EIM welcomes the evaluation of the Council Directive 2008/114/EC on the identification and designation of European critical infrastructures and the assessment of the need to improve their protection, initiated by the European Commission. EIM acknowledges that the terrorists threats in Europe put the critical infrastructures under a considerable amount of danger. Therefore, it is necessary to identify them and to ensure their protection to avoid any catastrophic consequences.
EIM would like to stress that a one-size-fits-all approach is not always feasible. There are still large differences at national level when it comes to protection on critical infrastructures. It is important for the Commission to keep that in mind during the evaluation and take the Member States’ differences into account. EIM would also like to emphasise that the first responsible actor for security remains the Member States, with whom the IMs and other actors cooperate.
EIM supports the consideration of other efforts of strengthening EU instruments for security, such as the adoption of the NIS Directive, as stated in the evaluation roadmap However, in the context of -rail-European critical infrastructure, as referred to in Annex I, EIM emphasise the importance in the due consideration of existing rail specific security and protective measures at Member State level as well as other prospective current works of DG MOVE during the evaluation, most notably, policy initiatives in improving rail passenger security. In this regard, EIM recognizes the need of coherence with other security legislations to avoid duplication and overlaps, in this case, between the potential recast of the European Critical Infrastructure Protection Directive and the potential legislative initiatives in rail security. With this regard, it is essential to avoid investing in a lot of measures which could prove inefficient and could lead, on the one hand, to a loss of competition of the railway sector and, on the other hand, to shifting risk to other more vulnerable sectors. In addition, all the possible measures should be accompanied by a reflection on the funding method.
Finally, EIM supports the evidence-based approach in the evaluation. Rail infrastructure managers are fully committed to contribute to the prospective public consultation and to all following steps.
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