Contribution of the Intergovernmental Organisation for International
Carriage by Rail (OTIF) on Innovation
Specifications for Railway Interoperability
by Stefan SCHIMMING, OTIF Secretary General
For many decades of the last century the International Union of Railways (UIC) Leaflets formed the technical requirements for railway vehicles. The RIV and RIC agreements within UIC made possible the free movement of vehicles between almost all the railways of Europe, provided they met the requirements specified - and it worked very satisfactorily. There was interoperability for freight wagons and passenger carriages. Then in 1991, the European Union started its policy of opening the European market and of setting technical requirements at Community level.
In 1999, the OTIF Member States, including all the (then 15) EU Member States, adopted the new COTIF Convention. The idea was to raise the UIC regulations tat applied to its member railways to Sate level, thus opening the way for more competition and avoiding repeated approval in every Member Stated by means of legislation. UIC agreed and in 1003 completed substantial work for OTIF, not by creating new regulations, but by restructuring the existing ones for the new purpose. The UIC regulations were well known, used and accepted by the whole rail industry, manufacturers, railways and approval/supervision authorities, so there was absolutely no need to create new rules.
|However, the ratification of COTIF was delayed until 2006 when the Convention finally
entered into force. The European Commission was taken by surprise and instructed the EU Member States
to declare not to apply the OTIF instruments for technical issues.
Instead the EU has started to "re-invent the wheel", setting up the European Association for Railway Interoperability (AEIF) and later the European Railway Agency (ERA), which now has about 120 employees drafting and adopting the Technical Specifications for Interoperability (TSIs) for the Community, completely disregarding OTIF. After some hesitation, in 2007 the Commission allowed ERA to invite OTIF to the ERA Working Parties drafting the TSIs, but recently ERA barred OTIF from most of these groups at the request of the Commission for "formal (political) reasons"!
So how are these TSIs? Are they better than the UIC leaflets? The answer is NO.
The TSI WAG (freight wagons), which has been in force since 2006, contains in its 470 pages a large number of errors and flaws. A catalogue containing several hundred problems was produced by ERA and a revision process for the TSI was started but has not yet been finalised. Since then, a new Interoperability Directive (2008/57/EC) has entered into force requiring consequential adjustments to the TSI WAG, but these have not yet been carried out.
In 2009 a number of the most critical errors were corrected by Commission Decision 2009/107/EC, but not all. That Decision also included additional requirements and closed a vast number of open points in the 2006 TSI version, thus achieving the same level of mutual recognition as we had with the RIV and the COTIF model, which is: approved by one railway/Member State means approved by all. But in the EU regulations this progress is limited to "passe-partout" wagons. A "passe-partout" wagon is one that has a 1435 mm track gauge, clearance profile G1, axle distance not bigger than 17,500 mm, etc. But what about other wagons? They will still need individual approval in every Member State.
Due to the condition set up by the Commission for accepting vehicles approved in a non-EU Member State that the OTIF technical requirements must be equivalent to those in the TSI, we have another problem. A fairly large number of technical drawings in the TSI are illegible. They are so "blurred" that one cannot be sure whether a particular vehicle construction is consistent with the regulations. Some formulae are incomprehensible; it is impossible to know whether to multiply or divide and the legend includes parameters other than those used in the formulae. OTIF is now trying to rectify this with the help of authorities of non-EU Member States and the industry.
However, the TSIs are widely praised - mainly by the Commission itself - as the new tool for interoperability. But blanket advertising is often necessary for a poor, superfluous, but expensive product. Why and for how long will the EU Member States accepts this?