Cableways Impact Assessment Study - Final Report - saferail.nl

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IA Study Concerning the Revision of the Cableways Directive Operating Costs and Conduct of Business/SMEs No companies that would be impacted have been identified and as such no costs would arise. Administrative Burdens on Businesses It is not considered that Options A2 and A3 would affect the existing administrative burden on businesses. Public Authorities One-off costs Should Option A3 be implemented, EU Member States would incur costs arising from the need to transpose the relevant changes into national legislation. In practice, the exact costs would depend on the specific changes agreed in the final version of the Directive and the regulatory model used in each country to implement the Directive (i.e. the number of departments involved in transposition or implementing the Directive). These costs are therefore likely to vary significantly between Member States (for example, Sweden is obliged to carry out an impact assessment on new EU legislation; it is expected that this may not be the case in some Member States). Specific data on the costs of transposition of EU legislation by Member States and their relevant departments/ministries are not readily available. As noted in RPA (2012) 32 , one UK impact assessment states that “the costs of amending current regulations to implement a Directive are thought to be around £700,000” (around €800,000). Although no details are given on the basis for this calculation, it is expected that these costs relate to a rather substantial legislative change and would include those costs of making (e.g. preparing an impact assessment, preparing a transposition note and presenting the legislation before parliament), printing and publishing the legislation. This estimate is significantly higher than the cost estimated in UK Department for Transport (2011) which notes that “a combination of legal and technical resources as well as policy advisors are usually required to implement such a change, costing approximately £15,687 per amendment” (approximately €18,000). Considering the relatively limited nature of many of the proposed changes to the Cableways Directive, it appears more likely that the costs of transposing these changes would be closer to the low-end estimate. Considering that the Cableways Directive needs to be aligned with the NLF, it can be expected that transposition costs arising from Option A3 alone would be significantly lower than this estimate. 32 RPA (2012): Ex-Post Evaluation and Impact Assessment Study on Enhancing the Implementation of the Internal Market Legislation Relating to Motor Vehicles, http://www.rpaltd.co.uk/documents/J746_MotorVehicleLegislation_FinalReport_publ.pdf Page 90
Risk & Policy Analysts The cost of changing the Application Guide attributable specifically to Option A2 is expected to be minimal as certain structures (regular meetings of the most relevant stakeholders such as those of the Standing Committee and of the Cableway Installations Sectoral Group of Notified Bodies) are already in place and these may provide the expertise needed to elaborate proposals to change the Application Guide. Recurring costs The Belgian competent authority noted that Option A3 would reduce recurring administrative costs due to avoidance of recurring queries. The German authorities expect increased administrative burden from Option A2 (associated with providing advice) but reduced administrative burden from Option A3. Innovation and Research No significant impacts are expected, although it is possible that Options A2 and A3 may have some impacts on companies currently developing products that could theoretically be newly brought into the scope of the Directive. Consumers and Households No impacts are expected. Specific Regions and Sectors No impacts are expected. Public Health and Safety Although three stakeholders pointed to potential improvements in passenger safety as a result of changes to the current framework; however, further information on specific problems with passenger safety has not been provided. As a more general comment, other stakeholders expect no safety improvements from the policy options assessed by this study. Conclusion There is no evidence that installations that would be affected by Option A2 or A3 are currently sold in the EU, perhaps with the exception of one case. 33 Therefore, these Options are unlikely to bring specific benefits at the present time. Benefits may arise 33 This assertion is based on the baseline scenario in this study treating the Wieli system manufactured by Josef Wiegand GmbH & Co. KG as already being within the scope of the Directive, following the recent Opinion of the Standing Committee for Cableways Directive 2000/9/EC on the Wieli system and other similar products (please note that this should not be construed as the consultants expressing an opinion on whether the Wieli system is now unambiguously included into the scope of the Directive). This assertion is also based on the assumption that the proposed options would focus on the standard rather than potential non-standard use of dry toboggan lifter systems, which tend not to (but could theoretically) be used to transport passengers between distinct points. Page 91
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