Study to analyse the ecological and overall social balance of night train services by rail in an intermodal and intramodal comparison

Our Full Comment:

The study contains many valuable suggestions for the German Ministry for Digital Affairs and Transport, which Back-on-Track Germany as part of a European network of night train initiatives would like to emphasise:

• Accelerate the replacement of the RIC standard by TSI to ensure the necessary resources and competences at ERA (or elsewhere),
• also by reversing the burden of proof with regard to the necessity of special national standards.
• These are also the prerequisites for supporting the proposed procurement of wagon material in the next step, in particular by reducing the interest burden, for example through guarantees, possibly combined with a state-owned RoSCo as a rescue company.
• We reiterate our call for the lifting of the ban on tunnel encounters in Germany and
• for the creation of HGV train paths for night trains in coordination with the SGV
• and the inclusion of night trains in regular-interval services.

However, we cannot understand some of the study’s conclusions:

• The assessment that the track access charges have a low activation effect is, in our view, due to the selected sample route, which distorts the picture. If you don’t travel 900 km to low-cost Switzerland but 1500 km from Berlin to Rome, the same calculation leads to values in the order of 14% as in the study by Nelldal (2021) or our joint study with Transport & Environment. If you then add an express surcharge in Germany and calculate the costs with the 1/3 cheaper Italian wagon material, train path and station charges are already the largest cost component. Although the study points out the market potential of longer routes (as we did when we presented our 2022 study), it fails to recognise track access charges as the main obstacle, partly because an analysis for Germany is not sufficient. It is not about individual rates, but about a fundamental decision to include night train services as a mandatory market segment to be recognised in track access charge systems, which we would strongly recommend to the EU Commission and the BMDV. This would automatically lead to a Europe-wide reduction to marginal costs. According to our calculations (from 2024), this measure would cost DB InfraGo €9 million p.a. – with the current night tariff it would be €12 million – provided that not a single night train was added.
• It is unclear to us why the unequal treatment of VAT should not be eliminated from a regulatory perspective. The reference to the EU is not convincing here, as the equal treatment of flights and trains is the norm rather than the exception throughout Europe.
• We would not recommend the new generation of Nightjets or the Intercity Notte carriages as starting points, as these developments point in the wrong direction in terms of space utilisation. There are now more innovative concepts that offer more comfort with less space requirements or day/night utilisation or both.

The study still appears to have some weaknesses in the calculation of potential (without, however, jeopardising the positive tenor of the study, on the contrary). In our view, the study

1. sets the maximum distances for potential night trains too low and
2. sets the costs of the rolling stock too high,
3. underestimates the price competition with air travel and
4. the impact on the climate.

In terms of distances, the study incomprehensibly assumes an average speed of 71 km/h instead of the usual 90 km/h in Germany. As a result, the assumed distance potential of 1000 (1500 km on HG routes) remains below what is currently already being travelled (e.g. Stockholm-Narvik, Prague-Split). In addition, there is the limitation to a maximum journey time of 14 hours, although the text also describes a time frame of 16 hours if necessary. In our view, it is not necessary to set a maximum journey time tolerance as a distance limit, as in the route concepts presented only a small proportion of passengers often travel from end point to end point. In fact, the journey times are imitated by the time required for buffering and cleaning to around 18 hours, which is why the overnight train Prague-Split was cancelled. With a broader framework covering distances of up to 2,700 km, it would be possible to identify more than 79 routes and possibly reach different conclusions regarding train path prices.

The calculation of the costs of the rolling stock is already incomprehensible with the given cost and interest rates. With an acquisition cost of €25.05 million and 6.5% interest, even taking into account a 15% reserve with straight-line amortisation and annual interest calculation, the annuities amount to around €2.23 million and not €2.93 million. The average purchase price of just under €3 million per wagon is also at the upper end of the known market prices for the standard wagons described. Furthermore, the assumed interest rate of 6.5 per cent is not substantiated. (source presented: WACC) This corresponds to the leasing costs for cars, are these more relevant than property interest rates, which are currently between 3 and 4%? We would be interested to know whether the risk assessment was based on rolling stock with Europe-wide approval, which the study claims to have assumed, and whether the EIB interest rates were taken into account. This is relevant, as with such interest rates and 30-year financing, the financing costs make up by far the largest proportion of the cost of the rolling stock and therefore deserve more attention. If, as calculated, 3.5% more interest makes the product 15% more expensive, the reverse is also true. At 54 euros / seat, the study is at the upper end of the spectrum of previous studies on the production costs of night trains, primarily because of this account approach.

