Commission staff working document accompanying the communication from the Commission to the European Parliament and the Council - Rail noise abatement measures addressing the existing fleet - Impact assessment report {COM(2008) 432 final} {SEC(2008) 2204}
Date: 2008-07-08
Institutions: European Commission
Subjects: environmental tax, impact study, noise, noise pollution, nuisance, rail transport, transport infrastructure

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 8.7.2008 
SEC(2008) 2203 

COMMISSION STAFF WORKING DOCUMENT 

accompanying the 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT AND THE COUNCIL 

Rail noise abatement measures addressing the existing fleet 

Impact Assessment report 

{COM(2008) 432 final} 
{SEC(2008) 2204} 

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TABLE OF CONTENTS 

Glossary 

Acronyms 

Executive summary 

1. 

2. 

3. 

4. 

4.1. 

4.2. 

4.3. 

5. 

5.1. 

5.2. 

5.3. 

5.4. 

5.5. 

5.6. 

5.7. 

6. 

7. 

Procedural issues and consultation of interested parties .............................................. 6 

Problem definition........................................................................................................ 9 

Objectives................................................................................................................... 14 

Policy options............................................................................................................. 16 

Description of policy options ..................................................................................... 16 

Pre-selection and combination of policy options ....................................................... 17 

Description of policy options selected for the detailed impact assessment ............... 19 

Analysis of impacts .................................................................................................... 21 

Basic assumptions for the impact assessment............................................................ 21 

Impacts of the policy options on the retrofitting programme .................................... 22 

Identification of impacts ............................................................................................ 24 

Economic impacts ...................................................................................................... 25 

Environmental impacts............................................................................................... 33 

Social impacts ............................................................................................................ 37 

Sensitivity analyses .................................................................................................... 40 

Comparing the options ............................................................................................... 43 

Monitoring and evaluation ......................................................................................... 49 

Annex I: Description of policy options 

Annex II: Pre-selection and combination of policy options 

Annex III: Identification of impacts 

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GLOSSARY 

Term 

Explanation 

For the measurement of noise, the logarithmic decibel scale (dB) is 
used. An increase/ decrease of 10 dB is generally perceived as "twice 
as loud" respectively "half as loud”. A person with average hearing 
would just barely perceive a difference of 3 dB. If two separate sound 
sources are producing the same noise level then the overall noise level 
resulting from the addition of these two sources will be 3 dB higher, 
e.g.: 90 dB + 90 dB = 93 dB. Unfortunately, this has also an effect on 
noise reduction: A train composed of 10 noise wagons emitting 90 dB 
and 10 silent wagons emitting 80 dB has an average noise emission of 
87.4 dB, just below the threshold of perception of the noise reduction. 

Brake block made of composite materials with different braking 
characteristics than traditional cast-iron brake blocks. If used for 
retrofitting existing wagons, a major adaptation of the braking system 
is required. 

Brake block made of composite materials with same braking 
characteristics as traditional cast-iron brake blocks. If used for 
retrofitting existing wagons, no major adaptation of the braking system 
is required. 

Decibel  

K-block 

LL-block 

Railway 
undertaking (RU) 

Any public or private undertaking, the activity of which is to provide 
transport of goods and/or passengers by rail 

Infrastructure 
manager (IM) 

Any body or undertaking that is responsible in particular for 
establishing and maintaining railway infrastructure 

Wagon owner 
(WO) 

Any body or undertaking other than a railway undertaking that is 
technically or financially responsible for wagons  

Net Present Value 
(NPV) 

Standard method for the financial appraisal of long-term projects. Each 
cash inflow/outflow is discounted back to its value on a given date. 

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ACRONYMS 

Acronym 

CO2 

dB 

DEV 

Description 

Carbon dioxide 

Decibel (unit for noise measurements, see glossary) 

Combined Option: differentiated track access charges + noise emission ceiling + 
voluntary commitment 

DEV-79 

Combined DEV option, wagons entering service from 1979 eligible for retrofitting 

DEV-84 

Combined DEV option, wagons entering service from 1984 eligible for retrofitting 

EU 

FTE 

IM 

Lden 

MS 

NOx 

European Union 

Full Time Equivalent person 

Infrastructure Manager 

Day-evening-night noise indicator 

Member State 

Nitrogen oxides 

NPV 

Net Present Value 

PM 10 

Particulate matter smaller than 10 micrometres 

RU 

Railway Undertaking 

SOV 

Combined Option: subsidies for retrofitting + operating restrictions for noisy wagons + 
voluntary commitment 

SOV-79 

Combined SOV option, wagons entering service from 1979 eligible for retrofitting 

SOV-84 

Combined SOV option, wagons entering service from 1984 eligible for retrofitting 

tkm 

Tons x kilometre 

tr·km 

Trains x kilometre 

TSI 

UIC 

WO 

Technical Specifications for Interoperability 

Union internationale des chemins de fer (International Union of Railways)  

Private Wagon Owner 

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EXECUTIVE SUMMARY 

This impact assessment prepares a Communication of the European Commission on rail noise 
abatement  measures  addressing  the  existing  fleet.  The  aim  of  this  policy  is  to  promote 
retrofitting  of  freight  wagons  with  low-noise  brake  blocks  by  providing  financial  incentives 
and/  or  setting  up  legal  requirements.  Retrofitting  has  been  identified  by  several  studies  as 
well as by an expert group advising the Commission as the most effective and cost-effective 
measure to reduce rolling noise emissions of freight wagons. 

In the course of the analysis it has been concluded that combinations of policy instruments are 
more  suitable  and  effective  than  single  measures.  Two  combinations  of  policy  options  have 
been  assessed  in  detail  regarding  their  economic,  environmental  and  social  impacts  and 
compared to the 'no policy change' option : 

(1) 

(2) 

"SOV": Subsidies for retrofitting, Operating restrictions for noisy wagons and 
Voluntary commitment; 

"DEV":  Differentiated  track  access  charges  (financial  incentives  for  silent 
wagons), Emission ceiling for railway lines and Voluntary commitment. 

Both  policy  options  (DEV  and  SOV)  demonstrate  their  effectiveness  in  achieving  the 
objective of noise reduction. The noise emissions of freight trains could be reduced by almost 
50% until 2013/2014 if a new type of low-noise brake blocks would be used that is yet not 
fully available on the market (so-called LL-blocks). 

For all policy options and scenarios assessed, significant additional costs for retrofitting and 
maintenance  can  be  expected  in  the  range  of  550  million  €  to  2.25  billion  €.  However,  the 
results of the cost-benefit analysis show for all policy options considerable net benefits in the 
range of 2.72 to 9.46 billon €. 

Due  to  lower  costs  and  higher  benefits,  the  use  of  LL-blocks  which  do  not  require  the 
adaptation of the braking system always leads to significantly higher net benefits than the use 
of so-called K-blocks (the low-noise technology used today to equip new wagons) even if it 
has been assumed that LL-blocks would only be fully available as from 2011.  

As  overall  result  of  this  impact  assessment,  policy  option  DEV  consisting  of  noise-
differentiated track access charges with a bonus for silent wagons, noise emission ceiling and 
voluntary  commitments  has  been  identified  as  the  most  appropriate  solution  to  achieve  the 
objectives.. The main advantages of this option are the highest benefits in terms of reduction 
of  number  of  citizens  affected  by  rail  noise  (with  a  benefits-costs  ratio  of  up  to  10),  lower 
costs than the SOV option, the direct link of this initiative to the policy objectives (to reduce 
noise  by  using  silent  wagons)  and  its  easy  application  to  wagons  registered  in  different 
Member States or even outside the EU. As this policy option also has certain implementation 
requirements,  solutions  need  to  be  elaborated  for  a  harmonisation  of  differentiated  track 
access  charges  at  European  level  and  for  passing  the  noise  bonuses  to  the  wagon  owners/ 
keepers bearing the costs of retrofitting.  

Moreover high priority needs to be given to the further development and homologation of LL-
blocks  as  the  most  economic  viable  technology  for  retrofitting.  By  implementing  policy 
option  DEV  providing  incentives  to  further  reduce  costs  of  retrofitting  and  following  the 
positive examples of the United Kingdom and Portugal of cost-neutral retrofitting, it should 
be possible to reduce the additional costs of retrofitting to a minimum. 

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1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

The Communication on rail noise abatement measures addressing the existing fleet has been 
part of DG TREN’s work Programme 2007 as initiative nr. 41. 

The  impact  assessment  report  has  been  drafted  by  DG  TREN's  Unit  for  rail  transport  and 
interoperability.  The  impact  assessment  process  was  steered  by  an  Inter-Service  Steering 
Group  chaired  by  DG  TREN  and  with  members  from  SG,  ENV,  JRC,  SANCO  and  ENTR. 
Furthermore,  experts  of  the  Economic  Evaluation  Unit  of  the  European  Railway  Agency 
provided valuable input and advice for the impact assessment study. 

Public consultation 

In the course of the preparation of a Communication on rail noise which addresses abatement 
measures for the existing fleet, the Commission presented in its Consultation Paper1 issued in 
May  2007  several  policy  options  to  the  industry,  in  particular  the  railway  undertakings,  to 
other actors concerned (such as wagon keepers, infrastructure managers, freight shippers and 
forwarders),  to  associations  representing  the  rail  sector  and  others  concerned  (local  and 
regional authorities, and NGOs) as well as to the Member States of the European Union. 

Interested parties have been requested to give their opinions on the solutions presented in the 
Consultation  Paper,  in  particular  via  the  questions  it  sets.  For  this  purpose,  an  online 
questionnaire has been made available during a consultation period of 8 weeks from 4 June 
until 31 July 2007. The Commission services also convened the interested parties on 23 May 
2007 to get feedback. The presentations given at the workshop as well as a summary of the 
results of the consultation are available on DG TREN's website: 
http://ec.europa.eu/transport/rail/environment/noise_en.htm 

Therefore, it can be concluded that the Commission’s minimum standards have all been met. 

In  the  following,  the  results  of  the  public  consultation  are  summarised.  A  more 
comprehensive description of the results has been published on DG TREN's website2.  

During the consultation period 73 replies have been registered including written contributions. 
60%  of  the  replies  have  been  provided  by  organisations/  companies  and  40%  by  citizens. 
Among  the  organisations  various  types  were  represented  such  as  associations,  public  sector 
bodies, private companies, governments at different levels and consultancy. 

The  vast  majority  of  participants  in  the  consultation  process  agreed  on  the  approach  of  the 
Consultation  Paper  to  focus  on  retrofitting  of  freight  wagons  and  to  provide  the  necessary 
political  and  legal  framework.  Furthermore,  due  to  the  expected  growth  of  rail  freight 
transport,  short-term  action  would  be  urgently  required  in  some  European  regions,  mainly 
along  the  main  rail  freight  corridors,  where  rail  noise  exposure  is  very  high.  In  general,  a 
preference for measures or at least harmonisation at European level was given.  

The  consultation  confirmed  in  principle  the  initially  proposed  targets  of  the  Consultation 
Paper. However, following the majority of the contributors the minimum remaining lifetime 

1 

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Consultation  document  of  the  Commission's  services:  Rail  noise  abatement  measures  addressing  the 
existing fleet. May 2007.   
http://ec.europa.eu/transport/rail/consultation/2007_rail_noise/doc/rail_noise_consultation_document_en.pdf 

Public consultation on "Rail noise abatement measures addressing the existing fleet" - Summary of the 
contributions received. 
http://ec.europa.eu/transport/rail/consultation/2007_rail_noise/doc/rail_noise_consultation_summary_071017.pdf 

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at the end of the retrofitting programme has been reduced to 5 years to ensure a significant 
noise reduction in mid-term. Furthermore, the target will be quantified as 97% of the axle-km 
performed by silent wagons (equivalent to retrofitting wagons with more than 10,000 km/a) as 
this definition is closer to the noise reduction objective. 

Concerning  the  deadline  for  the  completion  of  the  retrofitting  exercise,  the  majority  of  the 
participants preferred the completion of the retrofitting exercise before or by 2014. However, 
according  to  information  received  from  various  stakeholders,  this  is  technically  not  feasible 
(lack  of  capacity  of  maintenance  workshops  and  suppliers)  or  would  lead  to  significant 
additional  costs  as  the  wagons  could  not  be  retrofitted  within  the  normal  maintenance 
intervals  of  about  6  to  8  years.  Therefore,  2017  as  the  initially  proposed  target  date  can  be 
regarded as well balanced between the need for immediate action to reduce rail noise and the 
feasibility/  the  economic  situation  of  the  sector.  As  proposed  by  one  contributor  the  noise 
mapping  exercise  in  the  framework  of  Directive  2002/49/EC3  should  be  used  to  assess  the 
success of the retrofitting programmes: Against the 2007 maps as baseline, first improvements 
should be visible by 2012 and for the 2017 exercise; a substantial reduction of rail noise is the 
objective of this initiative. 

The  proposed  assessment  criteria  for  the  policy  options  have  received  a  positive  opinion  of 
the  majority  of  the  participants.  However,  two  changes  have  been  made  following  the 
consultation results: 

•  A  new  assessment  criterion  "Effectiveness  for  hot  spots"  will  cover  the  effectiveness 
regarding  the  noise  reduction  for  the  population  affected  and  if  a  policy  option  allows 
differentiating regarding location and time of day/night.  

•  To clarify that potential negative impacts on railways' modal share are covered by "Impact 
on transport policy", this criterion will be renamed as "Impact on competitiveness of rail 
freight". 

With  one  exception  the  policy  options  proposed  by  the  Consultation  Paper  have  been 
confirmed  and  will  be  further  evaluated  within  the  impact  assessment.  Tradable  noise 
emission permits were refused by a majority of the contributors and have been excluded from 
the assessment.  

It  has  been  widely  accepted  that  an  integrated  approach  would  be  required  as  no  single 
measure seems to be able to solve the problems. There was no clear indication about generally 
favoured policy options. Direct subsidies and differentiated track access charges have been in 
the focus of the discussion on the workshop, but also the use of legal instruments received a 
wide support of about 80% of the contributors to the online consultation.  

The  consultation  identified  a  clear  need  for  complementary  measures,  mainly  research  and 
demonstration projects for LL-blocks, the development of a harmonised classification system 
for wagons and their noise emission and of automatic wagon identification systems as well as 
studies on life cycle costs of retrofitting. These aspects are dealt with by the Communication. 

3 

Directive 2002/49/EC of the European Parliament and of the Council of 25 June 2002 relating to the 
assessment and management of environmental noise. OJ L 189, 18.7.2002, p. 12-25. 

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Use of external expertise 

After  the  decision  has  been  taken  to  carry  out  an  impact  assessment  for  this  initiative,  a 
request  for  services  including  the  terms  of  reference  of  the  study  has  been  submitted  to 
PriceWaterhouseCoopersAdvisory in the context of the Multiple Framework Contract for ex-
ante  Evaluation  and  Impact  Assessment  (reference  TREN/A1/46-2005)  on  29  March  2007. 
The  results  of  this  study  (hereafter  called  "PWC  study")  serve  as  basis  for  the  impact 
assessment. 

After  the  signature  of  the  contact  on  7  July  2007  the  kick-off  meeting  has  been  held  on  12 
July 2007. The interim report has been delivered on 10 September 2007 followed by the final 
report on 10 December 20074. 

Recommendations of the Impact Assessment Board 

Following the hearing on 20 February the Impact Assessment Board provided its opinion on 
22 February 2008 with 4 main recommendations for improvement or clarification: 

•  The  requested  summary  overview  of  who  bears  which  costs  has  been  integrated  into 

section 6. 

•  Possible implementation problems associated with the preferred option have been further 
elaborated in section 5.7 addressing in particular the transfer of noise bonuses to the wagon 
owners bearing the retrofitting costs as well as interim actions. 

•  The explanation of the pre-selection and combination of policy options in section 4.2 has 

been more detailed by making better use of the assessment described in Annex II. 

•  The  need  for  action  at  European  level  has  been  further  explained  in  section  2  by  better 

describing potential disadvantages of national measures. 

In  addition  technical  comments  made  prior  to  the  hearing  and  in  the  course  of  the  meeting 
have been considered for the final version of this impact assessment report. 

4 

PriceWaterhouseCoopersAdvisory:  Impact  Assessment  study  on  rail  noise  abatement  measures 
addressing the existing fleet. Final report December 2007. 
http://ec.europa.eu/transport/rail/studies/index_en.htm 

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2. 

PROBLEM DEFINITION 

Problem of railway noise 

Noise  is  one  of  the  most  widespread  public  health  threats  in  industrialized  countries. 
Therefore, the abatement of noise is necessary not only for comfort but also because of other 
important health effects such as cardiovascular problems and cognitive impairment. 

Rail  transport  is  generally  considered  one  of  the  most  environmentally  friendly  transport 
modes. However, the contribution of rail transport to noise pollution is significant, though still 
lower  than  that  of  road  transport  or  aviation.  According  to  European  Environment  Agency 
figures for 20005, about 10% of the population in the EU-15 was exposed to significant noise 
from  rail  transport  (as  compared  with  a  figure  of  30%  for  road  transport  and  10%  for  air 
transport). This seems to be a relatively low figure, but when compared to the modal share of 
rail and road freight transport (17% for rail and 73% for road of land transport6), the specific 
contribution of rail is significant. More precise figures are an expected outcome of the 2007 
noise mapping exercise according to Directive 2002/49/EC. The deadline for the submission 
of the first sets of strategic noise maps for major railways and large agglomerations was 30 
December 2007. 

In  some  European  regions  (e.g.  parts  of  the  Netherlands  and  the  Rhine  valley),  there  is 
substantial  public  opposition  to  rail  noise  demanding  political  initiatives  to  reduce  it.  If  no 
remedial  action  is  taken,  this  could  lead  to  restrictions  in  rail  freight  traffic  along  the  most 
important  European  rail  corridors.  Such  bottlenecks  would  be  likely  to  have  adverse  effects 
on  European  economies.  Furthermore,  a  possible  modal  shift  from  rail  to  road  on  these 
corridors  would  lead  to  increasing  environmental  impacts,  in  particular  greenhouse  gas 
emissions as the specific CO2-emissions of rail freight are significant lower than those of road 
haulage. 

Freight wagons and their braking technology as most important source of rail noise 

According  to  the  Position  Paper  on  the  European  strategies  and  priorities  for  railway  noise 
abatement  drafted  in  2003  by  the  Working  Group  Railway  Noise  of  the  European 
Commission  consisting  of  experts  from  Member  States  and  the  rail  sector7,  rolling  noise  of 
freight  trains  has  been  identified  as  the  most  important  source  of  rail  noise.  The  braking 
technology  used  nowadays  (cast  iron  brake  blocks  braking  on  the  wheels’  surface)  leads  to 
rough  wheel  surfaces  and  subsequently  to  a  high  level  of  vibration  of  rails  and  wheels.  As 
freight trains often operate at night, their noise emission is even more critical. 

Therefore,  the  Communication  and  the  impact  assessment  are  focussing  on  this  particular 
problem.  However,  as  a  following  step,  other  measures  such  as  requirements  for  the  track 
quality  or  measures  addressing  other  sources  of  rail  noise  (high  speed  trains  or  noise  from 
train horns) will be necessary to further reduce rail noise. 

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European Environment Agency: TERM 2001. Indicators tracking transport and environment integration 
in the European Union. Copenhagen, 2001. 
Of inland modes; DG TREN: Statistical pocketbook 2006, 
http://ec.europa.eu/dgs/energy_transport/figures/pocketbook/2006_en.htm 
Working Group Railway Noise of the European Commission: Position Paper on the European strategies 
and priorities for railway noise abatement, Brussels 2003, 
http://ec.europa.eu/transport/rail/ws/doc/position-paper.pdf. 

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Noise barriers as an expensive measure 

In response to rail noise problems, infrastructure-related rail noise abatement measures such 
as  noise  barriers  are  introduced  at  national  level.  Noise  reduction  of  about  10  dB  can  be 
achieved.  However,  the  EU-funded  research  project  STAIRRS  identified  that  noise  barriers 
have very low efficiency due to the investment costs in the order of magnitude of 100 billion 
Euros  if  only  5%  of  the  lineside  population  should  have  remaining  noise  above  an  Lden  of 
60 dB(A))8. 

