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° Railway sector organisations, NSAs, Notified Bodies
° Collects results of WGs (e.g. EMC WP) on closure of
open points
° Proposes clarifications and editorial improvements
° Takes care of coordination with related activities
(other TSIs, Registers)
° CCS WP, where all sector organisations, NSAs, Notified
Bodies coordination are represented

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° Every change marked in the CCS TSI draft is explained

and justified; the possible impact (e.g., product
development, certification process, etc.) is indicated
° Supported by a draft of CCS TSI with marked revisions
with respect to the text currently in force

#  % & % % & $

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° A single CCS TSI for HS and CR network
° ERTMS implementation rules according to the deployment
plan (͞old͟ chapter 7 and already approved amendment)
° HABDs and on-board data recorder are now in the rolling
stock TSIs
° Clarification on maintenance requirements, distinguishing
what shall be done for the certification of the structural
subsystem, and is therefore in the scope of the TSI, and
what is outside the scope and in the responsibility of the
SMS of the operators

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° The list has been updated with the new versions of
some specifications approved in the Change Control
is replacing former Appendix 1 to
Annex A and is referred in Annex A as Index 77
° m  
are a part of the 


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° The list of open points in % & ' has been updated
according to
Ñ Closed open points since the entry in force of the current
Ñ Clarifications in the new CCS TSI
è current situation
° EMC requirements are   

Ñ R  
means that there is no harmonised solution for
EMC requirements
Ñ 
 ! (National Technical Rules) are applicable to
open points
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ï Electromagnetic fields
ï DC and low frequency components of traction current
ï 25kV AC, 50Hz Electromagnetic interference limits for traction
ï 15kV AC, 16,7Hz Electromagnetic interference limits for traction
ï 3kV DC Electromagnetic interference limits for traction current
ï 1,5kV DC Electromagnetic interference limits for traction current
ï 750V DC Electromagnetic interference limits for traction current
ï Use of magnetic / eddy current brakes

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( &
° For the   
for different train
detection systems a step-wise approach has been chosen
Ñ Initial work package is dedicated to the elaboration of the
EMC solution for axle counters; proposals for track circuits
for different traction systems will follow subsequently
Ñ EMC WP experts have proposed already a solution for the
frequency management for axle counters
Ñ The proposal is complete, but proposed values for emissions
in 3 frequency ranges are not validated yet
Ñ The Agency would like to include the proposal in the
Interface document for voting on the CCS TSI draft proposal
in March by RISC, but it depends on results of current efforts
Ñ The Agency has also evaluated a possible impact assessment
of the frequency management proposal for axle counters
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  R * 

A positive economic impact is expected from the closure of the
current open point related to the Electromagnetic Compatibility
(EMC) concerning the interface between vehicle and train
detection systems.
Up to now, there are no harmonised values for emission /
susceptibility and the national rules are quite different, also
because of the different types of equipment applied. In the
framework of this revision, the open point related to EMC will be
partly closed for axle counters.
It is assumed that the applied methodology for the assessment of the
impact of a harmonized frequency management for axle counters
can be applied for track circuits as well.
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‰ "  

‰ "  

In general, a solution proposal will be specified as a frequency
management. The figure below shows how such frequency
management looks like in general for axle counters:

Example of a Frequency Management

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¦ "   



1. Number of allowed frequency bands for the operation of axle counters.
The number of frequency bands may depend on technical/physical
principles based on train detection. Figure 1 assumes the possibility of
using, after the closure of the open point, two different types of axle
counters working in frequency ranges close to 30 and 300 kHz (same
technology, but different frequency range) and one type, based on
a different technology, working in a range close to 1 MHz
2. Bandwidth of a frequency band
3. Limit upper value for the magnetic field (B) between frequency bands
4. Limit lower value for the magnetic field (B) inside a frequency band.
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The railway sector proposed a frequency management based on the

analysis of the susceptibility of ͞preferred͟ axle counters.

The frequency management of traction currents for track circuits has

the same shape (other frequency ranges of the frequency bands,
the traction current I is measured instead of the emitted magnetic
field B).

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This solution proposal impacts the different stakeholders differently:
å Vehicle suppliers due to the fact that the solution proposal may have
an impact on the design of new vehicles (locomotives and fixed train
å Suppliers of train detection systems due to the fact that the solution
proposal may have an impact on existing and new products.
å Infrastructure Managers due to the fact that the solution proposal
requires a trackside migration strategy.
å Railway Undertakings due to the fact that the solution proposal may
have an impact on the compatibility of existing (operated) and planned
vehicles with train detection systems conform to the solution proposal
(for RUs a vehicle based migration strategy is needed as well).

