EUROPEAN RAILWAY AGENCY

EUROPEAN RAILWAY AGENCY INTEROPERABILITY UNIT TECHNICAL OPINION ON GERMAN MINISTRY NOTIFICATION REF. 41351 REFERENCE: IU-WAG- TO3 DOCUMENT TYPE: TECHNICAL OPINION VERSION: 1.0 DATE: 19/10/2009 Edited by Reviewed by Approved by Name Sorin HANCI Andrzej Harassek Jean-Charles PICHANT Andreas SCHIRMER Denis BIASIN Position Project Officer Adviser Head of Interoperability Unit Date & Signat. 19/10/2009 PAGE 1 OF 17

AMENDMENT RECORD Version Date Section number Modification/description Author 1.0 19/10/2009 Preparation of version 1.0 Sorin HANCI Andreas SCHIRMER Denis BIASIN Version 1.0 Page 2/17

Table of Contents 1. Introduction... 5 2. Abbreviations and references... 6 2.1 Abbreviations... 6 2.2 References... 6 3. General description of the subject... 8 4. Errors considered to be critical by the German Ministry... 9 4.1 Draw gear... 9 4.2 Safe access and egress for the rolling stock... 9 4.3 Service (fatigue) loads... 9 4.4 Marking of freight wagons... 10 4.5 Marking of freight wagons - Annex B... 10 4.6 Safety against derailment when running on twisted tracks... 10 4.7 Parking brake percentage of the fleet... 11 4.8 Parking braking held gradient... 11 4.9 Fixing of tail lamps... 11 4.10 Quasi static movements... 11 4.11 The place of noise measurement... 12 5. Proposals sent by the German Ministry... 13 5.1 Draw gear... 13 5.2 Safe access and egress for the rolling stock... 13 5.3 Service fatigue loads... 13 5.4 Marking of freight wagons... 13 5.5 Marking of freight wagons - annex B... 13 5.6 Safety against derailment when running on twisted tracks... 13 5.7 Parking brake percentage of the fleet... 13 5.8 Parking braking held gradient... 14 5.9 Fixing of tail lamps... 14 5.10 Quasi static movements... 14 5.11 Place of noise measurement... 14 6. ERA technical opinion... 15 6.1 Draw gear... 15 6.2 Safe access and egress for the rolling stock... 15 6.3 Service fatigue loads... 15 Version 1.0 Page 3/17

6.4 Marking of freight wagons... 15 6.5 Marking of freight wagons annex B... 16 6.6 Safety against derailment when running on twisted tracks... 16 6.7 Parking brake percentage of the fleet... 16 6.8 Parking braking held gradient... 17 6.9 Fixing of tail lamps... 17 6.10 Quasi static movements... 17 6.11 Place of noise measurement... 17 Version 1.0 Page 4/17

1. Introduction The present document expresses the Agency technical opinion about a notification issued by German Ministry of Transport. The subject is related to several aspects from WAG TSI [1] and NOI TSI [5] considered as critical errors by NSA Germany (EBA). The WAG TSI and the NOI TSI are currently under revision. The issues raised by EBA will be taken into consideration within the frame of this revision. The ERA comments expressed in the present document reflect ERA position at the moment of writing and may be further modified following the discussions that will take place in forthcoming WAG TSI (resp. NOI TSI) revision Working Parties. Version 1.0 Page 5/17

2. Abbreviations and references 2.1 Abbreviations Abbreviation CR CEN EBA HS MS NSA NoBo TEN TSI WP Definition Conventional Rail European Committee for Standardisation NSA Germany ( Eisenbahn- Bundesamt) High Speed Member states National Safety Authority Notified Body Trans-European network Technical Specification for Interoperability Working party 2.2 References Ref. N Document Reference Commission Decision 2006/861/EC concerning the technical specification of interoperability relating to the subsystem rolling stock freight wagons of the trans-european [1] conventional rail system CR RST Freight Wagon Last Issue 28 th July 2006 [2] [3] [4] Hereafter: WAG TSI New mandate Commission Decision concerning a framework mandate to the European Railway Agency for the performance of certain activities under Directives 96/48 and 2001/16/EC Hereafter: New mandate Decision 2009/107/EC Commission Decision of amending Decisions 2006/861/EC and 2006/920/EC concerning technical specifications of interoperability relating to subsystems of the trans-european conventional rail system Hereafter: Amending WAG TSI EN 15566:2009 Railway rolling stock - Draw gear and screw coupling 13 th July 2007 23 th January 2009 January 2009 Version 1.0 Page 6/17

