EIM (European Rail Infrastructure Managers) believes ERA (European Railway Agency) must ensure the harmonized and interoperable deployment of ERTMS in the European Union. The authorization process shall happen without double checks or unnecessary costs being created for the railway sector.

EIM supports the ERTMS authorisation process being conducted in a safe, fast and cost effective manner. The European Railway Agency as the ERTMS system authority shall lead the process of a truly European interoperable and harmonized ERTMS deployment. In this context EIM expresses its concern to the proposal of having a two-stage ERTMS authorisation: one before the tendering documents are sent and one when the subsystem is placed in service. Procedures and tender requirements may differ in different MSs and pre-authorization at this early stage of tender documentation may negatively influence the smooth course of investment processes. All type of double work and checks shall be
firmly avoided.

EIM members are conducting large multiannual programmes in the framework of ERTMS deployment. These projects are often carried out on lines which are subject to traffic during the construction period. This, as much as other types of ERTMS deployment projects, has to be supported by a clear and consistent regulatory framework which doesn´t lead to extra delays for the projects. (Sometimes original project plans cannot be followed 100 % when a project is conducted on the field. This might require adjustment of the projects plans which has to be reflected in the regulatory framework). Reauthorisation of existing project plans should be required only for major changes – the authorisation process cannot be the hindering factor for a successful ERTMS deployment taking place in a timely manner. Therefore EIM is calling on the EU Institutions to avoid any kind of measures which are neither cost nor time-efficient, and bring inconsistencies which can eventually hinder an interoperable ERTMS system for the entire EU.

EIM is calling for the clear allocation of responsibilities in the legal framework. The roles of the ERA, NSA and relevant assessment bodies (mainly Notified Bodies “NoBo” and Independent Safety Assessors “ISA”) have to be clearly defined. Each actor needs to have a clear understanding of their roles and responsibilities in supporting a successful ERTMS deployment carried out by EIM members.

EIM members believe the ERTMS system is the future signaling system of the railways. This has to be supported by the legislative decisions being taken.