Therefore,  the  Working  Group  Railway  Noise  recommended  giving  priority  to  measures  at 
the source (vehicles and tracks) as they generally are more cost-effective. This would allow 
achieving a more sustainable situation of smooth running surfaces on the wheels and the rails 
("smooth  wheels  on  smooth  tracks").  A  recent  meta-study9  considering  several  studies  at 
European  and  national  level  confirmed  this  strategy  by  demonstrating  that  measures  at  the 
source, e.g. the use of low-noise brake blocks to ensure the smoothness of the wheel surfaces, 
are significantly more cost-effective than noise barriers.  
According to UIC figures10, a total of 150 - 200 million € is spent annually in Europe on these 
programmes with cumulative expenditure as of end 2005 of over 600 million €. Considering 
the  current  practice  and  the  pressing  requirements  to  draw  up  action  plans  according  to 
Directive 2002/49/EC aimed at reducing exposure to railway noise, there is a risk that non-
cost-effective  noise  abatement  measures  will  be  implemented  for  most  major  railway  lines, 
costing some billions of euros. 

Certainly, noise barriers could be an effective element of noise abatement programmes where 
necessary.  If  measures  at  the  source  complement  the  barriers,  the  length  and/  or  height  of 
barriers can be reduced leading to significant cost savings. 

Measures at source taken are not sufficient 

In  December  2005,  the  Commission  adopted  technical  specifications  for  interoperability 
relating to the subsystem "rolling stock — noise" (Noise TSI). This Decision introduced the 
first noise limits for rolling stock used in the European Union. These limits apply to new and 
renewed  rolling  stock  including  freight  wagons.  New  freight  wagons  have  to  be  equipped 
with low-noise brake blocks reducing the noise emission by about 50%. 

However, the introduction of this low-noise technology will take several years due to the long 
lifetime of rolling stock (see Figure 1). Without additional measures, not before 2020 half of 
the freight wagon fleet will be more silent. 

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10 

Working Group Railway Noise of the European Commission: Position Paper on the European strategies 
and priorities for railway noise abatement, Brussels 2003 
Oertli;  Schwarzenbach:  Cost-effectiveness  analyses  in  railway  noise.  In:  Conference  Proceedings 
"International Workshop Railway noise in urban areas". Pisa, November 2006. 
UIC: Noise Reduction in European Railway Infrastructure. Status Report 2007.  
http://www.uic.asso.fr/download.php/environnement/reductionbruitinfra_en.pdf 

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800.000

700.000

600.000

500.000

400.000

300.000

200.000

100.000

0
2009

FLEET

total fleet - w<1979
total fleet - w<1984
Low Noise
"retrofitted"
total fleet
end of time frame

2011

2013

2015

2017

2019

2021

2023

2025

2027

2029

2031

Figure 1: Predicted evolution of the freight wagon fleet (EU-27 countries with 1435 mm 
standard gauge)  

The  effective  reduction  of  the  noise  emissions  will  be  even  slower  due  to  the  logarithmic 
nature  of  noise  perception11.  Half  of  the  expected  average  reduction  of  8  dB  following  the 
renewal  of  the  fleet  with  low-noise  wagons  will  only  be  achieved  by  2025  (see  Figure  2). 
Therefore,  additional  measures  are  required  addressing  the  existing  fleet.  Retrofitting  these 
wagons with low-noise braking technology would speed up the noise reduction significantly. 

10

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7

6

5

4

3

2

1

B
d

0
2009

emitted sound level reduction [dB]

Reduction of Affected population >55dB [Mpers]

REDUCTION OF NOISE
AND AFFECTED POPULATION

2011

2013

2015

2017

2019

2021

2023

2025

2027

2029

10

9

8

7

6

5

4

3

2

1

s
n
o
s
r
e
p
M

0
2031

Figure 2: Predicted average reduction of emitted noise and affected population  

11 

For  the  measurement  of  noise,  the  logarithmic  decibel  scale  (dB)  is  used.  An  increase/  decrease  of 
10 dB  is  generally  perceived  as  "twice  as  loud"  respectively  "half  as  loud”.  Further  expiations  are 
provided in the glossary.  

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Low-noise technology needs further development 

The technology is now available to reduce rail noise significantly at its source. Several types 
of low-noise brake blocks have been developed by industry, tested and homologated by UIC 
(K-blocks  in  2003)  or  provisionally  homologated  (LL-blocks  in  2005).  K-blocks  are  very 
effective in noise abatement (reduction of up to 10 dB) and are in general regarded as about 
cost neutral for new vehicles. However, as they demonstrate different braking characteristics 
compared to the conventional cast iron blocks, retrofitting requires adjustments in the braking 
system, leading to additional initial costs in the range of EUR 3000 to 12000.  

LL-blocks  are  currently  developed  to  be  better  suited  to  retrofitting  because  they  do  not 
require such adjustments. However, due to technical problems or missing practical experience 
they  have  not  yet  received  the  definitive  homologation  and  most  of  the  currently  available 
types  of  LL-blocks  consist  of  sinter  metal,  an  expensive  material  leading  to  high  costs  per 
brake block. Currently, LL-blocks are expected to lead to an increase of maintenance costs. 

Obstacles for retrofitting 

The  main  obstacles  to  retrofitting  freight  wagons  on  a  large  scale  are  financial.  Even  if 
retrofitting  is  widely  agreed  to  be  the  most  cost-effective  way  of  significantly  reducing  rail 
noise, stakeholders do not have sufficient resources or incentives to do it: 

•  Railway undertakings (RUs) and wagon owners/ keepers could simply decide to launch a 
retrofitting  programme  for  their  own  wagons.  However,  they  do  not  have  sufficient 
incentives  to  do  so  as  they  have  to  bear  additional  costs  (retrofitting  and  the  risk  of 
increased maintenance costs) and there are no economic short-term benefits. Furthermore, 
the  rail  sector  is  under  high  competitive  pressure  from  other  transport  modes.  Certainly, 
retrofitting  would  be  an  investment  in  the  availability  of  network  capacity  (which 
otherwise might be reduced in the near future due to restrictions on noisy freight wagons) 
and the stability of track access charges, but the additional costs of retrofitting do impede 
any voluntary action. 

•  The infrastructure managers (IMs) are not responsible for the rolling stock. Moreover, the 
eventual  savings  in  infrastructure  maintenance  costs  due  to  less  rail  wear  following  the 
introduction  of  wagons  with  smooth  wheels  have  not  yet  been  determined  and  Member 
States are financing existing infrastructure-related noise abatement programmes. 

•  Member States could save money from retrofitting freight wagons, as costly infrastructure-
related  noise  abatement  programmes  could  be  reduced.  However,  they  have  no  direct 
influence over the RUs' decision on retrofitting freight wagons. 

•  Citizens living close to railway lines are affected by rail noise. They do not have any direct 
influence on decisions concerning noise abatement either at the source or by implementing 
infrastructure related-programmes.  

To summarise, retrofitting freight wagons to reduce the need to build noise barriers would be 
the most efficient solution for all stakeholders. The lack of direct influence on the decision on 
retrofitting  programmes  (IMs,  Member  States)  and/or  the  lack  of  short-term  benefits  and 
funds (RUs and wagon owners) are major obstacles to implementing the most cost-effective 
measures to reduce rail noise.  

This  can  be  regarded  as  a  market  failure  and  therefore,  public  intervention  is  required  to 
overcome  these  obstacles  by  identifying  and  promoting  the  most  effective  and  efficient 
measures to implement retrofitting at European level. 

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The EU's right to act 

Article  174  of  the  Treaty  establishing  the  European  Community  provides  that  Community 
policy  on  the  environment  shall  contribute  to  protecting  human  health  and  to  preserving, 
protecting and improving the quality of the environment. Moreover, Articles 6 and 152 of the 
EC  Treaty  links  health  and  environmental  protection  to  transport  policy  by  stipulating  their 
integration into all Community policies and activities. 

Furthermore, Article 156 of the EC Treaty in accordance with Article 155 (1) gives the EU 
the  power  to  take  measures  in  the  transport  sector  to  ensure  the  interoperability  of  the 
networks.  Based  on  Article  156  of  the  EC  Treaty  and  Articles  6  (1)  and  23  (1)  of  the 
Interoperability  Directive  for  conventional  rail12,  the  TSI  Noise  has  been  adopted  by  the 
Commission introducing limit values for new and renewed rolling stock. 

The issue of retrofitting the existing freight wagon fleet has been identified in section 7.4 of 
the Noise TSI, which states: "Given the long life-cycle of railway vehicles it is also necessary 
to  take  measures  on  the  existing  fleet  of  rolling  stock,  with  priority  for  freight  wagons,  to 
foster a noticeable reduction of the perceived noise level within a reasonable time period. The 
Commission will take initiatives to discuss options for retrofitting of freight wagons with the 
relevant stakeholders to achieve a general agreement with the industry." 

impact,  national  abatement  strategies  cannot  solve 

Today, about 50% of rail freight transport is international. For that reason, a large number of 
wagons run across national networks. As a small number of noisy vehicles can determine the 
noise 
the  problem  sufficiently. 
Furthermore, national approaches could negatively impact on cross border corridors and give 
a competitive advantage to some players against others. In addition, by Community law and 
its harmonised implementation different national approaches can be avoided. 

Therefore, it can be concluded that in accordance with the principle of subsidiarity as set out 
in Article 5 of the EC Treaty, the objective of reducing the number of people affected by rail 
noise  significantly  will  be  better  reached  by  complementing  the  action  already  taken  by  the 
Member States by a Community action on rail noise abatement. 

However, not all of the answers can be given at EU level. The Impact Assessment points out 
that various policy actions at EU and national level as well as actions taken by stakeholders 
are necessary; each have their role to play in realising the potential. It is essential that all these 
actors are actively involved. 

12 

Directive  2001/16/EC  of  the  European  Parliament  and  the  Council  of  19  March  2001  on  the 
interoperability of the conventional rail system. OJ L 110 of 20.04.2001; page 1. 

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3. 

OBJECTIVES 

General objectives 
EU transport policy, as recently reaffirmed in the 2006 Mid-term Review13 of the White Paper 
of  200114,  calls  for  effective  and  efficient  transport  systems  offering  high  quality  services, 
environmental  protection,  innovation  and  international  connections.  The  development  of  a 
European  Community  rail  area  would  meet  these  objectives  in  a  sustainable  manner,  as  it 
would ensure high energy efficiency  and a low level of pollutants' emissions.  However,  the 
impact of rail noise might result in restrictions to rail freight traffic along the most important 
European rail corridors. 

The  environmental  policy  of  the  European  Union  “aims  at  a  high  level  of  protection”  in 
particular  regarding  human  health15.  Article  7(1)  of  the  Sixth  Environmental  Action 
Programme16 sets the target of “substantially reducing the number of people regularly affected 
by long-term average levels of noise, in particular from traffic which, according to scientific 
studies, causes detrimental effects on human health”. The renewed Sustainable Development 
Strategy  adopted  in  2006  by  the  Council  sets  out  overall  objectives,  targets  and  concrete 
actions for seven key priority challenges for the period to 2010, one of which is sustainable 
transport. One of the operational targets set for this key priority is 'reducing transport noise 
both  at  source  and  through  mitigation  measures  to  ensure  overall  exposure  levels  minimise 
impacts on health'. 

In  this  context  and  in  accordance  with  Directive  2002/49/EC,  the  European  Commission 
develops and completes the existing set of Community measures concerning noise emitted by 
the major sources, in particular road and rail vehicles and infrastructure, aircraft, outdoor and 
industrial  equipment  and  mobile  machinery,  and  for  developing  additional  measures,  in  the 
short, medium and long term. 

In line with these policies, the overall target for rail noise abatement programmes addressing 
the existing fleet should therefore be to reduce the number of people regularly affected by rail 
noise,  by  means  of  abatement  measures  with  the  highest  cost-effectiveness  ratio  and  health 
benefits. Given that the lack of appropriate mitigating measures may be a serious threat to the 
development of rail traffic, the European Commission will prepare a Communication on rail 
noise which covers abatement measures for the existing fleet. 

13 

14 
15 

16 

COM (2006) 314 of 22.06.2006: "Keep Europe moving – Sustainable mobility for our continent – Mid-
term review of the European Commission’s 2001 Transport White Paper". 
COM (2001) 370 of 12.09.2001: “European transport policy for 2010: Time to decide”. 
See  the  Consolidated  Version  of  the  Treaty  Establishing  the  European  Community,  Article  174: 
"Community policy on the environment shall aim at a high level of protection […] It shall be based on 
the  precautionary  principle […]  environmental  damage  should as  a priority  be rectified  at  source  and 
[…] the polluter should pay." 
Decision 1600/2002/EC of the European Parliament and of the Council of 22 July 2002 laying down the 
Sixth Community Environment Action Programme, OJ L 242, 10.9.2002, p. 1. 

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Specific objectives 

The  retrofitting  exercise  should  in  principle  include  all  European  freight  wagons  with  an 
annual  mileage  of  more  than  10 000 km  and  an  expected  remaining  lifetime  of  at  least  5 
years. Wagons with a mileage of less than 10 000 km per year account for less than 3% of the 
overall  transport  performance  of  the  freight  fleet.  Therefore,  these  restrictions  could  reduce 
the cost of retrofitting significantly without jeopardising the objective of noise reduction. 

As additional indicator the number of axle-km run by low-noise wagons will be used, as this 
is more closely related to noise reduction than an indicator related to the number of wagons. 
The target is set as 97% of the overall European amount of axle-km (excluding wagons with 
low annual mileages of up to 10 000)), equivalent to the wagon-related target. 

To maximise noise reduction at an early stage, priority should be given to retrofitting wagons 
with a high yearly mileage. 

The proposed target date for completing the retrofitting exercise would be 2017. This assumes 
that  retrofitting  starts  in  2009/2010  (one  or  two  years  after  the  intended  adoption  of  the 
Communication) and that the normal maintenance cycle for freight wagons applies (about 6 to 
8  years).  Including  retrofitting  as  part  of  the  normal  overhaul  of  wagons  would  avoid  the 
additional  cost  of  withdrawing  wagons  from  service  and  moving  them  to  maintenance 
workshops. 

Furthermore, as an important milestone, against the 2007 noise maps (according to Directive 
2002/49/EC) as baseline, first improvements should be visible by 2012. For the 2017 mapping 
exercise  a  substantial  reduction  of  noise  emission  of  freight  wagons  is  the  objective  of  this 
initiative. 

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4. 

POLICY OPTIONS 

4.1. 

Description of policy options 

Possible policy options and instruments to support/ promote retrofitting of the European rail 
freight fleet are listed below and briefly described. Beside, a 'doing nothing/ no policy change' 
option  will  be  used  as  baseline  scenario  (policy  option  A).  Annex  I  provides  more  detailed 
descriptions of the policy options. 

The combination of different instruments is examined, as the problem is rather complex and 
rail freight and rail noise conditions vary greatly across the EU. 

Policy option B consists of actions paving the way towards a voluntary commitment by the 
various  stakeholders  –  railway  undertakings,  wagon  owners  and  infrastructure  managers.  A 
voluntary  commitment  could  include  such  components  as  commitments  to  individual 
objectives (e.g. individual retrofitting targets), to set up and implement appropriate retrofitting 
programmes  to  define  priorities  in  order  to  get  the  best  results  and/  or  to  financial 
contributions from the sector. 

To overcome the financing problem, which is the main obstacle to retrofitting, wagon owners 
could  be  given  financial  incentives  (policy  option  C).  In  this  context,  it  is  important  to 
underline that subsidies granted by Member States to economic actors should be regarded as 
state aids according to Article 87 of the EC Treaty. The EC Treaty generally prohibits state 
aid  which  affects  competition  between  markets  actors,  unless  it  is  justified  by  reasons  of 
general  economic  development.  The  European  Commission  is  in  charge  of  watching  over 
compliance of state aid with EU competition rules. For this purpose, the Commission services 
are preparing state aid guidelines for the rail sector. A draft of the guidelines17 has been made 
available  in  December  2007  for  consultation  with  the  Member  States  and  stakeholder. 
Following  instruments  to  provide  financial  incentives  have  been  examined  in  this  impact 
assessment: 

•  Differentiated track access charges (C1): This instrument addresses the existing financial 
flow  between  railway  undertakings  and  infrastructure  managers:  the  track  access  charge. 
The  railway  undertakings  would  receive  a  discount  on  this  charge  if  using  low-noise 
rolling stock. Based on Directive 2001/14/EC18 harmonising charging principles two basic 
models of differentiated track access charges could be used as an incentive: a cost-neutral 
bonus-malus system or a bonus system where the infrastructure manager receives financial 
compensation from the Member State. 

•  Subsidies  for  the  use  of  low-noise  wagons  (C2):  Another  instrument  for  granting 
financial  incentives  to  railway  undertakings  to  use  low-noise  freight  wagons  is  subsidies 
from  Member  States  directly  to  the  railway  undertakings.  The  subsidy  scheme  could 
contain components similar to a discount on track access charges.  

•  Subsidies for retrofitting (C3): This instrument consists  of  introducing noise  abatement 
programmes with direct public financial support. The cost of retrofitting would be partly or 

17 

18 

Preliminary draft Community guidelines on State aid for railway undertakings.  
http://ec.europa.eu/dgs/energy_transport/state_aid/consultation_ms_en.htm 
Directive  2001/14/EC  of  the  European  Parliament  and  of  the  Council  of  26 February 2001  on  the 
allocation  of  railway  infrastructure  capacity  and  the  levying  of  charges  for  the  use  of  railway 
infrastructure and safety certification, OJ L 75, 15.03.2001, p. 29. 

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16 

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fully  reimbursed.  Subsidies  for  retrofitting  could  be  granted  by  Member  States  or  at 
European level. 

•  Loans  at  preferential  terms  (C4)  could  be  granted  to  wagon  owners  to  promote 

retrofitting, in particular to support the initial outlay.  

•  Tax incentives (C5) provide financial incentives by granting tax allowances for operators 
applying more environmentally friendly solutions. To support retrofitting, composite brake 
blocks could be excluded from VAT. 

Beside  economic  incentives,  legal  instruments  (policy  option  D)  could  be  used  to  impose 
retrofitting  of  freight  wagons.  These  instruments  normally  entail  restrictions  on  the  use  of 
"noisy" wagons. They can be implemented at European, national or regional level: 

•  One  approach  would  be  to  impose  noise  limit  values  for  existing  freight  wagons  (D1), 
e.g. by extending  the scope of the Noise TSI to the existing  fleet  while at the same time 
fixing a calendar for phasing out "noisy" wagons.  

•  Operating restrictions for noisy freight wagons (D2): On certain sensitive lines and/ or 
at  certain  times  (at  night),  access  for  noisy  vehicle  types  or  train  formations  could  be 
restricted.  

•  The noise emission ceiling (D3) limits daily average emissions at a certain location along 
the  line.  For  example,  current  noise  emission  could  be  taken  as  a  limit  to  prevent  noise 
from  increasing  if  rail  freight  transport  grows.  Under  Directive  2002/49/EC,  Member 
States are legally competent to set such limits to environmental noise. The noise emission 
ceiling leaves it to the rail sector to find optimal solutions: either to use low-noise wagons 
or to reduce speed or number of trains.  

•  Under a tradable permit scheme (D4), a specific permit issued by public authorities must 
be obtained to produce emissions. A polluter who does not have enough permits can either 
reduce emissions or buy additional permits on the market. The number of permits would be 
reduced every year until the retrofitting target has been achieved. 

4.2. 

Pre-selection and combination of policy options 

A screening of the policy options against the criteria is leading to the identification of those 
policy  options  that  are  likely  to  meet  the  objectives  the  best.  They  are  further  assessed 
regarding  their  environmental,  economic  and  social  impacts.  The  screening  is  described  in 
detail in Annex II. 

As  result  of  this  evaluation,  policy  options  B  (voluntary  commitment),  C1  (differentiated 
track  access  charges),  C3  (subsidies  for  retrofitting),  D2  (operating  restrictions  for  noisy 
freight  wagons)  and  D3  (noise  emission  ceiling)  will  be  further  dealt  with  in  the  impact 
assessment. 

