cr ene tsi impact assessment report - european …€¦ · adif spanish infrastructure manager cba...

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

IU-report-OPE-on-TSI OPE-AnnexP-vehicle-identification-Annex1

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.




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.




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




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




1. INTRODUCTION

This report constitutes the annex 1 of the ERA report on the revision of the CR OPE TSI -

Annex P.




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





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





VIRS Vehicle Identification and Registration Study

VKM Vehicle Keeper Making




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


Austria Structured: 4+3+1

digit

Structured: 4+3+1


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




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.




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.




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:




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.




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




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.




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.




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




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).




Question 3: Have you noticed that vehicle categories are missing?


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.




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?


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?




Question 6: Did you simplify codes in Annex P.6 and P.7?


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?


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




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?




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.




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?


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




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:




- 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




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.




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.




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).




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.




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.




9. MONITORING AND EX-POST EVALUATION

Reserved.




10. ANNEXES

Annex


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 Freight Vehicles Special vehicles Loco-motives

Electric and

Diesel Multiple

Units


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


0%

New projects


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


10.2 DB IT systems Diagram

Annex


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


mobile data seizure


CDD record of freight train


mobile data seizure


HERMES data exchange for

international traffic


WIS wagons technical

database maintenance

database for wagons


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


FBR freight accounting

system


LPK freight accounting

system


LB wagons use reservation yes! Link with a VKM database until 2014!

GWD accounting of rented

wagons


WIS accounting for

degradation on wagons


SAP-ISI accounting for

degradation on wagons


10.4 Table on REMAINING IT APPLICATION TO BE UPDATED: SNCF

IT systems for operation, commercial and accountancy purposes

Annex


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


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

Annex


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


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


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


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.