Cross Acceptance CER Expectations
description
Transcript of Cross Acceptance CER Expectations
109 July 2009 CER
The Voice of European Railways
Cross Acceptance
CER Expectations
ERA Seminar, Lille, 17.11.2010
Libor Lochman
209 July 2009 CER
The Voice of European Railways
Involvement of CER members in the authorisation processes
RUs: – customer of a manufacturer applying for authorisation or– Applicant for authorisation Concerned about current prohibitive cost and time for vehicle
authorisation, which are affected by current differing national processes and non-transparent rules
IMs:– Currently making efforts to provide rules for technical
compatibility between vehicles and the network– Sometimes involved in testing Concerned about reliability and impact (wear) of vehicles
running on its network
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Current problems with XA
The classification of national rules in advance of projects not always available; the first applicant has to carry more cost and risk than subsequent applicants
In some authorization process our members face practical problems to apply the limits related to re-checking. – Some NoBo Certificates are considered to be more trustworthy
than others, hence some are re-checked by NSAs A vehicle type authorisation and a common approach for
modifications requiring re-authorisation is not available
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The Voice of European Railways
The way forward
To issue a recommendation, based on the works of the ERA on cross-acceptance, for the systematic use of TSI requirements in place of the National Notified Technical Rules, each time they cover the same parameter or hazard.
To identify what are the possible legal obstacles to the application of such recommendations on a European level as well as (if applicable) on national level
To issue a recommendation for the implementation of a “platform authorisation” concept
509 July 2009 CER
The Voice of European Railways
DV29 – the step in the right direction
GeneralCER strongly supports the idea to provide a common understanding amongst the Member States and the stakeholders. DV29 provides a good basis for a common understanding.CER supports the basic principles outlined in DV29
– separation of authorization from operation/maintenance– rules-based approach– limit to re-checks
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DV29 – proposals for an improvement
In order to prevent further diverging interpretations of Dir 2008/57 and of DV29, we would propose the incorporation of a process flowchart for first and additional authorizations clarifying the sequence, maximum duration, input and output, tools, roles and responsibilities related to each step
Clarification on requirements to related modifications of authorized vehicles
Time limits for the full implementation of the new regime, especially the tools:– Completion of National Notified Rules including improved
classification– Completion of Registers: RINF and ERATV
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The Voice of European Railways
Further options
– ERA mapping the national rules to hazards and vehicle functions
– Systematic analysis of national rules for the closure of TSI open points
– ERA role in NSA auditing to guarantee comparable authorisation processes
– Reduction of the on-track testing (CER would contribute to the on-track testing study by reviewing and completing the already collected information)
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The Voice of European Railways
CER vision
Lower approvals costs and time
Faster introduction of new train designs
Less on track testing in individual countries
Less barriers imposed by IMs to new train
introductions
Easier fleet cascades - moving around and
between countries after first delivery
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The Voice of European Railways
Thank you for your attention!
For further information, visit our website: www.cer.be
Libor Lochman
CER Deputy Executive Director
Tel: +32 2 213 08 82Email: [email protected]