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European Railway Agency
ERA recommendation: CR OPE TSI – Annex P
Impact Assessment Report
Reference: Document type: Final report
Version : 1.0
Date : 01/04/2009
Prepared by Reviewed by Approved by
Name Gilles Gardiol Sandra Scheufens Airy Magnien
Position Economic Evaluation Unit Interoperability Unit Head of Economic
Evaluation Unit
Date
&
Signat.
16/07/09
Gilles Gardiol
(signed)
16/07/09
Sandra Scheufens
(signed)
16/07/09
Airy Magnien
(signed)
AMENDMENT RECORD
Version Date Section number
Modification/description Author
0 15/09/08 All Gilles Gardiol
0.1 23/09/08 All Review of the whole document
Gilles Gardiol
0.2 24/09/08 All Review of the whole
document based on comments from Sandra
Scheufens
Gilles Gardiol
0.3 25/09/08 Summary,
2.3, 8.2.2, 9.4, 9.5
Agreed with Sandra
Scheufens, Additional comments from Sandra
Scheufens in 8.2.2, question 4 (GSM-R)
Gilles Gardiol
0.4 30/09/08 Review of sections related to VKM
Ny Tiana Tournier
0.5 01/10/08 Ny Tiana Tournier’s
comments taken into account
Gilles Gardiol
0.6 08/10/08 Review of the whole document
Airy Magnien
0.7 10/10/08 9.2 & 10.5 ERA justifications on
changes to CR OPE TSI
Annex P.4 copied in this report
Gilles Gardiol
0.8 30/10/08 All Additional information sent
by CER on 24/10/2008 and comments from Annex P WP
meeting on 29/10/2008 included in this report
Gilles Gardiol
0.9 04/10/08 All Additional information sent by CER on 31/10/2008
Gilles Gardiol & Airy Magnien
1.0 01/04/09 10.6 Result of additional questionnaire
Gilles Gardiol & Airy Magnien
European Railway Agency page 3/45
CR OPE TSI, Annex P - Impact Assessment Report
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Summary
(same text as in the ERA recommendation report \ Section on Impact Assessment)
The CR OPE TSI entered into force on 15 February 2007. Its Annex P on vehicle numbering
system standardised the way to attribute numbering identification. The wagons and coaches
fleet were already mainly standardised through EU27+NO+CH with the application of the
corresponding UIC leaflets. This was not the case for the traction and special vehicles.
3 key questions have been evaluated during the impact assessment:
1) How many vehicles are compliant with Annex P?
2) What is the return of experience on the implementation of the Annex P?
3) What would be the impacts if the current recognition of “institutional RUs”
would be cancelled from mid 2010 instead of 2013?
The basis for the third question is that the numbering process allows the recognition of the
“institutional RUs” from the other keepers (Annex P.4) during a transition period until 2013.
Meantime, the legislation environment has evolved with the new Interoperability Directive
2008/57/EC and the Commission Decision 2007\756\EC on the common specification of the
national vehicle register. Consequently, the Agency is developing a European Centralised
Virtual Vehicle Register (EC VVR), connected with the National Vehicle Register from each
Member State.
It was discovered that the use of the current Annex P could lead to misuse of the numbering
system. In addition confusion could occur if the link between numbering system and
“institutional RUs” were maintained (section 3.6 of the ERA recommendation report).
Therefore it was proposed to evaluate the impact of abandoning the recognition of
institutional RUs from mid 2010. Mid 2010 was proposed for the purpose of the impact
assessment as the estimated date for the entering into force of the revision of the Annex P.
A questionnaire was sent to the Network of NSAs on 10 March 2008 to assess the 3 key
questions above. The Agency received 11 answers which have been an input to update
Annex P.
The impacts on institutional RUs (question 3) were also discussed with CER representatives.
According to a first variant of the project scenario, CER claimed that the migration
period could cost 24 Million € to update the IT systems before mid 2011 for the 15
concerned RUs and therefore shall last until 2013. ERA noticed that an overestimate
could have been introduced with a factor 3 in the CER calculations.
European Railway Agency page 4/45
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Another variant of project scenario indicated that without speeding up the IT update
for mid 2011, the cost impacts could occur in some invoices sent the freight
customers: 8 M€ between mid 2010 and mid 2011 for the 15 concerned RUs and then a
decreased cost impact until 2013 along with the scheduled introduction of the IT
updates.
Nevertheless, no convincing justifications have been provided to support the recognition of
institutional RUs in the Annex P.4 up to end 2013. Too many uncertainties remained by the
end of October 2008 to perform a credible, fully quantified impact assessment. Several
fundamental ERA requests for clarification were unanswered by CER; the absence of reliable
information on software change nature and scheduling makes the analysis irrelevant.
European Railway Agency page 5/45
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Contents
1. INTRODUCTION ............................................................................................................................................ 7
2. REFERENCE, TERMS AND ABBREVIATIONS .................................................................................................. 8
2.1 Reference ........................................................................................................................................... 8
2.2 Units .................................................................................................................................................. 8
2.3 Definitions and abbreviations ........................................................................................................ 8
3. HISTORY ...................................................................................................................................................... 11
3.1 Previous impact assessment studies ........................................................................................... 11
4. METHODOLOGY ......................................................................................................................................... 13
4.1 Principles ........................................................................................................................................ 13
4.2 Methodology implementation ..................................................................................................... 13
4.3 Return of Experience ..................................................................................................................... 14
5. SUBSYSTEM SCOPE & DESCRIPTION ........................................................................................................... 16
5.1 Economic assessment scope ......................................................................................................... 16
6. SCENARII ..................................................................................................................................................... 17
6.1 Reference Scenario ......................................................................................................................... 17
6.2 Project Scenarii ............................................................................................................................... 17
7. REFERENCE SITUATION .......................................................................................................................... 19
7.1 List of questions to assess the reference situation ..................................................................... 19
7.2 Findings .......................................................................................................................................... 20
8. PROJECT SCENARIO .................................................................................................................................... 24
8.1 List of questions for assessing the project scenario .................................................................. 24
8.2 Justifications for a change in annex P.4 ....................................................................................... 25
8.3 Findings based on NSAs answers ............................................................................................... 26
8.4 Findings based on CER answers ................................................................................................. 26
8.5 Conclusions .................................................................................................................................... 33
9. MONITORING AND EX-POST EVALUATION ................................................................................................ 34
10. ANNEXES .................................................................................................................................................... 35
10.1 How many vehicles are compliant with Annex P? ............................................................... 37
10.2 DB IT systems Diagram ............................................................................................................ 38
European Railway Agency page 6/45
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10.3 Table on REMAINING IT APPLICATION TO BE UPDATED: DB AG ............................. 39
10.4 Table on REMAINING IT APPLICATION TO BE UPDATED: SNCF ............................... 39
10.5 ERA recommendation report on CR OPE TSI – ANNEX P - section 3.6 ............................ 42
10.6 Additional questionnaire and results 2009 – 01/04/2009 ...................................................... 44
European Railway Agency page 7/45
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1. INTRODUCTION
This report constitutes the annex 1 of the ERA report on the revision of the CR OPE TSI -
Annex P.
European Railway Agency page 8/45
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2. REFERENCE, TERMS AND ABBREVIATIONS
2.1 Reference
The documents listed below are referred to by numbers in round brackets, e.g. (5). Footnotes
use letters, such as: (a).