The  remaining  policy  options  have  been  checked  regarding  possible  combinations  as 
according  to  the  results  of  the  public  consultation,  no  single  instrument  is  regarded  as 
sufficient to achieve the objectives. Therefore, possible combinations of legal and economic 
instruments  have  been  further  analysed  regarding  complementarity  aspects  and  possible 
synergies  (see  Annex  II).  It  has  been  identified  that  a  combination  of  legal  and  financial 
instruments is likely to be most effective and efficient because: 

•  legal options not combined with financial incentives would result in excessive burden on 
the  rail  sector,  for  the  same  reasons  which  led  to  the  exclusion  of  policy  option  D1  (see 
Annex II); 

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•  financial  incentives  not  combined  with  legal  measures  could  not  guarantee  alone  a  high 
retrofitting rate due to a lack of obligatory nature of these instrument. In particular at long 
term,  accompanying  legal  measures  could  ensure  the  effectiveness  of  retrofitting 
programmes. Furthermore, possible double funding and/or a distortion of competition are 
two main disadvantages of combinations of financial instruments. 

•  Financial  incentives  combined  with  legal  instruments  put  more  pressure  on  the  players 
concerned to retrofit. In exchange they receive the financial support necessary to avoid a 
negative modal shift from rail towards road. 

The results of this analysis are summarised in Table 1, a detailed description is documented in 
Annex II. 

Table 1: Summary of the possible combinations of the selected policy options: Assessment of 
the degree of complementarity  

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Financial 
incentives 

Legal 
measures 

Differentiated track access charges (C1) 

Low 

Med. 

High 

Subsidies for retrofitting (C3) 

Operating restriction for noisy wagons (D2) 

Noise emission ceiling (D3) 

High  Med. 

Low 

As the combined measures are regarded as superior to the single policy options, the detailed 
impact assessment will focus on the two following combinations: 

1. 

2. 

"SOV": Subsidies for retrofitting, Operating restrictions and Voluntary commitment 
(C3 + D2 + B): 
For this combination of instruments the effectiveness to address hot spots would be 
higher  compared  to  subsidies  as  single  instrument.  In  addition,  negative  economic 
impact on the rail sector caused by the introduction of operating restrictions would be 
compensated by the subsidies.  

"DEV":  Differentiated  track  access  charges,  Emission  ceiling  and  Voluntary 
commitment (C1 + D3 + B): 
Noise  emission  ceilings  could  help  to  increase  the  effectiveness  of  track  access 
charges as RUs/ WOs would have more incentives for retrofitting than in case of a 
stand-alone  policy  option.  In  addition,  synergy  effects  could  be  used  as  both 
instruments  require  the  implementation  of  monitoring  systems  to  identify  silent/ 
noisy wagons. Therefore, the administrative costs per individual policy option could 
be reduced. 

A voluntary commitment by the sector is strongly recommended in any future scenario; it is 
considered as a part of all policy options assessed. As stand-alone measures it strongly lacks 
effectiveness (see Annex II). 

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4.3. 

Description of policy options selected for the detailed impact assessment 

Status quo (baseline scenario) 

The baseline scenario is based on the assumption of no EU action to provide incentive for the 
increase of wagons equipped with low-noise technology and of the kilometres run by these. A 
zero retrofitting rate is assumed. 

Based on the existing legislation, the implementation of Directive 2002/49/EC and the Noise 
TSI is assumed to continue: 

•  Noise  action  plans  leading  to  ongoing  infrastructure-related  rail  noise  abatement 

programmes with an annual volume of up to 200 M€; 

•  At the end of their lifetime, replacement of noisy wagons by new wagons equipped with 

low-noise technology complying with the limit values of the Noise TSI. 

The other policy options are assessed against this baseline scenario. Costs and benefits of the 
baseline scenario are set to zero. 

SOV (Subsidies for retrofitting, Operating restrictions and Voluntary commitment) 

The SOV combined option is characterised as follows: 

•  Subsidies  are  granted  on  demand  to  cover  retrofitting  costs  (on  presentation  of  invoices 
and demonstration of eligibility by owner or with fixed rates per wagon type) and possibly 
extra  administrative  and  maintenance  costs  (fixed  percentage  of  retrofitting  costs  which 
also takes into account an extra margin to avoid penalising the owner) for a defined period 
after a wagon has been retrofitted. 

•  Operating restrictions are introduced for hot-spots at the earliest date which allows not to 
penalise the railway sector; the restrictions consist of prohibition for wagons not equipped 
with  approved  low-noise  technology  to  circulate  during  the  night  time  (22-6  h)  on  given 
lines/nodes/corridors  already  identified  as  critical  by  Member  State  authorities;  wagons 
equipped  with  approved  low-noise  technology  are  identified  by  markings/  tags. 
Furthermore, the quality of track as influencing factor on noise emissions could be taken 
into account when defining operating restrictions. 

•  Voluntary  commitments  involve  RUs  (to  monitor  efficiency  of  low-noise  wagon 
management:  these  wagons  should  be  privileged  in  terms  of  load-factor,  mileage,  use  at 
hot spots) and IMs (to enforce operating restrictions). 

Following timetable is assumed for the option SOV: 

•  2008/2009: Member States prepare legal bases for funding programmes and for operating 
restrictions, notification of state aids to the European Commission; RUs prepare retrofitting 
programmes  (in  particular  engineering  in  case  of  K-block  retrofitting),  preparation  of 
voluntary  commitment  to  ensure  noise-reducing  fleet  management  (priority  for  high 
mileage wagons for retrofitting and use); 

•  2010 – 2013 (K+LL-blocks) resp. 2010 – 2016 (K-blocks): Retrofitting period (retrofitting 

of wagons funded by Member States); 

•  2014  (K+LL-blocks)  resp  2017  (K-blocks):  End  of  funding/  retrofitting  programmes; 

operating restrictions in force. 

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DEV (Differentiated track access charges, Emission ceiling and Voluntary commitment) 

The DEV combined option considered in this study is thus characterised as follows: 

•  Differentiated track access charges are put in place by IMs: a bonus is granted to RUs 
for  each  “wagon  path”  run  by  a  low-noise  wagon,  automatically  identified  by  tags.  The 
level of the bonus is adjusted to a certain mileage of wagons to be retrofitted (10 000 km/y 
according to the objectives of the Communication). Transfer of funds from RUs to WOs is 
to be ensured by market forces (the rental prices for silent wagons will increase compared 
to those for noisy wagons) and by making the discounts granted  to RUs “transparent” to 
WOs so that the latter feel entitled to claim a discount to the former. 

•  Noise emission ceilings are fixed at locations equipped with measurement stations (“noise 
traps”),  on  the  basis  of  emissions  measured  before  the  date  of  ceiling-enforcement-start 
(end of retrofitting programme). Noisy wagons are automatically identified. Penalties are 
imposed by the IM on “noisy” RUs. Penalties are eventually transferred from RUs to WOs. 

•  Voluntary  commitments  by  the  RUs  in  particular  to  transfer  funds  to  WOs  through 

discounts on demand. 

Following timetable is assumed for the option DEV: 

•  2008 – 2011: IMs prepare implementation of differentiated track access charges (charging 
scheme, monitoring system); Member States prepare legal basis for noise emission ceiling; 
RUs  prepare  retrofitting  programmes  (in  particular  engineering  in  case  of  K-block 
retrofitting), preparation of voluntary commitment to ensure that WOs benefit from bonus 
grated to RUs;  

•  2012 – 2014 (LL-blocks) resp. 2012 – 2018 (K-blocks): Differentiated track access charges 

implemented, retrofitting period; 

•  2015  (LL-blocks)  resp  2019  (K-blocks):  End  of  funding/  retrofitting  programmes;  noise 

emission ceilings in force. 

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5. 

ANALYSIS OF IMPACTS 

5.1. 

Basic assumptions for the impact assessment 

This impact assessment is based on following assumptions: 

•  The geographical scope is limited to EU Member States with a 1435 mm standard gauge 
system.  Within  these  interoperable  networks  action  is  needed  at  EU  level  as  national 
measures  are  of  limited  effectiveness  (see  section  2).  As  result,  of  the  EU-27  Member 
States, only the 18 countries needed to be considered accounting for 89.5% of the EU-27 
freight fleet and 83.9% of the net tkm transported in the EU-27. 
Non-standard  gauge  countries  are  not  considered  since  the  wagons  of  their  networks 
cannot run on the large European standard gauge network. The problem of noise emitted 
by  these  wagons  could  be  addressed  more  effectively  by  the  individual  countries,  not  at 
European level. However, if required the methodology applied in this report can easily be 
extended  to  these  wide-gauge  networks,  if  the  problems  are  to  be  addressed  at  the  EU 
level. 
Non-EU  countries  are  considered  only  qualitatively.  It  is  not  possible  for  them  to  be 
addressed  directly  by  the  Community.  The  countries  sharing  the  1435  mm  network  are 
mainly the Balkan countries (fleet of 4% of that of the 18 Impact Assessment countries), 
Switzerland  (all  wagons  retrofitted  by  2015  according  to  the  ongoing  retrofitting 
programme), Norway (share of 0.4% of the European 1435 mm fleet). 

•  LL-blocks are currently not fully homologated by UIC. However, as they are likely to be 
economically  more  viable  for  retrofitting  that K-blocks,  two  scenarios  are  considered  for 
the policy options:  
1.  LL-Blocks  will  never  be  homologated  and  retrofitting  is  fully  based  on  K-blocks 
("Retrofitting with K-blocks"); 
2.  LL-blocks  will  be  available  at  large  scale  as  from  January  2011  (before  this  date,  K-
blocks  will  be  used;  given  the  fact  that  at  end  of  2007,  3  different  LL-blocks  received  a 
provisional homologation and that one of them passed all tests according to the UIC leaflet 
541-419, this scenarios has a certain likelihood ("Retrofitting with K- and LL-blocks"). 

•  Effects  will  be  considered  in  the  time-frame  2009  –  2024.  The  effects  of  the  different 
policy  options  will  be  evaluated  until  2030.  The  degree  of  uncertainty  of  the  monetary 
values of costs and, most of all, benefits at later dates was reckoned to be too significant 
for a robust analysis. The standard discounting rate for Commission impact assessments of 
4% has been applied. 

•  100% compliance with all policy measures is assumed in order to compare the potential of 

the instruments. At a later stage, this assumption is subject to a critical review. 

•  A significant number of wagons has been built between 1979 and 1984. As it is likely to 
have a strong impact on costs and benefits of retrofitting, two scenarios are applied to the 
policy options: 
1. Limit birthdate 1979: all wagons built after 1979 are retrofitted; 
2. Limit birthdate 1984: all wagons built after 1984 are retrofitted. 

•  Wagon  lifetime  has  been  assumed  to  equal  bogie  lifetime  (frame,  major  suspension 

elements), in average 35 years is used for the lifetime. 

19 

UIC leaflet 541-4 "Brakes - Brakes with composition brake blocks - General conditions for certification 
of composite brake blocks" 

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21 

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•  Wagons  equipped  with  low-noise  blocks  (K  and  LL)  have  an  overall  noise  emission 
reduction of 8 dB on average track. This figure considers the noise emission reduction by 
K- and LL-blocks on smooth rail of about 12-13 dB according to measurements carried out 
in  200720  as  well  as  factors  limiting  the  noise  reduction  as  average  roughness  of  rails, 
switches, curves, braking noise and the noise level of locomotives that is assumed not to be 
reduced.  

As  result  following  scenarios  are  used  for  the  comparison  of  policy  options  under  different 
assumptions: 

Table 2: Scenarios for the impact assessment 

K-blocks 

K- & LL-blocks 

Limit birthdate 1979  Retrofitting  wagons  put 

into 
service  in  1979  or  later  with  K-
blocks 

Retrofitting wagons put into service in 
1979 or later with LL-blocks (as from 
2011; use of K-blocks in 2010) 

Limit birthdate 1984  Retrofitting  wagons  put 

into 
service  in  1984  or  later  with  K-
blocks 

Retrofitting wagons put into service in 
1984 or later with LL-blocks (as from 
2011; use of K-blocks in 2010) 

5.2. 

Impacts of the policy options on the retrofitting programme 

The  different  financial  options  act  as  incentives  for  retrofitting  and  thus  have  a  significant 
effect on the retrofitting rate. 

The  selected  range  in  terms  of  duration  of  the  retrofitting  programme  with  the  K-block 
solution  is  7  years;  there  is  no  point  considering  periods  of  less  than  7  years  (the  nominal 
interval  for  periodic  maintenance  is  about  6  –  12  years)  since  there  would  be  costs  for  the 
unavailability of wagons and in addition a potential saturation of workshop capacity. 

Since  the  retrofitting  programme  with  LL-blocks  is  less  expensive  and  workshop  capacities 
are no constraint, the selected duration of the retrofitting period is 3 years. 

The  policy  options  considered  have  been  differentiated  according  to  specific  characteristics 
and parameters in particular the ones listed here. 

•  Starting date: year in which the retrofitting programme will start. Both the SOV and DEV 
options necessitate a relatively long lead-in time. This leads to the consideration of a zero 
retrofitting rate for the first few years of the time frame. 

•  Retrofitting time frame: period between the first and the last retrofitted wagon. 

•  Annual retrofitting rate: average number of wagons retrofitted per year. 

•  Time for 100% silent wagons (years): number of years required to reach a fleet composed 

totally of retrofitted and new wagons (equipped with K-or LL-blocks). 

•  Wagons  to  be  retrofitted:  total  number  of  wagons  that  have  to  be  retrofitted  within  the 

period considered. 

20 

Measurements have been carried out within the SILENCE project (http://www.silence-ip.org/site/) and 
within the Dutch noise innovation programme 
(http://www.innovatieprogrammageluid.nl/GBpage.asp?id=1071) 

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Table 3: Characteristics of retrofitting programmes for different policy options  

Scenario 

Starting 
date for 
retro-
fitting 

Retro-
fitting time 
frame 

Average 
yearly 
retrofitting 
rate 

Baseline 

- 

- 

0 

% of 
silent 
wagons 
in 2017 

38% 

1-2010 

7 years  

45,700 w/y 

100% 

Time 
for100% of 
silent wagons 
(end year) 

Wagons 
to be 
retro-
fitted 

2030 

2016 

0 

320,000 

1-2010 

7 years  

27,400 w/y 

75% 

2021 

191,000 

1-2012 

7 years  

38,600 w/y 

73% 

2018 

270,000 

1-2012 

7 years  

27,100 w/y 

64% 

2021 

190,000 

1-2010 

4 years 

99,500 w/y 

100% 

2013 

397,400 

1-2010 

4 years 

50,000 w/y 

75% 

2021 

191,000 

1-2012 

3 years 

124,000 w/y 

100% 

2014 

372,000 

1-2012 

3 years 

64,000 w/y 

75% 

2021 

191,000 

O

I
R
A
N
E
C
S
K

O

I
R
A
N
E
C
S
L
L
+
K

SOV 
(1979) 

SOV 
(1984) 

DEV 
(1979) 

DEV 
(1984) 

SOV 
(1979) 

SOV 
(1984) 

DEV 
(1979) 

DEV 
(1984) 

Retrofitting rates for K-blocks of 50,000 wagons per year are still considered to be within the 
capacity of workshops. In fact, since roughly 560,000 wagons need to be inspected in about 6 
years, workshops are currently capable of handling over 90,000 wagons per year.  

Retrofitting with LL-blocks can be carried out at much higher rates since it simply requires 
brake block replacement which can be done outside the workshop. 

The following graphs show the evolution of the total fleet and of its composition in terms of 
retrofitted wagons and low-noise wagons (new + retrofitted) as a function of time. 

800,000

700,000

600,000

500,000

400,000

300,000

200,000

100,000

0
2009

total fleet - w<1979

total fleet - w<1984

Low Noise

"retrofitted"

total fleet

end of time frame

FLEET

2011

2013

2015

2017

2019

2021

2023

2025

2027

2029

2031

Figure 3: Fleet development under scenario K – SOV (1979)  

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800,000

700,000

600,000

500,000

400,000

300,000

200,000

100,000

0
2009

total fleet - w<1979

total fleet - w<1984

Low Noise

"retrofitted"

total fleet

end of time frame

FLEET

2011

2013

2015

2017

2019

2021

2023

2025

2027

2029

2031

Figure 4: Fleet development under scenario K – SOV (1984)  

800,000

700,000

600,000

500,000

400,000

300,000

200,000

100,000

0
2009

total fleet - w<1979

total fleet - w<1984

Low Noise

"retrofitted"

total fleet

end of time frame

FLEET

2011

2013

2015

2017

2019

2021

2023

2025

2027

2029

2031

Figure 5: Fleet development under scenario K+LL – DEV (1979)  

800,000

700,000

600,000

500,000

400,000

300,000

200,000

100,000

0
2009

total fleet - w<1979

total fleet - w<1984

Low Noise

"retrofitted"

total fleet

end of time frame

FLEET

2011

2013

2015

2017

2019

2021

2023

2025

2027

2029

2031

Figure 6: Fleet development under scenario K+LL – DEV (1984)  

5.3. 

Identification of impacts 

A  set  of  impacts  has  been  identified  as  possible  effects  of  the  proposed  policy  options.  In 
the  economic, 
accordance  with 

the  Commission  guidelines  for 

impact  assessment 

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environmental and social impacts are briefly described in the tables of Annex III and further 
elaborated in sections 5.4, 5.5 and 5.6. 

5.4. 

Economic impacts 

5.4.1. 

Investment cost for retrofitting 

Total costs for the retrofitting programme depend not only on unit cost of a retrofitted wagon 
but  also  on  retrofitting  time  frame,  speed  of  retrofitting,  total  number  of  wagons  to  be 
retrofitted and discount rate (see Table 4).  

Table 4: Quantitative description of cost factor for retrofitting 

Factors 

Assumption and quantitative description 

Number of axles and 
type of wagon  

According to the most recent analysis carried out for UIC/UIPUIRR wagons, 
30% of the EU-25 fleet has been considered made up of 2-axle wagons and 
70% of 4-axle wagons. 

Purchase of the 
components to be 
replaced  

Labour cost of the 
replacement 

Cost of testing and 
accepting retrofitted 
vehicle 

The price of a K block has been fixed at 23€ per shoe (accordingly with real 
cost figures given by different RUs) and for LL-blocks at 50 €. A yearly price 
decrease has been considered as a fully developed market could generate a 
price reduction.  
New brake cylinder: the purchase price of a brake cylinder could range 
between 700 and 1,000€;  
“empty-loaded valve” (replacement could be required replacement when 
cylinder is replaced): the valve could range between 900 and 1,350 € 
cost of the wheel: 800 €; it has been  assumed , based on experiences from the 
Swiss retrofitting programme, that 15% of the wheels need to be replaced (K- 
and LL-block retrofitting) 

Level of labour cost is widely differing in EU; so it has been considered that 
cost per hour could range from 41 to 53€. Thus the total labour cost ranges 
between 950 and 2,500 €. For the Impact  Assessment the value taken is 1,700 
€ per wagon with K-blocks; for LL blocks  no labour costs has been included as 
the blocks need to be changed anyway.  
According to an AEA Technology report21, the testing cost has been 
considered only for K-block retrofitting and has been estimated at 400€ per 
wagon 

Based  on  the  assumptions  described  in  the  table  before,  for  the  purpose  of  the  impact 
assessment the total cost for retrofitting has been considered: 

–  of 7.000 € per wagon with K-blocks solution; 

–  of 1.360 € per wagon with LL-blocks solution. 

Thus retrofitting using LL-Blocks could be significantly less expensive: in the analysis, only 
direct costs, brake block cost and wheel reprofiling will be considered for LL-Blocks.  

These  investment  costs  per  wagon  lead  to  following  total  investment  costs  for  retrofitting 
programmes  for  the  different  scenarios  between  260  million  Euros  and  more  than  2  billion 
Euros (see Table 5). Obviously, the total investment strongly depends on the technology used 

21 

AEA Technology: Status and Options for the reduction of noise emission from the existing European 
rail freight wagon fleet, January 2004. http://ec.europa.eu/transport/rail/studies/doc/aeat-final.pdf  

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and  the  question  if  wagons  built  between  1979  and  1984  are  included  in  the  retrofitting 
programmes.  

