Impact Assessment Full Revision of the Commission ... · The ECMs providing maintenance services for freight wagons only are not affected. Considering the expected increase of outsourcing

EUROPEANUNIONAGENCYFOR RAILWAYS

Making the railway systemwork better for society.

Full Impact Assessment

Impact Assessment

NA ECM

V 1.3

Revision of the Commission Regulation (EU) No 445/2011 of 10

May on a system of certification of entities in charge of

maintenance for freight wagons

Elaborated by Validated by Approved by

Natha lie DUQUENNE,

Torben HOLVAD, Jean-Marie Chris CARR,Name

Pedro MENESES DESCHAMPS, Josef DOPPELBAUER

Dana GHERGHINESCU

Economic Evaluation Project OfficerHead of Safety Unit,

Position Officer, Head of Sector SafetyExecutive Director

Project Officer Head of Sector EcoEv

Date 11/06/2018 11/06/2018 241

Signature

Document History

Version Date Comments

0.1 19/09/2017Preliminary version of the FIA report covering

Sections 1, 2 and 3 (partially)

0.2 06/10/2017Updated version of IA report covering Sections 1, 2

and 3

1.0 21/12/2017First complete draft of IA report covering all

sections; Review OG

1.1 25/04/2018Updated version of IA report taking into account

consultation comments and WP No. 3

1.2 15/05/2018Updated version of IA report taking into account

additional feedback and comments from WP No. 4

1.3 11/06/2018Final draft of IA report for RISCJune 2018 taking into

account final draft recommendation

I

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EUROPEAN UNION AGENCY FOR RAILWAYS Impact Assessment

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Contents

1. Context and problem definition 3

1.1. Problem and problem drivers 3

1.2. Main assumptions 3

1.3. Stakeholders affected 4

1.4. Evidence and magnitude of the problem 4

1.5. Baseline scenario 7

1.6. Subsidiarity and proportionality 8

2. Objectives 9

2.1. Strategic and specific objectives 9

2.2. Link with Railway Indicators 9

3. Options 10

3.1. Listofoptions 10

3.2. Description of options 10

3.3. Uncertainties/risks 10

4. Impacts of the options 11

4.1. Impacts of the options (qualitative analysis) 11

4.2. Impacts of the options (quantitative analysis) 19

5. Comparison of options and preferred option 21

5.1. Effectiveness criterion (options’ response to specific objectives) 21

5.2. Efficiency (NPV and B/C ratio) criterion 21

5.3. Summary of the comparison 21

5.4. Preferred option(s) 22

5.5. Further work required 22

6. Monitoring and evaluation 23

6.1. Monitoring indicators 23

6.2. Future evaluations 23

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1. Context and problem definition

Main problem: potential sub-optimal framework for managing1.1. Problem and . .

maintenance risks, particularly ifl the case of other vehicles than freightproblem drivers wagons.

Safety issues deriving from deficient maintenance are not in scope, as

the main objective of ECM certification was to prompt marketdevelopment whilst maintaining adequate safety levels and not toaddress possible safety issues.Problem drivers:Set A. related to the fact that current ECM regulation only covers wagonsand not locomotives, passenger coaches, DMU5/EMUs, other vehicles:

Potential inefficient, complex and resource-intensive processesfor RUs to make sure that maintenance of vehicles fulfils theirresponsibility for safe operation.This could particular be the case when using third party ECMs /maintenance providers as well as for technical advanced rollingstock.Possible existence of multiple/duplicative customercertification requests to ECMs and maintenance workshopsthat could result in additional costs for such entities anddifficulty for entering new market segments

Set B. related to the clarity and application of the current ECM regulation(these are of relevance for scope extension unless addressed as part ofthe revision of the ECM regulation):

Diversity of how requirements and methods are applied due todiverging interpretation in Member States (potentially leadingto misinterpretation) of the current provisions on ECMcertificationLack of clarity in the definition and allocation of responsibilitiesamong keepers, ECMs, RUs and other stakeholders operatingvehicles resulting in uncertainty among the concernedstakeholders and possibly additional costs

These problem drivers were considered during several meetings of the

ECM WP. Further evidence on the problem drivers are provided in AnnexEcoEvi setting out information collected from bilateral meetings andother sources.

1.2. Main assumptions The Safety Directive (Article 14.7) provides forthat: ‘By 16 June 2018, the

Agency shall evaluate the system of certification of the entity in chargeof maintenance for freight wagons, consider the expediency of extending

that system to all vehicles and the mandatory certification of

maintenance workshops and submit its report to the Commission’.