1. ERA Methodology Guidelines for Economic Evaluation, 12 June 2007
[ERA_EE_004063]
2. ERA questionnaire on Annex P, 10 March 2008 [ERA-007411-EN]
3. ERA Report on the revision of the Annex P, 5 November 2008 [version 1.4]
4. Buchanan Report (VIRS Study for DGTREN), Year 2003
5. Telematic Applications for Freight subsystem TSI (Commission regulation (EC)
No 62/2006)
Quotations from the above are in italics.
2.2 Units
International units and metric system have been used. Kilometres per hour are km/h, never
kph.
For thousands, millions and billions (= thousands of millions), the letters k, M and G are
prefixed; for instance : 1 M€ = one million Euros.
For numbers, the decimal separator is a dot “.” ; thousands are separated by spaces “ “
(neither “,” nor “.”).
2.3 Definitions and abbreviations
Term or abbreviation Definition
ADIF Spanish infrastructure manager
CBA Cost-Benefit Analysis
CER Community of European Railways
CH Switzerland
CIS Commonwealth of Independent States
European Railway Agency page 9/45
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Term or abbreviation Definition
CR OPE TSI Conventional Traffic and Operation Management TSI
DB Deutsch Bahn (Germany)
EC European Community
EC VVR European Centralised Virtual Vehicle Register
EE ERA Economic Evaluation Unit
ESG Economic Survey Group. The group has been set up by ERA and is
managed by its Economic Evaluation Unit. ESG is considering the
impact assessment work undertaken for the different
recommendations of ERA from the point of view of consistency and
correctness of methodology.
EU European Union
EVN European Vehicle Number
GSM-R GSM for Railways
HS OPE TSI High Speed Traffic and Operation Management TSI
IA Impact assessment
IM Infrastructure Manager (as defined in Directive 2001/14/EC)
IT Information technology
n.a Not applicable
NO Norway
NSA National Safety Authority
NVR National Vehicle Register
PC Personal Computer
RU Railway Undertaking (as defined in Directive 2001/14/EC)
SNCF Société Nationale des Chemins de fer (France)
TAF TSI Telematic Applications for Freight subsystem TSI
TSI Technical Specification for Interoperability
UIC International Union of Railways
European Railway Agency page 10/45
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Term or abbreviation Definition
VIRS Vehicle Identification and Registration Study
VKM Vehicle Keeper Making
European Railway Agency page 11/45
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3. HISTORY
3.1 Previous impact assessment studies
3.1.1.1 Buchanan Report (VIRS Study) (Client: DGTREN)
3.1.1.2 The VIRS study has evaluated in 2003 the different options to harmonise the
railway numbering system.
3.1.1.3 This study provided an overview of the numbering systems in practice in the
different EU Member States and neighbouring countries:
Source: Table 2.1, “Vehicle Identification Registration System” study for DGTREN (2003).
State Numbering System
Locomotives Multiple Units Hauled
Passenger
Vehicles
Hauled Freight
Vehicles
Belgium Semi-structured 4
digit
Semi-struct 4 digit
(DMU)/
unstructured 3 digit
(EMU)
UIC 438-1 UIC 438-2
Denmark Various1 Various Various Various
Germany Various2 Various2 Various2 Various2
Spain Structured: 3+3+1
digit
Structured: 3+3+1
digit UIC 438-1 UIC 438-2
France Semi-struct, 6 digit Struct: 1 letter + 2 to
5 digit UIC 438-1 UIC 438-2
Greece UIC 438-3³ Semi-struct 3 digit UIC 438-1 UIC 438-2
Ireland Unstructured: 3 digit Unstructured: 4 digit Unstructured: 4
digit
Unstructured: 5
or 6 digit
Italy Various struct
alphanumeric4
Various struct
alphanumeric4 Various Various
Luxembourg Semi-struct 3 to 4
digit Semi-struct 4 digit UIC 438-1 UIC 438-2
The Netherlands Semi-struct 3 to 4
digit
Semi-struct 3 to 4
digit UIC 438-1 UIC 438-2
Austria Structured: 4+3+1
digit
Structured: 4+3+1
digit UIC 438-1 UIC 438-2
Portugal Semi-struct 4 digit Semi-struct 4 digit UIC 438-1 UIC 438-2
Finland Semi-struct 2 to 4
digit Unstructured: 4 digit
Unstructured: 5
digit
5+1 digit/2 letter
+ 6+1 digit
Sweden Various5 Various Various UIC 438-2
European Railway Agency page 12/45
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State Numbering System
Locomotives Multiple Units Hauled
Passenger
Vehicles
Hauled Freight
Vehicles
United Kingdom
(Great Britain) Structured: 2+3 digit Structured: 3+3 digit
Unstructured: 4
to 6 digit
Unstructured/
Semi-struct: 6
digit
United Kingdom
(N. Ireland) Unstructured: 3 digit Unstructured: 4 digit
Unstructured: 2
or 3 digit n/a
Czech Republic UIC 438-3 UIC 438-3 UIC 438-1 UIC 438-2
Estonia Various Various Various Various
Latvia SZD6 SZD7 SZD SZD
Lithuania SZD6 SZD7 SZD SZD
Hungary
Struct: 1 letter + 4+3
digit/3 alphanumeric
+ 3 to 4 digit
UIC 438-3/3 or 4
letter + 3 digit UIC 438-1 UIC 438-2
Poland Structured: 2 letter + 3
digit + 3 digit
Structured: 2 letter +
2 digit + 4 digit UIC 438-1 UIC 438-2
Slovakia UIC 438-3 UIC 438-3 UIC 438-1 UIC 438-2
Slovenia 3+3 digit 3+3 digit UIC 438-1 UIC 438-2
Switzerland Various8 Various Various8 UIC 438-2
Norway Structured: 2 letters +
3 to 4 digits
Structured: 2 + 3
digit UIC 438-2
Bulgaria 2+3 digit 2+3 digit UIC 438-1 UIC 438-2
Romania 2+4+1 digit 2+4+1 digit UIC 438-1 UIC 438-2
CIS SZD6 SZD7 SZD SZD
Notes: 1. DSB use a structured 2 letter + 3 or 4 digit alpha-numeric system; other railways also use alpha-numeric
systems.
2. DBAG use UIC System (438-1, 438-2 and 438-3).
3. Renumbering from 1 letter + 3 digit system has just commenced.
4. For locomotives, FS use 1 letter + 3 or 4 digits + 3 digits; for multiple units they use 2 or 3 letters + 3 + 4 digits.
5. SJ constituents use structured 2 letter/3 alpha-numeric/3 letter 3 digit + 3 or 4 digit system.
6. Structured: 1 digit + 1 to 3 alphanumeric + 1 to 2 digit + 1 alphanumeric
7. Structured: 2 alphanumeric + 1 to 2 digit + 1 to 2 alphanumeric.
8. SBB are moving to UIC 438-3 for locomotives and use 438-3 for hauled passenger vehicles, as do BLS
3.1.1.4 The result of the study was to use the UIC leaflets as the main basis for the
specification of the Annex P of CR OPE TSI.
European Railway Agency page 13/45
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4. METHODOLOGY
4.1 Principles
4.1.1.1 The main guidelines for impact assessment come from the “General Economic
Guidelines” drafted by ERA/EE and approved by the RISC committee.