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*  &¦ 

R * 

UNIFE estimated 500 additional authorisations in the next 15 years.

So far, costs for EMC testing in the framework of an authorisation
are about 200 kΦ. No additional EMC testing is necessary if this
open point is closed. For this reason maximum expected total
benefits are 100 Mio Φ within a timeframe of 15 years or about
7 Mio Φ / year.
These benefits can only be realised once the open point is closed for
all kind of train detection systems and the trackside migration to
an interoperable train detection system is completed. In addition
harmonized requirements have to be applied for the off-TEN
network as well.

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% "   

For the more detailed analysis of the cost impact a questionnaire [9] was
sent out to the railway sector end of July 2009. In the following the
possible cost impact is described in a more qualitative way:
X Cost impact for vehicle manufacturers during the migration phase:
It can be assumed, that most existing vehicles are already partly
compliant to the solution proposal è they are compatible with at
least one of the ͞preferred͟ axle counters from which the proposed
frequency management is derived. In case of a renewal of a non TSI
conform axle counter an infrastructure manager will likely replace
the axle counter by a TSI compliant axle counter which is already
compatible with existing vehicles intended to run on the concerned

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Critical are vehicles not compliant to the solution proposal at all è in

this case a vehicle would not be compliant to none of the proposed
preferred axle counters. In case of a renewal of a non TSI compliant
axle counter, these vehicles cannot operate anymore and need a

There may be an additional negative impact, if existing vehicles would

be upgraded or modified and the Member State would demand to
apply the provisions of the TSI (related to EMC). In this case it has to
be assessed if existing vehicles already meet all requirements of the
solution proposal. As a consequence, these vehicles being not
completely compliant to the solution proposal need a modification.

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X Cost impact for vehicle manufacturers after migration phase

There might be any positive (or negative) impact expected in vehicle
design/production once only the harmonized TSI requirements have
to be met.
X Cost impact for manufacturers of train detection systems (axle counters)
There might be any positive (or negative or zero) impact expected in
design/production of new axle counters meeting the harmonized TSI

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X Cost impact for IMs

In case of renewal/upgrades, Infrastructure Managers may be
negatively or positively or zero impacted by being forced to install
TSI compliant axle counters. The impact might be very low due to
the fact that the ͞preferred͟ axle counters, which should be TSI
compliant, were selected by Infrastructure Managers.
X Cost impact for RUs
Existing vehicles, which are subject to a major modification/upgrade
in the future, likely have to meet all provisions related to EMC
concerning axle counters. This may cause a further modification
of these vehicles.
Existing vehicles which are not compliant at all to the proposed
solution, will need a modification once non TSI compliant axle
counters are replaced by axle counters being TSI compliant.
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According to the questionnaire, feedback was expected until end of
Oktober 2010. Until End of November the following feedback was
received and evaluated from:
ï Four vehicle manufacturers (Alstom/DE, Bombardier/FR,
Siemens/DE, Vossloh/DE)
ï Two European manufactures of axle counters (Siemens,
Frauscher), one non-EU manufacturer AltPro located in Zagreb
ï Nine main infrastructure managers from AU, CZ, DE, ES, HU, IT,
ï Two Railway Undertakings from NL and SK

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In the following focus will be given on the reported critical issues.

The impact to assess if an existing rolling stock design is compliant to
the FM, can range up to 800 kΦ per vehicle type and about up to
10 kΦ per vehicle. In addition, the impact to make existing vehicles
compliant to the FM can range up to 700 kΦ per vehicle. The
Agency will contact the concerned companies in order to analyse
the reasons for this high impact in more detail.
For new rolling stock designs, no negative impact seems to be
Most infrastructure managers reported no major cost impact for the
migration to TSI compliant axle counters in their network.
Nevertheless they stated that the migration will take at least 20
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DB Netz emphasized that two types of axle counters (ZP 43E and ZP 43M)
are not meeting the requirements of the frequency management.
A large amount of these types are installed in their network
(24.000/5.000). Migration to TSI compliant axle counters is only
economically viable in the context of a complete resignalling project
covering the exchange of interlockings. For these axle counters,
compliancy to TSI cannot be reached in the context of a normal renewal
project, where only counting heads are exchanged.
Therefore, the migration in Germany will take a very long time (at least
20-30 years). For the Agency, the economic impact on vehicle side is not
clear, if the frequency management would include the limit values
of these axle counters. In this context, it has to be considered that
anyway all vehicles operating in Germany have to be compatible with
these axle counters as long as they are installed in the network. Further
evaluation is necessary.
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In addition, a number of infrastructure managers expressed their

