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Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.

Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.

ANE
2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
SNC
SNCF

Company · France

19
files engaged
of 583 tracked
19
positions filed
in those 583 files
6
declared FTE
self-declared
3
EP accreditations
as declared to the register

Declared costs: €800K+ a year · in the register since 2009

Files both filed on (2)

Combined transport: support framework for intermodal transport of goods; calculation of external costs savings and generation of aggregated data · Single European railway area: use of railway infrastructure capacity

Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.

What each said, in their own words

Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.

Combined transport: support framework for intermodal transport of goods; calculation of external costs savings and generation of aggregated data

SNCF · filed 16 Sept 2021 · source

SNCF welcomes the publication of the inception impact assessment regarding the revision of the Combined Transport directive. Combined transport is one of the main drivers for achieving the ambitious growth targets for rail freight. In the context of the forthcoming revision of the Combined Transport Directive, the potential of intermodal solutions must be exploited.

Asociación de Empresas Ferroviarias Privadas · filed 30 Jan 2024 · source

Updating the intermodal transport support framework is essential. The proposal aims to provide a coherent intermodal transport support framework as, so far and according to the REFIT evaluation, this framework has had an insufficient impact. The proposal includes three provisions to promote intermodal transport in general: All intermodal transport is exempt from authorisations and quotas.

Filed in Spanish · English published by the European Commission

Single European railway area: use of railway infrastructure capacity

Asociación de Empresas Ferroviarias Privadas · filed 5 Apr 2022 · source

The Association of Private Railway Undertakings wishes to point out to the Commission the importance of international traffic in a country such as Spain which is at one end of the European continent and is highly dependent in its external trade on trade with the rest of Europe.

Filed in Spanish · English published by the European Commission

SNCF · filed 5 Apr 2022 · source

SNCF welcomes the call of evidence which initiates the discussion on updating the current framework as for international capacity and traffic management. Need to have a network approach A network approach should be implemented (unlike the current corridor approach), providing RUs with a single point of contact (C-OSS).

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