4.2 Methodology implementation
4.2.1.1 The methodology was implemented through a questionnaire sent on 10 March
2008 to the Network of NSAs:
to assess the situation of the current implementation of the Annex P (CR OPE
TSI)
to evaluate the impacts of changes introduced during the revision process of
the Annex P.
4.2.1.2 Based on the 11 answers received by the Agency, it was possible to determine the
issues and the stakeholders concerned. The following NSAs have answered:
Note the NSA UK provided its answer on the 29 October 2008.
European Railway Agency page 14/45
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4.2.1.3 It was identified that the main potential cost issue would be for CER members
the cancellation of institutional RU recognition through the EVN before 2013.
This has resulted in the following questions addressed to CER:
a. What is the impact if, after a transition period of 2 years (i.e. until mid 2010),
the CR and HS OPE TSIs mandate to keep a unique European Vehicle
Number (EVN) during its whole lifetime (except when there is a major
technical modification on the wagon, leading to a new authorisation for
putting into service)?
b. If the impact in a) is not acceptable for CER, what would be the adequate
transitional period?
4.2.1.4 For questions a) and b), it was asked to provide the relevant detailed
justifications, and to differentiate the case of new wagons (to be registered) from
existing wagons (with an existing vehicle number registered / not registered in the
NVR).
4.2.1.5 Other basic questions to analyse the impacts are:
- What kind of changes is required from IT point of view? What are the changes
introduced to establish a link between the current IT system and a VKM
database?
- What kind of IT configuration is used? (e.g. IT system installed on each PC
how many PCs, or: PC is only an interface with a server or web-based
application, ...)
- What is the frequency of updates of these IT systems? Taking into account
debugging, errors corrections, regular updates, ...
- What kind of training shall be put in place? (explain the real changes from
operational point of view)
- Why do you think that this IT update should require specific training
compared to other IT updates?
4.2.1.6 It was agreed that DB and SNCF would be the main respondents to the questions
sent to CER. However, an official statement from CER was considered necessary,
as usual.
4.3 Return of Experience
4.3.1.1 No changes had to be made to the general methodology. A few practical
problems that have been identified, and need to be taken care of in the future,
are:
European Railway Agency page 15/45
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4.3.1.2 The questionnaire was sent to the Network of NSAs who were in charge to liaise
with the railway stakeholders at national level to obtain the answers. It was
proved that the level of details given by the NSAs was not sufficient when there
were strong concerns from the RUs. Therefore ad hoc meetings have been carried
out between ERA and CER to attempt to get the relevant details;
4.3.1.3 Nevertheless, CER members were not able to justify their answers to the
questions drafted for the impact assessment (section 4.2.13 4.2.15). The reasons
are not clear to the Agency; preparation time (about one year) and clarity of
questions seem to have been adequate.
4.3.1.4 As a result, the process to obtain answers should be amended in such way:
due to the fact that NSAs have difficulties to liaise with the railway sector when it has
strong concern but expressed with too few justifications
due to the fact that the railway sector needs a long time to provide their detailed
justifications
it is proposed to identify in the forthcoming ERA questionnaires the issues to be
answered by the most appropriate stakeholder(s).
Note that this process is being used for the CR Locomotives and Passenger Rolling Stock TSI.
European Railway Agency page 16/45
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5. SUBSYSTEM SCOPE & DESCRIPTION
5.1 Economic assessment scope
5.1.1.1 The scope is related to
- new railway vehicles to be put into service according to the Interoperability
Directive
- existing railway vehicles requiring a new authorisation to be put into service
according to the Interoperability Directive
European Railway Agency page 17/45
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6. SCENARII
6.1 Reference Scenario
6.1.1 The reference scenario is the implementation of the current CR OPE TSI
– Annex P
6.1.1.1 The institutional RUs are in the process to update their IT applications before end
of 2013. The major change introduced by the Annex P currently in force is the
giving up, by the end of 2013, of the distinction between institutional RUsa and
other keepers in Annex P.4.
6.1.1.2 If the transition period is not shortened to mid 2010, the costs and/or workload
burden for re-registration will continue to affect the NSAs until 2013.
6.1.1.3 About the necessity of moving away from the reference scenario, see section
3.6 of the Annex P report.
6.2 Project Scenarii
6.2.1 The project scenario is the implementation of the revision of the CR
OPE TSI – Annex P.
6.2.1.1 The basis is the changes to Annex P introduced during the revision process and
discussed in the WP. There are two proposed variants, described hereafter.
6.2.1.2 The main change introduced by the revision of the Annex P is to abandon as soon
as possible the distinction between institutional RUs and other keepers. It will no
longer be possible to identify the institutional RU using the first four digits of the
vehicle number.
6.2.1.3 In practice, the earliest possible date for abolishing this distinction is mid to end
of 2010. This is our working hypothesis.
6.2.2 Project scenario (variant 1): Speeding up the IT migration
6.2.2.1 This scenario evaluates the potential cost of speeding up the migration of the IT
applications to match the revision of the Annex P: IT systems should be updated
by mid 2010 instead of end of 2013.
a “institutional RUs” is the wording used by Annex P; it designates the “historical” or
“incumbent” railway undertakings.
European Railway Agency page 18/45
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6.2.2.2 This means concretely that institutional RUs have to update their IT applications
by introducing a table providing the link between a vehicle number and a keeper
in order manage the vehicle fleet, and then send the invoices to the right
addressee.
6.2.2.3 In the reference scenario, these updates are already foreseen before the end of
2013. In the project scenario, we shall evaluate the cost impact to make migration
end earlier, i.e. mid 2010.
6.2.2.4 A shorter transition period would have reduced the cost and/or workload burden
for re-registration which affect the NSAs. However, this effect is not quantified in
our impact assessment.
6.2.3 Project scenario (variant 2): Without speeding up the IT migration,
impact on invoices with possible errors
6.2.3.1 The other project scenario evaluates the impacts on RUs of the revised Annex P
without changing the pace of IT migration.
6.2.3.2 This would result in potential errors in invoices when a train would consist of at
least one new wagon (or one existing wagon subject to an upgrade requiring a
new authorisation of placing into service). The frequency of this occurrence is
deemed to be very low because:
there are currently very few new wagons ordered per year (1% of the fleet, as
an order of magnitude).
there is, up to now, no reliable estimate of the annual number of existing
wagons subject to an upgrade requiring a new authorisation of placing into
service, and therefore requiring a new registration number. A first guess
would be 1 to 4% per year, as an order of magnitude.
only invoices related to international wagons used in single wagon transport
are in the scope of this project scenario.
6.2.3.3 The time & efforts spent to correct the invoices should be analysed in this
scenario. It would also be necessary to know the current number of invoices that
are not processed automatically today, and the number of invoices with errors.
European Railway Agency page 19/45
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7. REFERENCE SITUATION
7.1 List of questions to assess the reference situation
Question 1: How many vehicles are compliant with Annex P?
Question 2: If you had more than 1000 vehicles of one type to register, how have you done it?
Question 3: Have you noticed that vehicle categories are missing?
Question 3-1: If yes, could you give examples?
Question 3-2: how did you manage that?
Question 4: Due to GSM-R, the Annex P prescribes that inside each group of vehicles
(coaches, wagons, tractive stock and special vehicles) each 7-digit-number shall be unique.
Did this constraint have any impact on the registration?
Question 4-1: if yes, which ones?