wish to use specific non compliant axle counters even in case of
new or renewal projects (e.g. RFI/BCA 2002 Ducati, SZDC/PZN-01,
ZSR/RSR122) and ask for a Specific Case or a modification of the
frequency management. For all cases an economic justification
was not provided. Nevertheless the amount of concerned axle
counters seems to be very low.
Prorail from The Netherlands reported, that most (maybe even all) of
their currently installed axle counters are not compliant to the
proposed frequency management. They fear a negative impact on
rolling stock side once these axle counters are replaced by TSI
compliant ones due to the fact that existing rolling stock has to be
modified significantly.
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This negative impact on vehicle side for The Netherlands was
confirmed by the railway operator ͞NS Reizigers. It reports that
3000 vehicles are concerned and may be modified if the existing
axle counters are replaced by TSI compliant axle counters. It has to
be verified if the existing trains are not compatible to none of the
͞preferred͟ axle counters from which the frequency management
was derived.
In addition, it has to be checked if the list of preferred axle counters,
from which the frequency management was derived, includes axle
counters already in use in the Netherlands. If not, it has to be
investigated what kind of effect on train detection side or rolling
stock side is expected, if one of the currently used axle counters in
The Netherlands is considered in the frequency management as
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The European manufactures for axle counters confirmed that all their new
products will be compliant to the frequency management. Nevertheless
variable product specific costs may slightly increase (depending on type of axle
counter è e.g. Frauscher expected additional costs for TSI compliant counting
heads of about 1.300 Euro per head è this results in a total negative impact
of about 5 Mio Euro for all their European customers in case of renewal of the
existing axle counting system)
One non European Manufacturer (Altpro in Zagreb) reported that all their products
are currently not meeting the requirements of the frequency management.
Currently more than 4.000 axle counters are concerned. These types of axle
counters are already installed in some Member States e.g. Serbia, Spain,
Portugal, Hungary , and France. Unfortunately Altro did not mention the cost
impact for the modification of these axle counters so that they are compliant
to the frequency management. In addition no infrastructure manager in the
concerned Member States reported a negative impact resulting from the
renewal/upgrade of this type of axle counter.
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During the migration phase, the critical cost impact results from vehicles being
not compliant at all with the solution proposal (or in other words not
compatible with none of the preferred axle counters). These vehicles will
not anymore be able to operate on lines where existing axle counters are
replaced by TSI compliant axle counters.
Most existing vehicles are expected to be partly TSI compliant (i.e., compatible
with at least one of the ͞preferred axle counters͟). In order to reduce the
impact during migration, the Infrastructure Manager should install in case of
renewal or upgrade only TSI compliant train detection systems which are
also compatible with existing partly TSI compliant vehicles as well.
The analysis of the received impact reported by the railway sector leads to the
conclusion that specific provisions related to renewal/upgrade are needed
in chapter 7.

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Considering the situation of Germany, in several cases a non TSI compliant

axle counter cannot be renewed by a TSI compliant axle counter in
an economically viable way è especially if such renewals would require
changes in the interfacing interlocking system.
For this reason, the current draft TSI only mandates the application of the
TSI related to train detection systems when respecting the requirements
of the TSI does not require unwanted modifications or upgrade of other
track-side or on-board systems,
Considering the possible high impact for the conformity assessment of
existing vehicles (if they meet the requirements of the frequency
management) as well as its modification, it is not recommended to apply
the TSI in all cases of a vehicle modification which may change the
emission of magnetic fields (renewals or upgrade of some parts of the
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Care should be taken especially where there are modifications of

a vehicle, which are not related to any extension of the range of
use of the vehicle or not be performed in the framework of
an additional authorisation. In such cases the application of the TSI
should base on the results of a case by case cost benefit analysis.
There may be no direct benefits for the railway undertaking but
a high cost risk.
The questionnaire assumed that the proposed limit values have
been already 
 by the railway sector. But this is not
the case and changes in the frequency management may happen
after validation of the limit values. This would require an 


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