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EUROPEAN RAILWAY AGENCY

REPORT ON RAILWAY VEHICLE AUTHORISATION

PART 1 – THE CURRENT SITUATION

Reference: ERA/REP/2011- 01/XAC Document type: Final Report

Version : 1.9.5

Date : 14th April 2011

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Foreword

The Agency has a role to help facilitate the procedure for authorising the placing in service1 of vehicles and the harmonisation of the National Safety Authorities decision making processes for authorisation. This is particularly important in the transition phase until all the Technical Specifications for Interoperability (TSIs) are complete and all networks and vehicles conform to the TSIs. In this context this report is part of a suite of initiatives intended to facilitate vehicle authorisation. These initiatives include:

defining and maintaining the list of parameters to be checked for vehicle authorisation

compiling and maintaining the Reference Document that:

o lists the national rules for each parameter;

o describes the national legal framework covering the authorisation procedure, and

o records the equivalence of the various national rules for each parameter.

The Agency, under the auspices of its Cross Acceptance Working Party, set about understanding and documenting the different existing national authorisation procedures, their commonalities and differences. The analysis also identified technical subject areas of authorisation that generated the most cost, time delay and uncertainty.

It soon became clear that as well as determining the “status quo” of authorisation procedures used today, it was essential to have a common understanding of the new procedure contained within the recast Interoperability Directive. This led to the initiative with the European Commission to document a common understanding in the form of a Commission Recommendation (known as DV29 [2]). This part of the Agency report (Part 1) is one of three documents foreseen to cover the authorisation procedure:

The Agency Report on Vehicle Authorisation Part 1 – describing the current situation;

The Commission Recommendation DV29 [2] – the common understanding of the new procedures;

The Agency Report on Vehicle authorisation Part 2- describing the way forward for the future.

This study on vehicle authorisation was carried out by the Agency between April 2009 and October 2010 using the following inputs:

Questionnaires on the vehicle authorisation procedures sent to Member States/National Safety Authorities;

Questionnaires on cost driver parameters sent to the railway sector (manufacturers and railway undertakings);

Bilateral meetings with each of the National Safety Authorities and sector actors from that country to review their procedure;

Meetings with Member States representetives and sector actors to discuss particular examples (buisness cases);

A review of the obstacles to authorisation carried out within the Cross Accceptance Working Party;

Workshops with the sector;

1 “Authorisation for placing in service” will hereinafter be referred to as “authorisation”.

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Questionnaires per vehicle category sent to some manufacturers.

Many of the complexities derive from the mixing of two sets of procedures, roles, responsibilities and rules. One set is inherited from the “homologation” procedures, used to manage a vertically integrated monopoly railway. The other set are the new roles, rules and authorisation procedures put in place by the Interoperability, Safety and Access Directives to manage a “shared” railway system.

This “mixed” approach partially derives from the fact that the legal framework prior to the recast Interoperability Directive applied the Safety and Access Directives to the whole railway system. In contrast, the scope of the original high speed and conventional Interoperability Directives (and therefore the authorisation procedure) was confined to Trans European Networks (TEN). Implementation of the recast Interoperability Directive brings the scope of all three Directives into line. This gives an opportunity for significant simplification and “cleaning up” of rules and requirements.

Based on forecasts derived from work carried out by Union of European Railway Industries (UNIFE) with the Boston Consulting Group and discussions with major railway undertakings we conclude that there is a generally rising trend in the number of authorisations, with a pause taking place at the moment as a result of the recession. Before the recession resources for authorisation in the National Safety Authorities were tightly stretched and following cutbacks in government departments resources are likely to be further stretched during the recovery and beyond. National Safety Authorities and Ministries therefore have a keen interest in simplification of the procedure and the elimination of duplicate checks by mutual recognition.

There is clearly an issue around the concept of type. The Agency study revealed that, between 2004 and 2009, the average type size for “new” locomotive authorisation is only 7 and even for “new” wagons, only 69. Bearing in mind the cost and timescale for a design type authorisation this is economically very inefficient and puts rail at a disadvantage compared to its competitors. Furthermore, aircraft, lorries, buses and car types are all put on the market by the manufacturer with type authorisation already granted. In the rail sector authorisation has mostly been carried out on a project by project basis after orders have been placed. In other words, railway vehicle types are specially designed made and authorised “to order” rather than being placed on a particular market from a production line. This also gives a competitive disadvantage and puts new entrants who, normally purchase vehicles in small batches, at a disadvantage. The “platform” concept adopted by most manufacturers is an attempt to minimise the costs of the “to order” approach but it is not explicitly recognised in the recast Interoperability Directive.

Another key finding is that the procedures, roles and responsibilities are different in every country. This complexity is compounded by the fact that the Directives are interpreted and implemented differently in every country. Within the different legal frameworks in which they have to work many National Safety Authorities have reached cross acceptance agreements to take best advantage of potential mutual recognition. However whilst there is no common approach to the

procedures,

roles and responsibilities,

the benefits of mutual recognition are limited.

The networks of Europe have, in the past, been built to different specifications. These differences cannot be quickly or cost effectively engineered away. Furthermore most of the Member States have not yet put in place and published the Technical Rules describing the characteristics to which their network must be maintained. This makes it difficult at authorisation to verify compatibility between vehicles and their network.

This is sometimes worsened when the competencies of the actors and the design quality of vehicles are poor.

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It is essential for safety reasons to maintain the parameters of individual routes within certain values so that each route remains compatible with the vehicles which run over it. However many infrastructure managers do not publish “the nature of their infrastructure” in a way that can be used by railway undertakings to establish compatibility between routes and their trains.

Several examples were noted where uncertainty over the nature of the infrastructure of a particular route, required a new measurement of the characteristics of the infrastructure to be made and/or specific on-track test runs to verify compatibility. The results of these tests are often the intellectual property of one actor (eg a manufacturer or an incumbent railway undertaking). Knowledge of the nature of infrastructure gives the historically incumbent manufacturers and railway undertakings a competitive advantage. A parallel would be if lorry manufacturers were required to pay for the height of bridges to be measured or aircraft manufacturers to pay for runway lengths to be measured each time they intended to design a new vehicle and then for that knowledge to be retained as their intellectual property. It is clear that transparent national rules for network-vehicle compatibility and Network Statements/Infrastructure Registers that are fit for the purpose of route compatibility assessment remain an essential prerequisite for efficient authorisation and market opening.

European Rail Traffic Management System (ERTMS), European Train Control System (ETCS) and Global System for Mobile communications – Railways (GSM-R)) present particular issues. Although conceived at European level, national implementation project(s) are technically incompatible, so far, with each of the others. In one particular case there are three incompatible ETCS systems in the same country. Furthermore, the nature of the national/local ETCS/GSM-R infrastructure and the requirements for compatibility of on-board ETCS and GSM-R are, with one exception, not published and in most cases are not even known to the Member State.

Currently there are no implementations of ETCS demonstrating complete interoperability, and there are no agreements in place.

This means that duplicate verifications and checks between Member States are inevitable. Whilst ETCS could become more cost effective and interoperable in the long term, at the moment the cost of configuring, testing and authorising on-board ETCS for each route is very high and the results uncertain.

Particular technical parameters that drive the cost of authorisation are:-

On board Control Command Signalling (CCS):

o Integration of ERTMS;

o Integration of national signalling (Class B) Systems;

o Management of transitions between different CCS systems , and

o Electromagnetic Compatibility of the vehicle with train detection system.

Testing of vehicle / track interaction

Pantographs.

Part 2 of this report will take account of ongoing work and outline the way ahead and, looking at the issues identified, will establish whether a solution or simplification is already in place or planned. Where no route to resolution is in place Part 2 will identify options and opportunities. It is expected to be published in conjunction with the planned “high level task force” on vehicle authorisation.

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Executive Summary

The purpose of this Part 1 of the report is to describe the current situation on vehicle authorisation for placing in service2 procedures in all EU countries except Malta and Cyprus (EU25), NO and CH. With the co-operation of the National Safety Authorities and the railway sector actors (the “sector”), the current procedures and future plans have been examined by the European Railway Agency (the Agency). This study on the procedure for authorising the placing in service of vehicles was carried out by the Agency between April 2009 and October 2010 as follows:

Questionnaires on the procedure for authorising the placing in service of vehicles were sent to the Member States/National Safety Authorities.

Questionnaires on cost driver parameters were sent to the railway sector (manufacturers and railway undertakings).

Bilateral meetings with Member States and the sector were organised.

Workshops with the sector were also organised.

Questionnaires per vehicle category were sent to several manufacturers.

The Agency surveys revealed that there had been a slight increase in the number of vehicles granted authorisation over the period 2004 – Q2 of 2009. Over the period 2010 to 2022 an increase over current levels of 10,8% in new vehicles granted authorisation is expected, based on the actual 2007 to 2009 figures. The number of vehicles built per type is very low with an average figure of 44.

The interfaces within the procedure are complex and different in each Member State .

There is a very clear finding that the procedures, roles and responsibilities differ for a variety of reasons including:

Checking bodies (Notified Bodies , Designated Bodies ) having limited or multiple roles, and

Different national legal frameworks for the procedure for authorising the placing in service of vehicles.

The comparison with other transport modes shows that even if the legislation, actors and procedures differ, the principle of mutual recognition of approved types, certifications, checking bodies is widely established for air, road and maritime (within EU and internationally) but is in its infancy for rail at European level.

The comparison between vehicle categories shows:

Specific procedures regarding each category due to differing requirements.

Different levels of cross acceptance for different vehicle categories varying from the highest to the lowest level as follows: Wagons > Coaches > Train sets > Locomotives.

Train sets and locomotives are the most expensive due to their system complexity.

The following cost drivers have been identified:

On board Control Command Signalling : o Integration of European Rail Traffic Management System (ERTMS); Integration of

national signalling (Class B) Systems; Management of transitions between different CCS systems and Electromagnetic Compatibility of the vehicle with train detection system.

Testing of vehicle / track interaction.

Pantographs.

When considering the current and future procedures, the National Safety Authorities, the sector and the Cross Acceptance Working Party have raised a number of issues. Some of these issues will be addressed in the very near future through new EU Regulations and the remainder will be addressed later.


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Table of Contents

1 References, Terms and Abbreviations ...................................................................................................................... 8

1.1 Legal References ............................................................................................................................................... 8

1.2 Other references ............................................................................................................................................. 11

1.3 Abbreviations .................................................................................................................................................. 12

1.4 Definitions related to authorisation ............................................................................................................... 12

2 Railway vehicle authorisation background ............................................................................................................. 13

2.1 Evolution of the EU legal background ............................................................................................................. 13

2.2 Other applicable EU Directives and Regulations............................................................................................. 14

2.3 Differences between Homologation and Authorisation ................................................................................. 14

3 Railway vehicle authorisation trends and methodology ........................................................................................ 16

3.1 Railway vehicle authorisation trends .............................................................................................................. 16

3.2 Trends in the number of vehicle granted authorisations: actual from 2004 to 2009 .................................... 16

3.2.1 The actual and forecast in the number of vehicles granted authorisation: from 2004 to 2016 .................... 18

3.2.2 Update of forecasts and projects based upon the UNIFE/BCG 2010 World Market Report .......................... 19

3.3 Methodology ................................................................................................................................................... 21

4 Analysis of vehicles authorisation procedure ......................................................................................................... 22

4.1 Procedures analysis ......................................................................................................................................... 22

4.1.1 The actors ........................................................................................................................................................ 22

4.1.2 The stages of the procedure (and who is responsible for what in the stage) ................................................ 22

4.2 Process interfaces ........................................................................................................................................... 23

4.3 Roles and responsibilities ................................................................................................................................ 24

4.3.1 Ministry ........................................................................................................................................................... 24

4.3.2 National Safety Authority................................................................................................................................ 24

4.3.3 NoBo and DeBo ............................................................................................................................................... 26

4.3.4 Other checking bodies .................................................................................................................................... 26

4.3.5 Applicant ......................................................................................................................................................... 26

4.3.6 RU .................................................................................................................................................................... 27

4.3.7 IM .................................................................................................................................................................... 27

4.4 Transparency of requirements........................................................................................................................ 27

4.5 Verification and assessment ........................................................................................................................... 28

4.6 Comparison between transport modes .......................................................................................................... 28

4.7 Comparison between vehicle categories ........................................................................................................ 29

4.7.1 Introduction .................................................................................................................................................... 29

4.7.2 Wagons ........................................................................................................................................................... 31

4.7.2.1 The actors ................................................................................................................................................ 31

4.7.2.2 The stages of the procedure ................................................................................................................... 32

4.7.2.3 Documentation ....................................................................................................................................... 33

4.7.2.4 Specific issues of the wagon category .................................................................................................... 33

4.7.3 Locomotives .................................................................................................................................................... 34