Question 5: Have you noticed potential problems to apply the Annex P?
(potential in the sense that they have not yet occurred, but it might be in the future)
Question 6: You may have noticed that there are codes in Annex P.6 and P.7 which you never
used or which you will never use in the future, so you decided to simplify this.
Question 6-1: if yes, provide comments:
Question 7: When registering new tractive stock, do you use the second digit as description
of the type of tractive stock as defined in the table in Annex P.8 ?
Question 7-1: If no, which definition do you apply for the second digit ?
Code General vehicle type National definition
0 Miscellaneous
1 Electric locomotive
2 Diesel locomotive
3 Electric multiple-unit set (high speed) [power car or trailer]
4 Electric multiple-unit set (except high speed) [power car or trailer]
5 Diesel multiple-unit set [power car or trailer]
6 Specialised trailer
7 Electric shunting engine
8 Diesel shunting engine
9 Maintenance vehicle
European Railway Agency page 20/45
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7.2 Findings
7.2.1 How many vehicles are compliant with Annex P?
7.2.1.1 As of 1 January 2008, on the basis of 8 Member States (Austria, Belgium, Czech
Republic, Finland, France, Germany, Latvia, Portugal, Slovenia, Spain) who have
answered, 26 394 vehicles have been registered according to the new regime, i.e.
CR OPE TSI Annex P.
7.2.1.2 Nearly all these countries have reported good progress toward the registration
numbering in force with the CR OPE TSI.
7.2.1.3 Latvia has reported no progress: this has to be understood from the specific
situation of Baltic countries. This is due to the fact that wagons coming from third
countries on track systems other than 1435mm gauge are listed in other registers
and have a different numbering system. For these cases, the CR OPE TSI required
temporary 12-digit-numbers; this is abandoned due to Art. 32 of 2008/57/EC.
7.2.1.4 The answers to the question 1 “How many vehicles are compliant with Annex
P?” are detailed in the Annex 10.1.
7.2.2 Return of experience on Annex P (CR OPE TSI, 2006)
Question 2: Did you have more than 1000 vehicles of one type to register?
Total answers 11 Relative shares
Yes 3 27%
Did not happen 7 64%
n.a 1 9%
When the answer is “yes”, the subsequent question is “How have you done it?”. Although
the NSA should have contacted UIC to get the relevant numbering, in practice, the NSAs
which experienced a registration of more than 1000 vehicles sent a request to the NSA France
as reported to the RISC committee for the transition period of Annex P.9.
This situation was clarified in 2008 and now ERA recommends, with support from the
members of the WP, to transfer the Annexes P.9 – P.13 into Technical Documents, maintained
by ERA according to Art. 5, clause 8 of the Interoperability Directive (1). It is recommended
to follow the same rules and procedures as already applied on Annex P.1 of the TSI OPE (2),
(3) - the requirements and principles on the Vehicle keeper Marking (VKM) (ERA
recommendation, section 1.3.3).
European Railway Agency page 21/45
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Question 3: Have you noticed that vehicle categories are missing?
Total answers 11 Relative shares
Yes 4 36%
No 6 55%
n.a 1 9%
Question 3-1: If yes, could you give
examples?
Question 3-2: how did you manage that?
There was missing code for freight wagon
“Falls”
EPSF was contacted
We needed a number for the generator
vehicles. It’s made for chassis and body of
passenger coaches. No suitable digits was
found for that.
We used following identifications:
55109437001-4 where
5 = annex p.7 Vehicles for domestic traffic
5 = annex p.7 Vehicles special numbering for
technical characteristics
10 = annex p.4 FIN
9 = annex p.10 Vehicles of special design and
vans (digit 5)
4 = annex p.10 Side-corridor luggage vans,
with or without compartment
under customs seal (digit 6)
3 = annex p.10 121 to 140 km/h (digit 7)
7 = annex p.10 1 500 V~ + 1 500 V= (digit 8)
001 = Serial number
4 = check digit
That is not luggage van.
Tram – train.
Bi mode multiple units Registered then under the EMU category
For one type there are : EMU 26500
and the tractive unit code number 5 to 11 is
defined according to former historic RU and
there is an overlap of codification in very few
Trailer units with code 96 (for the first two
numbers) and EMU with 94.
European Railway Agency page 22/45
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cases such as : trailer of 6400 which are
numbered from 26400 to 26550 (2 means
trailer in SNCF word)
Container freight wagon with max speed >
140 km/h
EPSF was contacted
Driving trailer of double-stack passenger
coach
EPSF was contacted
Question 4: Due to GSM-R, the Annex P prescribes that inside each group of vehicles
(coaches, wagons, tractive stock and special vehicles) each 7-digit-number shall be unique.
Did this constraint have any impact on the registration?
Total answers 11 Relative shares
Yes 3 27%
No 5 45%
No answer 2 18%
n.a 1 9%
Question 4-1: if yes, which ones?
In these cases a new code was necessary; the process described in question 3.1 was applied.
This is necessary to avoid the re-use of the 7 digits – which is not in line with the requirement
of 12 digits available to create the EVN. In addition, the restriction was introduced to GSM-R.
After amendments in the GSM-R specifications, for wagons and locomotives the restriction is
not necessary anymore.
Question 5: Have you noticed potential problems to apply the Annex P?
(potential in the sense that they have not yet occurred, but it might be in the future)
Generally, no potential problems have been reported. The management of the Annex P,
especially the technical annexes, was clarified during the revision process.
It was mentioned that the use of Annex P.9 is problematical, and anyway too complicated.
Potential problems also might arise from the general remarks, section 2: Exemptions are
foreseen which may lead to discussions. How to handle the “temporary number” for these
vehicles?
European Railway Agency page 23/45
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Question 6: Did you simplify codes in Annex P.6 and P.7?
Total answers 11 Relative shares
Yes 1 9%
No 9 82%
No answer 0 0%
n.a 1 9%
Based on the comments received, the annex P.6 has been simplified in France giving up the
distinction between RIV and non-RIV companies. The French version has been discussed in
the WP.
Question 7: When registering new tractive stock, do you use the second digit as description
of the type of tractive stock as defined in the table in Annex P.8?
Total answers 11 Relative shares
Yes 8 73%
No 2 18%
No answer 0 0%
n.a 1 9%
Question 7-1: If no, which definition do you apply for the second digit ?
Code General vehicle type National definition for
Portugal
National definition for Spain
0 Miscellaneous 0 for all tractive
rolling stock
2
1 Electric locomotive 3
2 Diesel locomotive 1
3 Electric multiple-unit set (high
speed) [power car or trailer]
4
4 Electric multiple-unit set (except
high speed) [power car or
trailer]
5
5 Diesel multiple-unit set [power
car or trailer]
8
6 Specialised trailer 2 (as electric locomotive)
7 Electric shunting engine 3 (as diesel locomotive)
8 Diesel shunting engine Tractive units for infrastructure works: 3
Track, track car and trailer (ADIF): 2
Track, track car and trailer (private keeper): 4
Loading / unloading machine and repair train: 1
Track machine: 9
Rail / Road Machine: 7
9 Maintenance vehicle 9 for special
vehicles
European Railway Agency page 24/45
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8. PROJECT SCENARIO
8.1 List of questions for assessing the project scenario
Subject: Would there be an impact if “institutional RUs” cannot be identified as
owner/keeper of a coach or a wagon? (Appendixes P.4, P.6 and P.7)
According to the Annex P in force, certain numbers in the 12-digit code are reserved for some
railway actors as listed in Annex P.4 to identify owner/keeper of a coach or a wagon
It is important to understand with the following questions the use of the identification and
the impact if it does not exist anymore.
