The new ENE TSI concerns traction power supply infrastructure and came into force on 1 January 2015. Prior to then, much work was done to align previous standards to this TSI, including the production of Railway Group Standard GL/RT1210 “AC Energy Subsystem and Interfaces to Rolling Stock Subsystem” which contains the UK national technical rules mandated by ENE TSI.
This work was coordinated by RSSB and included the production of a strategy for the implementation of ENE TSI in 2011 which “notes that GB railway is constrained by its small loading gauge which is difficult and expensive to alter” and that “there should be a working presumption that current GB practice should be preserved unless a conscious decision to adopt standard European practice is made by industry through its stakeholder groups, having understood the economic consequences of such a decision”.
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Perhaps the most challenging requirement of GL/RT1210 is its mandate of Figure 4 of BS EN 50122-1:2011, which only allows live 25kV equipment within a 3.5 metre radius of the platform edge unless a CSMRA compliant risk assessment can justify reduced clearances. Prior to that, GE/RT8025 specified the minimum platform clearances to be those in Annex G, BS EN 50122. This is a UK special condition that takes account of the restricted British gauge by allowing a 2.75 metre radius of a platform edge.
However, in 2013, the relevant British Standards committee, which is not part of the railway standards process, expressed concerns about a minimum 2.75 metres clearance and, in 2013, updated BS EN 50122 with a national forward requiring that, until Annex G is revised, an appropriate risk assessment is essential if clearances less than specified in Figure 4 are used.
The clearance requirements of BS EN 50122 are, in effect, those that must be followed to comply with the Electricity at Work Regulations, which require potentially dangerous conductors to be suitably placed but do not define this requirement. In such cases, compliance with the relevant British Standard is generally the minimum deemed necessary to comply with the law.
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ENE TSI applies to “new, upgraded or renewed ‘energy’ subsystems”, so it is not concerned with the existing infrastructure. Its clearance requirements specify compliance with the notified national technical rules that are the relevant clauses of GL/RT1210.
For projects at an advanced stage, the 2008 Interoperability Directive allows EU member states to issue a derogation against a new TSI. Although the Department for Transport advised the EU that EGIP was such an advanced project, as it had “reached a significant degree of maturity when the TSI was published in terms of tenders, contracts and detailed design”, the project was not issued with a derogation so had to comply with GL/RT1210.