INTEROPERABILITY UNIT STUDIES: 1) MERGING OF HS AND CR TSIS AND 2) SPLITTING OF THE Reference: ERA/REP/13-2011/INT Document type: Report Annex 5 Version of Annex 3: Date of Annex 3: 1.0 31 January 2011 Edited by Checked by Approved by Name Gergana SIMEONOVA Olivier PIRON J-C. PICHANT Position INTEROPERABILITY Unit Junior Administrator INTEROPERABILITY Unit Head of Coordination Sector INTEROPERABILITY Head of Unit Date & Signature 31 Jan 2011 [signed] 31 Jan 2011 [signed] 31 Jan 2011 [signed] The following document has been produced by the European Railway Agency as a Final Report on the issues raised in section 2.2 of the Annex of the Commission Decision of 29.4.2010 concerning a mandate to the European Railway Agency to develop and review Technical Specifications for Interoperability with a view to extending their scope to the whole rail system in the European Union (Commission Decision C(2010)2576 final) concerning the carrying out of the complementary studies: 1) Complementary study on the pertinence of merging the HS and CR TSIs relating to Infrastructure, Energy and Locomotive and Passenger Rolling Stock in one single TSI for each subsystem. 2) Complementary study on the pertinence of including the requirements established in the transversal TSIs relating to Safety in Railway Tunnels, Persons with Reduced Mobility and Rolling Stock Noise directly in the TSIs related to the different subsystems. This document is intended to inform the European Commission on the analysis carried out. Where appropriate, on the basis of the results of these two complementary studies along with the results of the remaining three complementary studies listed in section 2.2 of the Commission Decision C(2010)2576 final, the mandate will be up-dated by the Commission in accordance with the procedure set out in Article 29(3) of Directive 2008/57/EC. Page 1 of 8
AMENDMENT RECORD Version Date Section number Modification/description Author 0.1 22 Nov 2010 All Creation of first draft GS 1.0 31 Jan 2011 Section 1 Section 2 Up-date of the scope of the annex to include the comments received since 22 Nov 2010 Inclusion of all comments received by 31 Jan 2011 GS Page 2 of 8
TABLE OF CONTENTS 1. SCOPE OF THE ANNEX...4 2. RECEIVED COMMENTS...5 CER (Representative Organisation)... 5 Danish Transport Authority... 6 National Transport Authority (National Safety Authority, Hungary)... 8 Sweden (Member State)... 8 Page 3 of 8
1. SCOPE OF THE ANNEX As specified in Section 5.3 of the report, following the submission of the report to the European Commission, the report was presented to the organisations consulted by the questionnaire, i.e. NSAs, NoBos and Representative Organisations, for their feedback. Additionally, the report was presented at the Railway Interoperability and Safety Committee (RISC) on 14-15 December 2010 in view of collecting the opinion of the Member States. This annex contains the comments by the consulted organisations and by the Member States received by 31 January 2011. Page 4 of 8
2. RECEIVED COMMENTS CER (Representative Organisation) The comments by CER were received on 20 November 2010 and have been incorporated in the report, version 0.5, as appropriate. The full text of the comments is included below: 1. Summary of the analysis of relevant TSIs: INF TSI: Some parameters may be necessary only for HS (e.g. flying ballast: this phenomenon does not occur < 190 km/h) ENE TSI: the modification of annex II of Directive 2008/57/EC as voted in the RISC of October 2010 (inclusion of the fixed part of the energy billing system) shall be taken into account RST TSI: It shall be clarified where the wagons used by the IM for infrastructure maintenance or construction are going to be addressed. In the WAG TSI or in the RST TSI as OTM? PRM TSI: the statement In the long term, it will be pertinent to include the requirements established in the PRM TSI directly in the TSIs related to the subsystems and to remove the accessibility to stations requirements when they are covered by another European legislation relative to accessibility to the built environment cannot be supported; the general EU legislation will never address the problem of the gap between railway vehicles and platforms. On the other hand it is not possible to agree with the attitude taken towards the continued existence of the non-railway specific requirements that are effectively additional to stations, compared with other public built environments, not only requiring specific features that are not particular to railway stations, but requiring NoBo assessment, all of which causes railway uncompetitiveness, compared with the other modes, precisely the opposite of the objective of the Interoperability Directive. 2. Couple of detail comments: Sections 6.3.2 / 6.3.4 should highlight that the clarifications that it will seek to introduce in the case of the RST TSIs, is when merged, which requirements only apply to trains which run at Page 5 of 8
