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.

The purpose of the authorisation of ERTMS elements is in the first place to assure the safety of the railway system. However, the authorisation process must also be conducted in fast and cost effective manner.

Against that background, EIM has concerns in relation to the authorisation process which has been envisaged for the ERTMS deployments during the 4th Railway Package trialogue discussions. Notably, the new article 41a requires that:

‘’the Agency should be in charge of assessing the technical solutions envisaged before any call for tenders relating to ERTMS track-side equipment is launched or published, in order to check whether they are compliant with the relevant TSIs and are therefore fully interoperable“.

This provision adds an additional step to the authorisation process. To EIM’s members the added value of this step is not clear. Tenders for ERTMS have to refer to the requirements of the CCS TSI and technical deviations are therefore not possible. Compliance of a tendered system is checked later on by a Notified Body which assures compliance with the provision of the TSI.

Therefore, EIM’s members consider a pre-check by ERA as an unnecessary double-check which would result in additional cost without providing any added value.

EIM members believe the ERTMS system is the future signalling system of the railways. To this end, EIM supports the European Railway Agency, as the ERTMS system authority which shall lead the process of a truly European interoperable and harmonised ERTMS deployment.

However, EIM calls upon the political decision makers not to impose the requirement laid down in the current proposal as all type of double work should be avoided.