The impact assessment is incorporating available information sources inorder to underpin the assumptions concerning costs and benefits:

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1.3. Stakeholdersaffected

1.4. Evidence andmagnitude of theproblem

The Agency’s Ex-Post report’ on the implementation of theRegulation 445/2011 (February 2015) presenting key results onthe costs and benefits of the certification scheme for ECMs,maintenance providers and maintenance workshops regardingfreight wagons.An Agency Early Assessment Report (June 2015) providing a basisfor the present impact assessment work, by indicating a first setof options (md. mandatory and voluntary scope extension) andelaborating on the main potential benefits and costs of each ofthose options.

Category of stakeholder Importance of the problem

RUs 5

IMs 3

ECMs 5

Maintenance workshops 5

Keepers 4

Manufacturers 3

RST leasing companies 4

Certification bodies (CB) 4

NSAs 4

Some stakeholders do not consider the extension of the scope as anurgent need. It is also suggested by some of those stakeholders that,when the management of maintenance is clearly defined and controlled,there may be no evidence that an actual problem needing solution exists.As such these views has been considered thoroughly in the impactassessment. In particular, this has been addressed through bilateralinformation exchanges with a broad range of stakeholders.

(I) Agency’s Ex-Post report on the implementation of the Regulation445/2011 (February 2015) highlighted the following:

Since 2012 the sector and a number of NSAs demonstrated interestfor the extension of scope to all vehicles

in 2015 a certification service to ECMs for locomotives andpassenger coaches was proposed at least by one company,which was already active in the certification of ECMs forfreight wagonsone NSA also started a process for defining a national ECMcertification scheme for locomotives and passenger coaches.Other countries are expected to follow, thereby potentially

1 The ECM Implementation Report can be accessed from this link:https://extranet.era.eu ropa.eu/safety/REVECM/Specific-reference-docu ments/implementation%20445-2011.zip

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resulting in increased diversity of management and deliveryof maintenance for railway vehicles.

A guideline for development of a voluntary certification scheme hadbeen proposed by the Agency in 2014 to the Freight Focus Group.However, the Freight Focus Group clearly indicated that the

guideline (as a non-legally binding instrument) was not enough butit could be the basis for the extension of scope of the Regulation.The results of a comprehensive questionnaire (with 200+respondents) launched by the Agency in 2014 reinforced theperception that the sector and several NSAs are strongly in favour ofthe extension of scope, for reasons such as:

need for a comprehensive (harmonised) certificationscheme for all vehicles thereby resulting in reducedadministrative burdena number of ECMs do not currently provide a service forfreight wagons onlyadvantage of a clear standardisation of rules formaintenance for all vehicles.

It is expected that the cost of certification for other vehicles wouldbe of the same order of magnitude as the cost for initial certificationof ECMs maintaining freight wagons (up to 40.000 - 50.000€ onaverage, although subject to variation between Member States).Currently, a voluntary ECM certification system for other vehicles isimplemented in one MS. The costs of this system are similar to thoseof certification of freight wagons and have decreased by up to 15%,compared to the costs of implementing previous nationalregulations.Extension of scope may be beneficial for RUs wishing to concentratetheir resources in transport activities because it would release themfrom the duty of putting in place internal maintenance services orassess and choose external maintenance services.However, the specific business models for passenger transportshould be considered, as they are different from those related tofreight transport for which the current Regulation applies to freightwagons. As such, this refers also to differences in terms of extent ofexchanges of vehicles between stakeholders. These differences maynecessitate adjustments to the provisions in the Regulation.

(II) Agency Early Assessment Report on extension of ECM certification

(June 2015) highlighted the following:

There is strong sector support for the scope extension, although RSTleasing companies and small maintenance providers are less infavour.The order of magnitude of the problem depends on the specificcontext of each stakeholder:

For RUs currently carrying out the maintenance of theirvehicles in-house, the issue of the sub-optimal control ofmaintenance risks is relatively limited depending on the

____________________________

complexity of the concerned rolling stock.




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The growing complexity of technical systems and thedecrease in public budgets for incumbent RUs may lead tothem totally or partially subcontracting the maintenance oftheir fleet.Differently, for RU5 already having outsourced maintenanceactivities this problem could be more substantial.For ECMs, maintenance providers and maintenanceworkshops, the extent of the issue resulting from the needto retain several maintenance management systems (to fulfildifferent customer requirements) will be determined bywhether their business focus is on a single customer and inone type of vehicle types or not, i.e. on multiple customersinvolving different types of vehicles.The ECMs providing maintenance services for freight wagonsonly are not affected.

Considering the expected increase of outsourcing of maintenance oflocomotives and coaches, together with the need for a reliable andcompetitive maintenance service market, the relevance of theidentified issue may increase in future. Thus, a flexible solution thatfits with the needs of different stakeholders is required.