high speed, as opposed to which requirements apply to those trains which can/will run on high speed lines, but not at high speed. Section 6.5.1. does the noise TSI not also cover plant when in transit, or is this a locomotive in the circumstance? A comment to clarify this is needed. Finally, allow me to remind you of the view of the sector on the priorities, as presented at the NRB meeting on 12/10: Closing of Open Points Extension of scope for structural TSIs (i.e. Rolling Stock, Infra + Energy) Elimination of inconsistencies of TSIs (HS+CR of the same subsystem, and between different subsystems) TSI Merging/splitting is not on the top. Danish Transport Authority The comments by Denmark were received on 24 November 2010 and confirmed once again on 21 January 2011. The full text of the comments is included below: Received on 21 January 2011, MS position: We refer to our comments forwarded to the Agency on 24 November 2010 (see below), and, once again, we underline - our support to the work reg. the merging of CR and HS TSIs - the expediency of splitting transversal TSIs in order to ensure - that TSIs are developed around well-defined sub-systems - effective implementation and ownership of the TSIs in question Received on 24 November 2010, NSA position: General remarks We prefer that TSIs are developed around 'clear-cut' subsystems since it reduces the vast number of TSI references to other TSIs. Such reduction in the number of references will, arguably, make it easier to 'navigate' in the TSIs, thereby Page 6 of 8
facilitating the tasks of the applicant, the NSA and the NoBo. Moreover, developing TSIs around 'clear-cut' subsystems is more in line with the subsystem division of Directive 2008/57. Merging HS and CR TSIs Since HS and CR TSIs deal with the same subsystems and, moreover, have a considerable number of requirements in common, merging HS and CR TSIs make sense. Furthermore, the performance of a large number of today's rolling stock is on the boundary between HS and CR, e.g. regarding speed (approx. 200 km/h). Splitting 'transversal' TSIs: We agree that splitting 'transversal' TSIs is less obvious than merging HS and CR TSIs. However, we think that there are convincing arguments in favour of dividing TSIs according to subsystems. The EC verification process for rolling stock, for instance, will become leaner if relevant PRM, SRT and NOI TSI requirements are placed in the future merged LOC&PAS TSI. SRT TSI We agree that the approach to formulating requirements is different (very risk oriented, that is). Hence, its requirements can be considered a whole. Yet, the requirements in question are traffic and infrastructure-related, i.e. requirements reg. the tunnel itself, rescue options, etc. Therefore, including SRT TSI requirements reg. vehicles in the future merged LOC&PAS TSI seems uncomplicated. PRM TSI We think that it is worth considering the so-called 'universal solution' approach where standard solutions are developed in a way so that all PRM needs are taken into consideration. In other words, all PRM needs are considered when developing all TSIs. Applying the 'universal solution' approach will, in our opinion, render a single PRM TSI superfluous. Page 7 of 8
National Transport Authority (National Safety Authority, Hungary) The comments by the Hungarian NSA, stating their agreement with the content of the report, were received on 19 January 2011. The full text of the comments is included below: [ ] referring to your e-mail on the studies on merging HS and CR TSIs and splitting 'transversal' TSIs I would like to inform you that we agree with their content without further comments. Sweden (Member State) The comments by Sweden were received on 18 January 2011. The full text of the comments is included below: Item 15: Merging and splitting of TSIs The Swedish opinion is that the merging of the high speed and conventional TSIs for the respective subsystems shall be done as soon as possible. We are pleased with the work started up by ERA on the merging of TSIs. However in our opinion also the transversal TSIs should be split and the requirements should be set for the respective subsystem in the corresponding TSIs. There should be one TSI for each subsystem, and all the relevant requirements should be set in one document for the applicant of authorisation of a specific subsystem. Page 8 of 8