Question 8: What is the actual use of this recognition?
Question 9: What will be the impact (on IT systems, on staff, on operation) (if any) if this
recognition no longer exists?
Template for the answer:
Vehicle type Specify the
fleet size (if
you think it
is relevant)
Change to IT systems:
Define which process is
concerned (maintenance,
shunting yard, train
preparation, allocation of
vehicles in the trains,
operational changes in
train composition or in
vehicles rosters, billing,
etc.)
Define the level of
the impact
(scale: number of
man-days to update
the IT process
Low: 60 man-days
Medium: 200 man-
days
High:1000 man-days)
Change to
staff
knowledge/tr
aining
Level of impact for
staff: special
training in addition
to normal training?
Yes/No (if yes,
number of hours,
...)
Wagons
Coaches
Locomotives
E-DMUs
Others
Question 9-1: For medium/high impact, provide detailed justifications (it could be attached
documents to your answer): Do you have other comments on the revision of the Annex P?
Question 10: Do you have other comments on the revision of the Annex P?
European Railway Agency page 25/45
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8.2 Justifications for a change in annex P.4
8.2.1 The ERA recommendation report indicates in its section 3.6 examples of
application of the current Annex P.4 which will lead to an EVN where it
is not possible to identify anymore the institutional RUs. This section is
copied in Annex 10.5 of the impact assessment report.
8.2.2 The two examples given in annex 10.5 show there are a number of cases
where the Annex P in force does not allow the RUs to freely choose the
country where to register railway vehicles.
8.2.3 There are other concrete cases of misuse of the Annex P which lead to
registration by the NSAs not in line with the Annex P:
8.2.3.1 Case study
Requests received from NSAs registering vehicles show furthermore that the processes of
changing the EVN when selling or hiring a vehicle lead to non-consistent information in
different registers:
A keeper from Member State A (keeper “MS A”) rents for 6 months 10 wagons to a keeper in
Member State B (keeper “MS B”). After 6 months, keeper “MS B” will give back the 10
wagons to the keeper “MS A”.
Since several years, the process is the following:
1 –the keeper « MS A » changes the registration when the wagons are rented for some
months in MS B they get a new EVN in MS B. (The registration in MS A is not always
modified due to a lack of information.)
2 – The wagons are operated for 6 months in MS B.
3 –When the wagons return to country A, the wagons are painted again with their former
EVN.
4 – Note that the keeper in MS A is still responsible for the maintenance during the renting to
the keeper in MS B.
As a consequence, there are invalid registration numbers in the Member State A during the
period when the wagons are rented in the Member State B.
8.2.3.2 Several keepers informed that this situation has occurred several times.
European Railway Agency page 26/45
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8.2.3.3 This case study indicates that as long as the EVN is not considered unique and
disconnected from the recognition of keepers, there will be temptation to find
ways to register incorrectly rolling stock.
8.2.4 Explicit identification of institutional RUs, as is the case with the
current annex P4, may open the door to discriminations. However, it
could not be established that this identification has been used by the
institutional RUs to put other keepers at some disadvantage.
8.2.5 The main rationale for changing Annex P4 is therefore the avoidance of
confusions or misuses mentioned above. Therefore, it was proposed to
shorten the migration period toward a new Annex P4 from 2013 to mid
2010 and evaluate the impacts.
8.3 Findings based on NSAs answers
8.3.1 Summary from questionnaire answers
8.3.1.1 Question 8: What is the actual use of this recognition?
Total answers 11 Relative shares
None 3 27%
None for NSA, needs of institutional RUs 5 45%
No clear answer 2 18%
No answer 0 0%
n.a 1 9%
8.3.1.2 The NSAs which have mentioned that institutional RUs could be impacted, if
Annex P.4 is amended as proposed by ERA, have not been in a position to give
detailed impacts.
8.3.1.3 It was foreseen that NSAs could have difficulties to quantify this impact,
therefore CER was asked in parallel to provide the relevant details.
8.4 Findings based on CER answers
8.4.1 Reminder
8.4.1.1 The answers from the NSAs having been not enough detailed to justify to
maintain the status quo on Annex P4, it was asked to CER to provide the relevant
justifications. Note that CER members were asked at the beginning of the process
European Railway Agency page 27/45
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to provide the relevant details to the NSAs to justify their position, i.e. November
2007.
8.4.2 Answers from CER members (DB and SNCF)
8.4.2.1 ERA proposed to hold a meeting with CER representatives from the WP Annex P.
There was a first meeting with SNCF on 4 July 2008 and a second meeting with
DB on 15 July 2008.
8.4.2.2 The questions detailed in section 4.2.1.3 were agreed during these meetings and
should have been answered before 7 September 2008. CER final answers were
sent on 24 and 31/10/2008.
8.4.2.3 DB and SNCF indicated that there is a missing masterpiece to be implemented
before the removal of institutional RUs from Annex P.4: there is today no
“database” having at European level a comprehensive list of all keepers with
their attached railway rolling stock fleet (called hereafter “VKM database”).
8.4.2.4 Therefore institutional RUs have started to create their own VKM database to
manage that, having in mind that this information is only partial and valid for
their own RU.
8.4.2.5 The institutional RUs are currently under a process of making the relationship
between their IT system and this “VKM database”. They request a transition
period up to 2013 to update their whole IT system.
8.4.2.5.1 CER requested a transition period until the end of 2013 with the following
justifications.
8.4.3 Project scenario (variant 1): Impact with a speeding up of the IT
migration
The following is the (we hope) truthful transcription of CER estimates:
“Qualitative justifications are stated during the meetings between ERA, SNCF and Railion
beginning of July 2008: codes are still used by many “historical” companies handling 700 000
IT systems for shunting, operation, accounting.
The economic justifications are not easy to assess.
First of all, an update for mid 2010 of the numerous concerned IT systems concerned in Europe,
linked together and used daily in operation, is clearly impossible. The date taken for the
economic evaluation is mid 2011, that seems also very near and not compliant . But try to have
an assessment on this basis of 2011.
The question is to know global estimation has been done by CER and sent to ERA on 24
October 2008:
European Railway Agency page 28/45
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- CER consider 10 applications per RU remaining to be updated until the end of 2013 (see
Annex 10.3 and 10.4b), either directly, or due to the flow exchange;
- Reference scenario (without revision of the Annex P): CER consider 100 days work for coding
and unit test, that represents the costs that RUs have to bear in all cases, wathever the date of
the update;
- Project scenario (with the revision of the Annex P): if the update is not included with other
evolutions and is sped up, all other costs (functional requirements, integrations tests, receipt
test, production integration, deployment, etc.) represent the extra costs of an earlier
implementation. Classically, these costs represent 3 times the coding and unit test workload, so
300 days per application, 3000 days per concerned RU, that means, with an average cost of
800 €/day, 2.400.000 € per concerned RU;
- As a consequence: the cost changes between the 2 scenarios are 200 days per application, 2000
days per concerned RU, that means, with an average cost of 800 €/day, 1.600.000 € per
concerned RU
- some RUs have already achieved their update. CER consider 15 RUs (in EU and OTIF) who
still have to update their IT systems. The following RUs have been mentioned by the CER
representative in the Annex P working party, pending confirmation that this is based on a
CER survey: B-Cargo, BDZ, CD, CFR, CH, CFL, MAV, PKP, RCA, SZ, Railion, SJ, SNCF,
Trenitalia, ZSSK. The following OTIF members could also be impacted: CFF, HSH, HZ, JZ,
MZ, NSB, TCDD, ZBH, ZRS.
