, where companies to a large degree can decide the cost
and timing of projects. In the Copenhagen metropolitan area, the cost of relocating a railway signal before the
rollout of new signals was 40.000
175.000 EUR. After the rollout the cost grew to more than 2,1 million EUR
an increase of 1,000-5,000 percent.
Proposal
In short
Interoperability and safety are key to a well-functioning Single European Railway Area, but revisions
need to focus on standardising market with competitive prices and quick time-to-market instead of
monopolies and bureaucratic procedures. The examples above show complexity of the railway sector and its
acquis is a crucial element in driving up costs. New regulation and more demanding standards on top of the
existing ones will only worsen the situation. While evidently bringing improvements, such as needed
standardisation in some parts of the infrastructure, the current acquis is in risk of being a contributing factor
in a modal shift
away
from rail
the opposite of the goal set out in the TEN-T regulation and the European
Green Deal.
Examples from Denmark suggests that the current approach to railway regulation in the EU, including the
approach to interoperability, safety and opening of the national markets, could be counterproductive for a
competitive and cost-effective railway.
EUU, Alm.del - 2024-25 - Bilag 79: Non-paper om begrænsning af omkostninger i det fælles europæiske jernbaneområde
We are, however, very interested in learning if other countries have had more success in making railway
operations, investments, maintenance and renewal more affordable and competitive compared to other
modes of transport.
We would therefore like the Commission to provide examples of successful and cost-effective implementation
of the acquis. Or alternatively point to non-EU countries that have successfully tried the same approach. This
includes the approach to opening of national markets with clear separations between infrastructure
managers, railway companies, supervisory authorities etc.
We would also like the Commission to comment on the possibility of launching a new REFIT programme
mapping out unintended legislative cocktail-effects and analysing costs versus benefits of certain railway
legislation. We believe that no question is too big to be addressed, and the assessment could include questions
such as:
Should the entire TEN-T railway
core network be covered by TSI’s?
Could there be scope for more alternatives or derogations?
How do the TSI’s support a standardised market that
reduces
costs, rather than increasing them?
Do the TSI’s need to be drastically simplified, or could they be aligned with requirements for other
modes of transport? Could a more risk-based approach be employed?
Are EN-standards opening up for industrial and competitive solutions?
Should safety be regulated at a European level, or is a there another approach?
Are assessors and notified bodies necessary?
Should trains and equipment be subject to the documentation and approval requirements as is the
case today, or is it possible to find a less burdensome solution?
Could larger parts of the paperwork related to documenting safety and interoperability be placed
within the railway infrastructure managers’ own organisation?
The Danish Ministry of Transport will gladly assist in this work as well as providing thoughts on these questions
as well as sharing examples of the challenges described above.