4.7.3.1 The actors ................................................................................................................................................ 35


4.7.3.3 Documentation ....................................................................................................................................... 36

4.7.3.4 Specific issues of the locomotive category ............................................................................................. 36

4.7.4 Coaches ........................................................................................................................................................... 37

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4.7.4.1 The actors ................................................................................................................................................ 37


4.7.4.3 Documentation ....................................................................................................................................... 38

4.7.4.4 Specific issues of the coach category ...................................................................................................... 38

4.7.5 Train sets ......................................................................................................................................................... 39

4.7.5.1 The actors ................................................................................................................................................ 40


4.7.5.3 Documentation ....................................................................................................................................... 41

4.7.5.4 Specific issues of the train set category .................................................................................................. 42

5 Analysis of cost drivers related to vehicle authorisation ........................................................................................ 43

5.1 Identified cost driver Parameters ................................................................................................................... 43

5.2 Reasons for criticality of parameters .............................................................................................................. 45

5.3 Economic Analysis of Cost Driver Parameters ................................................................................................ 45

5.4 Total Costs for an additional vehicle authorisation ........................................................................................ 47

5.5 Future potential total costs for additional authorisation ............................................................................... 47

5.6 Cost Driver Parameter Portraits ...................................................................................................................... 48

6 Obstacles to vehicle authorisation for placing in service ....................................................................................... 49

6.1 Issues list ......................................................................................................................................................... 49

6.2 Identified issues list ......................................................................................................................................... 49

6.3 Need for better understanding of some Directive requirements ................................................................... 50

6.4 Overlapping legislation ................................................................................................................................... 51

6.5 Setting up of National Rules ............................................................................................................................ 51

6.6 Establishing equivalence of National Rules .................................................................................................... 51

6.7 Management of the transition phase ............................................................................................................. 51

6.8 Languages ........................................................................................................................................................ 52

6.9 Continuous change of legal framework .......................................................................................................... 52

6.10 Organisational change management .............................................................................................................. 52

6.11 Vehicle type definition .................................................................................................................................... 52

6.12 Technical compatibility with the network (and other vehicles) ..................................................................... 53

6.13 Timing of the application of requirements ..................................................................................................... 53

6.14 Effects of other EU legislation ......................................................................................................................... 54

6.15 ERTMS Challenges ........................................................................................................................................... 54

7 Annexes ................................................................................................................................................................... 57

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1 References, Terms and Abbreviations

1.1 Legal References

Ref. N° Document Reference

Title Version

[1] The Recast

Interoperability Directive

Directive 2008/57/EC of the European Parliament and of the Council on the interoperability of the rail system within the Community

17 June 2008

[2] DV29

DV29/E06 - Draft Commission recommendation on the authorisation for the placing in service of structural subsystems and vehicles under Directive 2008/57/EC

7 January

2011

[3] Wagon TSI

CR TSI WAG - 2006/861/EC Commission Decision of concerning the technical specification of interoperability relating to the subsystem ‘rolling stock — freight wagons’ of the trans-European conventional rail system

28 July 2006

[4] Amendment to

Wagon TSI

CR TSI WAG Amendment - 2009/107/EC Commission Decision amending Decisions 2006/861/EC and 2006/920/EC concerning technical specifications of interoperability relating to subsystems of the trans-European conventional rail system

23 January 2009

[5] Noise TSI

CR TSI NOI - 2006/66/EC Commission Decision concerning the technical specification for interoperability relating to the subsystem ‘rolling stock— noise’ of the trans-European conventional rail system

23 December 2005

[6]

Persons with

reduced mobility TSI

PRM TSI - 2008/164/EC Commission Decision concerning the technical specification of interoperability relating to ‘persons with reduced mobility ‘in the trans-European conventional and high-speed rail system

21 December 2007

[7]

Safety in Railway Tunnels TSI

SRT TSI 2008/163/EC Commission Decision concerning the technical specification of interoperability relating to ‘safety in railway tunnels’ in the trans-European conventional and high-speed rail system

20 December 2007

[8]

Control-command and signalling

TSI for conventional rail

system

CR TSI CCS - 2006/679/EC Commission Decision concerning the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European conventional rail system

28 March 2006

[9]

First modification of Control –

command and signalling TSI for conventional rail and revision of

Control command and signalling TSI for high speed rail

system

CR TSI CCS – 2006/860/EC First modification and HS TSI CCS Revision Commission Decision concerning a technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European high speed rail system and modifying Annex A to Decision 2006/679/EC concerning the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European conventional rail system

7 November 2006

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:344:0001:0467:EN:PDF







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Title Version

[10]

Second modification of

Control –command and

signalling TSI for conventional rail

and first modification of


system

CR TSI CCS - 2007/153/EC Second modification and HS TSI CCS first modification Commission Decision modifying Annex A to Decision 2006/679/EC concerning the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European conventional rail system and Annex A to Decision 2006/860/EC concerning the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European high speed rail system

6 March 2007

[11]

Third modification of Control –

command and signalling TSI for conventional rail

and last modification of


system

CR TSI CCS - 2008/386/EC - Third modification and HS TSI CCS last modification Commission Decision modifying Annex A to Decision 2006/679/EC concerning the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European conventional rail system and Annex A to Decision 2006/860/EC concerning the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European high-speed rail system

23 April 2008

[12]

First amendment of Control

Command and signalling TSI for conventional rail

system

CR TSI CCS - 2009/561/EC - Amended Commission Decision amending Decision 2006/679/EC as regards the implementation of the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European conventional rail system

22 July 2009

[13] TSI INF for high

speed rail system

HS TSI INF - 2002/732/EC Commission Decision concerning the technical specification for interoperability relating to the infrastructure subsystem of the trans-European high-speed rail system referred to in Article 6(1) of Council Directive 96/48/EC

30 May 2002

[14]

Corrigendum To

High Speed TSI for Infrastructure for

high speed rail system

HS TSI INF Corrigendum - 2002/732/EC to Commission Decision 2002/732/EC of 30 May 2002 concerning the technical specification for interoperability relating to the infrastructure subsystem of the trans-European high-speed rail system referred to in Article 6(1) of Council Directive 96/48/EC

30 May 2002

[15] Revision of the TI INF for high speed

rail system

HS TSI INF Revision - 2008/217/EC Commission Decision concerning a technical specification for interoperability relating to the ‘infrastructure’ sub-system of the trans-European high-speed rail system

20 December 2007

[16] TSI Energy high

speed rail system

HS TSI ENE - 2002/733/EC Commission Decision concerning the technical specification for interoperability relating to the energy subsystem of the trans-European high-speed rail system referred to in Article 6(1) of Directive 96/48/EC

30 May 2002





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Title Version

[17]

Corrigendum of the Energy TSI

for high speed rail system for highs speed rail system

HS TSI ENE Corrigendum - 2002/733/EC to Commission Decision 2002/733/EC of 30 May 2002 concerning the technical specification for interoperability relating to the energy subsystem of the trans-European high speed rail system referred to in Article 6(1) of Directive 96/48/EC

30 May 2002

[18]

Revision of the High Speed TSI for

Energy for high speed rail system

HS TSI ENE Revision - 2008/284/CE Commission Decision concerning a technical specification for interoperability relating to the ‘energy’ sub-system of the trans-European high-speed rail system

6 March 2008

[19]

TSI for high speed rail system


HS TSI CCS - 2002/731/EC Commission Decision concerning the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European high-speed rail system referred to in Article 6(1) of Council Directive 96/48/EC

30 May 2002

[20]

Corrigendum to


TSI for high speed rail system

HS TSI CCS Corrigendum - 2002/731/EC to Commission Decision 2002/731/EC of 30 May 2002 concerning the technical specification for interoperability relating to the control-command and signalling subsystem of the trans-European high-speed rail system referred to in Article 6(1) of Council Directive 96/48/EC

30 May 2002

[21]

Modification to Annex A of


TSI for conventional rail

system

HS TSI CCS Modification - 2004/447/EC Commission Decision modifying Annex A of the Commission Decision 2002/731/EC of 30 May 2002 and establishing the main characteristics of Class A system (ERTMS) of the control command and signalling subsystem of the trans-European conventional rail system referred to in Directive 2001/16/EC

29 April 2004

[22] TSI Rolling Stock

for high speed rail system

HS TSI RST - 2002/735/EC Commission Decision concerning the technical specification for interoperability relating to the rolling stock subsystem of the trans-European high-speed rail system referred to in Article 6(1) of Directive 96/48/EC

30 May 2002

[23]

Corrigendum to TSI Rolling Stock

for high speed rail system

HS TSI RST Corrigendum to 2002/735/EC - Corrigendum

to Commission Decision 2002/735/EC concerning the

technical specification for interoperability relating to the

rolling stock subsystem of the trans-European high-

speed rail system referred to in Article 6(1) of Directive

96/48/EC

30 May 2002

[24]

Revision of the TSI Rolling Stock for high speed rail

system

HS TSI RST Revision - 2008/232/CE Commission Decision concerning a technical specification for interoperability relating to the ‘rolling stock’ sub-system of the trans-European high-speed rail system

21 February 2008

[25] Interoperability Directive of High speed rail system

Council Directive 96/48/EC of 23 July 1996 on the interoperability of the trans-European high-speed rail system

17 September 1996










http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31996L0048:EN:HTML

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Title Version

[26]

Interoperability Directive of

Conventional rail system

Directive 2001/16/EC of the European Parliament and of the Council on the interoperability of the trans-European conventional rail system

19 March 2001

[27]

Corrigendum to Directive

2004/50/EC amending

Directive 96/48/EC and Directive 2001/16/EC

Directive 2004/50/EC of the European Parliament and of the Council amending Council Directive 96/48/EC on the interoperability of the trans-European high-speed rail system and Directive 2001/16/EC of the European Parliament and of the Council on the interoperability of the trans-European conventional rail system

29 April 2004

[28]

Directive on development of the Community

railways

Council Directive 91/440/EEC on the development of the Community's railways 29 July

1991

[29]

Amendment of Directive on

development of the Community

railways

Directive 2001/12/EC of the European Parliament and of the Council amending Council Directive 91/440/EEC on the development of the Community's railways

26 February

2001

[30]

Directive of licensing of

railway undertakings

Directive 2001/13/EC of the European Parliament and of the Council 26 February 2001 amending Council Directive 95/18/EC on the licensing of railway undertakings

26 February 2001

[31] Directive of

Allocation of Capacities

Directive 2001/14/EC of the European Parliament and of the Council on the allocation of railway infrastructure capacity and the levying of charges for the use of railway infrastructure and safety certification

26 February 2001

1.2 Other references

Ref. N° Document Reference Title Version

[32] UNIFE/Roland Berger World Market Report 2008

[33] UNIFE/BCG/DVV World Market Report 2010

[34] ERA/EE

Intermediate Report on Cost Driver Parameters within the List of Parameters in Section 1 of Annex VII to the Interoperability Directive

2010

Note: the numbers in brackets [x] throughout the document refer to the tables in § 1.1 and 1.2



http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=31991L0440&model=guichett

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1.3 Abbreviations

Abbreviation Definition

CCS Control Command Signalling

CER Community of European Railways

CSM Common Safety Method

DeBo Designated Body

EEA European Economic Area

EC European Commission

EC Certificate European Conformity Certificate

ERA European Railway Agency

ERTMS European Rail Traffic Management System

ETCS European Train Control System

EU European Union

EU25 All EU countries except Malta and Cyprus

GSM-R Global System for Mobile communications – Railways

IM Infrastructure Manager

MS Member State

NoBo Notified Body

NR National Rule

NSA National Safety Authority

Q2 Second quarter of the year

RISC Railway Interoperability and Safety Committee

RIV Regolamento Internazionale Veicoli

RU Railway Undertaking

STM Specific Transmission Module

TEN Trans European Network

TSI Technical Specification for Interoperability

UIC International Union for Railways

UNIFE Union of European Railway Industries

1.4 Definitions related to authorisation

The following definitions are in line with the recast Interoperability Directive [1]

First authorisation: The authorisation granted by the first Member State for a new vehicle

Additional authorisation: The authorisation granted by another Member State after the above-

mentioned 1st authorisation

New authorisation: Authorisation granted by one Member State after the modification of an existing

vehicle

Renewed authorisation: Authorisation granted by a Member State after the renewal of a vehicle type

authorisation

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2 Railway vehicle authorisation background

2.1 Evolution of the EU legal background

With the opening of the market for rail operations and supply of goods and services it was necessary to put in place new rules and procedures for authorisation for placing in service3 of vehicles to reflect the fact that the management of the system is now “shared” between many independent actors, principally Infrastructure Managers (IM) and Railway Undertakings (RU), each responsible for their part of the railway system under a framework of rules and procedures put in place by Member States (MS) and the European Commission (EC).

