1. Impact Assessment of the revision of Regulation 445/2011
1st meeting of the WP for the
revision of Regulation 445/2011
23 May 2017, Valenciennes

2. Impact Assessment Revision of Regulation 445/2011
Adopted Impact Assessment (IA) Methodology
IMS procedure on IA (Annex 1 of MB Decision) - respects EC guidelines and ensures the application of the proportionality principle
IA template (Annex 2 of MB Decision) - respects the EC guidelines and includes guidance for filling in each of the sections

3. Impact Assessment Revision of Regulation 445/2011
Recommendation on the revision of Regulation 445/2011 will be accompanied by an IA to inform decision-makers about options and consequences
Full IA implying that impacts will as far as possible be quantified in monetary terms
To support the IA work data will be collected at different stages

4. Impact Assessment Revision of Regulation 445/2011
IA problem statement: sections
Problem and problem drivers
Main assumptions
Stakeholders affected
Evidence and magnitude of the problem
Baseline scenario
Subsidiarity and proportionality

5. Impact Assessment Revision of Regulation 445/2011
Problem definition
Problem
Absence of a harmonised certification system for ECMs, maintenance providers and maintenance workshops dealing with locomotives and coaches (identical to Regulation 445/2011 for freight wagons)
Main consequences
Difficulties for RUs trying to:
- Select an ECM which provides external maintenance services and corresponds to their exact needs
- Ensure that the maintenance externally provided to locomotives and coaches is adequate (risks are controlled and operations are safe)
Difficulties for ECMs and maintenance workshops having to deal with different requests for specific customer certifications

6. Impact Assessment Revision of Regulation 445/2011
Discussion at the 1st Working Party
Understanding the problems experienced by stakeholders
Consideration of current situation regarding:
Outsourcing of maintenance for RUs
Cost of certification for maintenance providers and ECMs

7. Impact Assessment Revision of Regulation 445/2011
Next steps for Impact Assessment
An additional stage for data collection may be necessary (detailed questions to selected members of the WP)
Determine problem statement, objectives and options
Mid-July
Assessment of impacts and comparison of options
Mid-October (next WP meeting: October)
First draft of the report
End of October
Final draft version of the report for consultation of the WP
15 December

8. Impact Assessment Revision of Regulation 445/2011
List of questions
Q1: What are the problems to be addressed by the revision of Regulation 445/2011, with reference to the current scope of the ECM scheme (freight wagons)?
Q2: What are underlying causes of those problems?
Q3: How important are these problems? (indications on the order of magnitude about the costs incurred by the problems)

9. Impact Assessment Revision of Regulation 445/2011
Q4: Regarding the issue of scope extension to other vehicles than freight wagons could you outline:
The main problems due to the absence of a harmonised certification scheme for these vehicles currently encountered?
The main causes/drivers of those problems?
The importance of those problems (especially regarding costs incurred)?

10. Impact Assessment Revision of Regulation 445/2011
Q5: Could you provide information on the extent to which maintenance activities are outsourced in your country?
Q6: Could you provide information on the typical certification costs concerning the current ECM certification scheme in your country?
(“costs” could concern internal staff-related costs incurred in the preparation for certification + fees paid by an applicant to the certification body)

11. Impact Assessment Revision of Regulation 445/2011
Q7: Could you provide information on other costs concerning the current ECM scheme in your country, e.g. costs relating to surveillance assessments?
(“costs” could concern internal staff-related costs incurred + fees paid to external bodies performing surveillance assessments)
Q8: Do you have other relevant ideas and/or inputs for the work on the IA?