- The total extra-costs represent so 24 millions euros for the 15 RUs from the European Union.
The assessment for the extra-costs is at least 24 millions euros, that is an unbearable burden
for railway sector only to anticipate mid 2011 an evolution that will in all cases be
implemented end 2013. On another hand, the benefits of an earlier update are not clear.
To be complete, other costs have to be added: IT dysfunctions will inevitably occur caused by the
excessively short time to update, even if finished in 2011, with the linked costs of non quality for
the clients, costs of additional number of employees to manage manually the operation and
accounting system during the repair time, etc.
Therefore, the deadline of end 2013 is for CER the best date to ensure an efficient (for the quality
of IT work and for the clients) transition to the target table in Annex P.6.”
8.4.3.1 ERA comments on the CER justifications:
8.4.3.1.1 Impact of the Annex P revision = 200 man-days without sufficient justification
on the type of coding, the work to be performed, ..., this information cannot be
used in the impact assessment.
8.4.3.1.2 The list of impacted RUs shows that freight operators of different “sizes” are in
the scope of this project scenario. In the impact assessment done for the TAF TSI,
the IT costs were differentiated for different sizes of freight operators. The same
principle should apply also here. The upper level of IT costs might be retained for
b Annex 10.2 gives an example of the full IT applications system for a RU
European Railway Agency page 29/45
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SNCF, Railion, and Trenitalia for instance, but they should not be attributed to
small operators (“small” in terms of freight traffic volume).
8.4.3.1.3 We understand that the added costs of faster migration result from reduced
likelihood to bundle the changes following Annex P with other software
maintenance tasks. This seems to be a high estimate of the additional costs.
8.4.3.1.4 Supposing that the added man.days are in the quantity proposed by CER: CER
indicated on 29/10/2008 that this IT work is outsourced; it cannot be managed by
internal IT staff. Average unit cost for IT staff under these conditions is estimated
by CER at 800€/man.day this seems to be overestimated. ERA estimate for
external IT staff cost supplied locally (2008 conditions) is 400€/man.day at most
for developers, and the same rate may even apply to analysts/developers
(depending on the complexity of the project). The French NSA indicated on
29/10/2008 that the IT costs for different kinds of external IT staff (programmer,
analyst-programmer, project manager) could vary from 450 to 580€/day.
8.4.3.1.5 ERA did not receive any planning of SNCF and DB IT application updates. CER
informed ERA on 29/10/2008 that this information is not available (even if it is
mentioned in section 8.4.2.7 that it exists). This information is fundamental to
assess the number of remaining IT applications to be updated before 2011.
8.4.3.1.6 CER estimated that 15 RUs still request to update, in average, 10 IT applications
per RU until 2013. This number is taken here into account, pending confirmation
by CER that this is the result of a survey.
8.4.3.1.7 Overall, we could say that CER overestimated the costs by a factor 1.5 (hourly
rates), times 2 (making accelerated migration an independent project), so a factor
3 overestimation is not unlikely.
European Railway Agency page 30/45
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8.4.4 Project scenario (variant 2): Updated Annex P without speeding up the
IT migration; impact on invoices with possible errors
8.4.4.1 CER has sent on 31/10/2008 the following justifications:
“Additional costs to manage accounting corrections if IT systems are not adapted. Note that the
corrections of faulty calculations have to be made manually since the first day of the non-recognition of
the RU by the number. In the course of time there will be more reclamation because of faulty invoices,
which must be adjusted by an additional number of employees.
The calculation is made in following table:
If the sector does not have a transitional period,
the costs will increase each year :
No transitional period
for one year
Turnover 2006 of all European RUs 17 366 M€ (1)
# 50% single wagon transport 8 863 M€
Turnover for the 60% of the concerned wagons that are used in international
transport
5 209.8 M€
Concerned turnover when each year 5% of the wagons are renewed 260.5 M€
Additional number of employees to manage the accounting corrections (2) 189
Costs for the additional number of employees if each employee costs 40 k€ 7.6 M€
(1) The freight turnover is currently being checked by ERA.
(2) One employee adjusted an accounting error value of 1 376 667 € in 2007
8.4.4.2 ERA comments on CER justifications:
8.4.4.2.1 If there is no transitional period after mid 2010 and if there is no speeding up of
IT update, the maximum total costs to correct possible errors in invoices
addressed by RUs to freight costumers could be 7.6 M€ between mid 2010 and
mid 2011, globally at EU level. This annual cost should decrease from mid 2011 to
2013 in parallel with the implementation of the regular IT updates.
8.4.4.2.2 It is not clear from the table above if the turnover is related to the RUs from EU27
or if it is strictly related to the 15 RUs mentioned by CER.
8.4.4.2.3 Strictly speaking, the financial cost of delayed invoicing (to the right addressee)
and therefore, delayed payment, should also be included. This would increase
the damage done by a few million Euros.
European Railway Agency page 31/45
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8.4.5 Conclusion
8.4.5.1 Too many uncertainties remained by the end of October 2008 to perform a
credible, fully quantified impact assessment. The absence of reliable information
on software change nature and scheduling makes the analysis irrelevant.
8.4.5.2 Nevertheless, the orders of magnitude suggest that:
Accelerating the migration of IT systems could be about as costly as correcting
invoicing errors, but
It is the biggest risk (late invoicing brings only financial risks; IT update
speedup induces a technological risk).
European Railway Agency page 32/45
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8.4.6 UIP Position
8.4.6.1 UIP has expressed in its email from 11 February 2008 their concerns about the
discrimination introduced by the recognition of institutional RUs:
“The requirement of CER to retain the codes reserved for the old UIC railways as
per P6 of the old Annex P cannot be maintained since it is discriminatory. It also
requires that wagons they hire-in have to change their numbers for no other
reason than to benefit from the privileges agreed between those railways. This
breaks the concept of the unchanging number requirement and raises the spectre
of Cartel operations. The accounting methods need to be changed to conform
with other sector operators.”
8.4.6.2 Although ERA has also asked UIP to provide detailed justification for the real
detrimental effect of this discrimination, there was information to that respect
given by UIP. It is therefore impossible to assess the risk (“spectre”) mentioned
here.
8.4.6.3 Therefore it was not possible to make a quantified impact assessment of the UIP
concern.
8.4.6.4 On 24 October 2008, UIP indicated to ERA that they could agree with the
transition period proposed by CER as long as there are no negative impacts for
the UIP members.
8.4.6.5 As mentioned in the Annex P report (section 3.6), as long as the transition period
is not overcome, the UIP members have to register their fleet in the countries
where their wagons are used in order that these wagons have a registration
number which can be easily recognised by the IT system of the institutional RU.
8.4.6.6 The negative consequence is that a change of registration from one NSA to
another one shall follow the process of new placing into service in order to get a
new registration number. This will be up to the NSAs to decide if they may
accept these wagons without any further technical checks and without any fee for
the registration.