Ref. N Document Reference [5] Decision 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 Hereafter: NOI TSI Last Issue 23 th December 2005 [6] [7] [8] [9] Corrigendum 01/16 DV55-EN01 1/59 Revision to the Conventional Rail Freight Wagon TSI and its related issues Hereafter: DV 55 Technical document TD 02 : List of fully approved k composite brake blocks for international transport Hereafter: TD 02 pren 15877-1:2009 Railway applications - Marking on railway vehicles - Part 1: Freight wagons Hereafter pren 15877-1 pren 15273-2 Railway applications - Gauges - Part 2: Rolling stock gauge Hereafter: 15273-2 18 th August 2005 30 th June 2009 August 2009 August 2005 Version 1.0 Page 7/17

3. General description of the subject According to New mandate [2], point 2.2, a critical error is defined as follows: Prevents the completion of subsystem or interoperable constituent design; Prevents the conformity assessment of the subsystem or the interoperable constituent; Prevents the placing into service of the subsystem or the placing onto the market of the interoperable constituent; Prevents the interoperability of the subsystem or the interoperable constituent; Presumably errors notified as critical should be judged in that respect. Version 1.0 Page 8/17

4. Errors considered to be critical by the German Ministry 4.1 Draw gear This subject is regulated within section 4.2.2.1.2.2. of the WAG TSI. The TSI requires: The maximum weight of the screw coupler shall not exceed 36 kg. This could lead to misinterpretation. Some Notified Bodies required that the weight of the whole screw coupler shall not exceed this value. The value is designed according to the moveable parts of the coupling especially for the handling by the coupler (staff). This means that the coupling hook bolt including the pin and the retainer do not have to be considered for the weight. The result could be that some heavy screw couplers are not able to be certified according to the TSI although the movable part of them excluding the above mentioned parts of the draw gear are not heavier than 36 kg. 4.2 Safe access and egress for the rolling stock This subject is regulated within section 4.2.2.2 of the WAG TSI. Recital Part of this chapter is Annex EE. In picture EE 1 is represented a distance between the AC-centre and the step of 495mm. At certain wagons this requirement cannot be fulfilled. Then the edge of the step rises into the area of the kinematic gauge. 4.3 Service (fatigue) loads This subject is regulated within section 4.2.3.3.1 of the WAG TSI Recital The requirements in the EN 12663 cannot be fulfilled completely by specific types of vehicles. The EN 12663 describes in 4.6.4 loadings of the infrastructure (especially) in table 15 speeding up in Y-direction for freight wagon 0,4 x g. In the new draft pren 12663-2 (August 2007) this requirement has been reduced to 0,2 x g. Version 1.0 Page 9/17

4.4 Marking of freight wagons This subject is regulated within section 4.2.2.5 of the WAG TSI The TSI requires: The markings shall be located as high as practicable on the wagon structure up to a height of 1 600 mm above rail level. The GCU requires the height of 1 600 mm if possible but not mandatory. The pren 15877 requires a maximum height of 2 000 mm. There are existing wagon constructions which do not provide enough space for the markings in a height of maximum 1 600 mm (e. g. bulk wagons with hoppers). 4.5 Marking of freight wagons - Annex B This subject is regulated within Annex B.1-Vehicle Unique Number of the WAG TSI. In Annex B the location of the marking is required very often as to the left, on each side. There are existing wagon constructions (e. g. wagons with tarpaulin or other flexible covers, flat wagons) which do not provide enough space for the markings only on the left side. 4.6 Safety against derailment when running on twisted tracks This subject is regulated within section 4.2.3.4.2.2 of the WAG TSI. The TSI requires: It is fixed in section 2.5 of Ann. JJ-2 of the Intermediate Revision of the TSI WAG (document 08/57 DV03) that the three methods given in EN 14363 are applicable. In addition according to section 4.1.1. of the EN 14363 it is alternatively possible to make a calculation without tests. In this case a checked reference vehicle must be available and in accordance with the chapter 4.1.3.3 of the EN 14363 for the calculation of the formulae of the second method have to be used. This should also be considered in the TSI to reduce the effort for the sector. The wrong formulae in section 4.2.3.4.2.2 were already deleted by the document 08/57 DV 03. In addition section 4.1 of the EN 14363 should be considered in 4.2.3.4.2.2. Version 1.0 Page 10/17

