POSITION PAPER Version 3.0 Revision of the Technical Specification for Interoperability / Energy (ENE) Brussels, September 26 th, 2012
1. REFERENCE DOCUMENT UNION RAIL SYSTEM - SUBSYSTEM Energy - TSI Energy IU_ENE_Consultation - Draft June2012 Date 25/06/2012 Edited by: Stanislaw LIS, Ignacio BALLESTER, Wouter MALFAIT 2. INTRODUCTION This Position Paper makes public the official CER beliefs and recommendations on and for the Technical Specification for Interoperability Energy Energy (ENE) - Version 8.2. It recommends changes and amendments to be done, ensuring the deployment of a safe, sustainable, costefficient and reliable railway systems with all its subsystems included. 3. GENERAL COMMENTS For a correct understanding of the aforesaid TSI, CER recommends to include the list with the explanation of all used abbreviations. (e.g. CEBD) The References to standards are to be updated. The Joint CER and EIM Support group note that the definitions of speed are different between the tables within the TSI and with the various ENs that are referenced. Can the ERA please check all the speed ranges are consistent within the TSI, with EN references, and between the TSIs. CER recommends to add a paragraph in chapter 7 how this TSI ENE applies for projects at advanced stage of development (in particular for those being launched under the highspeed or conventional TSI (in force) (see proposal made in the TSI LOC&PAS Chapter 7.1.1.2.2. - Version 1.3) 4. DETAILED COMMENTS PART OF THE TSI 1.2 GEOGRAPHICAL SCOPE (c) Other parts of the Union rail network, following as this TSI achieves the extension of scope process as described in Annex I section 4 of Directive 2008/57/EC. Justification Clarification of the Geographical scope PART OF THE TSI 1.2 GEOGRAPHICAL SCOPE CER detected diverging approaches between the ENE, INF TSI and the ID (Annex 1) about the categorisation of lines. August 2012 Page 2/10
PART OF TSI 2.1 DEFINITION OF THE ENERGY SUBSYSTEM Original Text: In accordance with ANNEX I clause 2.2 of the Commission Directive 2011/18/EU of 1 March 2011, amending Annexes II, V and VI to Directive 2008/57/EC, energy subsystem includes also trackside equipment of the electricity consumption measuring system. This TSI contains requirements for the on-ground data collection system part which receives CEBD from on-board EMS in accordance with the LOC&PAS TSI. CER Comment: We consider the listing of trackside equipment of the electricity measuring system and the on ground data collection system part as critical. We think it will result that on one hand all stationary measuring equipment has to be TSI compliant and on the other hand the same will occur for readout systems. We propose to delete the last two sentences of this paragraph. Furthermore, chapter 7.3.4 has also been adjusted to this situation. PART OF TSI 4.2.3. VOLTAGE AND FREQUENCY EDITORIAL REMARK The voltage and frequency of the Energy subsystem shall be one of the four systems, determined in accordance with Chapter 7: AC 25 kv, 50 Hz; AC 15 kv, 16.7 Hz; DC 3 kv, or; DC 1.5 kv PART OF THE TSI 4.2.5 CURRENT CAPACITY, DC SYSTEMS, TRAINS AT STANDSTILL This shall be achieved using a static contact force on the range for application, as defined in clause 7.2 of Pr EN 50367: 2012 PART OF TSI 4.2.6 REGENERATIVE BRAKING AC power supply systems shall be designed to permit the use of regenerative braking able to exchange power seamlessly either with other trains or by any other means. DC power supply systems shall at least be designed to permit the use of regenerative braking by exchanging power with other trains. CER Comment: It should always be possible to do more than exchange power between trains, but this is the base design position for DC systems PART OF TSI - 4.2.9 GEOMETRY OF THE OVERHEAD CONTACT LINE Overhead contact line shall be designed for use by at least one of the pantographs with the head geometry specified in the LOC&PAS TSI clause 4.2.8.2.9.2 August 2012 Page 3/10
CER spotted that this first sentence of chapter 4.2.9 will be removed in TSI ENE - Version 8.3. The wording and intention should remain as written above this referred TSI ENE Version 8.2 consultation version. PART OF THE TSI 4.2.9. (REFERENCE TSI ENE VERSION 8.3) Overhead contact line shall be designed for use by at least one of the pantographs with the head geometry specified in the LOC&PAS TSI clause 4.2.8.2.9.2. CER detected that this sentence was deleted in version 8.3. This sentence should remain in the TSI ENE. For high-speed networks CER has diverging positions: a) Keeping the High-speed TSI approach (1.600 mm single target + specific cases in Chapter 7) b) Application of the conventional approach to high-speed lines PART OF TSI - TABLE 4.2.9.1 - OVERHEAD CONTACT LINE WIRE HEIGHT Description v 250 [km/h] Track gauge system 1435 mm v < 250 [km/h] Track gauge system 1435 mm Track gauge system 1520/1524 mm network Nominal contact wire height (mm) Between 5080 and 5300 Between 5000 and 5750 Between 6000 and 6300 Minimum design contact wire height (mm) 5080 In accordance with EN 50119:2009 clause 5.10.5 depending on the chosen gauge 5550 Maximum design contact wire height (mm) 5300 6200 6800 1. Please revise the title of last items of clauses 4.2.9, 4.2.10, 7.2.3 and Article D.2 of Annex D as follows: Track gauge system 1520 mm network 2. Please revise the specification of parameters for contact line in Article 4.2.9 in relation to the figure D3 of Annex D and the figure D.3 itself. Justification: According to the Figure D3 of Annex D (Reference Version 8.3) are on open track and in station different contact wire heights. For the correct use Figure D3 is necessary to add further information on the rules associated to this picture. The best solution should be the picture containing only dimensions regulated on EU level with relevant associated rules. August 2012 Page 4/10