(Ill) Inputs and reflection from ECM Regulation Working party:

Following the Vt and 2 WP meetings in May and in October 2017 itappears that the strong support from the sector to the extension ofscope of the Regulation to all vehicles is somewhat less clear-cut.Some key aspects need to be taken into account:

not only the technical complexity of the subsystems formingthe vehicles, but also the costs deriving from certificationschemes on a wider basis throughout the lifetime ofvehicles.intended use foreseen for the vehicles and possiblespecificities in the management of maintenance by RU5operating passenger trainsthe influence that a possible scope extension may have onthe competitiveness of small maintenance providers andRUs.

Moreover, the positions expressed by the WP members do notnecessarily coincide on whether scope extension may involve allvehicles or not and whether it should be voluntary (mainly favouredby the sector organizations) or mandatory (mainly favoured by NSA5)although in both cases there is a range of views put forward.There are still references to harmonisation and transparencypurposes, which could help companies searching abroad for ECMs asregards the significant diversity of national rules.Some WP members believe that further efforts are needed in theimplementation of Regulation 402/2013 (CSM for risk assessmentand repealing Regulation 352/2009) in the area of maintenance,whereas stronger transparency in procedures and a closer


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collaboration between the involved parties would also be of

advantage.Another concern was the extent of harmonisation of assessment

criteria applied in practice by CBs.It was noted that no dramatic increase of costs is expected in case ofmandatory certification, if organisations comply with therequirements of the RSD. However, there was no consensus on this.

(IV) Considerations on the certification of maintenance workshops:

At present the certification of maintenance workshops is voluntary

according to the ECM Regulation (Regulation 445/2011). The lack ofidentification of a set of certifiable common operations carried outby workshops certification is seen as an issue and may result inhigher costs for RUs when assessing the ability of maintenanceworkshops to manage maintenance activities and to deliver theiroperational functions.Additional specific arrangements, including adequate monitoring

and surveillance measures of workshops, could be included in a

____________________________

contract, if an ECM decides to conclude one.

1.5. Baseline scenario Baseline scenario: continuation of the current legal framework, i.e. theapplication of the certification scheme of ECMs and maintenance

workshops to freight wagons only.

This may lead to persistent problem drivers:

- from Set A - section 1.1:

RUs searching for external maintenance services may find theselection of an ECM corresponding to their needs challenging (thiscould be especially serious for new entrant RUs, for which in-housemaintenance is not necessarily an option)RUs could find it challenging to obtain assurance that themaintenance externally provided to locomotives and coaches isadequate so that risks are controlled and operations are safe

For external ECMs and maintenance workshops providing services tolocomotives and/or coaches, the existence of different requests for

specific customer certifications or of different monitoring and

control systems at national level, including certification schemes, ispotentially also a disadvantageLack of recognition of voluntarily certified ECMs for maintenance ofother vehicles, which feel the need to re-assess and “re-certify” eachother.

- from Set B — section 1.1:

none of the issues regarding the current ECM Regulation would beaddressed (e.g. the lack of clarity in the definition and allocation ofresponsibilities between keepers, ECMs and RUs operating wagons

also not address any issues).




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As a result, the baseline would imply that management of maintenancerisks could continue at a sub-optimal level, including difficulties forsmaller maintenance providers when wishing to enter new markets.

1.6. Subsidiarity and The concept of ECM itself was introduced through EU legislation (the

proportionality RSD) thereby addressing the issue of subsidiarity. This was one of theelements considered to contribute to ensure safety is at least maintainedin the process of restructuring the European railway sector, with newactors being made responsible for functions previously assigned toincumbent operators. The options considered for scope extension adoptan incremental approach in line with the proportionality principle. ThusEU action is justified on this matter, as it had already been the case withthe Regulation regarding freight wagons.

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2. Objectives

Strategic objective(s) of the Agency with which this initiative is2.1. Strategic and

coherent Include:specific objectives

LI Europe becoming the world leader in railway safety

Promoting rail transport to enhance its market share

Improving the efficiency and coherence of the railway legalframework

LI Optimising the Agency’s capabilities

LI Transparency, monitoring and evaluation

Improve economic efficiency and societal benefits in railways

LI Fostering the Agency’s reputation in the world

The project’s general objective: to contribute to optimising themanagement of maintenance risks in the railway sector.

