Cableways Impact Assessment Study - Final Report - saferail.nl
Cableways Impact Assessment Study - Final Report - saferail.nl Cableways Impact Assessment Study - Final Report - saferail.nl
IA Study Concerning the Revision of the Cableways Directive also be used for occasional transport of passengers. There are approximately 100 such installations in Austria and it has been argued that the exemption for industrial installations in Article 1.6 of the Cableways Directive is not sufficiently clear in this respect. However, as this issue is not directly relevant to Policy Options A2 and A3, it is not considered further in this report. A cableway manufacturer noted that they were aware of two or three mixed purpose installations (in addition to the Wieli System) but these are located outside of the EU. The UK competent authority further stated that they experienced one case where it was not easy to determine whether an installation served a transport or a leisure function. This related to a rail mounted installation intended for transporting visitors between a car park and an adjacent amusement park. Other stakeholders (including competent authorities, operators and cableway and subsystem manufacturers) have not identified any such systems or problems with such installations. Summary of Stakeholder Views Based on the responses received to consultation, many stakeholders (with the exception of manufacturers of dry toboggan runs and Alpine coasters that might be opposed to policy action in general; please also note that the views of cableway operators are also dealt with separately further in this section) would prefer for changes to be enacted through Option A3 rather than Option A2. The majority of competent authorities, notified bodies and manufacturers, from whom responses to consultation were received, express a preference for Option A3. Option A3 is preferred as it is considered that this Option will ensure that there are no ‘grey areas’ and will ensure that adoption is conducted in a universal and binding manner across all EU Member States, avoiding any potential for confusion. Of the 18 competent authorities who responded, 12 would prefer changes to be enacted through Option A3, three would prefer Option A2, and the remaining three do not believe any change is necessary. Of the three notified bodies who responded to consultation, three supported Option A3 and one did not support any change. Two of the five manufacturers of cableways and manufacturers of subsystems and safety components, who responded to consultation, support Option A3, two do not believe any change is required (but if it were implemented, one would prefer Option A2) and one supports Option A2. Please note that despite expressing preference for Option A3, most respondents have not provided any information on past problems or installations that would be newly included into the scope of the Directive. In addition, the operator associations from France, Germany, Austria and Switzerland indicated that they do not support an extension of the Cableways Directive by means of adopting Recital 1 into the legal text of the Directive. The Finnish operators association stated that they were in favour of legislative change but the Slovenian association did not see any need to change the current provisions. Please note that the above views of operators’ associations only relate to one of the two elements of Page 88
Risk & Policy Analysts Option A3 (Recital 1 vs. clarification on mixed purpose installations) and as such they are dealt with separately in this paragraph. The Czech cableway operators’ association, on the other hand, stated that they support the inclusion of installations such as dry toboggan runs into the scope of the Directive as the current situation is confusing for operators. Dry toboggan runs tend to be managed by the same companies that operate ski lifts and these companies would welcome clarity and a unified approach for all installations managed by them. Consultation with manufacturers of dry toboggan runs and Alpine Coasters suggests that these companies may in general not be in favour of inclusion of their products into the scope of the Cableways Directive. Some of the potential problems that may arise from the inclusion of these installations into the scope of the Cableways Directive, raised in a consultation response from Josef Wiegand GmbH & Co. KG, can be summarised as follows: additional costs could have significant cost impacts on the manufacturer without corresponding improvement in passenger safety; should the whole installation be included into the scope of the Directive (as opposed to the uphill part only), this would have negative impacts on passenger safety as the Cableways Directive is said not to be suitable for the downhill part; and should only a part of the installation be included into the scope of the Cableways Directive, this would result in one installation being regulated by two different sets of (potentially contradictory) legal requirements. Josef Wiegand GmbH & Co. KG further proposed that should these installations be included into the scope of the Directive, it would be beneficial to amend Article 1(3) of Cableways Directive so that a fourth category of cableways is established, encompassing so-called ‘special cableway installations’. Modified technical solutions for these installations could then be established within the framework of the Directive. Impact on the Internal Market and Competition As no systems that would be included into the scope of the Directive have been identified, it is expected that the proposed options would have no impacts with regards to consumer choice, competition, barriers for new suppliers and service providers, anti-competitive behaviour or the emergence of monopolies and market segmentation. Impact on Competitiveness, Trade and Investment Flows Minimal impacts on the global competitive position of EU firms, trade barriers and investment flows are expected. Page 89
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Risk & Policy Analysts<br />
Option A3 (Recital 1 vs. clarification on mixed purpose installations) and as such they<br />
are dealt with separately in this paragraph. The Czech cableway operators’<br />
association, on the other hand, stated that they support the inclusion of installations<br />
such as dry toboggan runs into the scope of the Directive as the current situation is<br />
confusing for operators. Dry toboggan runs tend to be managed by the same<br />
companies that operate ski lifts and these companies would welcome clarity and a<br />
unified approach for all installations managed by them.<br />
Consultation with manufacturers of dry toboggan runs and Alpine Coasters suggests<br />
that these companies may in general not be in favour of inclusion of their products<br />
into the scope of the <strong>Cableways</strong> Directive. Some of the potential problems that may<br />
arise from the inclusion of these installations into the scope of the <strong>Cableways</strong><br />
Directive, raised in a consultation response from Josef Wiegand GmbH & Co. KG,<br />
can be summarised as follows:<br />
<br />
<br />
<br />
additional costs could have significant cost impacts on the manufacturer without<br />
corresponding improvement in passenger safety;<br />
should the whole installation be included into the scope of the Directive (as<br />
opposed to the uphill part o<strong>nl</strong>y), this would have negative impacts on passenger<br />
safety as the <strong>Cableways</strong> Directive is said not to be suitable for the downhill part;<br />
and<br />
should o<strong>nl</strong>y a part of the installation be included into the scope of the <strong>Cableways</strong><br />
Directive, this would result in one installation being regulated by two different<br />
sets of (potentially contradictory) legal requirements.<br />
Josef Wiegand GmbH & Co. KG further proposed that should these installations be<br />
included into the scope of the Directive, it would be beneficial to amend Article 1(3)<br />
of <strong>Cableways</strong> Directive so that a fourth category of cableways is established,<br />
encompassing so-called ‘special cableway installations’. Modified technical solutions<br />
for these installations could then be established within the framework of the Directive.<br />
<strong>Impact</strong> on the Internal Market and Competition<br />
As no systems that would be included into the scope of the Directive have been<br />
identified, it is expected that the proposed options would have no impacts with<br />
regards to consumer choice, competition, barriers for new suppliers and service<br />
providers, anti-competitive behaviour or the emergence of monopolies and market<br />
segmentation.<br />
<strong>Impact</strong> on Competitiveness, Trade and Investment Flows<br />
Minimal impacts on the global competitive position of EU firms, trade barriers and<br />
investment flows are expected.<br />
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