On 01 December, ERFA, along with other European railway associations, issued a joint statement on the need for the EU Council to adopt an agreement on a joint approach regarding the TEN-T Regulation which is in line with the ambitions laid out by the European Commission?s proposal. For rail freight to be able to achieve the targets agreed upon in the European Sustainable and Smart Mobility Strategy, it is important that infrastructure is developed in a timely manner and which will facilitate increased rail freight volumes.

For rail freight to be able to meet the objectives set out in the European Sustainable and Smart Mobility Strategy, it is essential that railway capacity management moves towards a system that is European, digital, flexible and secure. Rail freight undertakings must be able to book capacity which is in line with their business models and allows for flexibility to meet customer needs. Along with FTE (Forum Train Europe) and ALLRAIL, ERFA has agreed a common vision on how this can be achieved.

The functioning of European supply chains is being put at risk by increasing energy prices. There is a significant risk of a collapse of supply chains which rely heavily on rail freight for transportation due to unsustainable energy and transportation costs. The informal meeting of the Council of European Transport Ministers of 20-21 October should agree that Regulation (EU) 2022/1854 on an emergency intervention to address high energy prices will be applied to traction electricity used by freight trains.

The revision of the Train Drivers Directive will play an important role in ensuring rail freight can achieve its modal shift objectives. With the closing of the public consultation on the revision of the Directive, it is important that the European Commission adopts an approach which ensures the train driver certification process ensures a high level of safety of operations whilst also introducing greater flexibility and ensuring that language requirements do not become a bottleneck to the good functioning of the European rail freight market.

The impact of dramatically increasing energy prices in the rail freight market has the potential to not only reverse modal shift, but also to fundamentally change the composition of the European rail freight sector. Many smaller and medium sized railway undertakings are at risk of leaving markets or even bankruptcy depending on the evolution of energy charging policies. It is essential that measures are taken which support rail freight and ensure 20 years of market opening is not undermined.

On 06 July, the European Commission proposed a Council Regulation introducing rules to simplify procedures for State Aid to green transport. The adoption of the Regulation will enable the Commission to declare certain categories of State Aid to greener modes of transport compatible with the internal market and allow for the European Commission to introduce adopt a Block Exemption Regulation for certain aids. ERFA believes this will have a positive impact on modal shift, but raises the importance of the upcoming revision of the State Aid Guidelines for Railway Undertakings.

On 22 June, the European Commission's public consultation on boosting cross-border rail concluded. ERFA believes it is essential that the follow-up to this consultation process is that the European Commission adopts an ambitious legislative approach with a strong focus on capacity management, built along the provisions with TTR (Timetabling and Capacity Redesign), in order to ensure that rail freight is well placed to meet its long-term growth targets.

The liberalisation process has fundamentally changed, diversified and internationalized the European Rail Freight Market. Challengers have increased their market share on average in European Countries from 17% (2007) to an average market share of 48% (2021) and subsequently represent almost half of the EU rail market. In light of this trend, ERFA has identified different action fields on infrastructure, technological and competition policy which are crucial to secure fair competition and give Railway Undertakings, and especially challengers, support to efficiently contribute to modal shift and the targets of The Green Deal and European Sustainable and Smart Mobility Strategy.

On 16 March, the European Commission concluded its public consultation on the revision of the State Aid Guidelines for Railway Undertakings. What is already known is that the Guidelines are in need of modernization and a revision is therefore essential. ERFA believes it is important that the correct approach is adopted to this revision process so as to ensure the revised Guidelines play a constructive role in supporting a diverse and competitive European rail freight market.

The European Commission's Sustainable and Smart Mobility Strategy has set ambitious targets for rail freight, namely an increase of volumes carried by rail of 50% by 2030 and a doubling of volumes by 2050. For this to be achieved, it is essential that an international approach to capacity management is adopted. For this reason, in cooperation with ALLRAIL and FTE, ERFA has established a position on Commercial Conditions and an International Body for Compliance.

With the eagerly anticipated publication of the European Commission's proposal for a revision of the TEN-T Guidelines in December 2021, a pivotal discussion has begun on infrastructure development which will have a direct influence on rail freight's ability to meet its 2030 and 2050 growth targets. ERFA supports many of the provisions within the Commission proposal, but the text remains unfinished and further clarification and elaboration is needed in key areas. Crucially, it is essential that Rail freight can operate efficiently over the next 8-10 years in order to reach the 2030 growth targets.

Various industry associations raise serious concern regarding the amount, gravity and length of disturbances we are facing since the last two weeks on the German rail network. These disturbances, joined with a lack of alternative capacity being made available, has led to a situation where rail freight in and travelling through Germany on main corridors is coming to a near standstill.