Furthermore, in recent years, manufacturers and RUs have complained about the cost, timescales and uncertainty of the various national authorisations and have campaigned for a simplified European approach.

Since 1996 the procedure for placing in service of the subsystems that comprise a vehicle has been covered by European Directives on interoperability. The scope of granting authorisation has progressively been extended from the high speed Trans European Network (TEN) culminating in the recast Interoperability Directive which extends the scope to the entire European railway system. In addition to the comprehensive coverage given by the recast Interoperability Directive, it introduces the concept of granting authorisation for “vehicle”. It also introduces classification of national rules to facilitate, wherever possible, mutual recognition of the elements of the procedure for authorising the placing in service of vehicles carried out against national rules. This concept of “Cross Acceptance” as a stepping stone to full interoperability was initially proposed by the railway sector associations and supported by the EC.

The recast Interoperability Directive covers authorisation in the following Articles:

15.Procedure for placing in service;

16.Free movement of subsystems;

18.Procedure for establishing the ‘EC’ declaration of verification;

20.Placing in service of existing subsystems after renewal or upgrading;

21. authorisation of vehicles;

22.First authorisation for placing in service of TSI conform vehicles;

23.Additional authorisation for placing in service of TSI conform vehicles;

24.First authorisation for placing in service of non-TSI conform vehicles;

25.Additional authorisation for placing in service of non-TSI conform vehicles;

26.Authorisation for types of vehicles and

27. Classification of national rules.

The recast Interoperability Directive is now supplemented by the EC Recommendation - DV29 [2] - describing the common understanding of the procedure for authorising the placing in service of vehicles.


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2.2 Other applicable EU Directives and Regulations

For railway vehicles, in addition to the requirements specified by the recast Interoperability Directive, any other requirements from other EU Directives/Regulations are covered by the procedure for authorising the placing in service of vehicles. Examples are:

For tank wagons - Council Directive 1999/36/EC of 29 April 1999 on transportable pressure equipment.

For On Track Machines (vehicles specially designed for construction and maintenance of the track and infrastructure) – Directive 2006/42/EC of the European Parliament and of the Council of 17 May 2006 on machinery, and amending Directive 95/16/EC (recast)

For subsystems equipment - Directive 2004/108/EC of the European Parliament and of the Council of 15 December 2004 on the approximation of the laws of the Member States relating to electromagnetic compatibility and repealing Directive 89/336/EEC

For dangerous goods wagons - Directive 2008/68/EC of the European Parliament and of the Council of 24 September 2008 on the inland transport of dangerous goods

For vehicles equipped with engines having exhaust gas emissions - Directive 97/68/EC of the European Parliament and of the Council of 16 December 1997 on the approximation of the laws of the Member States relating to measures against the emission of gaseous and particulate pollutants from internal combustion engines to be installed in non-road mobile machinery

For EU Directives falling under the “New Legislative Framework” for marketing of products (the former “New Approach”), the conformity assessment is performed by Notified Body(ies) (NoBo). These may be different from those bodies notified under the recast Interoperability Directive.

For other EU Directives, other checking bodies may assess conformity against the requirements of those Directives.

2.3 Differences between Homologation and Authorisation

Prior to the development of the Access, Safety and Interoperability Directives (referred to hereafter as Directives), State Railway Authorities undertook “Homologation” of railway vehicles to ensure that they met the Safety and Commercial specifications.

The Directives introduced, because of the changed structure of the railway sector, the procedure for authorising the placing in service of vehicles. This ensures:

Market opening for suppliers of railway products and services – therefore creating a single market

Preventing further technical diversity in the European Railway Area, and

Safety Assurance.

The benefits of moving from “Homologation” to the procedure for authorising the placing in service of vehicles are that:

It is possible for manufacturers to place generic products on the market for a particular network

Each order would not necessarily provoke a different design and the procedure for authorising the placing in service of vehicles would not act as a barrier to new entrants

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With the procedure for authorising the placing in service of vehicles, the granting of authorisation is no longer controlled by the incumbent RU of the MS. Authorisation according to TSIs and national rules prevents projects from increasing the technical diversity of the railway system, and

Vehicles are granted authorisation to a set of European requirements (TSIs, ENs, etc.).

It should be noted that granting authorisation is a “snapshot” check of new or upgraded subsystems or vehicles to show that they meet the Essential Requirements (Safety, Reliability and Availability, Health, Environmental Protection, and Technical Compatibility).

After the vehicle has been placed in service it must be operated and maintained in accordance with the essential requirements relating to the vehicle. This shall be ensured by the Safety Management System of the RU.

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3 Railway vehicle authorisation trends and methodology

3.1 Railway vehicle authorisation trends

In order to understand the situation the Agency initially conducted three surveys in conjunction with the National Safety Authorities (NSA) and Sector organisations.

The purpose of the first survey was to assess the transposition of the current Directives, to understand the interfaces involved the procedure for authorising the placing in service of vehicles and to quantify the types and numbers of vehicles placed in service between 2004 and 2009 Q2.

This survey was carried out amongst the NSAs. It was a successful survey achieving a very high response rate. Although not all of the NSAs could answer questions relating to the years 2004 – 2008 because not all of the NSAs were in place throughout this period, all respondents provided useful information about their procedure and the quantities of vehicles they had granted authorisation.

A second survey was carried out with the assistance of Community of European Railways (CER), at the end of 2009 when the “Intermediate Report on Authorisation Processes” was being prepared. This enabled a forecast of the future granting of authorisations for vehicles from 2010 – 2013 by a sample of RUs. The Union of European Railway Industries (UNIFE) also assisted this work by providing access to their actual and forecast data for production of vehicles in the railway manufacturing sector from 2008 to 2016 [32]. UNIFE were able to assist our work further by allowing the Agency access to the findings, forecasts and data published in their 2010 update of the World Market Study carried out by the Boston Consulting Group [33]. This has enabled an update of the Agency’s projections of future authorisations to be granted 2021/2022.

The purpose of the third survey, which was filled in by manufacturers, was to analyse the granted authorisations of various vehicle categories and evaluate the costs and time delays incurred during the procedure for authorising the placing in service of vehicles.

3.2 Trends in the number of vehicle granted authorisations: actual from 2004 to 2009

The results of the number and types of vehicles being placed in service followed similar patterns. The perception from the raw data was that the number of vehicles to be placed in service was increasing rapidly. Diagram 1 illustrates the “normalised” data (taking account of the sample and time period covered by the data) for the numbers of vehicles placed in service while Diagram 2 illustrates the “normalised” data numbers of types of vehicles placed in service.

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Diagram 1 Diagram 2

Analysis of these data revealed the fact that there are very low numbers of vehicles per type granted authorisation – across all categories an average of 44 vehicles per type. The following table shows the average granted authorisations per type for both new and existing vehicles over the period 2004 – Q2 2009.

TABLE 1 Mean number of vehicles granted authorisation per type

Wagons Locomotives Passenger vehicles (not part of fixed formation trains)

Fixed formation trains

Vehicles

New Existing New Existing New Existing New Existing

69 157 7 12 17 19 22 27

However, when the data are normalised for the number of countries without NSAs prior to 2006 the numbers show only a slight increase. The trends for the European railway area (see Annex 1) are illustrated in diagram 3 below. Data for the years 2004 and 2005 are based on a small sample of NSAs while data for the year 2009 is an estimate based upon only 6 months of data. Not all countries fully reported all of the data. However, data has been estimated to address the missing data.

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Diagram 3- Estimate of the number of vehicles authorised to be placed in service in EU 25+ NO+ CH

* estimate for whole year based upon information provided for first half of year.

3.2.1 The actual and forecast in the number of vehicles granted authorisation: from 2004 to 2016

The Agency collected further data in conjunction with CER. The responses to this survey came from just under 10% of CER’s members (including the former national railways of the following countries: BE, DE, ES, FR, IT, SE and UK). The data collected covered the period 2010 – 2013 and is based upon expected deliveries of all types of vehicles that need authorisation by the RUs responding to the questionnaire.

The Agency used information provided by UNIFE who in conjunction with Roland Berger Consultancy had undertaken forecasting of vehicle production from 2008 to 2016 based on data covering 19 countries in the European railway area. The data comes predominantly from railway manufacturers, and are based upon:

2008 – 2010 - Project list – Member information, bank information and consultancy studies (Bottom up approach)

2011 – 2013 Medium-term forecasts based on projected volumes (Top down approach)

2014 – 2016 Long-term forecasts based on projected volumes (Top down approach)

The forecasts were prepared in 2008, prior to the onset of the period of economic recession and the Agency used both the CER and UNIFE data to produce a composite forecast for vehicles granted authorisation. The forecasts are illustrated in Diagram 4 below.

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This very clearly shows the impact of the period of economic recession that has hit the world recently, taking account of the production lags (typically +1 year). The expectation was that granted authorisations would fall from 2009 levels to a low point in 2011 then recovering in 2012 and 2013.

Diagram 4 - Actual vehicles placed in service 2004 – Q2 2009 and ERA projections to 2016

Over the period of 2010 to 2016 an overall increase of 1.2% per year was expected.

The data provided by NSAs, RUs (through CER) and manufacturers (through UNIFE) proved extremely useful and the Agency Cross Acceptance Working Party recommended that the information be updated on a regular basis.

3.2.2 Update of forecasts and projects based upon the UNIFE/BCG 2010 World Market Report

In early 2010 UNIFE, in conjunction with the Boston Consulting Group and its members, updated its World Market Report [32] and published their findings at the end of September 2010. This was the third world market survey [33] of the rail supply industry that UNIFE had published and showed that between 2008 and 2010 the industry had been affected by the serious economic downturn that is only currently abating. The studies had to look at market size and then forecast to 2015. The period beyond this to 2021 (in production terms, 2022 in granted authorisation terms) is a projection based on the forecast trends 2010 - 2015.

Using the actual and forecasts for Rolling Stock markets (See Annex 34) regionalised to Western Europe and Eastern Europe, the Agency was able to construct projections with sensitivities (+10% and -10% around the central projection) based upon UNIFE’s forecasts. ERA’s projection is shown in Diagram 5.

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Diagram 5 - ERA Projection for granted authorisations of new vehicles

The actual figures are in agreement with the data from the first Agency survey and show the data relating to new vehicles. The central projection for new vehicles granted authorisation ranges between 7065 and 13243 vehicles per year with an average of 9307 per year. While the short term is trending upwards the projections show a slight downward trend between 2010 and 2022.

UNIFE’s projections and forecasts with Boston Consulting Group used fewer variables as compared to the 2008 forecasts. The key variable in the model is based upon rail traffic growth (the Index of Transport Performance- see below). The forecast was based upon the triangulation of trends mentioned in section 3.1 of this document.

In addition Boston Consulting Group used UNIFE chosen “Experts” as inputs to develop scenario trends and mega-trends. Mega-trends are a process used by Boston Consulting Group to determine the likely future scenarios. UNIFE Members – not only members of steering committee – provided information across all product categories.

The Index of Transport Performance is based upon International Union of Railways (UIC) data and forecasts, which had been given at the Rail Market Monitoring Scheme meeting in September 2010.

The forecasting (to 2015) showed growth of 2.4% in the World Market, 1.8% in Western Europe and 2.0% Eastern Europe. The 1.8% forecast for Western Europe is the best case scenario and excluded budget issues. While in Eastern Europe budget issues may also be an important consideration, cohesion funding may offset the impacts arising from budget issues. The horizon to 2020/2021 is an extrapolation of trends from 2015.

The above forecasts will enable a baseline quantification of the costs for the procedure for authorising the placing in service of vehicles.

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3.3 Methodology

The methodology for quantifying the impacts of the current situation in regard to authorisation and of the cost drivers for additional authorisations has been set out in two reports already issued by the Economic Evaluation Unit:

1. Intermediate Report on Cost Driver Parameters within the List of Parameters in Section 1 of Annex VII to the Interoperability Directive (Annex 33), and

2. Impact Assessment Report - A baseline study - Current Authorisation Procedure and Cost Drivers for railway vehicles (Annex 34).

The methodology for analysing cost driver parameters only took additional authorisations into consideration because the cross authorisation effects are only present under this condition. In addition, only type authorisations for locomotives and unit rolling stock was evaluated due to the fact that majority of parameters to be checked for authorisation ( section 1 of Annex VII to the recast Interoperability Directive) concern these vehicles and types. The study was based on three steps:

a preliminary Agency internal analysis of possible cost drivers,

the drafting of a questionnaire, and

the organisation of bilateral meetings to get more detailed information about cost driver parameters.

The questionnaire was split up into two parts:

The first part dealt with general issues related to the authorisation of vehicles.

The second part was dedicated to real examples of vehicle authorisations. This second part consists of two sections: one related to reasons for parameter criticality and one related to the economic impact of parameters.