Specific objectives:1. Increase the efficiency for RU5 making sure that in their

maintenance of vehicles they fulfil their responsibility for safeoperation

2. Reduce presence of multiple / duplicative customer certificationrequests to ECMs and maintenance workshops

3. Reduce diversity of requirements and methods applied inrelation to the certification of ECMs and maintenance workshops

4. Enhance clarity in the definition and allocation responsibilitiesamong keepers, ECMs and RUs operating vehicles

2.2. Link with Railway n.a.

Indicators




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3. Options

3.1. List of options The following options are under consideration:

Option 0 (do-nothing)Option 1: Revision of current Regulation and scope extension tolocomotives as a voluntary certification scheme + voluntary-based certification of MW5.Option 2: Revision of current Regulation and scope extension toall vehicles (md. locomotives and coaches) as a voluntarycertification scheme + voluntary based certification of MWsOption 3: Revision of current Regulation and scope extension tolocomotives as a mandatory certification scheme with voluntarycertification for other vehicles + voluntary based certification ofMW5.Option 4: Revision of current Regulation and scope extension toall vehicles (md. locomotives and coaches) as a mandatorycertification scheme + voluntary based certification of MW.Option 5 (incremental from Option 4): Revision of currentRegulation introducing mandatory certification of maintenanceworkshops for all vehicles.

StakeholderscertifiedIvol u nta rycertificationof MW5possible forall optionsthoughmandatoryfor Option 5)

3.2. Description of

options Option Option Option Option Option Option0 1 2 3 4 5

Revision of No Yes Yes Yes Yes Yescurrent legaltextScope No Locos All All vehicles All vehicles All vehiclesextension vehicles

(ECMsIRegime of - Voluntary Voluntary Mandatory Mandatory Mandatorycertification for locos

Voluntaryfor the rest

ECM5 ECM5 ECM5 ECMs ECM5 andMW5

3.3. Uncertainties/risks Scope extension of the Regulation to other vehicles may bechallenging given the differences between freight and passengertransportation regarding business models

> Impacts of scope extension are influenced by broader maintenancemarket trends including the extent to which RUs are outsourcingmaintenance to external parties and the extent to whichmaintenance providers / ECMs tend to specialise in terms of thetypes of vehicles covered.

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4. Impacts of the options

4.1. Impacts of the The qualitative analysis is considering the impacts from a European

options perspective. This implies that the following statements take a higher

(qualitative level meaning that there could be national variations, as well as

analysis) variations within groups of stakeholders. It should also be noted that

the following analysis focuses on ECMs and MWs, RUs, keepers, RST

leasing companies, ECM CBs and NSAs. Overall, it is expected that the

main stakeholders affected by scope extension would be: ECM5, MW5

as well as RUs and keepers.

Category of Option 0 (baseline)

stakeholderECMs and Positive impacts No changesWorkshops

Negative impacts No changes

RUs Positive impacts No changes


Keepers Positive impacts No changes


RST leasing Positive impacts No changescompanies


ECM Positive impacts No changesCertificationBodies Negative impacts No changes

National Positive impacts No changesSafetyAuthorities Negative impacts No changes

Overall Positive impacts No changesassessment(input for Negative impacts No changes

section 5.1)

Category of Option 1 — Voluntary scopestakeholder extension to locomotives

ECMs and Positive impacts Only ECM5 having a commercialWorkshops net-advantage of certification

would opt for this scheme. No

______________________

significant implications for MWsNegative impacts For ECMs additional certification

costs, though likely to be somewhatmitigated by elimination of othercustomer certification requests. No

______________ ______________________

significant implications for MWs

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Given the limited scope of thiscertification scheme the businesscase may be relative modest.

RUs Positive impacts Similar level of assurance regardingthe maintenance for locomotives asfor freight wagons.

Negative impacts Given the limited scope of thecertification scheme the efficiencygains for RUs are modest comparedto the baseline.

Keepers Positive impacts For keepers being ECMs see aboveunder ECMs. In general, positiveimpacts could relate to moreefficient basis to assure to RUs thatvehicles (locomotives) providedmeet consistently safetyrequirements.

Negative impacts For keepers being ECMs see aboveunder ECMs.

RST leasing Positive impacts -

companiesNegative impacts Voluntary scheme with scope

limited to locomotives is notperceived to generate added-valuefor RST leasing companies in termsof reducing resources

ECM Positive impacts Certification scheme may supportCertification market opportunities for CBs forBodies certification of ECMs for other

vehicles (locomotives)Negative impacts Cost impacts to obtain

accreditation / recognition may bea barrier for CBs given the limitedscope of the certification scheme

National Positive impacts In those cases where the NSA isSafety also the ECM CB there could beAuthorities Negative impacts limited impact in terms of

resources.Overall Positive impacts Voluntary based certificationassessment scheme would imply that ECMs(input for would only apply if there is a

section 5.1) business caseHarmonisation benefits for RUs,though relative modestLimited scope would reduce anyadverse cost impacts

Negative impacts Identified problem drivers are likelynot to be sufficiently addressedunder this option

Category of Option 2 — Scope extension allstakeh older vehicles (voluntary)

ECMs and Positive impacts Voluntary framework for scopeWorkshops extension should ensure that only

ECMs having a commercial net

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advantage of certification wouldopt for this scheme. The risk ofduplicative certification requestsfor all vehicles may be reduced.The option could also bringadvantages by clarifying theresponsibilities between ECM / RUand Keeper for other vehicles

_____________________

No significant implications for MWs

Negative impacts For [CMs additional certificationcosts, though likely to be mitigatedby elimination of other customercertification requestsNo significant implications for MWs

RUs Positive impacts Similar level of assurance regardingthe maintenance for other vehiclesas currently for freight wagons.Clarity of responsibilities betweenRU / ECM / Keeper.