Table 5: Investment costs for different policy options  

Scenario 

Wagons to be retrofitted 

Total investment costs 

K  

SOV (1979) 

SOV (1984) 

DEV (1979) 

DEV (1984) 

K+LL  

SOV (1979) 

SOV (1984) 

DEV (1979) 

DEV (1984) 

320,000 

191,000 

270,000 

190,000 

397,400 

191,000 

372,000 

191,000 

2,240 M€  

1,337 M€ 

1,890 M€ 

1,330 M€ 

822 M€ 

542 M€ 

506 M€ 

260 M€ 

5.4.2.  Maintenance cost 

There  is  only  few  data  available  regarding  life  cycle  costs  of  K-blocks  (and  even  fewer  for 
LL-blocks). Therefore, the impact of retrofitting on maintenance costs can only be estimated. 
Some  experiences  from  RUs  or  WOs  show  no  impact  on  or  even  slightly  reduced 
maintenance  costs;  however,  others  observed  an  increase.  To  ensure  that  all  economic  risks 
related  to  retrofitting  are  covered,  conservative  assumptions  leading  to  an  increase  of 
maintenance costs have been made. 

As  considered  in  the  PWC  study,  the  life  cycle  costs  per  wagon  depend  mainly  on  the  life 
span of the wheel and brake blocks. Different researches suggest that composite brake blocks 
would lead to higher wheel wear (in comparison with cast iron blocks) but would show lower 
block wear in similar operating conditions. Following assumptions have been made: 

•  The  wheel  changing  rate  with  K-  and  LL-blocks  is  higher  than  for  cast  iron  blocks 

(350,000 km to wheel change compared to 480,000 km); 

•  For K- and LL-blocks more wheel reprofiling is required (230,000 km to wheel reprofiling 

instead of 350,000 km for cast iron blocks); 

•  The wear rate for K blocks is 3 times less than that of cast iron blocks; 

•  The wear rate for LL blocks is 4 times less than that of cast iron blocks (however, there is 

no full confirmation on the matter). 

This leads to a cost increase of 400 € per  100,000 wagon-km for K-blocks and 410 € for LL 
blocks, equivalent to 31% resp. 32%.  

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Table 6: Aggregated and discounted maintenance costs for different policy options  

Scenario 

Wagons to be retrofitted 

Discounted additional 
maintenance costs (2009-2024) 

K  

SOV (1979) 

SOV (1984) 

DEV (1979) 

DEV (1984) 

K+LL  

SOV (1979) 

SOV (1984) 

DEV (1979) 

DEV (1984) 

320,000 

191,000 

270,000 

190,000 

397,400 

191,000 

372,000 

191,000 

317 M€  

226 M€ 

238 M€ 

193 M€ 

406 M€ 

268 M€ 

347 M€ 

248 M€ 

Total  maintenance  costs  strongly  depend  on  the  number  of  wagons  retrofitting  and  to  less 
extend on the technology used as LL-blocks are according to the assumptions used likely to 
lead to slightly higher additional maintenance costs than K-blocks. 

5.4.3.  Administrative cost 

K-block  retrofitting  requires  tests  and  authorisation  procedures  for  retrofitted  wagons  to 
ensure safety as the braking characteristics of K-block are significantly different from those of 
cast iron blocks. The related costs – estimated at 400 € per wagon in average – are treated as 
part of the investment (see section 5.4.1). For the different K-block scenarios the total testing 
and authorisation costs are in the range of 76 to 128 M€.  

In  addition,  the  implementation  of  the  different  policy  options  will  lead  for  the  different 
stakeholders to added costs for the organisation, planning, development and management of 
the specific programmes and structures needed. 

Moreover,  the  different  policy  options  will  generate  the  need  (mainly  for  MS  and  IM)  to 
create specific monitoring programmes to follow and understand the real effectiveness of the 
wagon  owners’  retrofitting  programme  and  the  RUs’  performance  (in  case  of  operating 
restrictions or emission ceilings). 

Taking  into  account  the  above  assumptions  the  administrative  costs  have  been  estimated  in 
terms of: 

•  the total costs for added staff (measured as FTE, Full Time Equivalent) needed according to 

each policy option programme calculated as the sum over all 18 countries covered; 

•  specifically for the noise emission ceiling instrument (and the combined solution DEV), a 
noise  monitoring  system  capable  of  identifying  noisy  wagons/trains:  total  cost  for  the 
purchase,  installation  and  maintenance  of  several  noise  monitoring  stations  has  been 
considered.  

•  Assuming  a  unit  cost  of  €15,000  for  each  monito ring  station  and  a  total  number  of  160 
stations  (sum  of  stations  necessary  in  each  country,  estimated  on  the  basis  of  network 
complexity), it has been calculated for all 18 countries: 

–  a start up cost of 2,76 M€ (purchasin g, installation and SW development); 

–  a yearly cost for maintenance of 0,24 M€ 

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To set up and implement the policy options including the installation of a monitoring system 
for the option DEV leads – according to the study – to initial administrative costs of 6.1 M€ 
for SOV and 11.2 M€ for DEV (mainly investment). 

For the estimation of the ongoing administrative costs additional tasks regarding the financial 
transfers required, control and verification activities, additional tasks for the fleet management 
as well as maintenance of the monitoring system have been considered. The following table 
shows different figures for added ongoing administrative costs of each policy option: 

Table 7: Added ongoing administrative costs for different policy options  

Actor 

SOV - subsidy 

SOV – operating 
restrictions 

DEV – diff. access 
charges 

DEV – emission 
ceiling 

MS  

IM  

RU 

WO 

total 

1.6 M€ 

- 

Incl. in WO 

1.3 M€ 

2.9 M€ 

0.8 M€ 

3.6 M€ 

1.6 M€ 

- 

6.0 M€ 

- 

1.7 M€ 

0.6 M€ 

- 

1.6 M€ 

1.6 M€ 

- 

- 

2.3 M€ 

3.2 M€ 

For the policy option SOV, the ongoing administrative costs would be about 3 million Euros 
during  the  first  phase  when  subsidies  are  granted  and  subsequently after  the  introduction  of 
operating  restrictions  about  6  million  Euros.  The  costs  for  DEV  are  in  the  same  order  of 
magnitude,  2.3  million  Euros  in  the  first  phase  and  5.5  M€  after  the  introduction  of  the 
emission ceiling (total for ceiling and charges in case the differentiation of access charges will 
be continued). This can be confirmed by information provided by ProRail, the Dutch IM, that 
the current track access charge scheme is run by only two members of staff; a differentiation 
would not add much complexity as detection, monitoring and invoicing are fully automated. 

Overall,  with  the  exception  of  costs  of  testing  and  accepting  wagons  after  having  been 
retrofitted  with  K-blocks,  the  additional  administrative  costs  are  negligible  compared  to  the 
investment and maintenance costs of retrofitting. 

5.4.4.  Funding for the retrofitting programme 

The possible modal shift from rail to road due to retrofitting costs (see section 5.5.2), could be 
avoided by public funding. Therefore, both combinations of policy options contain measures 
to (party or fully) cover costs of retrofitting.  

For the policy option SOV it can be assumed that the funding needed is equivalent to 100% of 
total  investment  for  retrofitting  as  the  reimbursement  of  costs  would  be  done  based  on 
evidence provided by the RU or WO. Transaction costs are estimated as administrative costs 
in section 5.4.3. 

For the policy option DEV the calculation of the funding to be provided by public authorities 
is  more  complex  as  the  incentivising  mechanism  is  based  on  the  fact  that  RUs  will  benefit 
from a discount on the track access charges. These charges are currently imposed by each IM 
on  a  train-km  basis,  with  corrections  according  to  the  specific  situation  (e.g.  hour  of  day, 
passenger or freight train, etc.). According to the political address in the various EU countries 
regarding  financing  of  track  maintenance,  the  average  values  of  charge  per  train-km  vary 
from  country  to  country  (from  under  1  €/tr-km  to  about  10  €/tr-km).  Each  single  company 
will decide whether to retrofit and how many wagons to retrofit on the basis of its own cost-
benefit analysis. It will use a relatively high discount rate for this calculation (no less than 6%, 
probably 8% or 10%).  

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]

M

[

9
0
0
2
/
1

t
a

i

n
o
b
f
o
e
u
l
a
V

t
n
e
s
e
r
P

t
e
N

5000

4000

3000

2000

1000

0

DEV79 K (1/2011 - 12/2017)
DEV84 K (1/2011 - 12/2017)
DEV79 LL (1/2011 - 12/2014)
DEV84 LL (1/2011 - 12/2014)

K79

K84
LL79

LL84

0

0,01

0,02

0,03

0,04

0,05

0,06

0,07

European bonus value [€/w-km]

Figure 7: Net Present Values of costs and bonuses for the DEV scenarios  

Under  the  assumption  of  a  single  European  bonus  value  for  all  18  countries  considered,  a 
decision of the value to be taken should be based on the consideration that this value affects 
the following: The total amount of funding required by IMs from MS (total funding €) = (w-
km of low-noise wagons) × (bonus € / w-km).  Figure 7 shows the Net Present Value (NPV, 
basis: January 2009) of total bonuses transferred to RUs as a function of the European bonus 
value for different scenarios (retrofitting with K- or LL-blocks, limit birthdate 1979 / 1984), 
compared with the respective NPV of added costs for retrofitting. The intersections between 
the  horizontal  lines  representing  costs  and  the  other  lines,  representing  bonuses  transferred, 
indicate the values of European bonus value required to cover 100% of total costs. It can be 
seen that for all scenarios these values range roughly from 2 to 2.5 cents / w-km. 

However, these calculations only apply to a theoretical, fully homogenous fleet. In reality, the 
annual  mileage  of  wagons  and  the  individual  retrofitting  costs  are  individual  characteristics 
for  companies.  The  bonuses  calculated  for  the  fully  homogenous  fleet  are  no  sufficient 
incentives for many wagon owners to retrofit their fleet. To ensure a high retrofitting rate, the 
bonus  needs  to  be  higher  to  incentivise  even  owners  not  capable  of  running  high  mileages 
with their low-noise wagons and/ or with relatively high costs to retrofit their wagons. 

In Figure 8 the values of bonuses necessary to incentivise such owners have been calculated 
assuming average mileages of 10,000-20,000-30,000 km /year for their low-noise wagons and 
increments of unit costs  for  retrofitting of 50%-100%  respect  to  average.  The  time  required 
for complete return of investment has been taken as 8 years for retrofitting with K-blocks and 
4  years  for  retrofitting  with  LL-blocks.  A  sensitivity  analysis  to  this  parameter  is  shown  in 
Figure 9. 

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€
 
]

m
k
-
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/

[€

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m
k
-
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[€

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a
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n

i

0,20

0,15

0,10

0,05

0,00

DEV79K 50%

DEV79K 100%

DEV84K - 50%

DEV84K - 100%

K-blocks - return on 
investment in 8 years

]

m
k
-
w

/

[€

e
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a
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i

0,20

0,15

0,10

0,05

0,00

LL-blocks - return on 
investment in 4 years

DEV79LL - 50%

DEV79LL - 100%

DEV84K - 50%

DEV84LL - 100%

0

10000

20000

30000

40000

0

10000

20000

30000

40000

average mileage of LN wagons [km/year]

average mileage of LN wagons [km/year]

Figure 8: Bonus needed to incentivise retrofitting for owners under different conditions  

0,20

0,15

0,10

0,05

0,00

DEV79K 50%

DEV79K 100%
DEV84K - 50%

DEV84K - 100%

K-blocks - average 
mileage: 20,000 km/year

LL-blocks - average 
mileage: 20,000 km/year

DEV79LL - 50%

DEV79LL - 100%

DEV84LL - 50%

DEV84LL - 100%

]

m
k
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[€

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0,20

0,15

0,10

0,05

0,00

0

2

4

6

8

10

0

2

4

6

8

10

time for return on investment [years]

time for return on investment [years]

Figure 9: Sensitivity of the incentivising bonus value to the time for return on investment 

These calculations lead to values for the bonus in the range of 3 – 9 cents/ w-km according to 
the scenario, provided that all companies are capable of reaching 20,000 km / year on average 
for their low-noise wagons. However, for K-blocks there are serious doubts if the necessary 
incentives can be granted for wagons with an annual mileage of 10,000 km that – according to 
the objectives of this initiative – be covered by the retrofitting programmes. 

If bonuses were granted in this order of magnitude the total funding required to incentivise all 
or almost all wagon owners to retrofit would be about 25 to 85% higher than the total costs of 
retrofitting.  To  avoid  such  “overincentives”  or  subsidies  to  RUs  and  WOs,  the  aggregated 
bonus  for  a  silent  wagon  needs  to  be  limited  to  the  retrofitting  costs.  However,  the  exact 
determination of these values is difficult. Therefore, the funds to be provided by the Member 
States are estimated to be about 20% higher than the costs. This leads to following figures for 
the funding required for the different scenarios: 

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Table 8: Required funding for different policy options  

Scenario  Wagons to be retrofitted 

Total investment 

Required funding 

K  

SOV (1979) 

SOV (1984) 

DEV (1979) 

DEV (1984) 

K+LL  

SOV (1979) 

SOV (1984) 

DEV (1979) 

DEV (1984) 

320,000 

191,000 

270,000 

190,000 

397,400 

191,000 

372,000 

191,000 

2,240 M€  

1,337 M€ 

1,890 M€ 

1,330 M€ 

822 M€ 

542 M€ 

506 M€ 

260 M€ 

2,240 M€ 

1,337 M€ 

2,268 M€ 

1,596 M€ 

822 M€ 

542 M€ 

607 M€ 

312 M€ 

5.4.5.  Reduced investment for infrastructure-related noise abatement programme 

The  retrofitting  programme  connected  with  the  SOV  and  DEV  options  could  allow  the 
reduction of infrastructure investment for noise reduction (for instance for noise barriers by a 
percentage  of  programme  and/or  of  total  costs).  In  fact  many  areas  in  which  population  is 
subjected  to  noise  exceeding  national  limits  would  benefit  from  a  decrease  in  rolling  noise 
due to freight wagons which could in principle lead to noise returning within legal limits, thus 
avoiding infrastructure-related measures. This of course depends on the relative importance of 
the other sources of rail noise (squeal-, traction-, aerodynamic-, pantograph- noise etc.). 

However, it is important to consider that:  

•  to have a higher benefit of noise abatement, a high fraction of the fleet needs to be silent; 
considering this assumption, a transient period before retrofitting reduces rail noise has to 
be managed (for instance until 2014 or 2015); 

•  decisions  on  infrastructure-related  measures  are  often  taken  at  a  different  political  level 
(national, regional or even local) leading to difficulties of co-ordinating these programmes 
with retrofitting activities; 

•  investment  structures  are  “rigid”  and  there  are  difficulties  in  changing  scheduled 
investments (or eventually in shifting budget from IM to RU or WO); there are many long-
period programmes that cannot be rescheduled or reorganised in the mid-term; a reduction 
in investments has been assumed possible only after 5-10 years; 

•  infrastructure  investments  solve  problems  that  are  not  only  related  to  rolling  noise  of 

freight wagons running at night (such as noise emissions of passenger trains). 

Moreover  it  is  very  difficult  to  estimate  the  total  reduction  for  infrastructure-related  noise 
abatement costs and so far, no robust data is available. 

Nevertheless, an order of magnitude can be estimated on the basis of the results of the EU-
funded  research  project  STAIRRS22  which  demonstrated  that  the  same  order  of  benefits  in 
terms  of  affected  population  can  be  achieved  with  infrastructure-related  noise  abatement 
measures at costs of 2 to 4 times higher than those for retrofitting with K-blocks. 

This  impact  assessment  has  estimated  costs  for  retrofitting  with  K-blocks  of  approximately 
2,000  M€  (assuming  1979  as  the  limit  birthdate).  Th e  same  results  would  be  obtained  with 

22 

http://www.stairrs.org/ 

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investments  in  infrastructure-related  measures  of  4,000  –  8,000  M€,  leading  to  savings  for 
Member  States  in  the  order  of  2,000  –  6,000  M€  ove r  the  time-frame  considered  here.  It  is 
interesting  to  compare  these  figures  with  the  estimates  from  the  UIC  status  report23  which 
considers a value of up to 10,000 M€ in infrastruc ture-related measures investments. Of these, 
according  to  the  above  calculation  4,000  –  8,000  M€  would  be  saved,  leading  to  total 
expenses  of  2,000  –  6,000  M€  for  infrastruc ture-related  measures  plus  2,000  M€  for 
retrofitting. 

To summarise, based on the findings of the STAIRRS project and on the estimates of the UIC 
status  report  savings  due  to  a  retrofitting  programme  would  amount  to  approx.  2,000-6,000 
M€  (for  the  K-block  scenario s)  and  3,000-7,500  M€  in  case  of  LL-block  retrofitting.  But 
again,  these  figures  are  purely  theoretical  of  the  above  reasons.  Regarding  the  two  policy 
options,  the  differences  in  impact  on  reduced  investment  for  infrastructure-related  noise 
abatement programme are not significant. 

5.4.6.  Reduced investment cost for renewal of fleet 

Over  the  past  decades,  the  number  of  freight  wagons  in  Europe  has  decreased  while  the 
transport  performance  in  tkm  remained  about  stable.  Even  in  very  recent  years  when  rail 
freight  started  to  grow  the  trend  towards  smaller  fleets  continued.  This  phenomenon  could 
easily explained by the average mileage of wagons in Europe of about 20,000 km/a, much less 
than e.g. in the road sector. Therefore, it has been assumed for this impact assessment that this 
trend  will  continue  and  in  average  25,000  wagons  will  be  put  out  of  service  per  year  while 
20,000 new ones will be purchased. This leads to avoided annual investment costs of 450 M€ 
(assuming 90,000 € per wagon). 

Since  differentiated  track  access  charges  offer  the  possibility  of  higher  bonuses  if  higher 
mileages  are  run,  the  DEV  option  may  stimulate  an  improvement  of  fleet  management  in 
terms of know-how on how to obtain high average mileages for a part of the fleet or even the 
whole fleet. This would boost the impacts described above. However, this impact is extremely 
difficult to quantify. If a 10% contribution of differentiated track access charges to the overall 
efficiency gain was assumed, the economic benefit would be 45 M€ per year.  

For SOV, there are no strong economic incentives to support the development towards higher 
efficiency of wagon use. 

5.4.7.  Reduced maintenance costs for infrastructure 

Due  to  the  higher  wheel  wear  caused  by  composite  brake  blocks  (the  wheel  surface  is 
polished),  it  has  been  observed  that  the  number  of  wheel  defects  is  reduced  for  low-noise 
wagons (in particular wheel flats, cracks and wear of profile according to experiences of the 
Dutch  noise  innovation  programme)24.  This  high  quality  of  wheel  surfaces  has  a  positive 
impact  on  the  rail  and,  due  to  less  rail  wear,  infrastructure  maintenance  costs  are  reduced. 
However, the quantification of this impact is not yet possible. 

A  similar  effect  has  been  observed  in  The  Netherlands  after  the  introduction  of  the  wheel 
monitoring  system  Quo  vadis/  Gotcha  leading  the  a  decrease  of  infrastructure  maintenance 
costs by 5 to 10%25.  

23 

24 

25 

UIC: Noise Reduction in European Railway Infrastructure. Status Report 2007.  
http://www.uic.asso.fr/download.php/environnement/reductionbruitinfra_en.pdf 
J. Peen: Whispering Trains - Noise reduction on Freight Wagons. Presentation at the UIC Noise   
Workshop November 2007. http://www.innovatieprogrammageluid.nl/GBpage.asp?id=1054 
Lloyd’s Register Rail Europe: Project summaries; 
http://www.gotchamonitoringsystems.com/pdf/References.pdf 

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Therefore, it can be assumed that the implementation of retrofitting programmes would result 
in savings for IMs. These savings could be used to reduce the track access charges for silent 
wagons accordingly. 

5.4.8.  Competition within the rail sector 

The costs for retrofitting are most probably not equally distributed among the RUs and WOs. 
At  least  for  K-block  retrofitting,  large  WOs  and  RUs  (in  particular  incumbent  operators) 
could benefits from economies of scale, when purchasing supplies and in particular by lower 
tests costs as tests are required per wagon type. This could be a competitive disadvantage for 
newcomers on the rail freight markets. 

