Cableways Impact Assessment Study - Final Report - saferail.nl

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IA Study Concerning the Revision of the Cableways Directive In addition to a reduction in the number of companies in the sector, large cableway manufacturers appear to have branched out into their upstream supply chains, although, this process was already under way before the Directive came into force (for example, as described in Section 2, Doppelmayr acquired cabin manufacturer CWA in 2002 and Poma acquired Semer in 1991). Box 3.1 describes the process as it occurred for Italian suppliers of electronic parts. Box 3.1: Case Study – Electronics Manufacture and Cableways Manufacturers Consultation suggests that in the 1980s there were three or four manufacturers of electronic/control equipment in Italy that supplied cableways manufacturers. The two main manufacturers (Ansaldo and EEI) held 85% of the market while a few smaller firms held smaller market shares (no more than 10%). At this time, Leitner and Doppelmayr did not produce any electronic equipment themselves. In 2000, large cableways manufacturers started producing their own parts or buying standardised components for their applications and they now own 80% of the total market of electronic equipment for cableways in Italy. The remainder of the market is shared between other firms. It has been suggested that the Cableways Directive played a role in this process as it has pushed for standardisation which is more favourable for the large manufacturers rather than the small ones. With reference to the electronic component sector, it was further noted that each installation has a group of products particular to it and because of the Directive; the products have to be the same as what was certified and it is difficult to modify systems. Any change to the product requires assessment by the notified body. Large cableway manufacturers produce subsystems to satisfy 90% of their needs, but they do not satisfy all of their needs, with more customised systems being produced by smaller companies. To a certain extent, this is similar to the position/view of a small manufacturer which produces highly customised cable driven installations which are not subject to the Directive and which suggested that their products complement the product portfolios of the large players and as such there is no competition between them and the large players. Source: Based on an interview with a company, 1st March 2012. Page 64
Risk & Policy Analysts 4. OPTIONS FOR REVISION OF THE CURRENT FRAMEWORK (IMPACT ASSESSMENT STEPS 1 AND 2) Under the Commission’s Impact Assessment Guidelines 16 , the initial two steps of the impact assessment involve defining the problem, the objectives of legislative or nonlegislative intervention and setting out the associated policy options. These steps relate to a number of problems identified in the Commission’s Report on the implementation of the Directive (EC, 2011) as well as the foreseen alignment of the Cableways Directive to the New Legislative Framework (NLF) are set out in this section of the report. The assessment in this section is based on EC (2011), information collected during the first round of consultation undertaken for this study as well as associated discussions with DG Enterprise. 4.1 Problems with the Current Directive 4.1.1 Defining the Specific Problems Definition of Cableway Installations As noted in Section 2, Article 1.2 of the Directive defines cableway installations as: “installations made up of several components that are designed, manufactured, assembled and put into service with the object of carrying persons. These on-site installations are used for the carriage of persons in vehicles or by towing devices, for which the suspension and/or traction is provided by cables positioned along the line of travel”. Article 1.3 of the Directive further specifies that: “the installations concerned are: a) funicular railways and other installations with vehicles mounted on wheels or other suspension devices for which traction is provided by one or more cables; b) cable cars where the cabins are lifted and/or displaced by one or more carrier cables; this category also includes gondolas and chairlifts; c) drag lifts, where users with appropriate equipment are dragged by means of a cable.” Bearing in mind that the above definition was drawn up over a decade ago, it is worth considering whether it is still suited to current market developments. A broader and more general definition of cableway installations is actually provided in Recital 1 of the Directive. This definition explicitly recognises the potential for existing or future 16 European Commission (2009): Impact Assessment Guidelines, dated 15 January 2009 SEC(2009) 92 Page 65
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Ref. Ares(2012)1245393 - 22/10/2012
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