4.2.12 DYNAMIC BEHAVIOUR AND QUALITY OF CURRENT COLLECTION with the upper limit of Fm at the maximum line speed (instead of ;with a mean contact force Fm at the maximum line speed ) PART OF THE TSI TABLE 4.2.13 PROPOSED NEW TEXT: The overhead contact line of the pantograph head, that leads to classify OCL following types defined in Table 4.2.13: Justification: The scope of this clause is the classification of OCL following design distance type. This is not expressed in the clause. PART OF TSI - 4.2.13 TABLE 4.2.13 Proposal: The overhead contact line shall be designed for a minimum of two pantographs operating adjacently, having a minimum spacing centre line to centre line of the pantograph head as set out in Table 4.2.13. OCL designs for distances less than the given one in table 4.2.13 between the two pantographs are allowed. Justification: The overhead contact line shall be designed for a minimum of two pantographs operating adjacently, having a minimum spacing centre line to centre line of the pantograph head as set out in Table 4.2.13: This sentence can led to misunderstanding. PART OF TSI - 4.2.13 TABLE 4.2.13 CER recommends to change operating speed to design speed. PART OF THE TSI 4.2.15.3 LINES WITH SPEED V<250 [KM/H] CER Comment Refer to Pr EN 50367: 2012, Annex A;1 (instead of Pr EN 50367: 2006) PART OF TSI 4.2.17 ON-GROUND ENERGY DATA COLLECTING SYSTEM Clause 4.2.8.2.8 of LOC&PAS TSI contains the requirements for on-board Energy Measuring Systems (EMS) intended to produce and transmit the Compiled Energy Billing Data (CEBD) to an on-ground energy data collecting system. August 2012 Page 5/10
The on-ground energy data collecting system shall receive, store and export CEBD without corrupting it. CEBD shall be accepted for billing in all Member States. CER Comment: Our control centres and the readout system are accepted by national authorisation bodies. It has to be clear that the ENE TSI conformity assessment procedure defined in 6.1.4.1 is not necessary for the on-board Energy Measuring Systems (EMS). Foreign vehicle data has to be accepted. This is also standardised in an UIC leaflet. TSI compliance of the EMS makes no sense especially if recurring audits are necessary. PART OF THE TSI 4.3.4. CONTROL - COMMAND AND SIGNALLING The interface for power control is an interface between the energy and the rolling stock subsystems. However, it is controlled via the control-command and signalling subsystem and consequently the interface is specified in the CCS TSI and the LOC & PAS TSI. The relevant information to perform the switching of the circuit breaker, change of maximum train current, change of the power supply system and pantograph management shall be transmitted via ERTMS when the line is equipped with ERTMS. Harmonic currents affecting control-command and signalling subsystem are dealt with by the control-command and signalling subsystem. PART OF TSI 4.4 OPERATING RULES PART OF TSI 4.5 MAINTENANCE RULES CER recommends to revise the content of clauses 4.4 and 4.5 in order to reflect the responsibility of manufacturer supplier for provision of all relevant requirements on the operation and maintenance. Justification: The manufacturer supplier shall be responsible for provision of all relevant design specific requirements on the operation and maintenance. PART OF THE TSI 6.1.4 PARTICULAR ASSESSMENT FOR THE INTEROPERABILITY CONSTITUENT OVERHEAD CONTACT LINE FOOTNOTE TO 6.1.4 The Joint CER and EIM (Association of European Infrastructure Managers) Support group propose the following change: Footnote to 6.1.4 1 i.e. the speed of the two types of pantograph shall be at least equal to the design speed of the simulated overhead contact line. We propose to change to August 2012 Page 6/10