4.7 Parking brake percentage of the fleet This subject is regulated within section 4.2.4.1.2.8 Parking brake of the WAG TSI. The TSI requires: Wagon not specifically listed below (wagon for dangerous goods according to RID, wagons for the transport of car vehicles): At least 20 % of a fleet of wagons shall have a parking brake operated from the wagon (platform or gangway) or the ground. It is not defined what a fleet is. A Notified Body is not able to check whether a fleet of a RU fulfils this requirement. 4.8 Parking braking held gradient This subject is regulated within section 4.2.4.1.2.8 Parking brake of the WAG TSI. The TSI requires: The parking brake shall be designed such that fully loaded wagons shall be held in a gradient of 4,0 % with maximum adhesion of 0,15 with no wind. This value cannot be fulfilled by wagons equipped with composite brake blocks but on the other hand composite brake blocks are necessary to fulfil the TSI Noise. 4.9 Fixing of tail lamps This subject is regulated within section 4.2.7.4.2.2 Fixing of tail lamps, position of the WAG TSI. The TSI requires: At the vehicle ends, the tail lamp brackets shall be arranged in such a way that: - they are spaced more than 1300mm apart. At certain wagons this requirement cannot be fulfilled (e. g. containercarrying-wagon) 4.10 Quasi static movements This subject is regulated within Annex C 2.5.1.3 of the WAG TSI. Wrong formula by missing >0 tan[ 0-1 ] h hc Version 1.0 Page 11/17

4.11 The place of noise measurement This subject is regulated within the TSI Noise. TSI Noise refers to pren 3095. In this standard and also in the EN 3095 which is available now in section 6.2.3 it is required that if the measurement is to be carry out on both sides of the wagon (e. g. for asymmetric subsystems) they do not have to be carried out at the same time. Some Notified Bodies require to carry out the tests on both sides of every freight wagon although even if the freight wagon is symmetric. This leads to higher costs. Version 1.0 Page 12/17

5. Proposals sent by the German Ministry 5.1 Draw gear Add after the quoted sentence above: The coupling hook bolt including the pin and the retainer do not have to be considered for the weight. 5.2 Safe access and egress for the rolling stock Add a footnote at the value 495mm: If the edge of the step rises into the kinematic gauge it is permitted to reduce the measure 495 mm as far as necessary to avoid rising of the step into the area of the kinematic gauge. 5.3 Service fatigue loads Use of the new pren 12663 to fulfil this TSI - requirements. 5.4 Marking of freight wagons Change 1 600 into 2 000 (In the TSI WAG revision it is also planned to refer to the EN 15877) 5.5 Marking of freight wagons - annex B Add in 4.2.2.5: If the location of the markings as quoted in Annex B is not possible because there is not enough space on the left side it is allowed to locate them somewhere else on the side of the wagon. 5.6 Safety against derailment when running on twisted tracks At the end of the first sentence after given twisted track has to be put a full stop. In addition it has to be written: The proof has to be to lead according to section 4.1 of the EN 14363. 5.7 Parking brake percentage of the fleet At least 20 % of a procurement of a wagon type shall have a parking brake operated from the wagon (platform or gangway) or the ground. Version 1.0 Page 13/17

5.8 Parking braking held gradient EBA proposed solution The parking brake shall be designed such that fully loaded wagons shall be held in a gradient of 1,8% with maximum adhesion of 0,15 with no wind. Values: hand force = 500 N (like UIC 543, point 2.3.4) amplification ratio = 1400 :1 to 1500 :1 To be in consistency with the guide for K blocks the following inscription may be used: Pictogram In addition the formula for the calculation of the force of the handbrake (UIC 544-1, Point 8.3.1.1) and also the formula for the calculation of the gradient (UIC 544-1, point 8.3.3) shall be introduced into the TSI. 5.9 Fixing of tail lamps Change the requirement in: - they are spaced more than 1100 mm apart 5.10 Quasi static movements Add >0 in the quoted formula above: tan[ 0-1 ] >0 h hc 5.11 Place of noise measurement Add in TSI Noise: For symmetric freight wagons (or subsystems) the noise measurement tests are only to carry out on one side of the wagon (subsystem) Version 1.0 Page 14/17