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4 Analysis of vehicles authorisation procedure

The purpose of this analysis is first to understand and then compare existing procedure between:

the MSs;

the transport modes; and

the vehicle categories.

The Agency survey consists of 28 different reports: EU25 including Northern Ireland which has a physically separate railway system from Great Britain and two European Economic Area (EEA) countries NO and CH. Annexes 3 to 30.

4.1 Procedures analysis

4.1.1 The actors

At the moment the following actors are/ may be involved in the authorisation procedure: Ministry, NSA, NoBo, Designated Body (DeBo), RU, IM, Vehicle Keeper, Independent Safety Assessor, Independent Expert, Competent Person, Manufacturer, Contracting Entity, Specific technical committee, Registering Entity, Temporary Technical Committee or Technical Supervision Board, Competent Authority.

4.1.2 The stages of the procedure (and who is responsible for what in the stage)

The following stages were identified during the analyses of the existing procedure:

Setting requirements: informing applicants of what they must do to achieve the procedure for authorisation of vehicles

Defining National Rules (NRs):

Pre-engagement: Prior exchanges of information between the NSA and other parties including the applicant/ Contracting Entity (Vehicle Keeper, RU, Manufacturer, Other) where each entity, in particular the applicant, gets confirmation on the feasibility of the project

Pre-authorisation: Intermediate authorisation from the NSA pending the final authorisation; for instance prior to obtaining running tests results

Requirements freeze: All the requirements conform to agreed approach and are settled. From this point it is agreed that no additional requirements may be subsequently imposed. The applicant is given protection from any deviation from the agreed requirements (e.g. new rules being imposed )

Conformity assessment

Applying for authorisation

Granting authorisation

Checking Network compatibility: technical compatibility of the vehicle with the network over which it is intended to be operated

For additional authorisations (in other MSs), there may be pre-requisite(s). These are any criteria facilitating the procedure, e.g. other MS authorisations.

For many of these stages however, the responsibilities are different between the actors in different countries

In order to clarify the procedures steps to be applied for a specific authorisation, it is a common and recommended practice that early discussions between all actors take place. This is a necessary step

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to ensure that all parties understand the rules, requirements and procedure to be followed for the particular authorisation in question, thereby reducing the time, costs and the potential for surprises. This is usually called the “pre-application” stage. Typically, these take place between 18 months and 3 years before the official application for authorisation.

4.2 Process interfaces

The understanding of the process interfaces was developed in conjunction with NSA and sector organisations.

A process interface is when an actor undertakes a stage of the procedure towards the completion of placing a railway vehicle in service, e.g. when a contracting entity or RU meets with the NSA to discuss the pre-requisites for granting an authorisation or where a NoBo delivers a technical file to a vehicle keeper. A process interface may consist of one or more meetings and may extend in time from one week to more than two years.

For each of the identified stages of the procedure, the total number of interfaces between the involved actors per country was counted and summarised in diagram 6.

The number of process interfaces ranged between 10 (EL) and 57 (CH) with the mean number of interfaces being just over 28. There is no reason to conclude that fewer process interfaces leads to a less complicated authorisation procedure or conversely that more process interfaces leads to a more complicated authorisation procedure. Further work is required to analyse the impact of potential improvements to procedure(s).

Diagram 6 - Number of process interfaces per country

Diagram 6 shows the number of process interfaces per MS involved in the authorisation procedure of vehicles amongst EU25, NO and CH.

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The analysis of the individual NSA data showed that no MS was like another in the procedure for authorisation. Every MS was different from every other. This summary diagram indicates a highly complex set of interfaces. This was confirmed during the bi-lateral meetings with NSAs.

4.3 Roles and responsibilities

The Agency vehicles authorisation survey (see Annex 2) shows that the roles and responsibilities of the various bodies involved in the procedure are different across the MSs.

The roles and responsibilities of each actor during the authorisation procedure are described below.

4.3.1 Ministry

The Ministry of Transports is often the State authority for railways. In some countries, the Ministry is acting as NSA (e.g. EL, CH).

The national legal framework for authorisation is often issued by the Ministry. The elaboration of such regulation is done in cooperation with the NSA and the sector.

The Ministry acting as MS Railway authority is responsible for:

transposing Directives into national law

enforcing National and European legislation (this is sometimes delegated to the NSA)

putting in place and notifying the NRs

designating the bodies responsible for the verification of conformity with NRs (DeBos)

notifying the NoBos for their MS.

4.3.2 National Safety Authority

In most of the countries, the NSA is separate but under supervision of its relevant Ministry.

According to the Safety Directive the NSA acts on behalf of the MS to grant authorisation for vehicles. The NSA is responsible for granting formal authorisation of vehicles and vehicle types.

Some NSAs also grant a temporary authorisation or authorisation only for operation on specific lines or with restrictions: gauge, axle load, maximum operating speed. The concept of “Temporary Authorisation” is not foreseen in the recast Interoperability Directive.

NSAs grant the authorisation for vehicles which are already authorised in other EU/EEA countries (“additional authorisations”) with or without testing.

Most of the NSAs accept only submissions of documentation in their national language. However, some may accept partial or complete documentation in other languages (e.g. English or any other language that the experts can understand).

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Diagram 7 – Summary of the interfaces per actor in the authorisation procedure

A tabulation and breakdown of the individual procedures for authorisation for the different actors is shown in Annex 11.

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4.3.3 NoBo and DeBo

Accreditation of checking bodies and verification arrangements are considerably different between MSs:

In six countries there are several NoBos (AT, IT, PL, LV, SL, UK)

Some NoBos have no real experience as no authorisations have been granted to TSI conforming vehicles (NO),

In seven countries (ES, DE, BE, HU, PT, RO, SK) there is only one NoBo

In one country (CZ) the NoBo though having officially declared its independence is part of one RUs organisation,

NoBos do not exist in eight countries and Northern Ireland (FI, BG, NIE, CH, DK, LT, IE, LU, EE),

In nine countries (UK, NL, BE, PT, FR, CZ, ES, EL, SE) the NoBos are also DeBos,

In two countries (FI, NO), the DeBo is the NSA, and

In one country (DE) as well as the assessment by NoBos and DeBos an additional third party assessment must be carried out by Independent Experts who are accredited by the NSA but are contracted by the applicant.

4.3.4 Other checking bodies

For the EU 1520 mm railway system, non-EU countries checking body’s assessment may be accepted by the NSA.

Additional third party assessors, (e.g. Independent Safety Assessors), are sometimes involved for the Control Command Signalling (CCS) part of the vehicle. Commercially there may be only one Independent Safety Assessor in the market able to undertake such checks which may give rise to comptition or market dominance problems.

A Temporary Technical Committee or Technical Supervision Board may be involved in the authorisation procedure ( EE, LT, LV, BG, PL, BE, Northern Ireland (NIE)).

At the time of the survey there were no Common Safety Method (CSM) assessors in place in any MS.

4.3.5 Applicant

The formal application for authorisation starts with the submission of the complete file by the applicant.

Different arrangements may occur:

RU, Vehicle Keeper , Contracting Entity, or Manufacturer may be the applicant initiating the procedure for authorisation. The most frequent case is for the the RU to initiate the authorisation procedure. At the moment, in some cases only the RU is allowed to apply for the procedure for authorisation

The applicant/contracting entity is restricted only to an RU in one country (NO)

In some countries (RO, DK) the vehicle authorisation procedure is linked to a RU’s MS, therefore the applicant must have a partner RU to achieve the authorisation, and

In RO, the applicant is requested to have the vehicle registered in the National Vehicle Register before the formal granting of authorisation.

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4.3.6 RU

When running tests are necessary, an RU is involved in authorisation procedure as a service contributor/facilitator for the applicant.

4.3.7 IM

The IM is often involved in the procedure prior to the formal granting of authorisation by the NSA as an authorising body (in contradiction with the Directive ) or sometimes as a consultant for the NSA.

In three countries (SE, PL, AT), the IM issues a “Statement” demonstrating that the vehicle can be operated on a given network.

4.4 Transparency of requirements

In general, there is a legal document describing the procedure and requirements for vehicle authorisation. This document is very often available from the website of the NSA or the relevant Ministry. It contains high level description of the procedure and refers to other documentation containing the detailed technical requirements.

The latter are available either:

Internally within the NSA (UK, CZ),

On the NSA website (FR, DE, RO, SL, CH, DK, SE, HU, BE, BG, IT, LT, PL, PT, EE),

On the website of the IM (ES, NO, DE, SK, FI, UK, CZ, FR, DE, NL),

On the national legislation website (LU, LV),

On the unique integrated RU website (EL, IE, NIE),

Or from other sources depending on the scope of the authorisation applied for by the applicant (this could be a continuation of an already authorised type, a modification of an existing vehicle or an additional authorisation of a vehicle already authorised in another country).

Not all the requirements applied are covered by the NRs (either Technical or Safety), thus they cannot be considered as being fully transparent for all actors. New entrants to a MS have particular difficulties because they will not be aware of local “custom and practice” if it is not documented as a rule.

It should be noted that even where rules exist not all of them are notified.

The level of detail of the requirements differs between countries.

Many MSs/NSAs were concerned about the level of detail required for the specification of technical requirements. The EU legislation allows different approaches:

The risk-based” approach - A “Safety-case” based on risk assessment with less detailed technical requirements

The “rules-based” approach - At the vehicle-network interface detailed technical specifications are necessarry to ensure Tecnical Compatibility. These include specification of the related assessments, the specification of checks and the various checking bodies.

In some cases the inappropriate approach leads to unnecessary prescription. In other cases the lack of detailed specifications leads to Technical Incompatibility between projects.

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New legislation may contain requirements that can be interpreted in different ways. Sometimes errors are discovered in the light of experience and because these erroneous requirements are mandatory, it is difficult to deal with.

4.5 Verification and assessment

Not only do the roles of the bodies involved in the verification and assessment sometimes differ but also the extent of the verification and assessment differ between MSs.

For vehicles requiring authorisation in several MSs, in some countries (UK, CZ) additional authorisations are currently not required at all, in others the Ministries and NSAs try to limit the additional verifications and checks. Normally (with the exception of integration of on-board CCS into the vehicle) additional checks are only related to network compatibility in particular, Electromagnetic Compatibility and CCS interfaces.

According to comments from the Sector some NSAs sometimes challenge the way in which the conformity assessment had been carried out by foreign NoBos. As a consequence certificates are not accepted and additional tests have to be carried out.

In other countries, NSAs may allow a simplified procedure. For example, in the Baltic countries (LT, LV, EE), authorisation from a third country is valid if the vehicle is part of the common fleet operated on the 1520 mm railway system.

Some verifications/assessments are related to system reliability that may be either included in the RU’s Safety Management System or in the IM’s access charges (lower charges for track friendly vehicles and vice versa).

It is difficult to identify precisely for each MS or even globally the costs and delay generated by the authorisation procedure and its uncertainty.

Effectively, most of the actors from the industry (manufacturers, applicants) are very cautious in releasing information. However, it has been possible to establish the following as an indication from the bilateral meetings held with NSAs and their local sector organisations:

Up to an average of 2 years delay between the completion of the vehicle and the granting of the formal authorisation (for locomotives and Coaches)

Additional costs ranging from 100 to 1500 k€ for verifications and authorisation of modifications, and

Additional costs ranging from 100 to 4000 k€ for additional authorisation in other MS.

4.6 Comparison between transport modes

A study was undertaken by the Agency to compare the authorisation (or its equivalent: approval, certification, etc.) procedure of railway vehicles with other modes of transport.

The following modes were considered:

Road transport limited to the approval of trucks used for freight traffic

Air transport limited to the certification of civil aircraft

Maritime transport limited to Ship certification

The objective of the study was to find what the railway sector could learn or adapt from the other modes.

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The results of this study are shown in Annex 31. “Summary of the applicable legislation to the 4 different modes of transport: road, air, maritime and rail in the European Union (EU)”

The findings from the applicable legal base show that mutual recognition is widely established for road, air and maritime but is in its infancy for rail at EU level. There could be many reasons for this. For road transport mode, the legal basis for registration and entry into service is not common, but the technical requirements for type approval and the registration documents are. In spite of this there is mutual recognition of several certificates. There are only two actors involved in the type authorisation procedure: the manufacturer and the Approval Authority. Type-approval is applied in every MS. The technical requirements are very detailed in spite of the absence of an EU body for road safety.

For the air transport mode, there are very numerous safety requirements and the most complicated certification process. The existence of an International convention eases the European certification work which is also supervised by the European Aviation Safety Agency (EASA). There are several bodies that are allowed to certify aircrafts: European Aviation Safety Agency, National Aviation Authority and Qualified entities. The notion of type certification applies. There is a very high mutual recognition in and outside EU. This is counter balanced by an expensive certification process.