Negative impacts Given the voluntary status of thecertification scheme the efficiencygains will depend on take-up of thecertification system by LCMs andthe extent of trust by RUs

Keepers Positive impacts For keepers being ECMs see aboveunder ECMs.More efficient basis to assure toRUs that vehicles provided meetconsistently safety requirements.Advantages from clarity ofresponsibilities between RU / ECM

I KeeperNegative impacts For keepers being ECMs see above

under ECMs. Compared to thecurrent situation (baseline) limiteddirect changes for keepers notbeing ECMs.

RST leasing Positive impacts -

companiesNegative impacts Voluntary scheme is not perceived

to generate added-value for RSTleasing companies in terms ofreducing resources

ECM Positive impacts Certification scheme may supportCertification market opportunities for CBs forBodies certification of ECMs for other

vehicles.Negative impacts No significant issues for CBs. Any

cost / resource implications wouldnormally be covered throughrevenue from certificationactivities.

National Positive impacts In those cases where the NSA isSafety also the ECM CB there could beAuthorities

______________________

limited impact.

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NSAs may obtain advantages bysimplifying their assessment ofsingle safety certificate applicationsas well as targeting supervision

_____________________

tasks with respect to RUs.

Negative impacts -

Overall Positive impacts Potential for efficiency gains forassessment RUs and cost savings for ECMs(input for through reduced duplicative /section 5.1) overlapping customer certification

request.Advantages through reduceddiversity re. requirements andmethods applied in relation to thecertification of ECMs as well asprogress on clarity of

_____________________

responsibilities

Negative impacts Costs impacts notably for ECMs inrelation to the certification.However, given that it is avoluntary scheme this issue shouldin fact have limited implications.Furthermore, it should be notedthat in general the direct costsinvolved for scope extension are

_____________ _____________________

relatively low.

Option 3 — Scope extension allCategory of vehicles (mandatory forstakeholder locomotives; voluntary for other

_____________ _____________________

vehicles)ECMs and Positive impacts The risk of duplicative certificationWorkshops requests for all vehicles will be

reduced although the extent of thisadvantage is limited by thecertification scheme being partlyvoluntary. Clarify to a certainextent the responsibilities betweenECM / RU and Keeper for othervehicles. No significant implications

__________________

for MWs

Negative impacts For ECMs additional certificationcosts, though likely to be somewhatmitigated by elimination of othercustomer certification requests.Differentiating betweenlocomotives and other vehicles maylimit the extent of reduction induplicative certification. No

_______________ _______________________

significant implications for MWs

RUs Positive impacts RUs would obtain similar level ofassurance regarding themaintenance for locomotives as

________________________________ _____________ ____________________

currently for freight wagons. RUs




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will also benefit from someimprovements regarding the clarityof responsibilities between RU /

____________________

ECM / Keeper.Negative impacts Given the voluntary status of the

certification scheme with respect toother vehicles than locomotives theefficiency gains will depend on thetake-up of the certification systemby ECMs and the extent of trust in

____________ ____________________

the system by RUsKeepers Positive impacts For keepers being ECMs see above

under ECM5. Relative moreefficient basis to assure to RUs thatvehicles provided meet consistentlysafety requirements. Someadvantages from clarity ofresponsibilities between RU / ECM

_____________________

/ Keeper.Negative impacts For keepers being ECMs see above

under ECMs. Compared to thecurrent situation (baseline) limiteddirect changes for keepers notbeing ECMs, although any adversecost implications would need to becarefully monitored.The dual system for locomotives /wagons and other vehicles may

_____________ _____________________

limit the advantages.

RST leasing Positive impacts Facilitating the management ofcompanies maintenance by contractors

resulting in reduced costs, asregards locomotives. In the case ofother vehicles the implicationsneed to be considered carefullygiven the particularities ofmaintenance management of RUsoperating passenger trains.However, cost implications wouldbe mitigated by the voluntarystatus.

Negative impacts Possible impacts on costs wouldneed to be examined taking intoaccount the life cycle costs ofroIling stock particularly in the caseof locomotives.

ECM Positive impacts Certification scheme could supportCertification market opportunities for CBs forBodies certification of ECMs for other

vehicles.Negative impacts No significant issues for CBs.

The positive impacts could beuncertain given the voluntarystatus of the certification schemefor other vehicles than locomotives.