[1]For line speeds equal or greater than 250km/h, the design speed of the two types of pantograph shall be at least equal to the design speed of the simulated overhead contact line. For line speeds less than 250km/h, the design speed of the two types of pantograph shall be at least equal to the design speed of the simulated overhead contact line, but not greater than 250km/h. Justification: The interaction properties of high-speed pantographs are normally much better than those of low speed pantographs. Therefore this limit of 250 km/h was introduced. For 1 or 2 pantographs see comments made above (high-speed). PART OF THE TSI 6.1.4.2 ASSESSMENT OF CURRENT AT STANDSTILL CER recommends to add The conformity assessment shall be carried out in accordance with Pr EN 50367: 2012, Annex A.3 and shall fulfill the requirements set out in clause 4.2.5 PART OF THE TSI 6.2.4.4 ASSESSMENT OF HARMONIC AND DYNAMIC EFFECTS FOR AC SYSTEMS A compatibility study shall be carried out according to EN 50388:2012 clause 10.3. This study shall be carried out assessed only in the case of introducing converters with active semi-conductors in the power supply system. The Notified Body shall check if criteria of EN 50388:2012 clause 10.4 are fulfilled. PART OF TSI 7.2.3 MIGRATION STRATEGY FOR OCL GEOMETRY Overhead contact line shall be designed taking into account the following rules: New lines: o TEN lines, with speed equal or greater than 250 km/h shall accommodate both pantographs as specified in the LOC & PAS TSI clause 4.2.8.2.9.2, o Other TEN lines shall accommodate both pantographs as specified in the LOC & PAS TSI clause 4.2.8.2.9.2, Other lines of the Union rail network shall accommodate both pantographs as specified in the LOC & PAS TSI clause 4.2.8.2.9.2 Upgraded lines (including new electrification of existing lines): o If upgrade includes replacement of poles, the OCL design shall accommodate both pantographs as specified in the LOC & PAS TSI clause 4.2.8.2.9.2 unless the structure gauge prevents use of the 1950 mm pantograph, o.if during upgrade the pole replacement is not foreseen the procedure shall be as follows unless the structure gauge imposes other limitations: o the OCL design shall be chosen, which fits technically to existing pole spacing and can accommodate both pantographs as specified in the LOC & PAS TSI clause 4.2.8.2.9.2 (if necessary with operational restrictions for 1600 mm pantograph), August 2012 Page 7/10
o if such OCL design is not available, the existing design shall be adapted to accommodate both pantographs as specified in the LOC & PAS TSI clause 4.2.8.2.9.2 (if necessary with operational restrictions for 1600 mm pantograph). If this OCL is not recognised as an IC, it shall be assessed during the process of assessment of the subsystem, o if abovementioned steps cannot be met the new OCL shall be designed for use by one of the pantograph as specified in the LOC&PAS TSI clause 4.2.8.2.9.2. Renewed lines: The procedure shall be as follows unless the structure gauge imposes other limitations: o the OCL design shall be chosen to fit technically to existing pole spacing and can accommodate both pantographs as specified in the LOC & PAS TSI clause 4.2.8.2.9.2 (if necessary with operational restrictions for 1600 mm pantograph), o if such OCL design is not available, the existing design shall be adapted to accommodate both pantographs as specified in the LOC & PAS TSI clause 4.2.8.2.9.2 (if necessary with operational restrictions for 1600 mm pantograph). ). If this OCL is not recognised as an IC, it shall be assessed during the process of assessment of the subsystem, o if abovementioned steps cannot be met the new OCL shall be designed for use by one of the pantograph as specified in the LOC&PAS TSI clause 4.2.8.2.9.2. CER Comment: A fully comprehensive cost-benefit analysis for this strategy is missing. Regarding the upgrade and renewal of lines the technical feasibility is not proven, if the pole replacement is not foreseen. ERA shall provide a cost-benefit analysis and provide a sound business case which supports the suggested migration strategy regarding OCL geometry. CER in principal disagrees with the ERA proposal on chapter 7.3 as the ERA proposal is unnecessarily expensive. PART OF TSI 7.3.4 IMPLEMENTATION OF THE ENERGY SETTLEMENT SYSTEM The on-ground energy data collecting system (DCS) is a part of the trackside equipment of the electricity consumption measuring system. The DCS is intended to deliver CEBD to settlement systems. Within 5 years, after this TSI enters into force, MS shall implement or adapt the energy settlement system to be able to receive the CEBD from the a DCS and accept it for billing as defined in clause 4.2.17 of this TSI. This implementation should be done in collaboration with railway market regulator and energy market regulator. August 2012 Page 8/10
CER Comment: See our comment on chapter 2.1 PART OF THE TSI ANNEX C - TAB.C Use a.c. and d.c. throughout the document. PART OF THE TSI ANNEX C - TAB.C Change U mean useful (zone) to Zone used for simulation to calculate U mean useful and Change U mean useful (time) to Time used for simulation to calculate U mean useful Justification Changes were made to prevent misinterpretations. August 2012 Page 9/10
Disclaimer Community of European Railway and Infrastructure Companies (CER) AISBL Avenue des Arts 53 B-1000 Brussels Belgium Tel +32 2 213 08 70 Fax +32 2 512 52 31 contact@cer.be This CER document is for public information. Although every effort is made to ensure the accuracy of the information in this document, CER cannot be held responsible for any information from external sources, technical inaccuracies, typographical errors or other errors herein. Information and links may have changed without notice. August 2012 Page 10/10