Policy  option  DEV  incentivises  a  high  mileage  of  wagons  (see  section  5.4.6).  This  gives  a 
clear competitive advantage to private WO and new RUs as these companies use approaches 
for  fleet  management  different  from  the  ones  applied  by  incumbents  resulting  in  annual 
mileage of in some cases more than 100,000 km. 

Certainly,  these  effects  are  very  difficult  to  quantify.  Overall,  the  impact  on  competition 
within  the  rail  freight  sector  is  rather  limited  even  if  policy  option  DEV  provides  some 
advantages for small RUs and private WOs. 

5.4.9. 

Influence of restrictions for noisy wagons on non-EU countries 

The  non-EU  States  whose  wagons  can  run  on  the  networks  of  the  18  countries  considered 
(Balkan  countries,  Switzerland  and  Norway)  account  for  just  over  4%  of  the  total  fleet.  In 
Switzerland a retrofitting programme is ongoing will be completed by 2015. The other States 
may  be  incentivised  to  retrofit  their  wagons  with  the  DEV  option,  due  to  the  access  charge 
bonus. However, an agreement on their voluntary commitment would be appropriate.  

A  voluntary  commitment  by  these  countries  to  provide  financial  support  for  retrofitting  of 
wagons  registered  in  these  countries  is  essential  for  the  SOV  option  in  order  to  provide  the 
necessary incentives. 

5.5. 

Environmental impacts 

5.5.1.  Reduction of sound pressure levels 

As the noise reduction for K- and LL-blocks is at the same level (8 dB are assumed for this 
impact assessment, the total average noise reduction achieved by retrofitting only depends on 
two  factors,  the  number  of  vehicles  retrofitted  and  the  time  when  retrofitting  takes  places. 
Figure 10 and Figure 11 show the noise reduction over the time of the different policy options 
and scenarios compared to the status quo option. Certainly, the particular situation at specific 
railway  lines  could  deviate  from  the  average  development  according  to  the  traffic 
development and the rolling stock used. 

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Figure 10: Noise reduction under scenarios K  

Figure 11: Noise reduction under scenarios K+LL  

Obviously,  the  level  of  noise  reduction  achieved  is  the  same  for  all  options  including  the 
status quo. The only differences are the time when is reductions can be realised and the noise 
reduction level in the course of the retrofitting programme. 

According  to  the  calculations,  the  maximum  noise  reduction  is  earlier  achieved  by  the  LL-
block scenarios of option SOV 79 and DEV 79 (silent fleet by 2013 resp. 2014) followed by 
the K-block based scenarios of the same policy options (full reduction by 2016 resp. 2018). 
Regarding  the  noise  reduction,  retrofitting  the  wagons  with  a  birthdate  between  1979  and 
1984 shortens the time until a full reduction is obtained.  

5.5.2. 

Influence on the modal split between rail and road (environmental effects) 

In  accordance  with  the  assumptions  of  this  impact  assessment,  RUs  or  WOs  will  have  an 
added  cost  because  of  the  retrofitting  programme  and  incremental  maintenance  costs.  To 

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cover this maintenance cost increase, unless adequately funded, RUs will apply a proportional 
increase  to  the  final  customer  for  the  rail  transportation  services.  These  considerations  fully 
apply for the policy option SOV, as only the initial investment can be covered by subsidies. 
For DEV, these costs could be considered for the calculation of the bonus for silent wagons. 

According to the main literature, price changes often affect consumer decisions and transport 
activities  tend  to  follow  this  pattern.  This  has  been  considered  through  the  elasticity  of  the 
demand  related  to  the  price  change.  Even  if  the  elasticity  could  vary  over  a  wide  range 
depending  on  the  type  of  freight  and  the  commodity  group,  it  is  calculated  that  this  value 
could range between -0.25 and -0.3526. Within the analysis -0.35 level has been considered (as 
the worst case): this means that a 10% cost/price increase of the rail transport service reduces 
rail traffic by 3.5%. 

The  following  table  shows  different  rail  traffic  decreases  according  to  different  levels  of 
incentives for policy option SOV (K brake block scenario, 1984 as wagon limit birthdate). 

Table 9: Estimated transport price increase and modal (K, SOV, limit birthdate: 1984) 

Level of 
incentive 27 

Total Price Increase 
(€/tr-km) 

Average increase 
in pricing (%) 

Expected rail 
traffic decrease (%) 

Expected rail traffic 
decrease (mio tkm) 

No Subsidies 

50% of costs 

75% of costs 

100% of costs 

0.20 

0.10 

0.06 

0.01 

1.09% 

0.57% 

0.31% 

0.05% 

0.40% 

0.21% 

0.11% 

0.02% 

4,035 

2,115 

1,155 

196 

Rail demand reduction has to be satisfied by alternative modes of transport. So it is probable 
that the variation in rail demand could be followed by an increase in road transport demand. 
According  with  the  last  assumption,  a  cross-elasticity  has  been  considered  to  figure  the 
variation of road traffic demand corresponding to variations in rail transport demand.  

Accordingly,  total  modal  shift  towards  road  traffic  will  be  between  0.02%  and  0.4%  of  the 
total rail demand, equivalent to 200 million tkm (in case of incentives covering 100% of the 
costs of the retrofitting programme) resp. 4 billion tkm (in case of no incentives) according to 
the different scenarios within policy option SOV. For DEV, these values are lower or even 0 
if a bonus covering additional maintenance costs is sustained after the end of the retrofitting 
period.  

Based  on  these  calculations  emission  factors  for  the  most  significant  pollutants  (CO2,  NOx, 
PM)  have  been  applied  to  the  estimated  increase  of  road  traffic  in  order  to  estimate 
environmental costs. The emission factors are derived from the TREMOVE database28.  

The following table shows different net effects of increased emission (due to the increase of 
road traffic) and reduction of emission (due to reduction of rail traffic) in case of the lack of 
financial  support  for  retrofitting.  Similar  calculations  could  be  carried  out  for  road  traffic 
noise and fatal accidents. 

26 

27 
28 

Victoria Transport Policy Institute (http://www.vtpi.org/tdm/); RMH Breugem, DP van Vuuren, B van 
Wee, “Comparison of global passenger transport models and available literature” 
The incentive considers only the cost of the retrofitting programme. 
TREMOVE is a policy assessment tool developed by KU Leuven for the European Commission, DG 
Environment (http://www.tremove.org/) 

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Table 10: Estimated environmental impacts of a price increase of rail transport (K-blocks, 
limit birthdate: 1984) 

Increase of emission due to 
the increase of road traffic 

Emission reduction due to 
the reduction of rail traffic 

Net effect (no 
funding) 

Net effect 
(SOV) 

NOx 

PM 10 

CO2 

+2,998 t/y 

+75 t/y 

+282 Mt/y 

-483 t/y 

-29 t/y 

+2,515 t/y 

+126 t/y 

+45 t/y 

+2 t/y 

-27 Mt/y 

+254 Mt/y 

+13 Mt/y 

The  total  increase  in  road  transport  emissions  is  much  higher  than  the  reduction  of  air 
pollutants  and  greenhouse  gases  expected  as  result  of  rail  traffic  decrease.  In  case  of  full 
financial support for the investment costs related to retrofitting (according to the option SOV), 
the figures for the net increase of emissions are significantly lower. 

Concerning the savings of investment costs for the rail sector (see section 5.4.6), a decrease of 
transport  prices  and  subsequently  an  increased  demand  for  rail  transport  could  e  expected 
(modal  shift  from  road  to  rail).  Based  on  the  rough  estimation  of  45  M€  annual  saving  for 
DEV,  the  average  price  decrease  would  be  0.15%  and  the  rail  traffic  increase  0.06% 
equivalent  to  about  600 mio tkm.  This  effect  would  result  in  environmental  net  benefits  of 
about 400 t NOx, 8 t PM-10 and 38 Mt CO2 less emitted per year. 

Overall, the environmental impact of a possible modal shift is difficult to quantify and very 
likely to be insignificant provided that retrofitting will be at least partly supported (directly or 
indirectly)  by  public  funds.  For  DEV,  the  overall  impact  could  be  positive  or  negative,  for 
SOV a negative impact is more likely. As K-block retrofitting is more expensive, the risk of 
modal shift towards road is higher for the K-block based scenarios. 

5.5.3.  Traction energy saving due to reduced weight of brake blocks 

The replacement of cast iron brake blocks by K- or LL-blocks leads to a weight reduction of 
wagons as K-blocks and organic LL-block are significantly lighter (less than 50% of the mass 
of cast iron blocks). For sinter LL blocks, this reduction is less significant. 

Assuming an average  reduction of  125 kg per wagon and a specific energy consumption of 
20 Wh per tkm for relatively fast, long-distance freight with electric traction, the total savings 
are about 50 kWh per year and wagon resp. in the range of 10 to 20 to GWh, equivalent to the 
electricity consumption of 3,000 to 6,000 average households. 

The  relative  reduction  of  traction  energy  consumption  of  rail  freight  is  less  than  0.1%; 
however, savings of 5 to 10 Mt CO2 emission and 1.1 – 2.4 M€ can  be expected (depending 
on  the  number  of  wagons  retrofitted  according  to  the  policy  options  and  scenarios).  The 
environmental impact of this effect is in the same order of magnitude as the one of a possible 
modal shift under option SOV. 

5.5.4.  Reduced risk of forest fires 

This issue has proved to be relevant in Portugal. In this country the use of composite brake 
blocks  (LL  blocks  for  freight  wagons)  has  been  stimulated  among  other  reasons  in  order  to 
reduce  the  occurrence  of  bush  fires.  Although  not  a  decisive  impact,  it  may  have  certain 
relevance in terms of savings for Member States in the countries of Southern Europe which 
add to the other benefits of retrofitting wagons with composite blocks. 

The  reduction  of  the  risk  of  forest  fires  is  directly  linked  to  the  number  of  vehicles  to  be 
retrofitting and the timing of retrofitting. Therefore, the difference between the policy options 

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DEV and SOV are limited. More important are the technology used (K- or LL-blocks) and the 
decision whether the wagons built between 1979 and 1984 are retrofitted or not. 

5.6. 

Social impacts 

5.6.1.  Reduction of affected population 

Reduction of number of people affected 

The  reduction  of  the  population  affected  by  rail  noise  is  calculated  based  on  the  noise 
emission reduction and data/ assumption on the distribution of citizens along main rail lines. 
Unfortunately, the results of the noise mapping exercise according Directive 2002/49/EC have 
not been available for this impact assessment. 

Therefore,  older  existing  information  has  been  used.  Due  to  the  importance  of  affected 
population data and to the lack of specific information, two different data bases for affected 
population have been identified for the purpose of the impact assessment, in particular: 

•  population  calculated  on  the  basis  of  data  from  Entec  report  for  DG-ENV  (2006):  these 
figures estimating the number of people exposed to levels above 65 dB Lden derived from 
calculations  on  the  density  of  rail-noise-affected  population  reported  in  a  document  for 
DG-ENV by Entec UK Ltd and represent rail noise hot spots in Europe;  

•  population  according  to  the  INFRAS-IWW  report  (2004)29:  the  reduction  of  affected 
population  is  calculated  assuming  that  noise  exposure  levels  are  reduced  by  the  same 
amount as noise emitted (approximation), that 80% of the population affected by rail noise 
are  affected  by  rail  freight  noise  only  (and  20%  by  passenger  rail  noise  only)  and  that 
population  is  distributed  according  to  levels  of  noise  discretised  into  1  dB  intervals  (the 
discretisation  leads  to  the  particular  shape  of  the  benefit  curves).  This  study  uses  55 dB 
Lden as threshold for the estimation of the number of people exposed. 

As  Directive  2002/49/EC  retains  55 dB  Lden  as  criterion,  only  estimates  based  on  the 
INFRAS-IWW report are used for this impact assessment. 

The  following  charts  illustrate  the  effects  of  the  different  policy  options  on  the  achievable 
reduction of the affected population figures. 

29 

Infras, IWW: External costs of transport – update study 2004.  
http://www.uic.asso.fr/html/environnement/cd_external/docs/externalcosts_en.pdf 

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37 

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Figure 12: Reduction of affected population, K-scenario  

Figure 13: Reduction of affected population, K+LL-scenario  

The  reduction  of  number  of  persons  affected  by  railway  noise  is  the  same  for  all  options 
including  the  status  quo.  According  to  the  INFRA-IWW  method  used,  about  16.5  million 
citizens would benefits from retrofitting as the noise level they are exposed to will fall under 
55 dB.  

Regarding the comparison of policy options and scenarios, the considerations made in section 
5.5.1 also apply to the reduction of the number of persons affected. 

Reduction of health effects 

The reduction of the levels of exposure of the population to rail noise leads to a reduction of 
health  effects.  Recent  projects  show  that  these  can  be  quite  significant.  For  example  the 
World  Health  Organisation  (WHO)  is  coordinating  the  EBD  (Environmental  Burden  of 

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38 

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Disease)  noise  project  on  guidelines  for  the  estimation  of  the  disease  burden  generated  by 
environmental noise30. The health effects investigated in the project are: 

–  Cardiovascular disease; 

–  Sleep disturbance; 

–  Annoyance; 

–  Tinnitus; 

–  Cognitive impairment; 

–  Hearing loss. 

The policies presented in this impact assessment certainly lead to the beneficial effects listed 
above. However, such benefits are currently difficult to quantify and the results have a high 
level of uncertainty. The estimates are based on the amount of population no longer exposed 
to rail freight noise as well as on dose-effect relationships (for details see PWC study). As a 
result, the reduction of number of persons subject to annoyance and sleep disturbance due to 
rail  freight  noise  is  estimated  at  the  beginning  and  end  of  the  retrofitting  programmes.  This 
year varies according to the policy option (see section 5.2).  

Table 11: Estimates of the persons subjected to different levels of annoyance and sleep 
disturbance  

millions of persons affected 

Impact 

2009  End of retrofitting  ∆ [%] 

High annoyance 

Annoyance 

High sleep disturbance 

Sleep disturbance 

Low sleep disturbance 

5.3 

6.9 

1.6 

3.7 

7.3 

1.7 

2.6 

0.5 

1.3 

2.6 

-69% 

-67% 

-67% 

-66% 

-65% 

According  to  these  estimates  a  reduction  of  65  –  70  %  of  annoyed  and  highly  annoyed 
persons is expected respect to the initial situation once the whole fleet is composed of low-
noise wagons. Similarly, a reduction of 65 – 70% of persons subject to sleep disturbance is 
expected.  

Monetisation  

The  monetary  quantification  carried  out  in  this  impact  assessment  of  the  benefits  deriving 
from  the  reductions  in  persons  affected  and  sound  pressure  levels  is  thus  purely  indicative. 
However, interesting conclusions can be drawn from the comparison of costs and the benefits 
thus calculated. 

The  monetary  value  attributed  to  the  noise  reduction  benefits  has  been  determined 
intentionally  a  simple  way,  taking  into  account  the  values  available  in  literature  concerning 
annoyance  and  sleep  disturbance.  Recent  studies  showed  that  significant  health  effects  may 
arise from exposure to noise. In order to keep the analysis simple, a value of 10 € per dB and 
person  and  year  has  been  applied  verified  by  a  sensitivity  analysis  (see  PWC  study  for 
details). 

30 

http://www.who.int/quantifying_ehimpacts/national/en/ 

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Table 12: Monetised benefits for the affected population for different policy options  

K 

K+LL 

Scenario 

SOV (1979) 

SOV (1984) 

DEV (1979) 

DEV (1984) 

SOV (1979) 

SOV (1984) 

DEV (1979) 

DEV (1984) 

Benefit  

7,100 M€ 

4,100 M€ 

5,800 M€ 

4,400 M€ 

9,500 M€ 

4,400 M€ 

8,400 M€ 

5,200 M€ 

Obviously,  the  monetised  benefits  are  related  to  the  reduction  of  the  number  of  people 
affected.  The  highest  benefits  are  expected  for  the  options  SOV  1979  and  DEV  1979  when 
LL  blocks  are  used.  The  related  scenario  with  1984  as  limit  birthdate  shows  significantly 
lower benefits. The monetised benefits of SOV scenarios are in general slightly higher than 
those of the DEV scenarios. 

5.6.2.  Reduction of weight handled 

Low-noise  brake  blocks  are  made  of  composite  materials  resulting  in  substantially  lighter 
blocks compared with cast iron blocks (typical cast iron block mass: 13 kg, typical composite 
block mass: 4-8 kg).So K- and LL-blocks are easier and safer to handle. 

This  leads  to  a  positive  impact  on  health  of  maintenance  workers  as  the  number  of  back 
problems will decrease. This impact is not decisive in terms of the choice between the SOV 
and  DEV  options.  However,  policy  options  leading  to  fast  retrofitting  of  a  high  number  of 
vehicles, in particular SOV 1979 and DEV 1979 using LL-blocks provide the highest positive 
impact. 

5.6.3. 

Increased transparency 

The  implementation  of  some  instruments  connected  with  the  different  policy  options  for 
retrofitting can lead to the availability of data on noise reduction that would not otherwise be 
gathered just on the basis of the European Noise Directive. This is true in particular for Noise 
Emission Ceilings if these are enforced on the basis of measurements. 

5.6.4. 

Social impacts in non-EU countries 

Non-EU countries with 1435 mm rail systems would benefit from the retrofitting programmes 
implemented in EU Member States. The extent of the reduction of number of people affected 
by rail noise strongly depends of national retrofitting programmes in additional to the ones of 
EU Member States and is therefore not quantified in this impact assessment. 

Nevertheless, assuming that the share of silent wagons going to these countries is the same as 
on the territory of the EU Member States, up to 1 million citizens would benefit from noise 
emission  reductions  under  the  threshold  of  55  dB  (according  to  the  results  of  the  INFRAS-
IWW report, see section 5.6.1).  

5.7. 

Sensitivity analyses 

For some main parameters or assumptions, sensitivity analyses have been carried out and the 
results are briefly presented in the following. More details are described in the PWC study.  

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40 

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Date of full availability of LL-blocks  

For the calculation of costs and benefits of retrofitting, it has been assumed for the scenario 
"K+LL" that LL-blocks will be fully homologated in January 2011.  

Assuming an earlier  availability  for  policy option SOV (as for DEV, the implementation of 
the differentiated track access charges has been identified as the time-critical step) costs and 
benefits would change as follows: 

•  The  implementation  of  the  retrofitting  programme  with  LL-  instead  of  K-blocks  for  the 
first  years  permits  a  cost  decrease  of  roughly  17%  (1979  birthdate)  and  29%  (1984 
birthdate) respect to the "K+LL" scenario (see Figure 14); 

•  Due to a higher retrofitting  rate,  the number  of silent wagons in the first years would be 
higher and therefore, the benefit regarding the reduction of number of people affected by 
noise would increase by at least 10%. 

Therefore,  it  can  be  concluded  that  the  availability  of  LL-blocks  is  a  crucial  issue  for  both, 
costs and benefits of retrofitting. 

SOV

-17%-17%

-29%-29%

1,22

0,84

1,02

0,60

2,25

1,41

3

2,5

2

1,5

1

0,5

0

K

K+LL

LL

1979

1984

Figure 14: Total costs of retrofitting for policy option SOV and different technologies used 

Maintenance costs 

A variation of parameters determining maintenance costs leads to a range of –200 € to +3000 
€  additional  annual  costs.  Obviously,  the  im pact  on  maintenance  costs  is  wagon-  and 
company specific. Unfortunately, there are no exact figures available today. However, it can 
be concluded that there is at least a risk of additional costs. Therefore, financial support seems 
to be needed to provide the necessary incentives. 

However,  there  is  a  potential  for  savings  as  two  examples  of  retrofitting  programmes  for 
freight wagons in Europe show that at least cost-neutral solutions are technical feasible: 

•  In  the  United  Kingdom,  80%  of  the  freight  wagons  are  equipped  with  disc  brakes  or  K-
blocks.  Some  vehicles  have  been  retrofitted  with  K-blocks,  for  economic  reasons  as  the 
life-cycle costs are lower. K-blocks produced in the USA are used, for which purchasing 
costs are about 25% lower than of the UIC homologated European K-blocks31. 