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National Positive impacts In those cases where the NSA isSafety also the ECM CB there could beAuthorities limited impact. Moreover, NSAs

may obtain advantages bysimplifying their assessment ofsingle safety certificate applicationsas well as targeting supervisiontasks with respect to RUs. However,these advantages would for othervehicles than locomotives andwagons depend on the extent oftake-up of the certification schemeby ECMs and the trust placed in the

___________________

scheme by RUsNegative impacts In those cases where the NSA is

also the ECM CB there could be

______________ _____________________

limited impactOverall Positive impacts Potential for efficiency gains forassessment RUs and cost savings for ECMs(input for through reduced duplicative /section 5.1) overlapping customer certification

request. Reduced diversity re.requirements and methods appliedin relation to the certification ofECMs as well as progress on clarity

_____________________

of responsibilities.Negative impacts Costs impacts notably for ECMs in

relation to the certification withparticular reference to locomotives.However, it should be noted that ingeneral the direct costs involved forscope extension are relatively low.Advantages may be lowered due tothe dual systems in place forlocomotives / wagons and othervehicles

Category of Option 4 — Scope extension allstakeh older vehicles (mandatory)

ECMs and Positive impacts Duplicative certification requestsWorkshops for all vehicles will be reduced.

Clarifying the responsibilitiesbetween ECM / RU and Keeper forother vehicles. No significant

_____________________

implications for MWsNegative impacts For ECMs additional certification

costs, though likely to be mitigatedby elimination of other customercertification req uests. Moreover,the costs involved are relativelylow. Specific issues for small ECMswould need to be taken intoaccount. No significant implications

____________ __________________

for MWs


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RUs would obtain similar level ofassurance regarding themaintenance for other vehicles ascurrently for freight wagons. RUswill also benefit from clarity ofresponsibilities between RU / ECM

/ Keeper.

For negative impacts in case the RUis an ECM see analysis above forECM. In other cases it is likely thatnegative impacts would berelatively limited.

For keepers being ECM5 see aboveunder ECMs. A more efficient basisto assure to RUs that vehiclesprovided meet consistently safetyrequirements. Clarity ofresponsibilities between RU I ECM

/ Keeper.

For keepers being ECMs see aboveunder ECMs. Compared to thecurrent situation (baseline) limiteddirect changes for keepers notbeing ECMs, although any adversecost implications would need to becarefully monitored.

Facilitating the management ofmaintenance by contractorsresulting in reduced costs, asregards locomotives. In the case ofother vehicles the implicationsneed to be considered carefullygiven the particularities ofmaintenance management of RUsoperating passenger trains.

Possible impacts on costs wouldneed to be examined taking intoaccount the life cycle costs ofrolling stock.

In those cases where the NSA isalso the ECM CB there would belimited impact. Moreover, NSAscould obtain advantages bysimplifying their assessment of

single safety certificate applications

RUs Positive impacts

Negative impacts

Keepers Positive impacts

Negative impacts

RST leasingcompanies

Positive impacts

Negative impacts

ECM Positive impacts Certification scheme could support

Certification market opportunities for CBs for

Bodies certification of ECMs for othervehicles.

Negative impacts No significant issues for CBs. Anycost / resource implications wouldnormally be covered throughrevenue from certificationactivities.

NationalSafetyAuthorities

Positive impacts

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as well as targeting supervision

______________________

tasks with respect to RUs.

Negative impacts In those cases where the NSA is

also the ECM CS there would be

______________ ______________________

limited impact

Overall Positive impacts Efficiency gains for RUs and cost

assessment savings for ECMs through reduced

(input for duplicative / overlapping customer

section 5.1) certification request. Advantages

through reduced diversity re

requirements and methods applied

in relation to the certification of

ECMs as well as progress on clarity

_____________________

of responsibilities

Negative impacts Cost impacts notably for ECMs in

relation to the certification. It

should be noted that in general the

direct costs involved for scope

extension are relatively low.

Attention should be given to the

issue of small ECMs md. possible

maintenance market implications.

Option 5 — Combined with Option 4Cotegoryof

+ mandatory certification ofstakeholder

maintenance workshopsECMs and Positive impacts See description for Option 4 for

Workshops ECMs. There could be

harmonisation benefits for MWs

Negative impacts Cost impacts for certification of

MWs. In particular, this could be a

concern for small MWs / ECMs.

RUs Positive impacts See description for Option 4

Negative impacts Efficiency gains may be somewhat

lower due additional costs from

additional certification for MWs

Keepers Positive impacts See description for Option 4

Negative impacts Cost implications from MW

certification without significant

additional benefits

RST leasing Positive impacts See description for Option 4

companiesNegative impacts Cost implications from MW

certification without significant

additional benefits

ECM Positive impacts See description for Option 4

Certification

Bodies Negative impacts See description for Option 4

National Positive impacts See description for Option 4

Safety

Authorities Negative impacts See description for Option 4

Overall Positive impacts The only change compared to

_______________________________

assessment

_____________________

Option 4 is the addition of

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(input for mandatory certification forsection 5.1) maintenance workshops. It follows

that this option contributes well tothe achievement of the establishedspecific objectives although thelevel of achievement is somewhatlower compared to Option 5 due tothe interactions with twocertification schemes.

