To make possible the planned upgrades rolling stock programs through a realistic, ambitious, and simultaneous deployment of ETCS BL 3.
AERRL has analysed the ERA « Clarification note Authorisation of vehicles equipped with CCS train protection part according to set of specifications #1 (Baseline 2) after 31/12/2020 » (version 1) and has identified the negative consequences of this note for railway leasing companies and the competitiveness of rail transport. Due to this interpretation of the CCS TSI, many of planned upgrades rolling stock programs cannot be carried out, what means that safety and quality cannot be improved anymore during the several years needed to realize the ETCS BL 3 upgrade of thousands of railway vehicles across Europe. The ERA interpretation could not be able to meet its objective of generalized equipment in BASELINE 3 as soon as possible. AERRL urges ERA to organize a consultation with all the actors to allow the rolling stock owners to realize their planned upgrades programs and in the meantime to get the needed commitments regarding a simultaneous and realistic deployment of BL 3.
Locomotive lessors have over the past years massively invested in modern corridor, electric, diesel and dual-mode locomotives to support the cross-border operation of numerous European Freight and passenger railway Operators. Most of these are natively equipped with ETCS BL 2 and more recently BL 3.
The AERRL members have long been committed to the interoperability of ERTMS, the timely deployment of the best technologies and the regular upgrade of the vehicles they lease.
Thanks to the support of EU subsidies scheme, most of the AERRL members have already committed in upgrading their fleet towards ETCS BL3, from BL2 or legacy configuration.
To keep their fleet ready for operation in the different European countries also in the next few years, they have planned with the manufacturers some intermediate steps until BL 3 is available from the industry. For example, the following modifications are essential:
- Upgrade to comply with necessary upgrades on national class B systems or related systems.
- Bug fixes and usability improvements of current BL2 systems.
- Upgrade the GSM-R module (to be conform with national regulations).
- Upgrades and software release on Onboard Units or Gateways.
The ERA hereabove mentioned clarification note, which has a scope surprisingly broad, has implications for these upgrades plans that have not been foreseen.
This note makes the ETCS Baseline 3 mandatory for 3 groups of vehicles :
- The newly built vehicles installing for the first time ETCS after 31/12/2020.
- The vehicles for which an upgrade of ETCS is planned after 31/12/2020.
- The vehicles for which an upgrade is planned after 31/12/2020, which is not an ETCS upgrade, but which has directly or indirectly an impact on the use or functionalities of the existing ETCS.
Given that the AERRL members had not foreseen that the mandatory Baseline 3 would extend to pre-defined hypothesis 3, the clarification note could have one of the following three consequences:
- Modifications here above described under point 3 and requiring a new authorisation will be postponed or cancelled to avoid the refusal to approve the material because it’s not equipped with Baseline 3.
- Locomotives will be grounded because of the physical impossibility of performing the upgrades required by ERA, with huge consequences on the competitiveness of the railway sector.
- Safety and quality of railway operation cannot be improved due to the suspended possibility of upgrades on current systems.
Beyond the arguments that specifically concern the constraints of the lessors and other rolling stock owners, the ERA interpretation of the CCS TSI could not be able to meet its objective of generalized equipment in BASELINE 3 ETCS as soon as possible for 2 reasons.
On one hand, the manufacturers can give you some details of their vehicle release planning to prove that BL3 is already in planning, but also that to solve current problems, intermediate steps are necessary.
On the other hand, the infrastructure managers have not deployed the system yet. The first countries in Europe (after DK) with BL3 active are Belgium and Switzerland but not before 2025.
Furthermore, the necessary time for upgrading thousands of railway vehicles across Europe is several years.
For all these reasons, AERRL urges the European Agency for Railways to organize consultation with all the actors to allow the rolling stock owners to realize their planned upgrades programs and in the meantime to get the needed commitments regarding a simultaneous and realistic deployment of BL 3.