•  In  Portugal,  the  freight  fleet  of  about  4,000  wagons  has  been  retrofitted  with  LL-blocks 
(ICER  T903  and  JURID  833)  in  1997  and  in  addition,  passenger  carriages  have  been 

31 

Oral information received from Mr C. Carr, Department of Transport, UK 

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41 

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equipped with L-blocks. The costs were borne by CP, the incumbent operator. Since then, 
no technical problems occurred and life-cycle costs decreased32. 

To  make  best  use  of  this  potential,  policy  options  providing  incentives  for  such  cost 
reductions are needed, DEV does provide such incentives.  

Main risks of the two policy options regarding the implementation 

The  option  SOV  is  based  on  the  assumption  of  subsidies  covering  100%  of  the  initial 
investment.  There  are  no  experiences  with  state  aids  for  rail  noise  abatement  measures  for 
rolling  stock.  However,  according  to  the  draft  state  aid  guidelines  for  railways33,  a  funding 
rate  of  50%  is  regarded  as  proportionate  for  such  cases.  Above  these  thresholds  Member 
States must demonstrate the need and proportionality of the measures in question. 

It can be concluded that the subsidy component of policy option SOV might be a weak point 
regarding its legal compliance. Funding rates significantly below 100% risk to be ineffective 
(RUs and WOs do not make use of the subsidy scheme and do not retrofit) or to lead to high 
financial  burdens  for  railways  if  retrofitting  is  implemented  (e.g.  to  avoid  operating 
restrictions as part of SOV). 

For policy option DEV, individual approaches at national level would risk not being effective 
as the incentive for railway undertakings might not be sufficient if only some Member States 
introduced a bonus (as a critical mass is needed to provide sufficiently incentives to European 
RUs/WOs),  the  timeframes  were  contradictory  and  different  types  of  silent  wagons  were 
treated differently.  Furthermore, administrative  costs for non-harmonised schemes  would be 
unnecessarily  high.  Therefore,  the  common  and  simultaneous  implementation  of  this 
instrument  leading  to  the  necessary  incentives  for  retrofitting  needs  to  be  ensured  and  the 
harmonisation  at  European  level  is  crucial  for  the  success  of  differentiated  track  access 
charges.  

Beside  the  harmonisation  of  the  main  elements  of  charging  schemes,  the  development  of  a 
common  classification  system  for  wagons  and  their  noise  emission,  of  appropriate 
identification systems and registers are needed. 

As  far  as  the  identification  of  wagons  is  concerned,  appropriate  systems  are  under 
development  or  in  some  case  already  implemented.  They  will  allow  identifying  and  tracing 
wagons  running  on  the  network.  The  costs  of  such  systems  have  been  assessed  in  section 
5.4.3 concluding that total costs for installation and maintenance are in the order of magnitude 
of some millions of euros, significantly less than the direct costs of retrofitting.  

Classification  systems  need  to  be  developed  but  this  does  not  seem  to  be  to  complicated  as 
even simple schemes would be appropriate if harmonised at European level. 

National  vehicle  registers  already  exist  and  allow  the  integration  of  information  on  noise 
emissions of wagons. At European level the European Railway Agency currently develops a 
central register connecting the national registers. 

32 
33 

Written information received from Mr. P. Ferrão, CP (Portuguese Railways) 

Currently under development, see:  
http://ec.europa.eu/dgs/energy_transport/state_aid/consultation_ms_en.htm 

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6. 

COMPARING THE OPTIONS 

Both,  policy  options  DEV  and  SOV  could  be  effective  in  achieving  the  objective  of  noise 
reduction  as  defined  in  section  3.  97%  of  the  axle-km  performed  by  silent  wagons  resp.  all 
wagons  with  an  annual  mileage  of  at  least  10,000 km  would  be  archived  at  the  earliest  by 
2013 for policy option SOV and by 2014 for DEV (both in the case of LL-block retrofitting). 

Table  13  summarises  the  costs  of  retrofitting  programmes,  added  maintenance  and 
administrative  costs  as  well  as  total  noise  reduction  benefits  in  the  different  scenarios.  All 
values  are  expressed  in  monetary  terms  and  are  referred  to  the  period  2010-2024.  The  net 
benefits, i.e. total benefits – total added costs, are calculated. It is important to note that this 
net benefit does not take into account the incentivation margin and some additional economic, 
environmental  and  social  benefits,  which  could  not  be  determined  quantitatively  (such  as 
savings in investment costs for rolling stock and in maintenance costs for the infrastructure). 
The qualitatively assessed impacts are summarised in Table 14. 

Table 13: Overview of monetised impacts of the policy options and scenarios 

Impact  

Limit 
birthdate 

K (2009 – 2024) 

K+LL (2009 – 2024) 

Investment cost for retrofitting 
programme  

Added maintenance costs  

Added administrative costs for new 
tasks 

TOTAL ADDED COST 

Added BENEFIT on affected 
population  

TOTAL NET VALUE  

SOV 

DEV 

SOV 

1,847 M€ 

1,441 M€ 

728 M€ 

1,102 M€ 

1,018 M€ 

 488 M€ 

 317 M€ 

 238 M€ 

 406 M€ 

 226 M€ 

 193 M€ 

268 M€ 

DEV 

416 M€ 

214 M€ 

347 M€ 

248 M€ 

85 M€ 

93 M€ 

85 M€ 

93 M€ 

2,249 M€ 

1,772 M€ 

1,219 M€ 

1,413 M€ 

1,304 M€ 

 841 M€ 

856 M€ 

555 M€ 

7,071 M€ 

5,762 M€ 

9,460 M€ 

8,428 M€ 

4,133 M€ 

4,385 M€ 

4,450 M€ 

5,208 M€ 

4,822 M€ 

3,990 M€ 

8,241 M€ 

7,572 M€ 

2,720 M€ 

3,081 M€ 

3,609 M€ 

4,653 M€ 

1979 

1984 

1979 

1984 

1979 

1984 

1979 

1984 

1979 

1984 

1979 

1984 

Finally, the following figure shows the total benefit/cost ratio for each scenario (K and K+LL) 
and for different wagon limit birthdates (1979 and 1984). Again, the incentivation margin and 
the additional benefits are not included. 

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43 

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o
i
t
a
r
-
s
t
s
o
c
-
s
t
i
f
e
n
e
B

10

9

8

7

6

5

4

3

2

1

0

SOV 79
(K)

SOV 84
(K)

DEV 79
(K)

DEV 84
(K)

SOV 79
(K+LL)

SOV 84
(K+LL)

DEV 79
(LL)

DEV 84
(LL)

Figure 15: Benefits-costs-ratios for the policy options and scenarios 

Table 14: Overview of impacts assessed qualitatively 

Impact 

K 

K+LL 

Reduced infrastructure-related 
noise abatement programmes 

Reduced investment in new wagons 

Reduced maintenance costs for 
infrastructure 

Impact on competition within the 
rail sector 
Restrictions for 3rd country wagons 

Environm. impacts of modal shift  

Energy savings (weight reduction) 

Reduced risk of forest fires 
Reduced noise in 3rd countries 

Reduction of weight handled 

Increased transparency 

SOV 

++ 

DEV 

++ 

SOV 

++ 

DEV 

++ 

0 

+ 

- 

- 

- 

+ 

+ 

+ 

+ 

0 

+ 

+ 

0 

0 

- 

+ 

+ 

+ 

+ 

+ 

0 

+ 

0 

- 

- 

+ 

+ 

+ 

+ 

0 

+ 

+ 

0 

0 

0 

+ 

+ 

+ 

+ 

+ 

Explanation:  ++:  very  positive  impact;  +:  positive  impact;  0:  no  significant  positive  or 

negative impact; -: negative impact; --: very negative impact 

The  results  of  the  cost-benefit  calculation  show  for  all  scenarios  considerable  net  benefits. 
Furthermore,  it  needs  to  be  underlined  that  major  benefits  of  retrofitting  could  not  be 

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quantified  and  monetised  such  as  the  savings  due  to  reduced  infrastructure-related  noise 
abatement  programmes,  reduced  maintenance  costs  for  the  rail  infrastructure  and  efficiency 
gains  in  fleet  management.  These  benefits  have  the  potential  to  be  of  the  same  order  of 
magnitude as the costs of retrofitting. It can be concluded that retrofitting freight wagon with 
low-noise  brake  blocks  can  be  an  important  measure  to  reduce  the  negative  environmental 
impacts of railways and that the need for EU action in this field is confirmed. 

For all policy options and scenarios assessed, significant additional costs for retrofitting can 
be expected in the range of 550 million € to 2.25 billion €. The an alysis of the cost structure 
results in following conclusions: 

•  For  all  scenarios  the  investment  for  retrofitting  is  the  most  important  cost;  added 
maintenance costs amount to 13-16% of the total (K-blocks) and 32-45% of the total (LL-
blocks); administrative costs amount to 4-7% of the total (K-blocks) and 7-16% of the total 
(LL-blocks);  

•  Added  maintenance  costs  constitute  a  significant  portion  of  the  total  when  retrofitting  is 

considered to be done with K and LL-blocks;  

•  Added  administrative  costs  do  not  appear  to  be  decisive  although  they  refer  to  essential 

components of the retrofitting programme; 

Further  to  the  assessment  of  costs  and  savings  related  to  retrofitting  it  has  been  analysed 
which actor would bear the costs and who would benefit from revenues or savings (see Table 
15).  For  both  policy  options  railway  undertakings/  wagon  owners  have  to  bear  the  costs 
directly  related  to  retrofitting  (investment  and  additional  maintenance).  However,  SOV  and 
DEV (only in case of a bonus system) foresee a reimbursement of at least parts of the costs. In 
case  of  a  cost-neutral  bonus-malus-system  for  DEV,  this  would  not  be  the  case.  The  study 
demonstrated  that  this  would  lead  to  a  significant  increase  of  transport  costs  resulting  in  a 
modal shift from rail to road in the order of magnitude of 0.4% of the total rail freight demand 
(see section 5.5.2). As far as the allocation of noise abatement costs in competing modes of 
transport  is  concerned,  no  similar  measures  have  been  taken  for  road  transport  while  in 
aviation  noise-differentiated  airport  charges  are  in  place  at  some  European  airports  in 
accordance with national legislation. Therefore, a deviation from the polluters-pays-principle 
can  be  recommended  as  long  as  competing  modes  of  transport  do  not  bear  similar  cost  for 
noise abatement measures. 

The impact on IMs is rather small as the bonus granted to RUs would be compensated either 
by the MS or by revenues from a malus. 

MS  would  provide  funding  for  retrofitting  to  RUs/  WOs  either  directly  as  subsidies  or 
indirectly via the compensation paid to IMs for the noise bonus. However, it is very likely that 
savings in infrastructure related noise abatement costs will at least outweigh these costs (see 
section 5.4.5). Overall, retrofitting and providing financial support could be cost neutral for all 
parties involved as significant savings are possible (even if it has not been feasible within this 
impact assessment to quantify these savings). 

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Table 15: Overview of costs and revenues and which party bears them 

Cost 

RU/ WO 

IM 

MS 

Investment for 
retrofitting 

Additional 
maintenance  

SOV 

costs 

DEV 

costs 

costs 

costs 

SOV 

DEV 

SOV 

DEV 

- 

- 

- 

- 

- 

- 

- 

- 

Administrative costs 

costs 

costs 

costs 

costs 

costs 

costs 

Funding for 
retrofitting 
programmes 

revenues 
compensating 
investment 

revenues 
compensating 
investment & 
maintenance 
(only bonus 
system) 

- 

costs (only 
bonus 
system), but 
reimbursed 
by MS 

costs: 
subsidy to 
RU/WO 

costs (only 
bonus 
system): 
compensation 
to IM 

Investment for 
infrastructure-related 
noise abatement  

Investment cost for 
renewal of fleet 

Maintenance costs 
for infrastructure 

- 

- 

savings 

savings 

savings 

savings 

savings 

savings 

- 

- 

- 

- 

savings 

savings 

- 

- 

- 

- 

The comparison of the K-blocks and K+LL-blocks scenarios leads to clear results: 

•  The retrofitting costs with K-blocks are significantly higher than with LL-blocks (by 750 

million to 1 billion € according to the scenario); 

•  The  gross  benefits  of  LL-block  retrofitting  are  higher  than  those  of  the  related  K-block 
scenario. Even if K-block retrofitting can start earlier (due to the existing homologation of 
at  least  one  product),  in  the  LL-block  scenarios  retrofitting  programmes  are  completed 
earlier as the retrofitting rates with LL-blocks are much higher (brake systems do not need 
to  be  modified  for  retrofitting  with  LL-blocks,  no  problems  with  restricted  workshop 
capacities); 

•  Therefore,  the  K+LL  scenarios  always  lead  to  significantly  higher  net  benefits  than  the 

related K-block scenario;  

•  The  elimination  of  the  first  year  of  retrofitting  with  K-blocks  would  lead  to  a  further 
increase  in  net  benefits  (see  section  5.7);  a  rapid  homologation  of  LL-blocks  is  thus  an 
important objective for the effectiveness of the retrofitting programme; 

•  It  can  be  concluded  that  the  use  of  K-blocks  for  retrofitting  cannot  be  recommended 
provided  that  LL-blocks  will  be  fully  available  as  from  2011.  Certainly,  this  is  not 
guaranteed  but  this  looks  to  be  a  likely  scenario  as  by  end  of  2007,  three  products  have 
received a provisional homologation and one of them successfully passed successfully all 
tests.  An  earlier  homologation  than  in  2010  would  create  significant  additional  benefit. 
Therefore,  the  development  and  homologation  of  this  technology  shall  become  highest 
priority. 

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46 

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Based on both, the quantitative and qualitative impacts, the comparison of the policy options 
leads to following conclusions: 

•  The  “business  as  usual”  option  cannot  compete  with  the  two  other  ones  as  these  have 

positive benefits-costs-ratios and several additional positive impacts.  

•  The  DEV  option  has  better  benefits-costs  ratios  than  SOV  (for  the  K+LL-scenarios  9.9 
compared to 7.8 (1979 birthdate) resp. 9.4 to 5.3 (1984 birthdate). This is confirmed by the 
qualitative assessment where DEV shows better or equal results for all impacts considered. 

•  However,  it  has  been  shown  that  the  incentivation  margin  for  the  DEV  option  will 
probably  have  to  be  higher  than  for  the  SOV  option  (see  section  5.4.4);  dividing  the 
SOV/DEV total added cost values in Table 13, it can be seen that an incentivation margin 
for DEV of at the most 130% (K) or 150% (K+LL) that for SOV would lead to equal total 
funding  for  the  two  options  SOV  /  DEV.  Therefore,  it  is  of  high  importance  to  limit  the 
aggregated bonus for a silent wagon to the retrofitting costs. 

Concerning the intended exclusion of older wagons from retrofitting, two scenarios have been 
introduced with the limit birthdates 1979 and 1984. Following conclusions can be drawn: 

•  Before going to the quantitative considerations it is important to note that the values for the 
number  of  wagons  built  after  1979  /  1984  are  calculated  from  the  available  age 
distributions  with  a  procedure  that  does  not  lead  to  a  great  accuracy;  furthermore  it  is 
unknown  whether  in  the  future  these  wagons  will  last  longer  than  expected  (with  the 
consequence of noisy wagons running for a long time) or disappear quickly; 

•  Assuming the figures calculated, the choice of a limit birthdate of 1984 would obviously 
lead to less costs than the choice of 1979 due to the lower number of wagons to retrofit; 
however in all scenarios and for all values assumed for affected population it can be seen 
that a reduction in net benefit ensues; it thus can be concluded that to retrofit the wagons 
built between 1979 and 1984 (limit birthdate 1979) leads to higher benefits than costs. 

In  addition  to  the  results  aggregated  and  discounted  over  the  time,  the  annual  costs  and 
benefits have been analysed (see Figure 16 and Figure 17). 

CBA Analysis for K and 1979 scenario SOV

]

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€ 900.0

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Benefit DG Env An'06
Mainten. Costs

Benefit Infras
Adm Costs (SOV)

T OT  Extra Cost
Retrof Costs

Figure 16: Time-dependent costs and benefits (K, 1979, SOV) 

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CBA Analysis for K+LL and 1979 scenario DEV

]

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Benefit DG Env An'06

Mainten. Co s ts

Benefit Infras

Adm Cos ts  (DEV)

TOT Extra Cos t

Retro f Co s ts

Figure 17: Time-dependent costs and benefits (K+LL, 1979, DEV) 

This analysis underlines the advantages of LL-blocks for retrofitting as for K-blocks the costs 
occur  at  an  early  stage  but  benefits  are  delayed.  For  LL-blocks,  the  two  curves  are  more 
aligned. Furthermore, these graphs demonstrate a need for ongoing financial incentives to use 
low-noise wagons as long as their maintenance costs are higher than those of cast-iron braked 
wagons.  Only  a  mid-term  bonus  or  a  bonus-malus  scheme  on  track  access  charges  could 
provide these incentives.  

Furthermore,  for  K-block  retrofitting  the  initial  investment  is  obviously  of  higher  relative 
importance; therefore, the policy option SOV fits better to K-block retrofitting than DEV not 
providing  the  funding  at  the  time  the  costs  occur.  And  vice-versa:  The  more  relevant 
additional maintenance costs of LL-block retrofitting can be better provided by DEV with its 
continuous financial support. 

As  overall  result  of  this  impact  assessment,  policy  option  DEV  consisting  of  differentiated 
track  access  charges  with  a  noise  bonus  for  silent  wagons,  noise  emission  ceiling  and 
voluntary  commitments  has  been  identified  as  the  most  appropriate  solution  to  achieve  the 
objectives  of  rail  noise  reduction  while  maintaining  the  competitiveness  of  rail  freight.  The 
main advantages of this option are the highest benefits in terms of noise reduction/ reduction 
of  number  of  citizens  affected  by  rail  noise  (with  a  benefits-costs  ratio  of  up  to  10),  lower 
costs  than  related  to  the  competing  SOV  option,  the  direct  link  to  the  objectives  of  this 
initiative  (to  reduce  noise  by  using  silent  wagons)  and  its  easy  application  to  wagons 
registered in different Member States or even outside the EU. 

As  this  policy  option  also  has  two  main  disadvantages,  solutions  need  to  be  elaborated  for 
passing the noise bonuses to the wagon owners/ keepers bearing the costs of retrofitting (if not 
these same entity as the railway undertaking getting the bonus) and concerning intermediate 
measures as the implementation of differentiated track access charges requires some time. In 
this context voluntary commitments could play an important role by addressing the issue of 
bonuses  to  be  passed  to  wagons  owners  as  well  as  a  by  rapid,  but  co-ordinated 
implementation of differentiated track access charges by some infrastructure managers. 

The harmonisation of differentiated track access charges at European level is a crucial factor 
for  the  effectiveness  of  this  instrument  as  solely  national  solutions  would  not  provide  the 
necessary  financial  incentives  for  retrofitting  and  could  lead  to  unacceptably  high 
administrative costs. 

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High priority needs to be given to the further development and homologation of LL-blocks as 
the  most  economic  viable  technology  for  retrofitting.  By  implementing  policy  option  DEV 
providing incentives to further reduce costs of retrofitting and following the positive examples 
of the United Kingdom and Portugal of cost-neural retrofitting, it should be possible to reduce 
the additional costs of retrofitting to a minimum. 

7. 

MONITORING AND EVALUATION 

With  regard  to  the  objectives  of  the  Communication  on  rail  noise  abatement  measures 
addressing  the  existing  fleet,  the  following  indicators  seem  suitable  to  measure  its  progress 
and the related costs: 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

(7) 

(8) 

(9) 

Total number and share of vehicles retrofitted per country 

Total silent fleet per country 

Number and share of axle-km run by low-noise wagons 

Costs of retrofitting per country 

Annual noise bonuses granted per infrastructure manager 

Average annual maintenance cost per wagon (per country and per wagon-km) 

Total average noise reduction (dB) 

Noise reduction on affected population 

Noise reduction at particular “hot spots” 

The  noise  mapping  exercise  in  the  framework  of  Directive  2002/49/EC  should  be  used  to 
assess  the  success  of  the  retrofitting  programmes:  Against  the  2007  maps  as  baseline,  the 
effectiveness of retrofitting programmes will be monitored, the need for emission ceilings can 
be elaborated and the fine-tuning of ceiling values can be carried out. In this context, suitable 
data  related  to  the  indicators  7,  8  and  9  is  reported  by  Member  States  to  the  Commission 
under the above mentioned Directive. 