Negative impacts Cost impacts on maintenanceworkshops which could increasethe overall costs of certificationwithout bringing any additionalbenefits compared to option 4.There could be a risk of over-certification overlapping with the

________________________________ _____________ _____________________

requirements for ECMs.

4.2. Impacts of the The quantitative analysis (the specific assumptions on parameter values

options are set out in Annex EcoEv 2) includes in particular:

(quantitative Cost impact for ECM5 and Maintenance Workshops:

analysis) o one-off costs for initial certification under ECMo recurring costs per annum for surveillance activities by

certification body as well as renewal of ECM certificationCost savings (benefits) for ECM5 and RUs due to reduced duplicativecertification systems and increased harmonisation

o one-off cost savings are assumed insignificanto recurring costs savings (per annum) - the main cost changes

concern any savings generated per annum by havingreduced number of audits

Notes:For all categories the estimated quantitative impacts measurethe change in mill. Euros relative to the baseline (Option 0 or Do-Nothing).In the case of one-off impacts the values are assumed to beincurred in a single year only (Year 0 in the CBA calculation).For recurring impacts the values shown are incurred each yearover the assumed lifetime (20 years).

Cost and benefit values given for stakeholder groups are

expressed per entity. Therefore, in order to determine the total

impact these values would need to be multiplied by the number

of entities affected.Cost figures for ECMs and maintenance workshops include bothinternal and external items

These are estimates based on the input collected from the NSAs and thesector, grounded on assumptions and can therefore not be considered

as being accurate measurements.



EUROPEAN UNION AGENCY FOR RAILWAYS Impact AssessmentFIA ECM

V 1.3

Category of Option 0 Option Option Option Option Option

stakeholder (baseline) 1 2 3 4 5

ECM / Recurring 0.00 0.014 0.016 0.014 0.016 0.015

MWs benefits(euro)One-off 0.00 0.04 0.04 0.04 0.04 0.06costs(euro)Recurring 0.00 0.02 0.02 0.02 0.02 0.03costs(euro)

RUs Recurring 0.00 0.014 0.016 0.014 0.016 0.015benefits(euro)Costs 0.00 0.00 0.00 0.00 0.00 0.00(euro)

Overall Recurring 0.00 2.6 5.8 7.9 11.7 10.9benefits

(euro)One-off 0.00 3.8 7.6 11.4 15.2 21.3costs(euro)Recurring 0.00 2.2 4.4 6.6 8.7 12.5costs(euro)

The NPV and B/c figures are calculated using a 4% discount rate (inaccordance with the EC Better Regulation Guidelines, 2017). Furtherdetails of the quantitative modelling of impacts are provided in AnnexEcoEv 3.

As part of the validation of the CBA a sensitivity was performed forOption 4 reducing the cost savings potential from 25% to 12%. Theresults are also included in Annex EcoEv 3 showing a B/c ratio of 1.01(and NPV value of 1.00 mln EUR).

Option 0 Option 1 Option 2 Option 3 Option 4 Option 5

(baseline)

NPV(input for

0.0 1.4 12.2 7.5 24.4 -43.2section5.2)

B/C ratio(input for

N/A 1.0 1.2 1.1 1.2 0.7section5.2)

________ ________ ________ ________ ________ _____

120 Rue Marc Lefrancq I BP 20392 I FR-59307 Valenciennes Cedex 20 / 30Tel. +33 (0)32709 6500 I era.europa.eu


FIA ECM

V 1.3

On the basis of the findings from section 4.1 the extent to which the various

options respond to the specific objectives have been assessed, using a scale

from 1-very low response to S-very high response. Subsequently, the

individual scores for each option are added together and the average score

per option is calculated (effectiveness).Option 0 Option Option Option Option Option

(baseline) 1 2 3 4 5

In crease theefficiency for

1 2 4 3 5 4RUs assuranceof maintenanceReducedduplicative

1 2 4 4 4customercertificationReduceddiversity ofrequirements 1 2 4 3 5 4and methodsapplied by CBsEnhancedclarity in thedefinition/ 1 2 4 3 5 4allocationresponsibilities

Overall score 4 8 16 14 20 16

Effectiveness(average 1 2 4 3.5 5 4score)

5. Comparison of options and preferred option

5.1. Effectiveness

criterion (options’

response to

specific objectives)

5.2. Efficiency (NPV On the basis of the findings from section 4.2, the overall efficiency of the

and B/C ratio) various options is rated as follows. The following principle for the scoring is

criterion adopted:

1 if B/c ratio <1 or NPV <=0> 5 if B/c ratio >1 and NPV >0

Option 0 Option Option Option Option Option


Efficiency 1 5 5 5 5 1

5.3. Summary of the In the following table the comparison of options is summarized taking into

comparison account both the effectiveness and efficiency dimensions.

