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Subsets 119, 120 and 121 are NOT mandatory at the moment.
Subset 121 is NOT listed in the Annex A of the CCS TSI, nor in the informative documents of the CCS TSI Application Guide.
Subsets 119 and 120 are listed in the Annex A of the CCS TSI without version and with a note: “Reference to these specifications will be published in the Application Guide, waiting for clarifications on the rolling stock side of the interface”. The intention is to make them mandatory, once an agreement is reached on the content. Therefore, in the meantime, they have to be considered as informative documents.
Notified Bodies do not have to check compliancy against informative document, which include Subsets 119, 120 and 121.
GSM-R performance is important for the safe integration between GSM-R and ETCS. ETCS suppliers ask for the evidence related to Subset-093 and they want to see it in the GSM-R EC Certificate. However, there is no definitive agreement on mandatory performance requirements for the network (trackside subsystem) or for the different Interoperability Constituents (EDOR, ETCS on board-EVC, RBC), nor on the way to measure their performance. In this situation, the assessment by a Notified Body (NoBo) is not possible.
Subset-093 includes requirements between the interface of the EVC and the EDOR, and the interface between the GSM-R network and the RBC. This does not correspond with the entities that the NoBo has to assess (subsystems or interoperability constituents, as defined in the CCS TSI. Therefore, the document, as it is, is not suitable for the assessment of the trackside subsystem or for the EDOR.
The FRS requirement 2.3.13 imposes the obligation in the network to support data communications in case it is going to be used for ETCS Level 2 or 3. This is the reason for classifying this requirement as MI (mandated by the CCS TSI. The Notified Body (NoBo) has to verify that, if the network is going to be used for ETCS L2 or 3, it supports data communications.
In the FRS, the meaning of the clause is that the network should be prepared for the data communication. In fact, SRS 3.2.2 and 3.2.3 have to be fulfilled (and verified by the NoBo). There is currently no mandatory quality of service (QoS) stated in the CCS TSI, therefore, the reference to the “required quality of service” is not to be understood as something to be verified by the NoBo.
Subset-093 is listed in the CCS TSI Application Guide and so, has to be considered as informative document. NoBos do not have to check compliancy against it, unless a specific section is explicitly referred to in a mandatory requirement.
The required quality of service is currently a matter to be agreed at the project level. The check of the fulfilment of the required quality of service is out of the scope of the NoBo verifying the subsystem. An assessor can be requested to check many additional items, in addition to those required by the TSI. This may be done, but always outside of the process for verification of the subsystem, as additional checks if requested by the applicant, in which case the assessor will be acting as a technical expert and not as NoBo.
In order to make clear the scope of the verification carried out for the FRS 2.3.13 requirement, a note in the Technical file can be added, stating that there is no specific QoS required in the CCS TSI, and therefore, no QoS verification has been done.
GSM-R performance is important for the safe integration between GSM-R and ETCS. ETCS suppliers ask for the evidence related to Subset-093 and they want to see it in the GSM-R EC Certificate. However, there is no definitive agreement on mandatory performance requirements for the network (trackside subsystem) or for the different Interoperability Constituents (EDOR, ETCS on board-EVC, RBC), nor on the way to measure their performance. In this situation, the assessment by a NoBo is not possible.
Subset-093 includes requirements between the interface of the EVC and the EDOR, and the interface between the GSM-R network and the RBC. This does not correspond with the entities that the NoBo has to assess (subsystems or ICs, as defined in the CCS TSI. Therefore, the document, as it is, is not suitable for the assessment of the trackside subsystem or for the EDOR.