This a first assessment of the European Commission’s proposal for revision of the Union guidelines for the development of the trans-European transport network (TEN-T Regulation (EU) No 1315/2013) which was published on 14 December 2021. It analyses the current proposal against the original TEN-T Regulation and EDF’s 2021 Position Paper on TEN-T.
The European Commission’s proposal provides a solid basis for improving the legal framework to advance accessibility of intermodal transport for persons with disabilities. However, to be effective and practical, TEN-T should add more concrete requirements for development and funding of TEN-T projects.
The following elements of the proposal are good and should be maintained in the final text:
- Horizontal requirement on accessibility for all users, including for persons with disabilities and reduced mobility (Article 49).
- New intermediate deadline of 2040 for the development of the TEN-T network.
- Consideration of increasing the benefits for transport users, including persons with disabilities and reduced mobility as one of the objectives of TEN-T (Article 4).
- Compliance of the TEN-T Regulation with relevant Union and national laws, including in relation to state aid, public procurement, and accessibility, and EU non-discrimination law (Article 8).
- Giving priority to measures that contribute to, among other aims, improving accessibility for all users, including persons with disabilities or reduced mobility (Art. 12).
- Additional accessibility and disability-related requirements for rail and road transport infrastructure (Articles 19 and 31).
- Accessibility and disability-related requirement for the development and implementation (including monitoring) of sustainable urban mobility plans (Article 40 and Annex V).
- Requirements to improve accessibility through new technologies, including by multimodal digital mobility services and improved access to travel information (Article 44).
- Possibility to set up European working groups on interoperability, cross-boarder passenger rail services, urban nodes, cooperation with third countries or other topics as needed (Article 52).
However, to be effective the text of the proposal must be strengthened and clarified further. Some shortcomings of the current text include:
- Lack of quantitative or qualitative indicators, targets and timelines for improving accessibility of the TEN-T network.
- Lack of clear references to relevant EU accessibility law such as the Rail Accessibility Regulation (TSI-PRM) or the European Accessibility Act, and the UN CRPD.
- Lack of accessibility and disability-related requirements when setting additional priorities for inland waterway (Art. 23), maritime (Art. 27), air transport (Art. 34), multimodal transport (Art. 38) infrastructure, or for urban nodes (Art. 41).
- Lack of accessibility and interoperability requirements for vehicles, vessels, aircrafts, and rolling stocks which use the TEN-T infrastructure.
- Lack of earmarked funding or prioritization of projects to improve accessibility of the TEN-T network, as well as lack of transparency how TEN-T development funds are used in relation to accessibility (improving or creating more barriers).
- Lack of requirements for publishing accessible data on accessibility of TEN-T projects.
- Lack of assurances for meaningful involvement of organizations with disabilities in setting priorities for the TEN-T network development and involvement in projects.
- Lack of accessibility requirements for development of infrastructure in third countries supported by EU that connects to the TEN-T network.
- Use of language inconsistent with the CRPD.
Read the full document through the below links:
- EDF analysis of EC proposal for TEN-T revision (Word)
- EDF analysis of EC proposal for TEN-T revision (PDF)
For further questions contact Mher Hakobyan, EDF Accessibility Officer (mher.hakobyan@edf-feph.org).