8.4.6.7 Note that if the transition period is not shortened to mid 2010, the costs and/or
workload burden for re-registration affects the NSAs.
European Railway Agency page 33/45
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8.5 Conclusions
8.5.1 The present report indicates in its section 8.2 where the current CR OPE
TSI Annex P could lead to mistakes or confusion if:
8.5.1.1 the recognition of institutional RUs is maintained
8.5.1.2 The keepers continue changing the EVN when they rent their wagons or hire
wagons to or from other keepers.
8.5.2 No convincing justifications have been provided to maintain a
migration period up to end of 2013.
European Railway Agency page 34/45
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9. MONITORING AND EX-POST EVALUATION
Reserved.
European Railway Agency page 35/45
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10. ANNEXES
European Railway Agency page 36/45
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IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1
Annex
IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1
10.1 How many vehicles are compliant with Annex P?
Member State
Share in percentage of fleet compliant to the reference numbering system at 15/02/2007
(entry in force of OPE TSI)
Share in percentage of fleet compliant on 01/01/2008 to the CR OPE TSI Number of new registration since entry into force of the CR OPE TSI on
01/01/2008
Loco-motives
Electric and
Diesel Multiple
Units
Hauled Passenger Vehicles
Hauled Freight
Vehicles
Special vehicles
Locomotives Electric and Diesel Multiple Units
Hauled Passenger Vehicles
Hauled Freight Vehicles Special vehicles Loco-motives
Electric and
Diesel Multiple
Units
Hauled Passenger Vehicles
Hauled
Freight
Vehicles
Special
vehicles
UIC 438-3
UIC 438-3
UIC 438-1
UIC 438-2
UIC 438-4
Relative share
If not 100%,
expected date for
compliance
Relative share
If not 100%, expected date for
compliance
Relative share
If not 100%, expected date for
compliance
Relative share
If not 100%, expected date
for compliance
Relative share
If not 100%, expected date
for compliance
Units Units Units Units Units
Austria ~ 100 % ~ 100 % ~ 100 % ~ 100 % 0% 100% n.a 100% n.a 100% n.a 100% n.a 100% n.a 15 0 0 1509 416
Belgium 0 0 100% 100% 0% 8% 15/02/2013 0% 15/02/2013 100% n.a 100% n.a 0% 15/02/2013 60 0 0 200 2
Czech Republic
0 0 70% 100% 0 4% 2015 7% 2015 73% 2015 100% 0 2020
2 24 40 1047 0
Finland 0 0 0 0 1
0%
New projects
according to OPE TSI
0%
New projects
according to OPE TSI
0%
New projects
according to OPE TSI
5000% New projects according to
OPE TSI 0
New projects according to OPE TSI
0 1 6 45 4
France 0% 0% 100% 100% 0%
100% in database, but not paint on RST
International rolling stock: 2013.
Domestic rolling stock: under
discussion.
100% in database, but not paint on RST
International rolling
stock: 2013. Domestic
rolling stock: under discussion.
100% n.a 100% n.a 0%
International rolling stock:
2013. Domestic
rolling stock: under
discussion.
100 400 0 400 ?
Germany 0 0 90-95 % 95% 0 5-10 % Jan 2009 5-10 % 01/01/2009
90-95 %
Jan 2009 95% Jan 2009 0 2010 1250 400 200 19700 200
Latvia 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Portugal 100% 100% 100% 100% 0% 100% n.a 100% n.a 100% n.a 100% n.a 10% April 2008 14 0 0 125 100
Slovenia 0% 0% 100% 100% 100% 20% 15/02/2013 30% 15/02/2013 100 100 40 15/02/2013 0 0 0 0 0
Spain 100% 100% 100% 100% 0% 100% 100% 100% 100% 0% 2011 12 35 0 52 35
Annex
IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1
10.2 DB IT systems Diagram
Annex
IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1
10.3 Table on REMAINING IT APPLICATION TO BE UPDATED: DB AG
IT application
name
Purpose Foreseen
update
Comments: explain why the transition period
cannot be shortened
PVG record of freight train
composition, including
mobile data seizure
done! Link with a VKM database already integrated!
FpIV record of freight train
composition, including
mobile data seizure
done! Link with a VKM database already integrated!
CDD record of freight train
composition, including
mobile data seizure
done! Link with a VKM database already integrated!
HERMES data exchange for
international traffic
done! Link with a VKM database already integrated!
WIS wagons technical
database maintenance
database for wagons
done! Link with a VKM database already integrated!
LWM fleet management yes! Link with a VKM database until 2014!
LWV fleet management yes! Link with a VKM database until 2014!
FLO fleet management yes! Link with a VKM database until 2014!
ZAB freight accounting
system
yes! Link with a VKM database until 2014!
KUSS freight accounting
system
yes! Link with a VKM database until 2014!
FBR freight accounting
system
yes! Link with a VKM database until 2014!
LPK freight accounting
system
yes! Link with a VKM database until 2014!
LB wagons use reservation yes! Link with a VKM database until 2014!
GWD accounting of rented
wagons
yes! Link with a VKM database until 2014!
WIS accounting for
degradation on wagons
done! Link with a VKM database already integrated!
SAP-ISI accounting for
degradation on wagons
yes! Link with a VKM database until 2014!
10.4 Table on REMAINING IT APPLICATION TO BE UPDATED: SNCF
IT systems for operation, commercial and accountancy purposes
Annex
IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1
IT system Purpose Update foreseen Other comments
NAW All basic information to
operate the wagons in
freight trains: train
composition (technical
details for wagons),
shunting station, <
None Evolution not planned, single
wagon, marshalling yard,
train composition (length,
date of inspection), <
DEF Déplacement Yes Recent IT application
MARS Wagon en séjour Yes (full IT
application to be
redesigned)
DECOMPTE Works with NAW for RU
wagons, commercial
application
End of application :
2011
SESAME Sales and Invoices End of application: ? SESAME is coupled with
BOC (back office client) and
will be fully transferred to
BOC
eLV Electronic « Lettre de
voiture »
Yes
Orpheus IT exchange of transport
contract
Linked with HERMES ?
HERMES Exchange of data for
international traffic, lié
avec Goethe
Yes (evolution
prévue pour Goethe)
Many international IT systems
are linked with HERMES
FLEET Gestion de parc interne
pour livrer les wagons au
client
Yes
ISR International appli,
répond au besoin TAF
TSI. Va s’ouvrir au EF non
historique
Yes
CLICSERVICE Fourni comme service à la
clientèle, suivi
Yes, continuous
update
Annex
IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1
d’acheminement,
INFOService
NORMA Accounting
IT systems for rolling stock management
IT System Purpose Update
foreseen
Other comments
MARGO It manages the
maintenance of wagon
fleets for which SNCF has
a maintenance contract :
SNCF wagon fleet, the
private wagon fleet and
the service wagon fleet
NAW and MARGO are in
constant relation
Yes : 2009
100 000 wagons today
For wagons with country code 87
(France): special tariffs
For wagons from other countries:
problem today to accept them in the
database (only the number can be
filled in, not the technical
characteristics). Therefore in 2009,
MARGO will be opened to accept
foreign wagons (other country code
than 87) with all the technical
characteristics. This will be managed
by a direct link between the wagon
number and the keeper name.