For maritime transport mode, there are the least common technical rules and requirements for ship classification; instead there are some general safety guidelines. The Classification Societies recognised by the EU are responsible for both defining and checking the technical requirements for ship classification and certification. However, there is full mutual recognition of all classification certificates in and outside the EU.

For railway transport mode, even if there is a common legal base mutual recognition is in practice still very limited. Most of the authorisations are valid only in one MS territory. There are also many actors involved in the authorisation procedure. This is because of the historical development of the European Railways and also the very recent entry into force of the comprehensive common EU legal base for vehicles authorisation, which means that national procedure continue to apply for off-TENs authorisations in each MS until the recast Interoperability Directive has been implemented in that MS.

There is no single solution to enhance mutual recognition for railways. However, from the other modes, the following can be considered as factor for success:

Common technical requirements including the related checks,

Type approval or certifications, and

Limited number of actors.

Other possible causes of the differences have not been investigated further due to the complexity of vehicle / network compatibility assessments for rail.

4.7 Comparison between vehicle categories

4.7.1 Introduction

The following analysis is based on:

An Agency survey distributed amongst some vehicles manufacturers,

The contribution of the sector during the Agency workshop of the 26/05/2010 on the “Procedure of vehicle placing in service”, and

http://e2010.era-ext.eu.int/XA/XA_WP/Library/Forms/AllItems.aspx

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The reports from the bilateral meetings with the MSs.

The term “Business Case” means an example of vehicle(s) authorisation for placing in service. The term “Procedure(s)” used in this section means the framework under which the authorisation for placing in service is or was conducted.

For each category of vehicle, the following procedure have been analysed when possible:

New vehicle type , based on an already existing or on a completely new design,

Modification of an existing type,

Authorisation under cross acceptance agreements, and

Additional authorisation.

Some business cases had several procedures (sometimes up to four, noted above. Table 2 below summarises 62 business cases with a total of 86 analysed procedures:

TABLE 2: Business cases per vehicle category

Category Procedure

Wagons Locomotives EMUs +DMUs Coaches Total

Authorisation of a new vehicle type

11 12 16 4 43

Additional authorisation in another MS

1 11 3 0 15

Authorisation under Cross-Acceptance agreements

1 5 6 2 14

Modification of an existing vehicle type

2 7 3 2 14

Total 15 35 28 8 86

The analysis focused on the following:

For all vehicle categories: Authorisation of a new vehicle type based on an already existing or a completely new design - 43 procedures

In addition for:

o Locomotives: Additional authorisation in another MS - 11 procedures o EMUs and DMUs: Authorisation under Cross-Acceptance agreements - 6 procedures o Coaches: Modification of an existing vehicle type - 2 procedures

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4.7.2 Wagons

The legal technical requirements applicable to wagons authorisation procedure evolved as below:

RST – Freight Wagon NRs CR TSI NOI 2006/66/EC

CR TSI WAG 2006/861/EC

CR TSI WAG amendment 2009/107/EC

[5] [3] [4]

Before 23rd June 2006 X

From 23rd June 2006 to 30th January 2007

X x

From 31st January 2007 to 30th June 2009

X x x

From 1st July 2009 to date X x x x

Amongst the 11 analysed procedures:

One falls under the first period (no obligation to apply EU Technical rules )

Nine fall under the third period, in one case a derogation from TSIs was granted

One falls under the fourth period.

4.7.2.1 The actors

The applicant

Amongst the business cases analysed the applicant were:

Manufacturer - 55 %

Wagon keeper - 27 %

RU - 18%.

NoBo/DeBo/Other checking bodies (CA, Independent Safety Assessor, Independent Expert )

We found little consistency between MSs & NSAs in respect of checking bodies:

When there is no NoBo (in two countries), the NSA acted as NoBo.

When the NoBo and the DeBo (in one country) were the same entity the procedure was simpler.

In one business case, two NoBos were involved in the assessment against the CR TSI WAG [3] with a contracting/leading NoBo who issued the EC certificate and a subcontracting NoBo who performed part of the assessments.

In one business case related to dangerous goods tank wagons, there was a double assessment of the link underframe/tank by the NoBo and the CA.

In one business case, an Independent Safety Assessor made the gap analysis between the existing NRs and the in force TSIs.

The Independent Expert acted as technical support for the NSAs.




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National Safety Authority

As with checking bodies there was little consistency in the role played by NSAs, with the exception of the granting of authorisation:

In all cases, the NSA has granted the authorisation.

In most of the cases, the NSA received the applications even when technical file was not completed.

The NSA played also the role of NoBo when there was no NoBo.

In most of the countries, the NSAs based their decision on the opinion of Independent Expert .

The NSA, on behalf of the Ministry, granted a derogation from the CR TSI WAG [3] in one case.

IM

Compared to other types of vehicles, the role of IMs in the authorisation granted by the NSA is very limited although they provide critical information in respect of infrastructure compatibility:

In most of the cases, the IM was involved from the beginning of the authorisation procedure.

In one case, the IM was involved at the final stage only. It received the complete technical file for consultation and issued its advice within one month.

4.7.2.2 The stages of the procedure

Setting requirements

The procedure for setting requirements are not clear:

In one business case, the requirements were set up by the NoBo for the authorisation of a new vehicle type based on an already existing design. The NoBo evaluation was based on the changes from the existing design. In one business case, an initial type authorisation was granted in 2000 under NRs compatible with the Regolamento Internazionale Veicoli (RIV) requirements. Due to a change of the NRs, before issuing authorisation of the same vehicle type, the NSA required the applicant to track the changes between the previous and the new technical requirements.

In one business case, a gap analysis between the technical file of the former series (authorised according to NRs) and the CR TSI WAG [3] requirements that entered into force was required from the applicant.

Though all MSs publish rules in some cases their legal status are not clear.

Assessment

As with the setting of requirements, assessment procedures are not clear:

The declaration of conformity was required for an individual wagon or an entire series.

For RIV marking, one NSA considered that a checking body should verify the conformity with RIV rules whereas another NSA was satisfied with only a RIV declaration of conformity without verification from a NoBo/DeBo.

New noise tests were required for the same type of wagons equipped with wheelsets of the same technical design but provided by a different manufacturer (same Interoperability Constituent with a different EC Certificate).

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4.7.2.3 Documentation

Preliminary engagement

In almost all cases, it was necessary to carry out a preliminary engagement, ususally before the design stage. Often a technical description of the project preceeds the preliminary engagement.

Technical file

Requirements for Technical Files are not clear:

In two cases, it was not clear what documentation was required for authorisation.

EC certificates

There was a degree of misunderstanding concerning conformity certificates:

When several NoBos checked the conformity, only the contracting NoBo issued the EC certificate.

Intermediate Statements of Verification

These were not observed in any of the cases analysed.

Authorisation

It is not clear what constitutes authorisation and when a new authorisation is required:

All authorisations were issued by the NSAs within the maximum periods regulated by the recast Interoperability Directive [1].

In one case the authorisation was split into two steps: the authorisation followed by an “operating permit”.

In some countries, authorisation is sometimes linked to maintenance. When a component is replaced, e.g. wheelsets, bogies, with similar but not identical components, the authorisation is no longer valid.

4.7.2.4 Specific issues of the wagon category

Positive

The positive points in relation to authorisation procedure for wagons are:

Most of the wagon fleet fall under the category of “Go anywhere” wagon which is in the scope of “cross-authorisation” as foreseen in the amendment of the CR TSI WAG amendment [4]. Therefore the need for additional authorisation is limited to specific cases or particular wagon categories. Unfortunately, the unique business case that fell under the 4th period where “cross-authorisation” was legally possible could not benefit from this as they were G2 wagons.

Two countries’ approach is to preserve as much as possible the validity of former approved designs where the applicant is able to demonstrate that the changes have no safety impact.

The TSI regime as applied to wagons results in a much shorter authorisation procedure than other vehicle categories.

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Negative

In contrast to above the negative points were that:

New requirements introduced as part of the TSI regime, e.g. TSIs Wagon and Noise in particular, has resulted in increases in costs and delays for authorisation.

Due to the availability and conformity of test tracks for assessment against CR TSI NOI [5], costs and delays have increased compared to the time when there were no noise requirements .

The delays in resolving errors in the CR TSI WAG [3] has led to uncertainty, delays and increased costs. Compared with the former RIV regime, there is no automatic authorisation of wagons from non-EU countries and vice-versa. An additional authorisation procedure is necessary.

The Sector reported that the formal process for resolving TSI deficiencies takes a long time. An example that was reported showed that from the initiation of the process requesting a technical opinion for WAG TSI errors to the official response by the Agency took over 1 year. A Railway Interoperability and Safety Committee (RISC) document is still under discussion.

The right balance between technical harmonisation and cost benefit analysis was raised through the implementation of the CR TSI WAG [3] in one country due to late discovery of the need for specific cases.

4.7.3 Locomotives

The legal technical requirements evolution applicable to locomotive authorisation procedure evolved as below:

RST CR Locomotive NRs

CR TSI NOI

2006/66/EC

CR TSI CCS SRT TSI

2008/163/EC

CR TSI CCS

2009/561/EC

2006/679/EC

2006/860/EC

2007/153/EC

2008/386/EC

[5] [8] [9] [10] [11] [7] [12]

Before 23rd June 2006 x

From 23rd June 2006 to 26th September 2006

x x

27th September 2006 to 6th November 2006

x x x

7th November 2006 to 5th March 2007

x x x x

6th March 2007 to 31st May2008

x x x x x

1st June 2008 30th June 2008

x x x x x x

1st July 2008 31st August 2009

x x x x x x x

1th September 2009 x x x x x x x x



















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To date there is no TSI in force for this category of vehicle. The TSI for LOC and PASS has been voted by Railway Interoperability and Safety Committee (RISC) in May 2010. It is envisaged to be adopted at the earliest by the end of the first trimester of 2011.

Amongst the 12 analysed business cases for type authorisation three fall entirely under NRs. The remaining 9 cases fall under the last 5 periods where some TSIs were in place.

4.7.3.1 The actors

The applicant

Amongst the 12 analysed business cases the applicant were:

Manufacturer - 46 %

Vehicle Keeper - 13%

RU - 41%.

NoBos/DeBos/Other checking bodies (Independent Safety Assessor)

For locomotives there was a greater degree of role consistency except that:

In one country, where there was no NoBo, a foreign NoBo was accepted

In one case the risk assessment related to signalling was validated by an Independent Safety Assessor

In one country the NoBo also acted as DeBo and Independent Safety Assessor for the assessment against NRs

National Safety Authorities

Again, the understanding of the role was clearer except that:

NSA also played the role of NoBo when there was no NoBo

NSA in cooperation with all involved actors checked the complete technical file including the tests results

In some cases the NSA only granted temporary or time limited authorisations with some restrictions

Infrastructure Managers

For IMs there was a low degree of role consistency:

In one case the IM was involved in the running tests in cooperation with the RU and the manufacturer

In one case, the applicant has selected the IM for the assessment of the locomotive compatibility with the infrastructure



The procedure for setting requirements is different and sometimes evolve during the authorisation:

In some cases requirements were further detailed during the preliminary discussions

In one country the requirements were settled by a NoBo for a modification of an existing design based on the evaluation of the changes from that design

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In one case “the requirements were clearly frozen” until the end of the authorisation

In one case the requirements were changed during the procedure

Checking network compatibility

The procedure is not clear :

In one business case, because the results of the network compatibility checks from other countries were considered insufficient, the IM proceeded with additional tests under NoBo supervision

In one business case, due to two different signalling system suppliers, network compatibility proved very difficult to verify


Preliminary engagement

In almost all cases, it was necessary to carry out a preliminary engagement, usually before the design stage.

In most of the countries all or part of the documentation had to be supplied in national language.

Intermediate Statement of Verification

The role of Intermediate Statements of Verification seems not to be clear because:

In one country the authorisation procedure has been temporarily suspended due to the difficulty to implement the current section 2 of Annex VI of the recast Interoperability Directive on Intermediate Statement of Verification

Authorisation

What constitutes authorisation and when a new authorisation is required is not clear:

In some cases the authorisation was issued temporarily, or with some resctrictions because of missing proof of compliance

In one case temporary operating authorisation was granted pending locomotives modification in particular of the Automatic Train Control/Automatic Train Protection system

In one country, the NSA asked for changes in the locomotive configuration for safety reasons. This was presented as an alternative either to the withdrawal of the already issued authorisation or a different operating conditions with an additional train driver

4.7.3.4 Specific issues of the locomotive category

Positive

The positive points in relation to authorisation for locomotives are that:

The current bi or multi-lateral cross acceptance agreements have started to reduce the total costs for authorisation

“Platform” based locomotives are also starting to reduce total costs for authorisation. There is currently no common definition of “Platform” in the regulatory framework..