At various points, the study claims that night trains are already competitive with air travel. However, the study uses a single external source from spring 2023 and its own surveys from the same year, which only take into account direct flights. It is unclear whether the secondary airports popular with Ryanair (e.g. Charleroi for Vienna-Brussels) were also taken into account. The price ranges are not representative, as the source given for the year 2024 shows. The average prices, adjusted for inflation, are now back at the pre-corona level.

The climate impact is essentially underestimated due to outdated data: Radiative forcing is set at a factor of 2.1 for international flights in the study. Here, Rambøll decided against the more recent findings of Lee et al. and in favor of the “more conservative” factor of 2.1, which the Federal Environment Agency still recommended for international flights in 2020, which was recently corrected to 4.3 in line with the findings by Lee et al. With an EWF approach according to current findings, Rambøll would arrive at flight emissions of 388 gCO2/pkm instead of 197.51 CO2e/pkm based on fuel consumption in 2019.

Radiative forcing is assumed to have a factor of 2.09 in the study. However, the state of research since 2021 is an average of 3.0 when using GWP* accounting, the study ewas mentioned. According to this, the emission savings in air traffic would be 0.638 and in the upper estimate 3.2 million tonnes of CO2, the total balance would be 0.608 and in the upper estimate 3.234 million tonnes less CO2e.

Further details:

• Comfort appears to have been evaluated linearly with space requirements. This would not be expedient, as comfort can also be increased without reducing the space density, which is also necessary in order to increase economic efficiency.
• The emissions specific to the means of transport were extrapolated on the basis of an estimated additional empty weight of 11 tonnes. However, a couchette wagon only has an additional empty weight of 1 tonne (https://www.deutsche-reisezugwagen.de/wagendaten/248-bvcmz/) and, given the lower passenger numbers on night trains, the total weight would have to be taken into account anyway. We would assume that the effects would balance each other out, at least in the configuration outlined, so the values would have to be corrected to 588 t CO2e in the lower estimate and 3744 t CO2e in the upper estimate.

In addition to these points of criticism, it should be emphasised that the study evaluates some current proposals and debates on how sustainable night trains are and how they can become more economical, among other things:

• A quantification of the difference in energy and infrastructure costs when using high-speed trains and night trains on high-speed lines,
• We welcome the proposal to agree on two loading gauge standards across Europe,
• A falsification of the doubts about the sustainability of the railway system raised by the study ‘Holistic ecological balancing of transport systems’,
• A comprehensive overview of transport capacities per operator as at 08/2023,
• An assessment of future developments in energy and fuel production,
• A (negative) assessment of the economic viability of complete on-board restaurant cars, unfortunately without the alternative of the still more discussed on-board bistro variant,
• Factors for the additional costs of X and Y routing,
• Factors for labour cost savings through automation,
• A review of routes opening within the next 10 years, both for possible substitution of night trains with faster daytime services and for the potential of extended night train services,
• An assessment of yield pricing as a measure to optimise capacity,
• The study evaluates current PSO practice and proposes to consider one-off start-up subsidies, the financing or provision of wagons (including maintenance), TAC reductions and – as new measures – energy cost subsidies and the assumption of the risk of infrastructure deficits as alternatives to PSO.

Overall, we welcome the study as a valuable contribution to an up-to-date assessment of the potential of night train services. It would be welcome if the Ministry, as the client, were to authorise the publication of the data on which this study is based, if necessary removing proprietary sources.

This would increase the usefulness of the study for current and potential night train operators and facilitate further research on the topic.