Other  data  has  to  be  reported  by  the  rail  sector  (IM:  bonus;  RU/WO:  wagons,  costs). 
Therefore,  reporting  and  monitoring  issues  should  be  one  element  of  the  voluntary 
commitment of the sector to promote retrofitting. 

Improved awareness on rail noise issues and exchange of information between stakeholders, 
as encouraged by the Communication, will also contribute to constantly improving the actions 
undertaken. 

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ANNEX I: DESCRIPTION OF POLICY OPTIONS 

Possible policy options and instruments to support/ promote retrofitting of the European rail 
freight fleet are listed below (see Table 16) and briefly described. Beside, a 'doing nothing/ no 
policy change' option will be used as baseline scenario.  

A combination of different instruments may be examined, as the problem is rather complex 
and rail freight and rail noise conditions vary greatly across the EU. 

Table 16: List of policy options and instruments  

Policy option 

Instrument  

A: Status quo (as baseline scenario) 

B: Voluntary commitment by the rail sector 

C: Financial incentives for retrofitting 

C1: Differentiated track access charges 

C2: Subsidies for the use of low-noise wagons 

C3: Subsidies for retrofitting 

C4: Loans at preferential terms 

C5: Tax incentives 

D: Legal measures to impose retrofitting 

D1: Noise limit values for the existing fleet  

D2: Operating restrictions for noisy freight wagons  

D3: Noise emission ceiling 

D4: Tradable permit system 

1. Voluntary commitment by the rail sector 

This  option  consists  of  actions  paving  the  way  towards  a  voluntary  commitment  by  the 
various stakeholders – railway undertakings, wagon owners and infrastructure managers. It is 
based on the assumption that it would be up to railway associations to take over the central 
role  in  organising  retrofitting  programmes.  Commitment  is  needed  from  all  stakeholders  as 
retrofitting involves action at different levels.  

A  voluntary  commitment  could  include  such  components  as  commitments  to  individual 
objectives (e.g. individual retrofitting targets), to set up and implement appropriate retrofitting 
programmes  to  define  priorities  in  order  to  get  the  best  results  and/  or  to  financial 
contributions from the sector. 

2. Financial incentives for retrofitting 

To overcome the financing problem, which is the main obstacle to retrofitting, wagon owners 
could  be  given  financial  incentives.  As  a  rule,  subsidies  granted  by  Member  States  to 
economic  actors  should  be  regarded  as  state  aids  according  to  Article  87  of  the  EC  Treaty. 
The EC Treaty generally prohibits state aid which affects competition between markets actors, 
unless it is justified by reasons of general economic development. The European Commission 
is in charge of watching over compliance of state aid with EU competition rules to ensure that 
this  prohibition  is  respected  and  that  exemptions  are  applied  equally  across  the  European 

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Union.  For  this  purpose,  the  Commission  services  are  preparing  state  aid  guidelines  for  the 
rail  sector.  A  draft  of  the  guidelines  has  been  made  available  in  December  2007  for 
consultation with the Member States and stakeholder. 

Differentiated track access charges  

This  instrument  addresses  the  existing  financial  flow  between  railway  undertakings  and 
infrastructure  managers:  the  track  access  charge.  The  railway  undertakings  would  receive  a 
discount on this charge if using low-noise rolling stock.  
At  European  level,  Directive  2001/14/EC34  harmonises  charging  principles.  One  of  these 
principles  is  that  infrastructure  charges  may  be  set  to  take  account  of  the  cost  of  the 
environmental impact of train operations, including noise. Any charge differentiation should 
in principle reflect the magnitude of the impact on the environment. As Directive 2001/14/EC 
does not allow an increase in overall revenue (unless there are similar charges for competing 
modes of transport), two basic models of differentiated track access charges could be used as 
an incentive: 

–  A cost-neutral, bonus-malus system; 

–  A  bonus  system  where  the  infrastructure  manager  receives  financial  compensation  from 

the Member State. 

This  instrument  is  applied  in  Switzerland  since  2002  and  will  be  introduced  in  The 
Netherlands in 2008/2009.  

Subsidies for the use of low-noise wagons 

Another instrument for granting financial incentives to railway undertakings to use low-noise 
freight  wagons  is  subsidies  from  Member  States  directly  to  the  railway  undertakings.  The 
subsidy scheme could contain components similar to a discount on track access charges.  

Article  10  of  Directive  2001/14/EC  lays  down  requirements  for  compensation  schemes  for 
unpaid environmental and other costs. It needs to be investigated in detail whether a subsidy 
scheme for the use of low-noise wagons would fully comply with these requirements.  

Subsidies for retrofitting  

This  instrument  consists  of  introducing  noise  abatement  programmes  with  direct  public 
financial support. The cost of retrofitting would be partly or fully reimbursed. Subsidies for 
retrofitting could be granted by Member States or at European level. 
Several  Member  States  already  have  rail  noise  abatement  programmes  in  place35.  However, 
they  all  cover  infrastructure-related  measures  such  noise  barriers  or  insulated  windows.  In 
Switzerland, the federal government finances the retrofitting of about 7 500 wagons owned by 
SBB  and  4 000  privately  owned  wagons  with  K-blocks.  Costs  are  estimated  at  EUR 125 
million. 

34 

35 

EN 

Directive  2001/14/EC  of  the  European  Parliament  and  of  the  Council  of  26 February 2001  on  the 
allocation  of  railway  infrastructure  capacity  and  the  levying  of  charges  for  the  use  of  railway 
infrastructure and safety certification, OJ L 75, 15.03.2001, p. 29. 

UIC Status Report: Noise abatement on European railway infrastructure, Paris, 2007. 

51 

   EN 

                                                 
Loans at preferential terms 

Loans could be granted to wagon owners at preferential conditions to promote retrofitting, in 
particular to support the initial outlay. The level of the incentive strongly depends on whether 
the  initial  outlay  is  recouped.  For  retrofitting  with  K-blocks,  savings  on  maintenance  costs 
might be possible in some cases. However, full pay-back cannot be expected.  

Tax incentives 

In  general,  this  instrument  provides  mechanisms  of  fiscal  incentives  by  granting  tax 
allowances  for  operators  applying  more  environmentally  friendly  solutions.  This  instrument 
has been used to encourage the use for car emission abatement measures in several countries. 
To support retrofitting, composite brake blocks could be excluded from VAT. 

3. Legal measures to impose retrofitting 

Beside economic incentives, legal instruments could be used to impose retrofitting of freight 
wagons.  These  instruments  normally  entail  restrictions  on  the  use  of  "noisy"  wagons.  They 
can be implemented at European, national or regional level. 

Noise limit values for the existing fleet 

One  approach  would  be  to  impose  noise  limit  values  for  existing  freight  wagons,  e.g.  by 
extending  the  scope  of  the  Noise  TSI  to  the  existing  fleet  while  at  the  same  time  fixing  a 
calendar for phasing out "noisy" wagons.  
Such an instrument has been used in the aviation sector. Regulation (EC) No 925/199936 aims 
at  reducing  noise  originating  from  aircraft.  It  prohibits  Member  States  from  registering 
aircraft with poor noise performance.  

Operating restrictions for noisy freight wagons 

On certain sensitive lines and/ or at certain times (at night), access for noisy vehicle types or 
train formations could be restricted. Like other instruments such as access charges or emission 
ceilings,  access  restrictions  require  individual  vehicles  to  be  identified  and  classified 
according to their noise emissions. 

This approach has not yet been used to reduce rail noise, but it has been used for noise from 
aviation.  Directive  2002/30/EC37  allows  the  operation  of  aircraft  at  airports  to  be  restricted 
following  an  environmental  impact  assessment.  As  a  consequence,  night  flights  are  not 
allowed or strictly limited at certain airports. 

Noise emission ceiling 

The noise emission ceiling limits daily average emissions at a certain location along the line. 
For example, current noise emission could be taken as a limit to prevent noise from increasing 
if  rail  freight  transport  grows.  Under  Directive  2002/49/EC,  Member  States  are  legally 
competent to set such limits to environmental noise.  

36 

37 

Council  Regulation  (EC)  No  925/1999  of  29  April  1999  on  the  registration  and  operation  within  the 
Community of certain types of civil subsonic jet aeroplanes, OJ L 115, 4.5.1999, p. 1. 

Directive  2002/30/EC  of  the  European  Parliament  and  of  the  Council  of  26  March  2002  on  the 
establishment  of  rules  and  procedures  with  regard  to  the  introduction  of  noise-related  operating 
restrictions at Community airports, OJ L 85, 28.3.2002, p. 40. 

EN 

52 

   EN 

                                                 
The  noise  emission  ceiling  leaves  it  to  the  rail  sector  to  find  optimal  solutions:  the  railway 
undertaking  may  use  vehicles  with  lower  emissions  to  increase  the  number  and/or  speed  of 
trains  without  exceeding  the  noise  limits.  Therefore,  the  noise  emission  ceiling  gives  an 
incentive to use low-noise vehicles. Noise emission ceilings could directly address noise 'hot 
spots' in the European network. Furthermore, infrastructure-related measures are also covered 
by this instrument leading to a holistic approach of rail noise reduction. 

Tradable permit system 

Under  a  tradable  permit  scheme,  a  specific  permit  issued  by  public  authorities  must  be 
obtained  to  produce  emissions.  A  polluter  who  does  not  have  enough  permits  can  either 
reduce emissions or buy additional permits on the market. In theory, this minimises the cost of 
emission reductions. 

To apply this system to rail noise, a permit could be required for the use of noisy wagons. The 
number of permits would be reduced every year until the retrofitting target has been achieved. 

In Europe, a tradable permit system has been applied to greenhouse gas emissions from power 
plants and industrial installations since 200538. Extension to aeroplane emissions is currently 
under discussion. 

38 

Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a 
scheme for greenhouse gas emission allowance trading within the Community and amending Council 
Directive 96/61/EC, OJ L 275, 25.10.2003, p 32.  

EN 

53 

   EN 

                                                 
ANNEX II: PRE-SELECTION AND COMBINATION OF POLICY OPTIONS 

1. Assessment criteria 

With the aim to focus the detailed impact assessment on the most appropriate options, various 
criteria are used to assess whether the policy options and instruments are suited to achieving 
the established objectives: 

•  Effectiveness: Is the instrument suited to achieving the objective of the retrofitting exercise 
(equipping  wagons  with  low-noise  brake  blocks,  giving  priority  to  vehicles  with  a  high 
annual mileage)? To what extent?  

•  Suitability for wagons from other Member States: If measures are to be taken at national 

level, do they address foreign vehicles as well?  

•  Implementation  time:  How  long  will  it  take  before  the  instrument  will  deliver  tangible 

benefits?  

•  Impact on competitiveness of rail transport: Does the instrument create obstacles to the use 

of rail freight transport, particularly on the main European corridors?  

•  Efficiency: How high is the ratio of noise reduction to the cost of the exercise?  

•  Administrative feasibility and cost: Does the instrument create an additional administrative 

burden for the rail sector and what are the related costs? 

•  Consistency  with  the  existing  legal  framework:  Does  the  instrument  fit  into  the  existing 

European and national legal framework? 

•  Traceability  of  the  results:  Does  the  instrument  easily  allow  its  effects  and  costs  to  be 
monitored?  As  far  as  public  funds  are  concerned,  transparency  is  crucial  to  the  scheme's 
credibility. 

•  Complementary  nature:  Is  it  possible  to  combine  two  or  more  instruments  without  any 

negative impact on their individual effectiveness and efficiency? 

•  Effectiveness  for  hot  spots:  Is  the  option  effective  regarding  the  noise  reduction  for  the 
population effected? Retrofitting wagons do not automatically lead to a noise reduction as 
they  have  to  be  used  where  many  people  are  exposed  to  high  noise  levels  (“hot  spots”). 
Does the policy option allow a differentiation regarding location and time? 

2. Screening and its results 

A screening of the policy options against the criteria is leading to the identification of those 
policy  options  that  are  likely  to  meet  the  objectives  the  best.  They  are  further  assessed 
regarding their environmental, economic and social impacts.  

As  a  result  of  the  public  consultation,  the  policy  option  D4  (tradable  permits)  has  been 
excluded as results of the consultation. As the only instrument the majority of the contributors 
refused  tradable  noise  emission  permits.  About  40%  even  strongly  disagree.  As  this 
instrument is likely to have serious disadvantages like a long implementation time as there is 
today no legal basis in place, high administrative costs and the missing capability to address 
rail noise 'hot spots', it has not been further assessed within the impact assessment. 

The  remaining  policy  options  have  been  assessed  against  the  criteria  leading  to  a  semi-
quantitative  mark  "very  good",  "good",  "medium",  "poor"  or  "very  poor".  The  results  are 
documented in the following tables. 

EN 

54 

   EN 

Table 17: Screening of policy options – Effectiveness 

Evaluation 

Comments 

Voluntary commitment (B) 

poor 

Differentiated track access charges 
(C1) 

medium 

Subsidies for the use of low-noise 
wagons (C2) 

medium 

Subsidies for retrofitting (C3) 

very good 

Not legally binding and no economic 
incentives, however, priority to vehicles with 
high mileage possible 

Only indirect impact, but incentive to give 
priority to vehicles with high mileage; 
problem of economic advantage to be 
transferred to wagon keeper 

Only indirect impact, but incentive to give 
priority to vehicles with high mileage; 
problem of economic advantage to be 
transferred to wagon keeper 

High effectiveness due to direct impact; 
financial aid directly to keeper 

Loans at preferential terms (C4) 

very poor 

Low economic incentive 

Tax incentives (C5) 

Noise limit values for the existing 
fleet (D1) 

Operating restrictions for noisy 
freight wagons (D2) 

very poor 

very good 

good 

Noise emission ceiling (D3) 

good 

Low economic incentive (tax reduction only 
provides limited cost reduction) 

Legal measures are in general relatively 
effective 

Legal measures are in general relatively 
effective; potential problems with 
enforcement 

Legal measures are in general relatively 
effective; potential problems with 
enforcement 

EN 

55 

   EN 

 
 
Table 18: Screening of policy options – Suitability for wagons from other Member States 

Evaluation 

Comments 

Voluntary commitment (B) 

good 

High in case of commitment at European level

Differentiated track access charges 
(C1) 

very good 

High (equal treatment of all wagons) 

Subsidies for the use of low-noise 
wagons (C2) 

medium 

In theory high, but doubts if subsidies given 
for foreign wagons 

Subsidies for retrofitting (C3) 

poor 

strong doubts if subsidies given for foreign 
wagons 

Loans at preferential terms (C4) 

very good 

High (no restrictions to certain MS) 

Tax incentives (C5) 

Noise limit values for the existing 
fleet (D1) 

Operating restrictions for noisy 
freight wagons (D2) 

very poor 

Low: only for RUs/ keepers paying taxes in 
the respective MS 

very good 

If imposed at EU level 

very good 

Equal treatment of all wagons 

Noise emission ceiling (D3) 

very good 

Equal treatment of all wagons 

Table 19: Screening of policy options – Implementation time 

Evaluation  Comments 

Voluntary commitment (B) 

medium 

Differentiated track access 
charges (C1) 

Subsidies for the use of low-
noise wagons (C2) 

medium 

medium 

Subsidies for retrofitting (C3) 

medium 

Loans at preferential terms (C4) 

medium 

Tax incentives (C5) 

medium 

Potentially fast, but missing legal obligations could 
lead to delays 

Depends on bonus and strategy of keepers, could 
accelerate retrofitting if limited in time, depends on 
monitoring and identification systems 

Depends on amount of subsidy and strategy of keepers 
and on monitoring and identification systems, could 
accelerate retrofitting if limited in time 

Depends on design of subsidy scheme and use of 
existing funds, need for legal basis, notification to the 
Commission required 

Slow implementation could be expected, requires time 
to prepare projects, introduction of scheme needed  

Slow implementation could be expected (low 
incentive) 

Noise limit values for the 
existing fleet (D1) 

medium 

Time for adoption of legislation + transition period 

Operating restrictions for noisy 
freight wagons (D2) 

good 

Faster to implement than limit values or noise 
emission ceiling 

Noise emission ceiling (D3) 

medium 

Development of scheme is rather complex and 
therefore time-consuming 

Table 20: Screening of policy options – Impact on competitiveness of rail transport 

EN 

56 

   EN 

 
 
 
Evaluation 

Comments 

Voluntary commitment (B) 

medium 

Differentiated track access charges 
(C1) 

good 

Ensures competitiveness, but financial 
contributions of sector would increase costs 

Depends on system: bonus or bonus/malus 
scheme (with compensation for IM); mileage 
of wagons 

Subsidies for the use of low-noise 
wagons (C2) 

very good 

Depends on amount of subsidy and mileage of 
wagons 

Subsidies for retrofitting (C3) 

very good 

Could be cost-neutral for sector 

Loans at preferential terms (C4) 

very poor 

Incentive is rather limited 

Tax incentives (C5) 

poor 

significant contribution of sector required 

Noise limit values for the existing 
fleet (D1) 

Operating restrictions for noisy 
freight wagons (D2) 

very poor 

High additional costs for sector  

poor 

High additional costs for sector, but not as 
high as for limit values as this instrument is 
more focussed; limits network capacity 

Noise emission ceiling (D3) 

medium 

High additional costs for sector, but flexibility 
for sector for cost-effective implementation; 
limits network capacity (but less than 
operating restrictions do) 

EN 

57 

   EN 

 
 
Table 21: Screening of policy options – Efficiency 

Evaluation 

Comments 

Voluntary commitment (B) 

very good 

Differentiated track access charges 
(C1) 

Subsidies for the use of low-noise 
wagons (C2) 

good 

good 

Subsidies for retrofitting (C3) 

medium 

Loans at preferential terms (C4) 

very good 

Provides incentives to sector to ensure 
efficiency (focussed retrofitting; sector's 
financial contribution avoids overrunning 
costs) 

Strong incentive for focussed retrofitting, but 
risk of 'overcompensation' for high 
performing wagons 

Strong incentive for focussed retrofitting, but 
risk of 'overcompensation' for high 
performing wagons 

No incentive for focussed retrofitting in case 
of 100% funding; partly funding ensures 
efficiency to some extend, only 
reimbursement of costs occurred 

Strong incentive for focussed retrofitting as 
high contribution of sector required 

Tax incentives (C5) 

very good 

Strong incentive for focussed retrofitting as 
high contribution of sector required 

Noise limit values for the existing 
fleet (D1) 

medium 

Operating restrictions for noisy 
freight wagons (D2) 

medium 

Noise emission ceiling (D3) 

very good 

Requires retrofitting of whole fleet (very in-
efficient; only if no transition period 
foreseen), but scrapping/ replacement of old 
wagons can be expected; high incentive for 
sector to limit costs 

Requires retrofitting of significant parts of the 
fleet (expected to be in-efficient), but 
scrapping/ replacement of old wagons can be 
expected; high incentive for sector to limit 
costs 

Leaves freedom to sector to optimise 
composition of fleet 

EN 

58 

   EN 

 
 
Table 22: Screening of policy options – Administrative feasibility and cost 

Evaluation 

Comments 

Voluntary commitment (B) 

very good 

Differentiated track access charges 
(C1) 

medium 

Subsidies for the use of low-noise 
wagons (C2) 

very poor 

Subsidies for retrofitting (C3) 

good 

No bureaucracy to be expected; however, 
agreement and monitoring scheme required 

Additional burdens due to more complex 
track access charging scheme (likely to be 
calculated based on single wagons and not on 
full trains as today); however, existing 
financial flow can be addressed 

Funding schemes with interface to data on 
track access charges/ train composition 
required; new financial flow from state to 
keeper: more complex than C1 

Funding schemes in-line with state aid 
provisions required; transparency of costs/ 
reporting system needed 

Loans at preferential terms (C4) 

medium 

Design of appropriate projects required 

Tax incentives (C5) 

very good 

Noise limit values for the existing 
fleet (D1) 

medium 

VAT reduction for composite brake blocks 
without significant administrative burden 
possible 

