EIM proposes a clear reference to the ‘data relating to train movements within the meaning of Annex II’ that is to be provided on a non-discriminatory basis to railway undertakings and ticket-vendors. EIM believes this achieves the intended purpose of including paragraph 4 of article 9 in the recast, which is to clarify the data to be made available by Infrastructure Managers to Railway Undertakings. 

With regards to Article 24 (a), EIM calls upon an implementation period of 2 years following the date of compliance of the recast regulation to allow rail station mangers sufficient time to facilitate the changes required to provide a “no pre-notification” mobility assistance service without compromising on the quality and punctuality of the mobility assistance service provided as well as the safety of passengers and railway staff.