6. ERA technical opinion 6.1 Draw gear The lack of precise explanation of screw coupling weight cannot be considered as a critical error. Coupling hook pin is installed on the draw hook and therefore when screw coupling is handled the weight of fixed part is not included. Thus, this fixed part should not be considered as part of the screw coupling weight. In the frame of revision process, this problem has been considered and a reference to EN 15566 [4] will be included in the future WAG TSI. Additional explanations related to the screw coupler weight will be included in the Application Guide. 6.2 Safe access and egress for the rolling stock This is not considered as a critical error because it is possible to design a new wagon complying with these requirements. However, it is understandable that these requirements introduce burden to the design of wagons and therefore the requirements related to footsteps will be carefully reconsidered in the revision process. This will be done in close relationship with the CEN. 6.3 Service fatigue loads The notification does not stipulate which kind of specific vehicles cannot comply with this requirement and does not give any information about the reasons why it cannot comply. Pending this information, we cannot consider this as a critical error. The EN 12663:2000 defines in its section 4.6.4 - Track induced loading a value of 0,4xg for acceleration in y-direction, mentioning that this value may be reduced in cases of improved suspension. This issue has been considered during the revision process and was concluded that the value of speeding up in Y direction of 0,2 x g is the correct one and should be applied. As a consequence reference will be made to the EN 12663-2 (expected date of publication early 2010) in the future WAG TSI. 6.4 Marking of freight wagons This is not considered as a critical error because the TSI is addressing new construction, upgraded or renewed wagons. Version 1.0 Page 15/17

More flexibility on the position of markings will be given in the revised WAG TSI by referring to the forthcoming EN 15877-1[8] (envisaged date of publication mid 2010). 6.5 Marking of freight wagons annex B This is not considered as a critical error because the TSI is addressing new construction, upgraded or renewed wagons. The requirement in the current WAG TSI to the left already gives some flexibility in the interpretation. In the revised WAG TSI the reference to the forthcoming EN 15877-1 is meant to solve this issue. 6.6 Safety against derailment when running on twisted tracks This cannot be considered as a critical error. Section 2.5 Dynamic behaviour of the vehicle of Amending WAG TSI [3] regulates: In addition to the specifications of section 4.2.3.4 of this TSI, it is required that for the particular cases of the bogies not listed in annex Y, EN 14363 or leaflet UIC 432 apply. In addition to the specifications of section 4.2.3.4.2.2 of this TSI on safety against derailment when running on twisted tracks: One of the three methods given in EN 14363 applies; Freight wagons are exempted from these tests if they comply with the requirements of UIC leaflet 530-2. This subject has been considered scrupulously by WAG WP and further on voted by the MS and the only case allowing an exemption from the stationary testing is when the wagon is complying with UIC 530-2. 6.7 Parking brake percentage of the fleet This point has been recognised already as an error within the DV55 [6] where the following proposal for amendment has been made: At least 20% of all wagons not specifically listed below operated by a contracting entity shall have a parking brake operated from the wagon (platform or gangway) or the ground, to be confirmed through the Rolling Stock Register. However this was not considered as critical and therefore the issue is being already addressed within the revision process. The preliminary conclusion, based on the draft recommendation OPE TSI, is that this requirement should be deleted from the revised WAG TSI. Version 1.0 Page 16/17

6.8 Parking braking held gradient During the revision process this issue has been considered and a preliminary conclusion is that this requirement can hardly be fulfilled by wagons using composite brake blocks. However, no evidence of this has been received so far by the Agency. To alleviate the requirement the following has been proposed for the revised TSI: The parking brake shall be designed such that fully loaded wagons shall be held in a gradient of 1,8 % with maximum adhesion of 0,15 with no wind. In addition the TD 03 published on the Agency Web site may be used for calculations of the force and of the gradient according UIC leaflets and EN standards. 6.9 Fixing of tail lamps This is not considered as a critical error because the TSI is addressing new construction, upgraded or renewed wagons. It is deemed that the design of such wagons can be adapted to comply with the requirements of the TSI. However this will be considered in the revision WP. 6.10 Quasi static movements The term asymmetry (dissymmetry) is defined as: tan[η 0-1 ] h-hc in WAG TSI. Same formula is applying in pren 15273-2 [9] section 6.4.2.5.1 when describes term related do dissymmetry. In clause C.2.5.1.3 is a reference to 1.4.2.3 that does not exist and in fact should be read as a reference to section C.2.4.2.3. In the calculation of z = deviation from the track central position the term is correctly used with no influence on the final result in both documents, moreover when η 0 1 the negative mathematic result of asymmetry is not taken into account. In fact there is no final impact when calculating therefore this should not hinder authorisation for placing into service. The revise WAG TSI will include a reference to the EN 15273-2 (foreseen date of publication end 2009). 6.11 Place of noise measurement This cannot be considered as an error. The EBA comment and proposal will be considered within the frame of the revision of the NOI TSI. The latest version of the pren3095 already requires measurement on both sides only if the unit is not acoustically symmetrical. For your information the harmonisation of methods for assessment of conformity by different NoBos is addressed by NB RAIL. Version 1.0 Page 17/17