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PRIME subgroup on Implementing Acts

Join the PRIME subgroup meetings to discuss implementing acts under Directive 2012/34/EU, focusing on direct costs, ERTMS DTACs, Framework Agreements, and Noise DTACs. Engage in an open and frank conversation about the requirements and concerns of IMs.

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PRIME subgroup on Implementing Acts

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  1. PRIME subgroup on Implementing Acts Edyta Jaszczuk-Jezierska Director of StrategyDepartment PKP PLK S.A.

  2. Purpose and organisation of the meetings • The meetingsareconvened in order to havean open and frank discussion to developimplementing actsunder Directive 2012/34/EU, in particular to represent IMs’ approach to the requirements of the Commission • Scope for discussion: directcosts, ERTMS DTACs, Framework Agreements, NoiseDTACs • Works organisation: Morning session: IMs with EIM/CER Afternoonsession: Commission joins for open discussion Discussing writtensubmissions from IMs unable to attend the meeting

  3. Direct costs (I) IMsmainconcerns: • The need for clearerdefinition of directcosts • Proposedact is too narrow and toolittleroom for flexibilityisleft • The adequacy of a market-can-bearit test • Direct costs are marginal costs for the Commission, whileIMshavedifferentmodalities to calculatedirectcosts • Mark-ups

  4. Direct costs(II) Discussion: • No substantial disagreement amongstakeholderswith the basic principle of charging,only on the basis of direct costs • Sometrafficcontrolcan be justified as directcosts: 10% of costsrelated to signaling and traffic management personnelhasbeenincluded to directcostscalculation • Thresholds and figuresmainly derivesfrom the CATRIN study • Provision for usingeconometricmodels • Commision’snegative list

  5. Framework agreements IMsmainconcerns: • The ceiling approach;interaliaas a potential barrier to new entrants • Surrender of capacity Discussion: • Framed by ongoing discussions in SERAC • The wayof defining and measure capacity, when it should be surrendered • Ceilingsapproach vs transparency and competition • Whetherthe ceiling is line-based or network-wide, • Re-using surrendered capacity • No firm conclusions but ongoing request for input

  6. Noise differentiated track access charges IMsmainconcerns: • The financial equilibrium of IMs • Impacton competitiveness of rail freight • Time frame for the system • Administrativeburden Discussion: • Strong consensus on the scheme being voluntary • Holder of information of traincomposition(what % of wagons are silent) Awaiting next draft of the act for next SERAC

  7. ERTMS differentiated track access charges IMsmainconcerns: • The financial equilibrium of IMs • Level of incentivestructure vs cost of retrofitting • Bonus/malusmodels Discussion: • Strong consensus among IMs:the business case for retrofitting as a serious challenge • The design of the incentivesregarding different models (bonus/malus) • Nofocuson Steer Davies GleaveConsultation,but rather on the principle itself

  8. Outputs and value • Forum enables IMs a distinct voice in discussionwith the Commission • Clear impact demonstrated on details on direct cost, waiting to see on others • Relies on Commission’s willingness to change – demonstrated on detail but not yet on principle

  9. Thankyou for yourattantion!

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