Matthias Ruete, European Coordinator for ERTMS, published in July 2022 his Second Work Plan in a context of revision of the technical specification for interoperability (TSI) relating to the Control Command and Signalling (CCS).
AERRL welcomes the European coordinator’s commitment to a better synchronised deployment, both for the trackside and on-board. Furthermore, AERRL makes concrete proposals to jointly move towards a single European system.
Further EU coordination required after 15 years of regional implementations without a joint planning and standardized roll-out.
15 years after the start of ERTMS programme, 14% of the revisedCNC network operates with ETCS. About 18 % of the European locomotives fleet is equipped. EU is still struggling to ensure interoperability in a diverse European environment of national approaches. Synchronised deployment however requires a strong coordination at EU level.
Infrastructure managers and EU member states are not obliged to invest nor to publish any binding implementation schedules. Only vague forecasts are provided to rolling stock keepers, which nevertheless are required to make huge investments in on-board ETCS equipment.
A European digital platform publishing the level of the characteristics, as well as the planning of deployment of the ERTMS on the European core network corridors, which fits the needs for railway undertakings, fleet owners and the supply chain doesn’t exist.
AERRL urges the EU to coordinate a uniform implementation of ERTMS deployment at EU level, by making detailed publication of planned and contracted track side deployment compulsory for Member States or Infrastructure Managers. Furthermore, AERRL supports an empowered centralised European system authority in the form of ERA.
Retrofitting of rolling stock to be 100 % subsidized in order to further develop competition
Newly delivered ETCS rolling stock which receive subsidy under the CEF program, are competing against existing modern 15 years old rollingstock. This older equipment needs costly retrofits or upgrades with limited funding support from EU. For these the subsidies granted by the European Commission barely cover 20% of the ERTMS related investments, this level being even lower for 15 years old rollingstock.
Costs increased year after year, mainly for retrofitted equipment. Insufficient subsidies and increasing costs make investments in complex retrofit and upgrade of ETCS on-board for existing rolling stock increasingly loss-making. If the costs of retrofits and upgrades remain high and continue to be mainly funded by locomotive owners without any substantial EU support, new entrants will no longer have access to locomotive equipped with the ETCS BL compatible with the infrastructure and existing equipment will be early retired. This leads to the opposite of what is intended under the ERTMS programme, it being the creation of a single European railway area.
AERRL urges for
-CEF ERTMS budget to cover 100 % of costs for retrofitting and upgrading rolling stock
-Amount of subsidies per ETCS on-board unit cost to be reviewed with the aim to integrate retrofitting and upgrade projects
-ERTMS retrofit prices to be kept under control by creating the conditions for a competitive market and/or ensuring maximum cost of retrofitting equipment
-A review of the EU funding framework conditions in terms of maturity of project, granularity in project assessment, definition of terms, flexibility, inclusivity, and predictability.
An audit or the rejection of the draft CCS TSI 2022 revision contrary to the foundations of the Green Deal
The current draft of the new CCS TSI is conceived for a non-existing rail-world where interoperability is already a reality and class B systems have disappeared. Its authors have ignored that during the next 15 years class B systems will be still in operation.
As described above, the situation is currently critical for equipment that is 15 years old and has another 15+ years of life ahead of it. This is not only due to the need for installation of one or several class B systems on cross-border rolling stock. This is also due to too frequent compulsory technological changes at EU level (2 in 15 years’ time). Rolling stock owners must invest in different class B systems and upgrade the EU safety system after a few years implementation, which increases the risk of obsolescence for modern 15 years old locomotives, not to mention older equipment.
The introduction of another new base line (BL4) after two major changes in the past 15 years, forms a direct threat for the existence of multiple keepers in the rail industry, directly negatively impacting the effect of the Grean Deal.
In addition, locomotive owners must endure an inflation of ESC-types: infrastructure managers can introduce per line an ESC-type, where rolling stock must be tested and approved, this contradicts the European approach to a region lines network across Europe.
Example: a loco for the corridor BE/NL-DE-CH-IT: before 5 class B-Systems, now planned ~50 ESC-types that all shall be tested & approved per vehicle type (numbers: NL: 23, BE:4, DE:3, CH: 3, IT: 18).
AERRL denounces EU draft measures accelerating the obsolescence of European modern rail rolling stock and urges for a sustainable planning of implementation of ERTMS BL 4, guaranteeing a life cycle of at least 15 years for renovations/improvements carried out or in progress.
Only changes in accordance with industrial capabilities are safe and can be made mandatory
The current industrial capacity to meet all the requirements for the implementation of the ETCS BL 3 on-board unit is insufficient. Industry is working under time pressure and will not have upgrades for all equipment types ready within the set timelines.
In such a context, EU aims to make mandatory BL4 requiring further upgrades to be executed in a short time, without knowing if the industry can meet all the demands for supply and retrofit/upgrade of locomotives with the new BL in the defined timeframe. This haste and lack of organisation jeopardizes the EU’s commitments about excellence in railway safety culture.
AERRL urges for an in-depth audit before the possible approval of the EU Commission proposal of CCS TSI 2022 revision. Such audit to provide a clear development planning established in close consultation and cooperation with the industry, based on the industry capacities, and decreasing prices for fit, retrofit and upgrade, with industry’s commitment.
Because the situation is critical for equipment that is 15 years old and has another 15 years of life ahead of it, the European Rail Rolling Stock Lessors need before setting a deadline for the implementation of a new ETCS BL,
-full transparency of Member States and infrastructure managers made mandatory and strengthened ERA power as system authority, in order to open the door to a synchronised and coordinated deployment.
-be assured that ERTMS retrofit prices are under control by creating synchronised conditions for a competitive market and/or ensuring maximum cost of retrofitting equipment.
-be assured that the EU has the necessary budgets and funding framework conditions, to be able to support all operators wishing to invest; EU subsidies for Rolling stock should provide 100% of the costs related to ERTMS retrofit and upgrades.
-be assured that each baseline has a lifetime of at least 15 years.
-a full and independent audit of the industry capability to deliver the ERTMS retrofit in due time: including engineering and production capacities, deadlines and commitments.
Without taking into account these essential requirements, the current draft revision of the CCS 2022 TSI undermines the foundations of European railway safety requirements, ERTMS role out, Green Deal and fair competition in the single European railway area.