Rail Update: Major Renovations 2029 – Keep Deadlines for Feedback in Mind!

Deutsche Bahn is planning extensive major renovations on the high-performance corridors over the coming years. These long-term construction projects, including the major renovations, require consultation between DB InfraGO and the access rights holders. The basis for this process is DB InfraGO Guideline 402.0305, which sets strict deadlines for submitting feedback.

The Federal Network Agency (BNetzA) places great importance on these deadlines: In the legally binding agilis decision of February 7, 2025, it clarified that access rights holders lose their right to be heard (preclusion) if they miss the prescribed deadlines. The deadlines by which alternatives to the planned months-long full closures can be proposed end approximately three years before the start of the respective measure.

Therefore, it is crucial for all access rights holders to keep track of the dates of the major renovations affecting them and actively use the designated consultation periods to present their operational interests.

Consultations take place via the KOMBau portal, where the specific deadlines can be accessed. Currently, the deadlines for feedback related to measures planned for the target schedule year 2029 are becoming relevant.

Content Requirements for Feedback

According to Section 14 of Guideline 402.0305, access rights holders can particularly address the following points:

1. Timing – e.g., specific calendar days on which closures should be avoided (such as during major events)
2. Affected route sections – e.g., notes on why certain stations or connecting services must remain accessible
3. Type of closure – single-track closure or full closure
4. Alternative concepts – e.g., alternative service offers or diversion routes
5. Further considerations – any additional aspects relevant to one's own operations

Practical Tip: KOMBau Is a Management Issue

The relevant deadlines and notices from KOMBau should not only be monitored by operational departments but also anchored at the management level. This ensures that they are integrated into all planning and decision-making processes within the company.

Summary of Recommendations

1. Regularly check the latest information and deadlines in the KOMBau portal
2. Observe feedback deadlines strictly
3. Prepare responses in a timely and structured manner

Meeting the tight consultation deadlines and drafting focused feedback is a challenge for many access rights holders. Our Rail team is happy to assist you in effectively and promptly presenting your operational concerns.

The author, as well as your usual contacts in the Rail team, are happy to assist you with any questions!

Gisela Hebrant, LL.M.
hebrant@tigges.legal
+49 211 8687 185