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Negative


Although they are not required for wagons and passenger coaches, expensive endurance running behaviour type tests were required during authorisation for locomotives (850 k€).

Often, for the same project the manufacturer was the applicant for the vehicle type authorisation and the RU was the applicant for the vehicles authorisation thereby increasing the number of actors involved in the procedure.

There is currently no “type authorisation” procedure in the meaning of the the recast Interoperability Directive [1] but there are similar procedure in most of the national regulations relating to series continuation.

European Rail Traffic Management System (ERTMS)/ European Train Control System (ETCS) constitutes a significant cost driver for international operations.

4.7.4 Coaches

The legal technical requirements applicable to Coaches authorisation evolved as below:

RST – Coaches CR NRs CR TSI NOI

2006/66/EC SRT TSI

2008/163/EC PRM TSI

2008/164/EC

[5] [7] [6]


From 23rd June 2006 to 30th June 2008

x x

From 1st July 2008 to date x x x x

To date there is no TSI in force for this category of vehicle. The TSI for LOC and PASS has been voted by Railway Interoperability and Safety Committee (RISC) in May 2010. It is envisaged to be adopted at the earliest by the end of the first trimester of 2011

Amongst the 6 analysed business cases:

One falls under the first period

Three fall under the second period, and

Two fall under the third period.

4.7.4.1 The actors

The applicants

Amongst the 6 analysed business cases the applicant were:

Manufacturer - 50 %

RU - 50 %

NoBos/DeBos

For carraiges there was a certain degree of role consistency except that:

In one country the NoBo checked compliance with both TSIs and NRs and also performed some laboratory tests. The NoBo departments performing tests and checking compliance were independent.




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In one country the NoBo checked the tests results related to vehicle compatibility with the infrastructure either in a laboratory or on the network.

National Safety Authorities

Again, the understanding of the role was clearer except that:

In most of the cases, the role of the NSA regarding authorisation is an administrative verification of the documentation supplied by the applicant.

The NSA requests additional checks, when there are doubts.

Infrastructure Managers

For IMs their role in carriages authorisation was similar except that:

In one case the involvement of the IM was limited to commercial path allocation for infrastructure compatibility tests.



The procedure is not clear because:

In all cases the requirements were settled by the NSA or by the NoBo.

In one case the NSA was involved in the pre-engagement, during which the requirements were justified.


Authorisation

In one case, after completion of the technical file the authorisation was issued within the term regulated by the NRs or by the recast Interoperability Directive [1] .

4.7.4.4 Specific issues of the coach category

Positive

The positive points in relation to authorisation for carraiges are that:

In one case, a multi-lateral cross acceptance agreement was seen to have reduced the total costs for authorisation.

Negative


The market supply for coaches is mostly modification of existing vehicles. Therefore, the main issue is the handling of grand-father’s rights.

The LOC & PAS TSI (voted but not yet in force) does not include the principle of cross-authorisation for “Go-anywhere passenger coaches” (former RIC). This is considered as a step backwards by the sector.

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4.7.5 Train sets

The legal technical requirements evolution applicable to CR EMU/DMUs authorisation evolved as below:

RST CR EMUs/DMUs NRs

CR TSI NOI

2006/

66/EC

CR TSI CCS SRT TSI

2008/386/EC

PRM TSI

2008/1

64/EC

CR TSI CCS

2009/561/EC

2006/679/EC

2006/860/EC

2007/153/EC

2008/386/EC

[5] [8] [9] [10] [11] [7] [6] [12]


From 23rd June 2006 to 26th September 2006

x x

27th September 2006 to 6th November 2006

x x x

7th November 2006 to 5th March 2007

x x x x

6th March 2007 to 31st May2008

x x x x x

1st June 2008 30th June 2008

x x x x x x

1st July 2008 31st August 2009

x x x x x x x x

1th September 2009 to date

x x x x x x x x x

Amongst the 12 analysed business cases for type authorisation:

three fall under NRs

three fall under the last time period

one started in 2001 and the trainset was authorised in 2006

one started in 2006 , delivery envisaged between 2009-2014

one project started in 2007, application for placing in service sent in 2008, authorisation envisaged for November 2010

one project contract signed in 2005, preliminary type authorisation granted in May 2006, final authorisation in September 2008

one started in May 2009, a provisional technical admission issued for a limited period in 2010.

one started with application for the type authorisation on February 2008, requirements freezing on May 2006.





















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The legal technical requirements applicable to HS trainsets authorisation evolved as below:

RST CR EMUs/DMUs

NRs

HS TSI RST HS TSI ENE HS TSI CCS SRT TSI

PRM TSI

HS TSI RST

HS TSI ENE

2002/735/EC

Corrigendum to

2002/735/EC

2002/733/EC

Corrigendum To

2002/733/EC

2002/731/EC

Corrigendum To

2002/731/EC

2004/447/EC

2006/860/E

C

2007/153/EC

2008/386/EC

2008/163/EC

2008/164/E

C

2008/232/CE

2008/284/CE

[22] [23] [16] [17] [13] [14] [21] [9] [10] [11] [7] [6] [24] [18]

Before 1st

December

x

1st

December 2002 to 28

th April

2004 x X x x x x X

29th

April 2004 to 6

th November

2006 x X x x x x x x

7th

November 2006 5

th March 2007

x X x x x x X x x

6th

March 2007 31

st May 2008

x X x x x x x x x x

1st

June 2008 30

th June 2008

x X x x x x x x x x x

1st

July 2008 31

st August 2008

x X x x x x X x x x x x x

1st

September 2008 30

th September

2008

x

*

x x x x x x x x x x x

1st

October 2008 to date

x ** x X x x x x x x x x

* repealed and replaced by HS TSI RST 2008/232/CE

** repealed and replaced by HS TSI ENE 2008/284/CE

Amongst the three analysed business cases :

one project started in 2002 under the HS Directive 96/48/EC using the former NRs. The first train was delivered on August 2007

one project started in started in 2007, first prototype in 2088, expected in 2011

one case started before 2002, under NRs, in operation since 2000.

4.7.5.1 The actors

The applicant

Amongst the analysed business cases the applicant were:

Manufacturer - 66 %

Vehicle Keeper - 6,5%










































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RU -22%

Contracting Entity / manufacturer - 6,5%

NoBos/DeBos

For train sets there was a greater degree of role consistency except that:

In one case, a risk analysis required by the NSA in order to justify derogation from the HS TSI RST was conducted by a NoBo who had also undertaken the risk analysis report

In one case, the assessment against NRs was performed by a NoBo. National Safety Authorities

In contrast with other vehicle categories, their role was not clear because:

In one country the NSA granted a derogation from the HS TSIs in two cases.

In one country the NSA received 19 requests for derogation which were all accepted and granted.

In one case, which involved three NSAs, they accepted all assessments done under the supervision of each NSA and did not require multiple checks (Cross-acceptance agreement).

In one country the NSA granted a temporary authorisation with some restrictions (maximum speed) and additional requirements (operation records, maintenance plan, fulfilment of safety requirements).



The requirements are not clear because:

The bilateral agreement between an EU and a non-EU country specified the technical parameters to be complied with by the vehicles subject to this agreement.

In one country, after the vehicle was manufactured, it was discovered that one requirement related to crashworthiness was not fulfilled. This has been compensated by a risk analysis and a subsequent derogation.

In one case with authorisations sought with two countries, the different National legislations and operations practices were sometimes conflicting.

Checking network compatibility

The checks were related and almost specific to each business case:

In one case the running tests were performed by an independent non-EU country laboratory under supervision of a NoBo from another EU country

In one case all the actors (Applicant, Vehicle Keeper, Manufacturers, NoBo, and two IMs) organised the compatibility checks to prevent duplication of checks and inconsistencies between the two involved IMs.


Technical file

Requirements for Technical File are not clear because:

In one case, the different methodologies of the two involved NSAs, required the applicant to have two different technical files.

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EC Certificates

The EC certification procedure is complex because:

In the case of a HS train set, three EC certifications were required for the following subsystems:

HS TSI RST,

HS TSI CCS, and

HS TSI ENE

Authorisation

Authorisation for placing train sets in service contains several steps for the observed business cases:

In six cases, a temporary authorisation was issued pending validation of technical behaviour of the vehicles/safety case.

In two cases, the authorisation was split into two steps: Authorisation and authorisation to operate.

4.7.5.4 Specific issues of the train set category

Positive

The positive points in relation to authorisation for train sets are that:

In a number of cases, bi and multi-lateral cross acceptance agreements were seen to have reduced the total costs for authorisation.

Negative


The length of time for the authorisation procedure is longer compared to the other vehicle categories. On average, it takes 4 years for a HS train set to be authorised compared with the mean time for other vehicles being 2 years.

The main issues are related to network compatibility checks e.g. the train control systems.

The case where 19 derogations to TSIs were granted was observed only for this category. This might be because the TSIs requirements are too high or their implementation is complex. There is a perceived need for an implementation guide.

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5 Analysis of cost drivers related to vehicle authorisation

As noted above, in section 3, a separate study was conducted relating to cost driver parameters for additional authorisations. In order to understand the cost drivers for additional vehicle authorisations the Agency used two sources of information to identify these cost drivers:

The results of questionnaires to the sector.

The bilateral meetings with the sector.

The questionnaire was sent in June 2009 to the railway sector organisations to collect information about parameters considered to be cost drivers in the field of vehicle authorisation. The information received from the filled-out questionnaires was treated confidentially.

The Agency evaluated feedback from main manufacturers supplying European markets for locomotives and unit rolling stock.

The Agency assumed that the knowledge of such “cost drivers” would support the setting up of priorities for the evaluation of equivalence of NRs.

5.1 Identified cost driver Parameters

The study assumed at the beginning a number of technical parameters (see table 3) to be cost

drivers. The railway sector confirmed all these parameters to be cost drivers in the authorisation

procedure.

TABLE 3 - Cost driver parameters

Parameter Explanation

CCS Integration of ERTMS inside the vehicle.

Equipment of locomotives with additional Class B systems

Existing national trackside Automatic Train Protection/Automatic Train Control systems require the use of Class B systems in a vehicle.

Different requirement leading to exchange of pantograph

Different existing power systems as well as the different geometry of the overhead contact line may lead to additional/different requirements related to the pantograph.

Testing to proof running dynamic behaviour

Different track geometry characteristics (especially rail inclination) require the proof of running dynamic behaviour.

Aerodynamic effects Impact of aerodynamic loads caused by the vehicle upon other parts of the railway system and upon the environment.

Different brake performance requirements

Different brake performance requirements which result from constraints of the existing infrastructure.

Different requirements to design and equip driver’s cab

Different operational requirements which lead to modifications of the driver’s desk or cab.

Different national requirements on push pull controls

As different technical solutions of push pull control exist, traction units and steering coaches/coaches have to be equipped with the different solutions required by the operator.

Different national requirements on push pull controls

As different technical solutions of push pull control exist, traction units and steering coaches have to be equipped with the different solutions required by the operator.

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In addition the sector identified additional parameters as cost drivers, summarised in table 4.

TABLE 4 - Additional cost driver parameters

Parameter Explanation Reasons for its criticality

Electromagnetic Compatibility

The emission of electromagnetic fields from the vehicle must not influence any trackside signalling equipment (train detection systems). Currently this is an open point in the CCS TSI.

Field tests are required to check the compatibility with train detection systems.

Fire Protection and Emergency Measures

Different national requirements have in the past lead to additional assessments and may have caused major modifications to vehicles.

Note: Nowadays a European standard for Fire Protection is available. For newly designed vehicles the problem does not exist.

TCMS Software Assessment

Risk analysis/assessment of the functional modules of a locomotive/ fixed train composition.

Quality management of the software inside a locomotive/ fixed train composition.

Any change of functionality in the TCMS required for additional authorisations may cause a re-assessment of TCMS. The documentation has to be translated into other languages. Any modification of the TCMS for additional authorisations may cause the loss of the existing authorisation.

Door Control Functions

Safety requirements

Doorstep Operation (e.g. different platform heights and operating conditions in winter season)

Redesign of doors may be necessary.

Gauge conflicts

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5.2 Reasons for criticality of parameters

The study included an analysis of the possible reasons (see table 5) why these parameters are

considered to be critical.

TABLE 5 - Reasons for the criticality of parameters

Reason Explanation

Missing NRs Requirements. The NRs for a certain parameter are not known or not available to the applicant asking for authorisation.

Unwritten NRs. The NRs are known but not explicitly notified.

Test procedure lacking / missing requirements for tests.

The NRs are incomplete due to the missing requirements to check conformity to the NR.

Acceptance of presented documentation.

The NRs incomplete because the requirement related to the documentation for the proof of conformity to NRs is missing.