ORESTE Wheelset database Yes
SCRIBX Global view on all wagon
technical characteristics
Yes Linked with NAW
TANDEM Incident during operation
GMAO Transversal IT system for
follow-up of maintenance
and invoice management
to the keeper
2011 :
coaches and
TGV
Wagons will be taken into account
later
DARWIN Wagon without « lettre de
voitures » shall come back
to the shunting station
foreseen by the Keeper
Production:
December
2008
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10.5 ERA recommendation report on CR OPE TSI – ANNEX P - section 3.6
10.5.1.1 Extract from the ERA recommendation report version 1.4 on CR OPE TSI – Annex
P
“3.6 Connection between Annex P.4 and Annex P.6 /P.7 – an explanation
In the following the background of CER’s request is explained.
Before the entry into force of the first railway package, the “governmental” railway
companies took care of infrastructure and traffic; the railway company managed the
whole railway system. This included the decision if a vehicle is put into service on this
company’s network. Between the governmental railway companies and some few
private Railway Undertakings existed an agreement concerning the use and billing of
the wagons and coaches. These railway companies had the different company codes
(e.g. 87 for SNCF, 80 for DB). Only very few “private” RUs had an own code. If not, the
“private” RU’s wagons were registered with the code of the company authorising the
placing into service on its network.
To distinguish between the railway company’s fleet and the “private RU’s” fleet, the
first two digits were used:
The company used the digits for “RIV-companies” (see TSI OPE 2006/920/EC, Annex
P.6), for the “private” RUs, another range of numbers was used (e.g. 31 for DB and
SNCF, 33 for NACCO or others).
Thanks to this concept, each owner could be identified by the first four digits of an
EVN:
31 80: DB; 31 87 SNCF, 33 87: „private“ RUs in FR; 33 80: „private“ RUs in DE.
In the following the consequences of the distinction between the different types of RUs
shall be reflected:
The concept described worked until the NSAs were established and took over the
registration and the decision about a vehicle’s placing in service.
Nowadays, due to the first legislative Railway package, UIC and furthermore AEIF
changed the “company code” into the code of the country registering a vehicle. In the
same time, the distinction between “institutional” and “private” RUs was made by the
first two digits (as before the amendment). This means that each vehicle registered in
Germany for the first time has 80 as digits 3 and 4. But with the Interoperability
Directive all RUs have the possibility to register vehicles for the first time in another
Annex
IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1
country. This includes that, even if the distinction between “institutional” and
“private” RUs would be kept, the fleet could not be identified by the first four digits
any more if historical RUs register vehicles in other countries than their home country.
Example 1: registration for the first time of a wagon by an “institutional” RU in a
foreign MS:
If DB decides to register a vehicle first time in Netherlands, then the first four digits
according to the former Annex P.4 and P.6 would be the following:
31 84 (31 according to Annex P.6 for an interoperable vehicle of an RIV-company listed
in Annex P.4 (DB is listed in Annex P.4), 84 for the first registration in France.
So 31 84 could be a vehicle of each company listed in the former Annex P.4 – which is
not helpful for a fleet management basing only on the first four digits of the number.
(CER explains that the fleet management bases on the first four digits of the EVN, not
all twelve and requests a transition period until end of 2013).
If the 31 was only to be given to the company listed in the row for the concerning
country code, this would mean that the DB-vehicle put into service in Netherland for
the first time should receive a 35 84 (35 for non-listed company in combination with 84,
84 for France registering the wagon for the first time). This would, in connection with
the four-digit based fleet management, mean that all listed companies would need to
put into service all their vehicles in the country allocated in Annex P.4 in order to
obtain the necessary number combination. Example 2: registration for the “second
hand wagon” by an “institutional” RU
If ÖBB wants to purchase an SNCF wagon without any technical modification, ÖBB
would be obliged - according to the CER-position - to re-register this wagon in Austria
in order to get the digits 1-4 that should express the fact that this wagon is kept by
ÖBB. This constraint of registration is linked to RU-internal administration processes
like the IT-systems for fleet management. The re-registration is not required by EU-
legislation, it is even not in line with the life-long EVN. This re-registration is to be
understood as a new placing in service with its accompanying costs.
When the vehicle is returned, it can receive its old number depending on the
registering entity’s decision.
Annex
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10.6 Additional questionnaire and results 2009 – 01/04/2009
Summary for the impact assessment of the revision of the Annex P – CR OPE TSI
History
A first impact assessment of the revision of the CR OPE TSI Annex P was performed by ERA
in 2008 (here attached, version 0.9 of 4/11/2008). Due to the strong CER concerns on the
impact assessment results, ERA offered a second opportunity to CER to provide relevant
justifications.
As detailed information was not delivered, ERA sought assistance from Infeurope (an IT
company) to develop a questionnaire intended to obtain information about the IT systems
impacted, and to derive reliable estimates of the economic impacts of the change
anticipation.
This questionnaire was discussed between ERA and CER and agreed by CER on 9 January
2009. CER decided to base the evaluation on the contributions of two particular members of
CER.
Process and exchange of document
The questionnaire was sent to CER on 15 January 2009 and sent back to ERA on 30 January
2009 by both contributors. On the request of both, the answers were sent under the
confidentiality process established by ERA. The confidentiality process stipulates, first, that
the answers shall be sent only to the ERA officer in charge of the economic evaluation for the
related ERA recommendation and, secondly, to provide conclusions in a way that does not
allow to trace original information back to its provider. CER provided on 1 February 2009 a
statement which is based on former information given by CER members before the
confidential questionnaire has been sent out.
Scope
The (revised) annex P applies to wagons used in international single wagon traffic and put
into service after the enforcement of the revised Annex P (at the soonest mid-2010). “Putting
into service” relates to new or upgraded wagons (in about equal shares), with a yearly flow
representing about 2% to 4% of the overall wagon fleet.
Relevant impacts to be studied according to the railway sector are the following, and are
especially commercial:
- invoicing of transport services
- distribution of freight wagons
- calculation of rental charges.
Annex
IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1
Analysis of the confidential answers to the ERA questionnaire
The confidential answers have shown that:
1) The statement on the compliance date with the draft revised Annex P is different: one
indicated to be ready by the end of 2010, another indicated to be ready by the
beginning of 2013.
This does not support the stated CER positionc that all CER members would be
impacted by the draft revised Annex P if it is enforced from by mid 2010.
2) The reasons to delay the introduction of the draft revised Annex P are not supported
by evidence from the confidential questionnaire.
This does not support the IT cost impacts mentioned by CER.
3) Another fundamental request from ERA has not been answered: there was no
indication on the planning of the update for each IT system concerned. Only 2013 was
mentioned as final deadline when all IT systems updates would fit together, without
any evidence.
This does not support the cost impacts mentioned by CER on management of
mistakes in invoices related to new wagons used in international single wagon traffic
and put into service after the enforcement of the revised Annex P. The ERA position
is, providing that IT systems are not updated in 2010, there will be at least a gradual
update of the IT systems along the years and this will decrease the number of
possible mistakes in invoices.
Conclusion
The detailed answers through the confidential process have not supported the declaration of
necessity to keep the recognition of the “institutional” RUs during an extended migration
period. Therefore the CER position has not been confirmed.
c Impact Assessment Report, Section 8.4 « Findings based on CER answer » (4/11/2008,
version 0.9). CER sent on 1/02/2009 a new position paper to ERA with the same types
justifications but higher amounts of economic impacts.
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