The European rail rolling stock lessors highlight the weaknesses of the draft CCS TSI 2022 revision and urge the EU to amend its draft to avoid compromising competition in the rail freight market, threats to improved safety and accelerated obsolescence of existing modern rolling stock. The situation is critical for equipment that is 15 years old and has another 15 years of life ahead of it. Before setting a deadline for the implementation of a new ETCS BL, key issues should be solved related to transparency, ERTMS retrofit prices, EU budget to subsidize retrofits and upgrades, EU funding framework conditions, stability of technology and industry capacity.

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