Additional Re-engineering costs to equip vehicle with additional / different hardware.

Due to the characteristics of the existing trackside infrastructure (e.g. related to the signalling system or energy system) additional hardware/components need to be installed on the vehicle.

The study did not reveal dominant causes which need specific attention. The reason “Additional Re-

Engineering (Additional Hardware)” came out slightly higher, which was not a surprise due to the

fact that different infrastructure characteristics in each MS (e.g. Automatic Train Control/Automatic

Train Protection) typically require additional hardware. In addition, the analysis of reasons revealed

that two parameters slightly dominate with regards to their criticality from a technical point of

view:

Equipment of locomotives with Class B systems

Different braking requirements

This leads to the conclusion that these parameters should be analysed with a higher priority when

cross-referencing NRs.

5.3 Economic Analysis of Cost Driver Parameters

Based on the feedback provided by the sector, the quantitative cost impact of the individual cost driver parameters is shown below in Table 6. The table indicates the costs for testing and assessment but does not include costs related to additional engineering; e.g. installation of additional pantograph, Class B system, etc.

While costs have been estimated or given to the Agency for the various stages of the authorisation procedure, in general, the benefits of authorisation (its purpose) have not been discussed or investigated. This is an issue to be addressed in part 2. Without the benefits, it is not possible to tell whether the costs are excessive or justified. It is also not possible to understand the disadvantages of removing aspects of the authorisation procedure, even though costs might be saved however it is fair to say that where duplicate checks are in place it is likely that this adds cost witjout benefit.

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A number of the actors commented that as there was no “Authorisation” before the Directives much of what is now done is seen as “additional source of costs and delays” again reinforcing the observation that the intended replacement of “homologation” procedure by the “authorisation” procedure has not taken place.

TABLE 6 - Quantitative evaluation of main cost driver’s parameters

Parameter Quantitative Cost Impact (Range)

Integration of ERTMS in vehicle. 25 – 200 k€

Equipment of locomotives with additional Class B systems. 100 – 150 k€

Different requirement leading to exchange of pantograph. 200 k€

Testing to proof running behaviour. 100 – 200 k€

Aerodynamic effects. 0 – 250 k€

Different requirements to design and equip driver’s cab. 25- 250 k€

Different brake performance requirements. 100 – 300 k€

Different national requirements on push pull controls. 20 k€

Electromagnetic Compatibility. 100 – 300 k€

Train Control and Monitoring System (TCMS) Software Management (incl. Functional Risk Assessment).

100 – 350 k€

Table 7 provides an overview of the relative cost impact as a percentage of the total cost of Additional Authorisation.

TABLE 7- Relative cost impact of parameters

Parameter Averaged Relative Cost Impact

(100%: complete costs of an

additional authorisation)

CCS 15

Equipment of locomotives with additional Class B systems. 15

Different requirement leading to exchange of pantograph. 10

Testing to proof running behaviour. 10

Aerodynamic effects. 5

Different requirements to design and equip driver’s cab. 5

Different brake performance requirements. 5

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Parameter Averaged Relative Cost Impact

(100%: complete costs of an

additional authorisation)

Different national requirements on push pull controls. 1

Other issues – not dealt with in this study, e.g. the authorisation

procedure. 34

The relative cost impact was derived from examples other than those used for the analysis of the absolute cost impact (see table 6). The sector was more open to providing figures for the relative cost impacts than absolute costs.

The high relative cost impact for the parameters related to CCS/ Class B systems result from two specific examples, where this cost impact was very high and dominant. It was not possible to assess if these examples excluded costs for additional engineering and hardware. Costs for additional engineering and hardware cannot be influenced by cross acceptance. These costs can be influenced by the chosen migration strategy towards a harmonised target system, which is outside the scope of the study.

5.4 Total Costs for an additional vehicle authorisation

The total costs of an additional authorisation for a locomotive or a fixed train formation vary significantly due to the following reasons:

Whether a MoU between the involved MSs already exists, when the additional

authorisation was planned and demanded? A cross acceptance MoU will reduce the

authorisation costs significantly.

Is the trackside infrastructure in the MS, where the vehicle will operate, similar or

different to the infrastructure of the MS where the first authorisation was granted?

The greater the difference, the higher the additional authorisation costs. These costs

cannot be influenced by cross acceptance agreements.

In the worst case (no existing MoU and significant difference of infrastructure), the additional authorisation costs can reach several million Euros.

Reported total costs for an additional authorisation (based upon the questionnaires and discussions carried out with rail manufacturers) vary between 900 k€ up to 2000 k€ per locomotive type.

5.5 Future potential total costs for additional authorisation

Total additional authorisation costs in the range of 400 - 500 k€ are considered to be reachable in the future according to section 5.5.5 of the Agency Intermediate Report on Cost Driver Parameters (See Annex 33). Potential UNIFE estimated that cost reductions due to cross acceptance will total up to 400 M€ for the next 15 years. The basis of this calculation is as follows:

In the next 15 years about 35 new different types of locomotives and 15 new fixed train-formations will be developed.

Each type of locomotive and fixed train formation will require an additional authorisation in 10 MSs (=500 additional authorisations).

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The average costs for receiving one additional authorisation were estimated to be 1600 k€ (which is in line with the feedback from the questionnaire).

A “perfect” cross acceptance may reduce the costs of an additional authorisation by 50% (800 k€)

This leads to a resulting cost reduction of 400 M€ within 15 years (discount factors ignored).

It is difficult to identify precisely the costs and delay generated by the authorisation procedure. Effectively, most of the actors from the industry (manufacturers, applicants) are very cautious on that.

5.6 Cost Driver Parameter Portraits

The Cost Drivers study (see Annex 33) attempted to understand and develop a picture of the cost

drivers affecting subsequent authorisations, the factors that lead to this and the importance of the

cost driver.

For each cost driver parameter a the portrait includes:

Categorising it as “A” parameter (not infrastructure related) or “C” parameter

(infrastructure related)

Explaining the reasons for its high impact,

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6 Obstacles to vehicle authorisation for placing in service

The Sector has not yet seen the benefits and reduced costs that come from replacing 27 national approaches to authorisation with one common approach envisaged by the Directive 2008/57[1].

The current authorisation procedure involving a mixture of requirements of EU Directives and NRs is considered by the sector more expensive and more extended than under the old regime. This is primarily because the checks and authorisations that the new procedure is intended to replace have mostly not yet been withdrawn. Furthermore, new constraints are occurring within the “new regime” (eg Noise TSI requirements).

6.1 Issues list

The issues list that follows have been identified from:

the business cases discussed with the 27 countries, with the experts involved in the authorisation procedure,

the Cross Acceptance Working Party, and

the Cross Acceptance workshop with the sector on vehicle authorisation.

6.2 Identified issues list

There is a need for better understanding of some Directive requirements:

o Different roles and responsibilities allocated to the actors in the different EU MS that hinders mutual trust and therefore mutual recognition

o The existence of more than one authorisation entity complicates the procedure

o The “trigger” for a new authorisation differs amongst EU MS even if partially planned in the Directives or through the TSI

o Different approaches to “Grand father’s rights”, where existing vehicles are allowed to carry on running even if not in conformity with the new rules that now apply for authorisation

o Disparity between applicable rules and the related assessments in the various countries requires the applicant/contracting entity and the manufacturer to adjust their application

o Understanding the difference between the new Authorisation procedure and the former Homologation procedure, and

o Better guidance for the completion of the Technical file.

Overlapping legislation

The need to set up NRs and make them transparent

Establishing equivalence of NRs

Limited mutual recognition of results of testing and inspections means that even though proof of conformity has been given there might be further additional checks

Management of the transition phase

Use of several languages for documentation for authorisation of cross-border vehicles that extends the project duration up to twice (CZ and its neighbouring countries) as opposed to NO where English is accepted which facilitates the procedure.

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Continuous change of legal framework

Organisational change management

Technical compatibility with the network (and other vehicles)

Timing of the application of requirements

Effects of other EU legislation

Sometimes the verification tests are also used for product development to de-bug products

Increased use of software products may exacerbate the problem highlighted in the previous point

Design quality of vehicles

Competencies of actors, and

Impact of the installation or upgrade of ERTMS lines.

The sector identified that a critical issue affecting all their authorisation procedure was the need for timely, synchronised and correctly transposed or implemented EU regulations (Directives and TSIs). Some of the identified issues are addressed with additional EU regulations and are developed in this section.

The following draft EU recommendations voted in October 2010 will form the basis of solutions to some of these issues mentioned above:

The draft Commission Recommendation DV29 [2]

The Commission Decision on the Reference Document, including the application guide on the Reference Document to be established by the Agency.

The main issues listed above are further detailed hereafter.

6.3 Need for better understanding of some Directive requirements

All of the actors identified that there were significant differences in interpretation of core parts of the Directives amongst the MSs.

The Commission Recommendation DV29 [2] addresses the following issues:

The concept of authorisation is understood differently between MSs/NSAs

The scope of authorisation is different between MSs

The role and responsibilities of checking bodies are interpreted differently e.g.

o The role and responsibilities of a NoBo

o The use of non recognised checking bodies such as Independent Safety Assessor

o Involvement of IM in the authorisation procedure.

The role of the NSA in the authorisation procedure varies from only checking the existence and completeness of the documentation in the technical file through to checking the work of the checking bodies and carrying out checks itself.

Though the first version of the Commission Recommendation DV 29 [2] addresses part of the issues, the following still need to be addressed in a future version:

Extent of modification requiring a new procedure for authorising the placing in service of vehicles authorisation - The threshold triggering a new authorisation is interpreted differently by MSs/NSAs,

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Vehicle type definition,

Independence criteria of checking bodies.

6.4 Overlapping legislation

Theoretically, there is a problem with overlapping legislation relating to authorisation on TEN and off-TEN. All MSs have adopted a pragmatic approach and have tended to adopt the newer legislation, typically with their old procedure, which may be sub-optimal.

Future national implementation of Directive 2008/57 [1] will need to cover both: on TEN and off-TEN and include additional authorisations.

Some Sector organisations have proposed that there is no requirement to wait for the scope of TSIs concerning rolling stock to be extended to cover existing non TENs lines because such vehicles are designed to operate over both types of networks.

This will give the opportunity for simplification and “cleaning up” of procedures.

6.5 Setting up of National Rules

Requirements for vehicle authorisation can be found at the moment in many documents and others may be “unwritten”. This creates uncertainty for the applicants.

However many of the rules specifying railway equipment in the past were internal “company rules” of the former national state railways. The scope and content of these “company rules” must migrate either to the RUs and IMs Safety Management Systems or to the NRs set by the MSs.

It is intended that this will be resolved by the publication of these rules in the Reference Document which will collate and make public all the national requirements for vehicle authorisation whatever their documentary origin.

The setting up of consistent and workable NRs (“cleaning up” of NRs) is a challenge that each MS has to tackle with limited resources.

6.6 Establishing equivalence of National Rules

Cross Acceptance (recognition of equivalence of rules between MSs) is already applied in some countries on a bi or multi-lateral basis.

However the decision criteria for an “A” category (equivalent) or “C” category (not equivalent) are not exactly the same in every agreement nor are they exactly the same as the definitions in Directive 2008/57 [1].

With the Commission Decision on the reference document voted in October 2010, this issue should be addressed as the Agency will establish an application guide for establishing the equivalence of NRs.

6.7 Management of the transition phase

Every MS will have to simultaneously:

transpose and implement the Directive 2008/57 [1] considering DV29 [2], and

clean up its rules when applying the Commission Decision relating to the Reference Document.

migrate the existing cross-acceptance agreements to the requirements of the Commission Decision on the Reference Document

There will be a transition phase where the former procedure and rules will need to evolve towards the new regime of establishing consistent and workable national legal frameworks.

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During the “current” transition phase (which theoretically ended on the 19th July 2010), there was a need to coordinate the MSs’ approach regarding procedure for authorising the placing in service of vehicles authorisation where feasibly possible while maintaining the current level of safety.

6.8 Languages

The use of several languages for vehicles to be authorised in several MSs is a burden for the whole sector. The MSs approaches varies from the very flexible ones who accepts documentation in other EU languages to the very strict ones who require an official translation of the documentation.

The EU Directives do not impose any particular language to the MSs but the sector wishes a simplified approach where:

the list of documents to be translated should be limited,

A set of documentation: Certificates, Declaration of conformity having a common format that will allow their mutual recognition without further translation by NSAs and others.

6.9 Continuous change of legal framework

Continuous changes in the legal framework (amendment of European Directives, entry into force or revision of TSIs, new EC Decisions, new National legislation, etc.) results in a learning process for all actors and additional costs for the industry.

To avoid over-burdening the sector it is necessary first to implement fully the applicable EU and National legislation and then to keep to a minimum extent the further legal changes or amendments.

