20.1. 2022: BACK ON TRACK SUBMISSION ON EUROPEAN COMMISSION ACTION PLAN
1) INTRODUCTION
The plan correctly identifies issues and points in a positive direction but it is not ambitious enough. For example, 11 new international night train routes to carry 2.5 million passengers per year are not enough when the French government is proposing 15 new routes just in France to carry at least 5 million.
A more ambitious study by the independent network ‘Oui au train de nuit’ has shown that night trains throughout Europe could transport 100 million passengers a year along 350 routes.
2) CHARGES AND TAXES
We welcome the suggestion for both harmonised and lower track access charges and EU-wide VAT exemption for cross-border travel. We understand that such exemption already applies to exports and imports between Member States.
We are also disappointed that the document does not give a very clear figure of what could be a fair access charge and which should not exceed the marginal costs.
3) REMOVING OBSTACLES
There must be a clear timetable for removing such obstacles and improving infrastructure, ticketing and information systems so that more ambitious day and night services can be introduced. In this context we are concerned that some companies and some governments are reluctant to share data or answer questions. Political pressure must be used if necessary to require them to do so.
Of course, political pressure is easier to exercise when the railway operators are publicly owned. On the other hand, franchisees and open access operators can bring innovation to the benefit of all users. Consideration must be given to the conditions under which new operators enter the market.
4) INFORMATION AND RIGHTS
Better information is even more important now that open access operators are starting to provide international services. The European Commission should encourage innovative solutions to make booking journeys which include night trains as easy as any other journey by train or plane.
Passenger rights concerning information, booking and compensation if something goes wrong, must also be observed – and the most basic passenger right of all is to have a train service that fulfills the customer’s needs.
5) REPLACING AIR BY RAIL
Corridors where flights can be replaced by trains must be identified and ambitions set. We propose that the European Commission list the 500 most used intra-EU routes of up to 2000 km and estimate how and when they can be replaced by trains. The European Investment Bank should finance construction of a pool of rolling stock for both day and night trains on such routes.
6) LENGTH OF JOURNEY
On some routes a night train journey time of 8-10 hours should encourage modal shift, but on others 12 hours will be more acceptable (to avoid very late departures or very early arrivals). On longer routes, such as Denmark to Switzerland, 15 hours is acceptable. Night trains should use high-speed lines in appropriate cases.
7) ARRIVAL TIMES
It should be a priority to develop TEN-T corridors into major stations at the times in the morning convenient for travellers.
The Commission highlights “Pilot Projects” on page 17 in this context. It should be clarified that TEN-T corridors for long-distance night trains must be developed as a whole, so that these can enter major cities at the right times in the morning; that capacity must always be present and that these trains must have higher priority than local, regional and national trains at the same places and times.
8) STAFF, CONTROLS AND LANGUAGE
The question of border controls on night trains must be addressed. Night sleep should not be disturbed by any border control. In aviation, large parts of passport controls are left to airport staff. Night train staff can deal with this and should receive relevant training in addition to the training required for all on-board staff. The outdated language requirements also need to be addressed.
9) TOURISM AND REGIONS
The European Commission should support the night train concept through co-funding to promote eco-friendly tourism and accessibility to authorities in popular tourist areas. International visitors to an area like northern Italy should appreciate being able to sleep on a night train and thus have more daytime to enjoy their holiday.
10) MONITORING MODAL SHIFT
There must be measurable ambitions for modal shift, such as a matrix showing percentage shares of traffic, by both day and night trains, over particular distances at 5-yearly intervals.
At present it is not clear what political targets for modal shift are presented and nor are any tools presented to evaluate ongoing development. The overall efforts to increase rail’s share of EU passenger transport must be juxtaposed by an overview of this type.