Option 0 Option Option Option Option Option


Effectiveness 1 2 4 3.5 5 4

Efficiency 1 5 5 5 5 1

Overall 1 3.5 4.5 4.3 5 2.5

rating

120 Rue Marc Lefrancq I BP 20392 I FR-59307 Valenciennes Cedex


21 / 30


FIA ECM

V 1.3

5.4. Preferred The following options are the two top ranked:

option(s) > Option 4 (mandatory scope extension to all vehicles) has the highesteffectiveness (5) and the highest NPV (24.4 mill. Euros)Option 2 (voluntary scope extension to all vehicles) has a relativelylower effectiveness (4) and a relatively lower NPV (12.2 mill. Euros)

It should be emphasised that although both options have positive net-benefits the order of magnitude for both benefits and costs are higher forOption 4 compared to Option 2. This has two implications: 1) the overall gainsare higher for Option 4; 2) the costs involved would also be higher makingthis option more vulnerable. This implies that the choice of option wouldcome down to a trade-off between net-benefits and financial risk. In thisregard one particular factor that could be decisive for putting Option 4forward would be any provisions for Agency monitoring of ECMs and ECMCertification Bodies. This is likely to add efficiency related benefits (not takeninto account in the above figures of quantitative benefits). In particular, wehave estimated the potential net-benefits of having in place a robust Agencymonitoring of these organisations to involve up to 0.5 mill. Euros per annum.This could strengthen further the case for Option 4 with mandatory scopeextension for all vehicles.

Not foreseen5.5. Further work

required




HA ECM

V 1.3

6. Monitoring and evaluation

6.1. Monitoring Preliminary proposal for headline indicators:

indicators Overall level of correct implementation of the RegulationNumber of identified major non-compliances with the certificationrequirements per country and per applicationNumber of new, amended and renewed ECM certificatesNumber of revoked ECM certificates

Preliminary proposal for in-depth information requirements:Overall perceptions and experiences of ECM certification bystakeholders (CBs, NSA5, ECMs, keepers, maintenance workshops,RU5/IMs, leasing companies)Views on the implementation of specific elements of the Regulation(detected issues and advantages, non-anticipated results, etc.)Actual implementation costs (focusing on obtaining practicalinformation about costs incurred by the different parties)Perceptions among ECMs on whether there are changes in resourcesused for applying for ECM certification and for preparing for theannual surveillance activities (with specific examples)Perceptions among CBs on whether there are changes in resourcesused for assessing ECM certification applications and for carrying outsurveillance activities (with specific examples)Opinions from RU5/IMs and other stakeholders on the systemestablished by ECMs to monitor their performance and theperformance of their outsourcing partnersViews from ECMs, RU5/IMs and other stakeholders on theeffectiveness of the communication arrangements for requestinginformation on the maintenance/operation of vehiclesOpinions from ECMs and maintenance workshops on theeffectiveness of the exchange of views between NSAs and CBs toavoid duplication of assessmentsPractical examples of the Regulation having influenced the openingof the market for maintenance services and/or interoperability in theEU.

Key data sources may include:Specific Agency monitoring activities regarding ECMs and CBsprovided for in the revised RegulationAnnual reporting by NSA5 on ECM certification and supervisionMonitoring of NSAs’ activities by the AgencyAnnual ECM reporting to CBsCooperation among CBs by the AgencyDedicated interviews/surveys issued through the NSA Network andthe Cooperation Bodies WP, as required.

6.2. Future evaluations Based on the monitoring indicators and other relevant information,future ex post evaluations of this initiative may be considered, asrequired. Moreover, it could also be foreseen to provide for the

120 Rue Marc Lefrancq I BP 20392 I FR-59307 Valenciennes Cedex 23/30



HA ECM

V 1.3

preparation of a comprehensive implementation report in line with thecase for the current ECM Regulation. Such a report could be prepared 4-5 years after the revised Regulation entered into force with the purposeof having an in-depth examination of return of experience as well asconsideration to any adverse implications.

120 Rue Marc Lefrancq I BP 20392 I FR-59307 Valenciennes Cedex 24 / 30Tel. +33 (0)32709 65 00 I era.europa.eu

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Documents

Impact Assessment Full Revision of the Commission ... · The ECMs providing maintenance services for freight wagons only are not affected. Considering the expected increase of outsourcing