The tracking of the changes to the applicable frameworks may be envisaged as a tool to partly overcome this issue.

6.10 Organisational change management

New organisations with new roles and responsibilities, new documentation and new procedure need to be managed. During transition this leads to discontinuity, uncertainty and cost for the sector.

This is an unavoidable issue linked to the transition phase but the following tools might be helpful for the whole sector:

Making Application guide or Guideline documentation available for the actors

Training the actors involved in the new procedure with the new tools

Foreseeing the changes, in particular within NSAs to ensure continuity.

6.11 Vehicle type definition

The definition of vehicle type is different between countries. This is under discussion in the Agency European Register of Authorised Type of Vehicles (ERATV) working party.

What triggers a new authorisation is linked to the vehicle type definition. A common approach from the MSs will be possible through only an European definition.

The sector advocate a new concept of “platform” not foreseen in the recast Interoperability Directive. The relationship between “type” and “platform” and how long a type authorisation is valid for a design (“grandfathers rights” for a design type that does not meet the current rules) needs to be determined in the near future.

DV29 [2] is clear - a vehicle additional authorisation in another MS checks only the network-vehicle compatibility

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The single exception to this is where a significant safety risk is demonstrated. Many NSAs were prepared to authorise vehicles that continued to be operated in conformity with the rules that applied when it was originally authorised, i.e. the vehicle had “grand-father rights”. The cases that were observed, e.g. Romania, Austria and Slovakia, only the parts that were modified needed to conform to the rules and specification. Nevertheless, the MSs and their NSAs found the authorisation of previously used vehicles difficult, especially in respect of additional authorisations, (authorisations in a second MS) for the following reasons:

Lack of visibility of the specifications that applied for its first authorisation in the first MS.

Transparency of the specifications that applied at that time in the second country to establish if it would have grandfathers’ rights if it had been first authorised in the second country.

Many of those participating in the bilateral meetings and particularly those from the sector felt that they could derive benefits from operating such vehicles but that further clarity in the procedure of authorising vehicles with “grand-father rights” was needed.

6.12 Technical compatibility with the network (and other vehicles)

An integral part of the authorisation procedure in the recast Interoperability Directive [1] is the verification of technical compatibility between network and vehicle, (e.g. Electromagnetic Compatibility between a new vehicle and existing train detection systems). In some countries this is not yet integrated into the authorisation procedure. We observed that often the IM operated an additional approval procedure in respect of technical compatibility with the network. Usually, this (quasi-regulatory) service is not paid for by the applicant/contracting entity unlike the services of a NoBo, DeBo or NSA.

The issue of technical compatibility is further complicated because a double-judgement approach is often used. An Independent Safety Assessor approves a safety case based on judgement and then the NSA/IM makes a second judgement on the safety case to authorise the vehicle. This approach lacks transparency and legal certainty as the judgement based approach means that:

A future applicant is unaware of what the NSA has accepted as “safe enough” for previous authorisations,

An applicant has no certainty that what was accepted last time will be accepted this time, and

An applicant has no certainty that what has been accepted as part of an application by another party will be deemed acceptable for him.

It is important to understand how and when MSs will migrate to a position where these open points in NRs will be filled and the potential for discrimination between applicants will be eliminated.

6.13 Timing of the application of requirements

Some MSs include a “requirements freeze” in their procedure whereby at a point the applicant, the manufacturer and the NSA agree which specifications and rules will apply. In other MSs applicants are exposed to the risk of rule changes until the day of authorisation. This legal uncertainty often adds costs and delay in the form of last minute modification and the associated verification. At such a late stage any modifications will be extremely costly.

In order to facilitate the opening of the market and to avoid “surprises” manufacturers need to know the rules at the time of commencing their design. This can often be up to two years before authorisation.

Ironically, during the period of the delay whilst a modification, to deal with new rules which have come into force after design but before authorisation, is being designed, implemented and

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checked, train services are usually operated with older vehicles that do not conform to the new requirement but are protected by grandfathers’ rights.

The mismatch in approach is also an obstacle to cross-acceptance between MSs and is particularly difficult to deal with if the new rule is a TSI that is applied at different times by the EU MSs.

6.14 Effects of other EU legislation

Sometimes requirements of other EU Directives complicate the authorisation procedure, e.g. Electromagnetic Compatibility Directive.

6.15 ERTMS Challenges

Authorisation of on-board ETCS and Global System for Mobile communications – Railways (GSM-R)

present some especially difficult challenges. This is primarily because ERTMS projects have been

managed and authorised in a way that is not consistent with the principles and requirements of the

three interoperability directives. In particular most (possibly all) of the existing ERTMS schemes

were project managed and authorised as self-contained systems integrated across trackside and

on-board but not with each other. As a result the underpinning principle of interoperability - that a

TSI conform train may operate on a TSI conform network without the need for any additional

certification or checks is not in practice respected.

This has had several effects on the authorisation procedure.

Whilst existing ERTMS installations are safe, the essential requirement of Technical Compatibility

contained within the three interoperability directives, more specifically that “The technical

characteristics of the infrastructure and fixed installations must be compatible with each other and

with those of the trains to be used on the rail system “ has not been respected. For example, within

one country there are three incompatible ETCS installations with no guarantee of compatibility

between the various national GSM-R networks. Keepers wishing to install GSM-R for “go anywhere”

operation are told that they must have a different SIM card for each network.

The policy of MSs (or their IMs) has been to specify their national versions of ETCS to most closely

match the national signalling systems (in some cases including requirements that contradict those

in the TSI). This has led to maximum diversity in the application of ETCS and correspondingly higher

overall costs for design, testing, certification and authorisation than those which would have been

achieved with a more consistent set of project applications.

Futhermore, because of the lack of clear separation of on-board and trackside requirements for

authorisation the different on-board requirements for each ETCS fitted route have not been

published as NRs. Indeed, because they have been contained within project “safety cases” most

MSs and their NSAs are unaware of the requirements for on-board ERTMS against which vehicles

have been or should be authorised.

In parallel with this the existing TSIs contain a very broad scope of possible implementation options

and interpretations. Because of this uncertainty and diversity, it has not yet been possible to

achieve a test regime to give sufficient confidence for on-board that ensures ”Technical

Compatibility” between all possible combinations of options and interpretations that may be used

trackside.

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Meanwhile Specific Transmission Modules (STM), integrated into on-board ETCS to enable

operation with national signalling systems, create a further dimension of diversity of requirements

to be checked at authorisation and also to be rechecked each times an additional authorisation for

another ETCS route or MS class B system is required for the on-board installation.

In this context suppliers of ETCS on-board have designed equipment tailored for specific trackside

solutions rather than for interoperable operation. As an example, one manufacturer reported that

there are 350 parameters within their on-board product that need to be configured and tested. This

takes around 12 months of simulation and on-track testing. Missing confidence in the reliability and

safety of ERTMS products, the NSAs require, for each new configuration of a locomotives with

ERTMS, proof by on-track testing, which in some cases can be very time consuming, especially in

vehicles with multi-system configurations and Specific Transmission Modules (STM).

To complete the picture of diversity it appears that at the moment no ETCS on-board product

meets all the requirements contained within the TSI specifications.

As well as driving up the cost and complexity of design, manufacture, verification and authorisation,

the diversity of requirements between projects and non-transparency of these requirements means

that mutual recognition between NSAs of ETCS checks and authorisations is not in place. There are

no ETCS cross acceptance agreements and only one MS has supplied any national ETCS or GSM-R

requirements for the Reference Document of NRs. Duplicate verifications and checks between MSs

are inevitable.

In fact the process historically used for authorisation of vehicles with ETCS on-board makes

interoperability a logical impossibility. A vehicle that has been authorised in one Member State will

need at least software changes to make it compatible with the second Member State’s

implementation of trackside ETCS. These modifications invalidate the first authorisation, so the on-

board will need a new authorisation for the first Member State.

If this new authorisation for the first Member State requires further changes then the authorisation

in the second Member State then becomes invalidated.

This effect is compounded if operation is intended over several Member States networks. The facts

that each Member State’s ETCS on-board requirements on top of ETCS specifications are not

transparent and Member States require that upgrades of infrastructure also trigger new

authorisation of on-board often makes the problem even worse. In consequence the authorisation

of on-board ETCS and GSMR is considered by keepers and RUs as expensive, uncertain and time

consuming. For international operation ETCS and GSMR authorisation presents a high risk obstacle

to be overcome. For an existing locomotive ETCS installation can add between 25% to 60% to the

lease price.

More work needs to be done to:

establish the cost and timescales for an additional authorisation for subsequent ETCS routes

manage the installation/upgrade of ETCS and GSMR lines in a better way, and

identify the way forward to resolve all the issues of diversity, non-transparency of

requirements and non-interoperability highlighted above.

This will be covered in the Agency report on ERTMS certification and part 2 of this report.

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Concluding remarks and Next Steps

We conclude that there is a generally rising trend in the number of authorisations, with a pause taking place at the moment as a result of the economic recession. Before the recession, resources for authorisation in the NSAs were tightly stretched and following cutbacks by MS governments resources may be further stretched during the recovery and beyond. NSAs and Ministries therefore have a keen interest in simplification of the procedure and the elimination of duplicate checks by mutual recognition.

The procedures, roles and responsibilities are different in every country. This complexity is compounded by the fact that the directives are interpreted and implemented differently in every country. Within the different legal frameworks in which they have to work many NSAs have reached “cross acceptance” agreements to take best advantage of potential mutual recognition. However whilst there is no common approach to the procedures, roles and responsibilities, the benefits of mutual recognition are limited. It is helpful that a common approach is being put in place by the recast Interoperability Directive and that there is a common approach to how it is to be implemented in document DV29 [2]. Nevertheless, it is clear that there is still a lot of work needed to implement this common approach. Compared to other transport sectors the concept of a “shared system” is very much in its infancy in the rail sector. To achieve interoperability existing ERTMS authorisation procedures must be changed to conform to the requirements of the recast Interoperability Directive, in particular those relating to transparency of national requirements and the achievement and verification of Technical Compatibility. This report has set out the facts relating to Vehicle Authorisation, backed up by clear evidence from NSAs and the Sector. The Agency intends to issue a Part 2 of this report which will take account of ongoing workstreams and outline the way ahead. Looking at the issues identified, it will establish whether a solution or simplification is already in place or planned. Where no route to resolution is in place it will identify options and opportunities. It is expected to be published in conjunction with the planned “high level task force” on vehicle authorisation.

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7 Annexes

Annex 1- Used designations and abbreviations of Member States

Annex 2- Results of the ERA vehicles authorisation survey

Annex 3- Final report on vehicles authorisation processes in Spain

Annex 4- Final report on vehicles authorisation processes in Finland

Annex 5- Final report on vehicles authorisation processes in Norway

Annex 6- Final report on vehicles authorisation processes in the United Kingdom

Annex 7- Final report on vehicles authorisation processes in the Czech Republic

Annex 8- Final report on vehicles authorisation processes in France

Annex 9- Final report on vehicles authorisation processes in Germany

Annex 10- Final report on vehicles authorisation processes in the Netherlands

Annex 11- Final report on vehicles authorisation processes in Latvia

Annex 12- Final report on vehicles authorisation processes in Northern Ireland

Annex 13- Final report on vehicles authorisation processes in Austria

Annex 14- Final report on vehicles authorisation processes in Belgium

Annex 15- Final report on vehicles authorisation processes in Bulgaria

Annex 16- Final report on vehicles authorisation processes in Switzerland

Annex 17- Final report on vehicles authorisation processes in Denmark

Annex 18- Final report on vehicles authorisation processes in Estonia

Annex 19- Final report on vehicles authorisation processes in Greece

Annex 20- Final report on vehicles authorisation processes in Hungary

Annex 21- Final report on vehicles authorisation processes in Ireland

Annex 22- Final report on vehicles authorisation processes in Italy

Annex 23- Final report on vehicles authorisation processes in Lithuania

Annex 24- Final report on vehicles authorisation processes in Luxembourg

Annex 25- Final report on vehicles authorisation processes in Poland

Annex 26- Final report on vehicles authorisation processes in Romania

Annex 27- Final report on vehicles authorisation processes in Sweden

Annex 28- Final report on vehicles authorisation processes in Slovenia

Annex 29- Final report on vehicles authorisation processes in Slovakia

Annex 30- Final report on vehicles authorisation processes in Portugal

Annex 31- Summary of the applicable legislation to the 4 different modes of transport: road, air, maritime and rail in the European Union

Annex 32- Individual analysis of process interfaces

Annex 33- Report on cost driver parameters within the list of parameters in section 1 of annex VII to the 2008/57/EC

Annex 34- Impact Assessment Report - A baseline study. Current Authorisation Processes and Cost Drivers for railway vehicles

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