Implementation of concept of 'in-use-
compliance' required; medium administrative 
burden if no tests required to demonstrate 
compliance 

Operating restrictions for noisy 
freight wagons (D2) 

medium 

Requires more complex train paths 
management; difficult enforcement 

Noise emission ceiling (D3) 

medium 

Complex calculations for each line, 
complicated train paths management; 
measurements required? difficult 
enforcement; however, automated systems 
could reduce the burden significantly 

EN 

59 

   EN 

 
 
Table 23: Screening of policy options – Consistency with the existing legal framework 

Voluntary commitment (B) 

very good  No legal basis needed 

Evaluation  Comments 

Differentiated track access 
charges (C1) 

very good 

Explicitly foreseen in Article 7 (5) of Directive 
2001/14/EC 

Subsidies for the use of low-noise 
wagons (C2) 

medium 

Subsidies for retrofitting (C3) 

medium 

Could be based on Article 10 of Directive 
2001/14/EC; national legal basis to be put in place; 
compliance with state aid rules to be ensured 

National legal basis to be put in place; compliance 
with state aid rules to be ensured 

Loans at preferential terms (C4) 

very good  No legal basis needed 

Tax incentives (C5) 

medium 

National legal basis to be put in place 

Noise limit values for the existing 
fleet (D1) 

poor 

Implementation of concept of 'in-use-compliance' 
required which is today not foreseen in the legal 
interoperability framework  

Operating restrictions for noisy 
freight wagons (D2) 

medium 

Could be based on Article 8 of Directive 
2002/49/EC; national legal basis to be put in place 

Noise emission ceiling (D3) 

medium 

Could be based on Article 8 of Directive 
2002/49/EC; national legal basis to be put in place 

Table 24: Screening of policy options – Traceability of the results 

Evaluation  Comments 

Voluntary commitment (B) 

Differentiated track access 
charges (C1) 

good 

good 

Monitoring could be part of commitment 

Track access charges revenues are in principle 
publicly available; noise reduction effect can be 
calculated on this basis 

Subsidies for the use of low-noise 
wagons (C2) 

very good 

Subsidies need to be published; noise reduction 
effect can be calculated on this basis 

Subsidies for retrofitting (C3) 

very good 

Loans at preferential terms (C4) 

good 

Tax incentives (C5) 

very good 

Subsidies need to be published; noise reduction 
effect can be calculated on this basis 

EIB loans are in principle published; noise 
reduction effect can be calculated on this basis 

Tax revenues are published; noise reduction effect 
can be calculated on this basis 

Noise limit values for the existing 
fleet (D1) 

Operating restrictions for noisy 
freight wagons (D2) 

medium 

medium 

Noise emission ceiling (D3) 

medium 

Noise reduction effect can be calculated; no 
information on financial impact available  

Noise reduction effect can be calculated; no 
information on financial impact available 

Noise reduction effect can be calculated; no 
information on financial impact available 

EN 

60 

   EN 

 
 
 
 
Table 25: Screening of policy options – Complementary nature 

Evaluation  Comments 

Voluntary commitment (B) 

very good 

Fits well to other options (less to legal instruments) 

Differentiated track access 
charges (C1) 

Subsidies for the use of low-noise 
wagons (C2) 

Subsidies for retrofitting (C3) 

good 

poor 

poor 

Loans at preferential terms (C4) 

good 

Fits to voluntary and legal instruments, not to 
subsidies and tradable permits  

Fits to voluntary and some legal instruments, not to 
other financial instruments 

Fits to voluntary and some legal instruments, not to 
other financial instruments 

Fits to voluntary and legal instruments, not to 
subsidies 

Tax incentives (C5) 

good 

Fits to voluntary and legal instruments, not to 
subsidies 

Noise limit values for the existing 
fleet (D1) 

medium 

Fits to some financial instruments, less to other 
legal instruments and voluntary commitments 
(depends on transition period foreseen) 

Operating restrictions for noisy 
freight wagons (D2) 

medium 

Fits to some financial instruments, less to other 
legal instruments and voluntary commitments 

Noise emission ceiling (D3) 

medium 

Fits to some financial instruments, less to other 
legal instruments and voluntary commitments 

Table 26: Screening of policy options – Effectiveness for hot spots 

Evaluation  Comments 

Voluntary commitment (B) 

very good  A commitment could focus on certain lines or 

corridors 

Differentiated track access 
charges (C1) 

Subsidies for the use of low-noise 
wagons (C2) 

good 

good 

Bonus for certain lines or corridors possible, but 
adds more complexity to the schemes 

Bonus for certain lines or corridors possible, but 
adds more complexity to the schemes 

Subsidies for retrofitting (C3) 

poor 

Loans at preferential terms (C4) 

poor 

No direct link to hot spots; however, wagons used 
on certain corridors could be given priority 

No direct link to hot spots; however, wagons used 
on certain corridors could be given priority 

Tax incentives (C5) 

very poor  No link to hot spots, low general effectiveness 

Noise limit values for the existing 
fleet (D1) 

Operating restrictions for noisy 
freight wagons (D2) 

poor 

No direct link to hot spots  

very good  Restrictions could explicitly focus on hot spots 

Noise emission ceiling (D3) 

good 

Ceilings could cover hot spots 

EN 

61 

   EN 

 
 
 
 
The  summary  of  results  of  the  screening  of  the  policy  options  are  presented  in  Table  27 
and 
(policy 

options 

C5) 

C1 

– 

EN 

62 

   EN 

Table 28 (policy options B, D1 – D3). 

Table 27: Screening assessment of policy options providing financial incentives 

Differentiated 
track access 
charges (C1) 

Subsidies for 
use of low-
noise wagons 
(C2) 

Subsidies for 
retrofitting 
(C3) 

Loans at 
preferential 
terms (C4) 

Tax 
incentives 
(C5) 

medium 

very good 

medium 

medium 

good 

poor 

very poor 

very poor 

very good 

very poor 

medium 

medium 

very good 

medium 

medium 

good 

very good 

very good 

very poor 

poor 

Effectiveness 

Suitability 
foreign wagons 

Implementation 
time 

Competitiveness 
of rail 

Efficiency 

good 

good 

medium 

very good 

very good 

Administrative 
feasibility 

medium 

very poor 

good 

medium 

very good 

Legal consistency  

very good 

medium 

medium 

very good 

medium 

Traceability of 
the results 

Complementary 
nature 

Effectiveness for 
hot spots 

good 

very good 

very good 

good 

very good 

good 

good 

poor 

good 

poor 

poor 

good 

good 

poor 

very poor 

Overall 

good  

medium  

good  

poor*  

poor*  

*: very poor effectiveness leading to reduction by one rank in the aggregated result 

EN 

63 

   EN 

 
Table 28: Screening assessment of legal measures and voluntary commitments 

Noise limits for 
existing fleet (D1)

Operating 
restrictions (D2) 

Noise emission 
ceiling (D3) 

Voluntary 
commitments (B) 

very good  

very good 

good 

good 

very good 

very good 

poor 

good 

Effectiveness 

Suitability foreign 
wagons 

Implementation 
time 

Competitiveness 
of rail 

Efficiency 

Administrative 
feasibility 

Traceability of the 
results 

Complementary 
nature 

Effectiveness for 
hot spots 

Legal consistency  

poor 

medium 

very poor 

medium 

medium 

medium 

good 

poor 

medium 

medium 

medium 

medium 

medium 

medium 

medium 

medium 

very good 

poor 

medium 

medium 

very good 

very good 

very good 

good 

medium 

medium 

medium 

very good 

Overall 

medium  

good  

poor 

very good 

good 

good  

good 

good  

As a first approach all "good" rated policy options are selected for further assessment. This is 
confirmed by the following more detailed evaluation: 

•  Policy option B, a voluntary commitment by the sector, receives a high mark as it offers 
various advantages regarding the efficiency, administrative burdens, legal consistency and 
complementary nature. However, following the experience with the UIC/CER/UIP action 
programme39 and due to its poor effectiveness it cannot be regarded as appropriate stand-
alone measure.  

•  The  "Differentiated  track  access  charges"  and  the  "Subsidies  for  the  use  of  low-noise 
wagons" (C1 resp. C2) follow the same principle idea to grant financial incentives for the 
use of silent wagons, but C2 requires the establishment of new financial flows between two 
actors  (Member  State  authorities  and  RU  resp.  WO).  This  leads  to  significant 
disadvantages such as high additional administrative burdens and a limited suitability for 
foreign  wagons.  As  the  advantages  are  rather  limited,  differentiated  track  access  charges 
will be dealt with in the detailed analyses whereas the subsidies for the use of low-noise 
wagons are excluded. 

•  Subsidies  for  retrofitting  (C3)  have  on  the  one  hand  clear  disadvantages  like  problems 
regarding foreign wagons and the low effectiveness to address noise "hot spots". However, 
as there are many strong points like the very high effectiveness and concerning the impacts 

39 

In 1998 UIC, CER and UIP proposed the ‘Action Programme Noise Reduction Freight Traffic’ which 
aims to retrofit the European freight fleet in use during the next decade. The programme, however, has 
never started due to technical problems at the beginning and most importantly due to lack of funding. 

EN 

64 

   EN 

 
                                                 
on  railways'  competitiveness,  this  policy  option  has  been  selected  for  the  detailed 
assessment.  This  selection  is  in  line  with  the  results  of  the  public  consultation  and  the 
stakeholder  workshop  where  policy  options  C1  and  C3  have  been  in  the  focus  of  the 
discussions. 

•  The policy options C4 (Loans at preferential terms) and C5 (Tax incentives) are expected 
to have a very poor effectiveness as they provide very limited financial incentives for RUs 
to  retrofit.  In  case  of  implementation  of  retrofitting  programmes  at  large  scale,  this 
instruments would require major financial interventions from industry and would therefore 
result in high financial burdens for the sector, leading to an increase of transport prices and 
potentially to a modal shift towards road transport (higher environmental burden including 
noise). As other options do provide necessary incentives, C4 and C5 are not further dealt 
with in the detailed impact assessment. 

•  Compared  to  the  other  legal  instruments,  noise  limits  for  existing  fleet  (D1)  have  been 
assessed  as  the  most  effective  policy  options  of  this  group.  However,  the  use  of  this 
instrument  would  be  a  serious  threat  for  rail  freight  as  high  costs  for  the  sector  would 
reduce its competitiveness. Furthermore, D1 does not comply with today's legal framework 
for  interoperability  that  does  not  foresee  the  instrument  of  compliance  for  rolling  stock 
already  in  use  (unless  it  gets  upgraded  or  renewed).  Therefore,  as  there  are  no  other 
significant  advantages  compared  to  the  other  two  legal  instruments,  noise  limits  for  the 
existing fleet are excluded from the detailed impact assessment. 

•  The  policy  options  D2  and  D3  (Operating  restrictions  and  Noise  emission  ceiling)  offer 
various  advantages  (such  as  high  effectiveness,  in  particular  for  hot  spots)  with  limited 
disadvantages at the downside. As the direct comparison does not lead to a clear ranking, 
both options are selected for the detailed analyses. 

As result of this evaluation, the preliminary finding of the screening can be confirmed. Policy 
options B, C1, C3, D2 and D3 will be further dealt with in the impact assessment. 

3. Combinations of policy options 

The  remaining  policy  options  have  been  checked  regarding  possible  combinations  as 
according  to  the  results  of  the  public  consultation,  no  single  instrument  is  regarded  as 
sufficient to achieve the objectives. Moreover, it has to be considered that it is quite unlikely 
that a single solution could be suitable, effective and successful, because: 

•  legal options not combined with financial incentives would result in excessive burden on 
the  rail  sector,  for  the  same  reasons  which  led  to  the  exclusion  of  policy  option  D1  (see 
chapter 0); 

•  financial  incentives  not  combined  with  legal  measures  could  not  guarantee  alone  a  high 
retrofitting rate due to a lack of obligatory nature of these instrument. In particular at long 
term,  accompanying  legal  measures  could  ensure  the  effectiveness  of  retrofitting 
programmes. 

A voluntary commitment by the sector is strongly recommendable in any future scenario; it is 
considered as a part of all policy options assessed. As stand-alone measures it strongly lacks 
effectiveness (see Annex II, section 2). 

The  possible  combinations  of  legal  and  economic  instruments  have  been  further  analysed 
regarding complementarity aspects and possible synergies (see Table 29): 

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•  The  two  selected  financial  instruments  (differentiated  track  access  charges  and  subsidies 
for retrofitting) are difficult to combine. A possible double funding and/or a distortion of 
competition  are  two  main  concerns.  The  competition  issue  becomes  relevant  in  case  of 
different funding schemes in Member States. A successive use of both instruments might 
be acceptable, in particular as subsidies necessarily have a transient character (until the end 
of the retrofitting programmes); however, further reflections are needed on this issue. 

•  The  combination  of  the  two  selected  legal  measures  (operating  restrictions  and  emission 
ceiling)  is  possible  and  potentially  advantageous.  Simultaneous  application  of  different 
instruments  could  distinguish  among  lines.  The  application  at  different  times  is  also 
possible.  However,  the  implementation  of  such  a  combination  would  be  extremely 
complex  to  design  and  would  be  related  to  a  high  risk  of  non-optimal  solutions. 
Furthermore, the high burden for the sector due to missing financial support clearly led to 
the exclusion of this combination. 

•  In  case  of  a  combination  of  differentiated  track  access  charges  and  operating  restrictions 
(C1 and D2), the added value would be rather limited as the track access charges do not 
have  a  significant  weak  point  that  needs  to  be  compensated.  However,  operating 
restrictions could help to increase the effectiveness of track access charges as RUs/ WOs 
would  have  more  incentives  for  retrofitting  than  in  case  of  a  stand-alone  policy  option. 
Overall the degree of complementarity of this combination can be regarded as medium. 

•  These  considerations  also  apply  for  differentiated  track  access  charges  combined  with 
noise  emission  ceilings  (C1  and  D3).  In  addition,  synergy  effects  could  be  used  as  both 
instruments  require  the  implementation  of  monitoring  systems  to  identify  silent/  noisy 
wagons. Therefore, the administrative costs per individual policy option could be reduced. 
As consequence, this combination has a higher degree of complementarity as "C1 + D2". 

•  In  case  of  a  combination  of  subsidies  for  retrofitting  and  operating  restrictions  (C3  and 
D2), the complementarity would be high as the effectiveness to address hot spots would be 
higher compared to subsidies as single instrument. In addition, negative economic impact 
on  the  rail  sector  caused  by  the  introduction  of  operating  restrictions  would  be 
compensated by the subsidies. Overall, the degree of complementarity of this combination 
can be regarded as high. 

•  For the combination of subsidies for retrofitting and noise emission ceilings (C3 and D3), 
some  complementary  effects  can  be  expected,  in  particular  regarding  the  suitability  for 
foreign  wagons  which  would  be  covered  by  the  ceiling.  Other  positive  effects  deriving 
from the combination of both policy options are more limited than for the combination "C3 
+  D2"  (e.g.  emission  ceilings  have  a  less  direct  impact  on  hot  spots  and  compensate  the 
disadvantage of subsidies in this regard to a lower degree than operating restrictions do). 
Therefore, the overall level of complementarity of this combination is regarded as medium. 

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Table 29: Summary of the possible combinations of the selected policy options  

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Financial 
incentives 

Legal 
measures 

Differentiated track access charges (C1) 

Low 

Med. 

High 

Subsidies for retrofitting (C3) 

Operating restriction for noisy wagons (D2) 

Noise emission ceiling (D3) 

High  Med. 

Low 

As the combined measures are regarded as superior to the single policy options, the detailed 
impact assessment will focus on the two following combinations: 

–  "SOV":  Subsidies  for  retrofitting,  Operating  restrictions  and  Voluntary 

commitment (C3 + D2 + B); 

–  "DEV":  Differentiated  track  access  charges,  Emission  ceiling  and  Voluntary 

commitment (C1 + D3 + B). 

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ANNEX III: IDENTIFICATION OF IMPACTS 

In  accordance  with  the  Commission  guidelines  for  impact  assessment  the  economic, 
environmental and social impacts are systematically compiled in the following tables. 

Table 30: Identified economic impacts 

Impact on 

Description 

Competition in the 
internal market 

Investment cost for the retrofitting programme depending 
mainly on the number of types and number of wagons of each 
type.  

Operating costs and 
conduct of business 

Added wagon maintenance costs. Different wheel and brake 
block wear-rates will generate different maintenance costs per 
wagon-km mainly depending on wagon characteristics, type of 
operation, type of brake blocks. 

Administrative 
costs on businesses 

Added  administrative  costs  for  new  tasks.  Administrative 
costs  will  increase  or  arise  for  some  MS  or  IM  for  the 
implementation of the monitoring system to identify silent and/ 
or  noisy  wagons  (differentiated  track  access  charges,  emission 
ceiling, enforcement of operating restrictions); 
Costs will be incurred to maintain and manage such a system.  

Type of 
assessment 

Quantitative 

Quantitative 

Quantitative 

Public authorities 

Funding for the retrofitting programme by MS to provide the 
necessary financial incentives for RUs and WOs. 

Quantitative 

Public authorities 

Competition in the 
internal market 

Reduced investment for infrastructure-related noise 
abatement programme: Retrofitting could lead to a reduction 
of future noise abatement programmes today financed by public 
authorities and usually implemented by IM. However, the 
reduction is difficult to quantify as the programmes are based on 
political decisions. 

Reduced investment cost for renewal of fleet: The current 
development towards higher performance of freight wagons 
(annual mileage resp. tkm) could be stimulated by differentiated 
track access charges by giving preference to using the available 
silent wagons. This could lead to savings due reduced annual 
investments in new wagons. 

Qualitative 

Qualitative 

Competition in the 
internal market 

Competition  within  the  rail  sector:  Costs  and  subsidies  for 
retrofitting  might  not  be  equally  distributed  among  the  RUs. 
Competitive  advantages/  disadvantages  for  some  market  player 
could be a result. 

Qualitative 

Operating costs and 
conduct of business 

Reduced  maintenance  costs  for  infrastructure:  Retrofitting 
would  lead  to  a  reduction  of  damages  of  rail  caused  by  wheel 
defect. Savings for IM can be expected. 

Qualitative 

Third countries and 
international 
relations 

Influence of restrictions for noisy wagons on non-EU 
countries. The degree of restriction has the potential to affect 
cross-border trade with non-EU countries. 

Qualitative 

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Table 31: Identified environmental impacts 

Impact on 

Description 

Noise emission 

Reduction of sound pressure levels. These positive effects 
derive from the increase of the fraction of low-noise wagons 
respect to the total fleet and from the mileage run by these 
wagons.  

Type of 
assessment 

Quantitative 

Mobility (transport 
modes) and the use 
of energy 

Influence on the modal split between rail and road 
(environmental effects). The possible modal shift from rail to 
road could cause a high increase in transport externalities.  

Qualitative 

Mobility and the 
use of energy 

The likelihood or 
scale of 
environmental risks 

Traction energy saving due to reduced weight of brake 
blocks: Composite brake blocks are lighter than cast iron ones. 
This leads to a reduced net weight of freight wagons resulting in 
savings in energy consumption. 

Quantitative 

Reduced risk of forest fires: Retrofitting reduces the likelihood 
of fire breaking out due to sparks from the block-tyre interface.  

Qualitative 

Impact on 

Description 

Table 32: Identified social impacts 

Public health and 
safety 

Benefits in terms of noise reduction, population affected by 
freight rail noise and consequent health effects: reduction of 
sound pressure levels to which affected population is exposed 
(reduction of affected population by railway noise over 55 dB). 

Type of 
assessment 

Quantitative 

Standards and 
rights related to job 
quality 

Reduction of weight handled by wagon maintenance workers 
due to lighter blocks could lead to improved working conditions 
and reduced risks of health problems.  

Qualitative 

Increased transparency due to publication of data on noise 
exposure. 

Qualitative 

Governance, 
participation, good 
administration, 
access to justice, 
media and ethics 

Public health and 
safety 

Social impact in 3rd countries: Reduction of number of people 
affected by rail noise to be expected in non-EU countries 

Qualitative 

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