Colin Buchanan and Partners
Introduction
COLIN
BUCHANAN AND PARTNERS Planning, Transport, Economics Software, Market Research
European Commission Vehicle Identification and Registration
Final Report
Colin Buchanan and Partners
Introduction
1. INTRODUCTION 1.1 Authority and Brief 1.2 The Study Team 1.3 Background 1.4 Study Methodology 1.5 Assistance Provided 1.6 Structure of Report
1-4 1-4 1-4 1-5 1-9 1-11 1-11
2. CURRENT ARRANGEMENTS 2.1 Placing Vehicles in Service 2.2 Vehicle Numbering Systems 2.3 Railway Coding Systems 2.4 Relevant EU Directives 2.5 Legal Obligations 2.6 Number of Vehicles 2.7 Uses of Numbering Systems 2.8 Particular Issues for non-UIC Members 2.9 Interface with OSJD
2-1 2-1 2-9 2-18 2-20 2-24 2-32 2-33 2-36 2-37
3. ANALYSIS OF EXISTING SYSTEM 3.1 Legal Compliance
3-1 3-1
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6.4 6.5 6.6 6.7 6.8
Database and Register Issues Definition of a Vehicle Form of Identifier VIN Issues Maintenance and Insurance
7. ANALYSIS OF OPTIONS 7.1 Placing Vehicles in Service 7.2 Database and Register Issues 7.3 Form of Identifier 7.4 VINs 7.5 Maintenance and Insurance 7.6 Cost Benefit Analysis 7.7 Evaluation of Identification System Options 7.8 Evaluation of Numbering System Options
Introduction
6-3 6-5 6-6 6-9 6-11 7-1 7-1 7-3 7-8 7-15 7-20 7-22 7-28 7-32
8. CONCLUSIONS 8.1 Organisational 8.2 Technical
8-1 8-1 8-2
9. RECOMMENDATIONS 9.1 Organisational Recommendations 9.2 Technical Recommendations
9-1 9-1 9-3
Colin Buchanan and Partners
Introduction
1. INTRODUCTION
1.1 Authority and Brief
1.1.1 In May 2002 a consortium led by Colin Buchanan and Partners (CBP) supported by Pegasus Transconsult Ltd (PTC) was appointed by the Directorate-General for Energy and Transport of the European Commission (the Commission) to undertake a study into “Vehicle Identification and Registration” (Contract No 2002/B27040B/E2/ SO7.11682/ETU). 1.1.2 The study’s purpose was to investigate the way in which rail vehicles are identified and placed into service, in the context of the changing organisational structure of the rail industry; with specific emphasis on the operation of the Single Market and compliance with EU legislation and policy objectives in the sector. 1.1.3 The main tasks defined by the Commission were to:
Examine the position of vehicle identification and registration in
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Introduction
1.3 Background
1.3.1 Up to the end of the last century Europe’s rail networks were organised on national lines, which for the preceding half century had been almost exclusively in the hands on monolithic state owned organisations (subsequently to as national railways/national railway undertakings herein). With the exception of government government direction and some safety regulation these organisations were totally responsible for all matters pertaining to rail networks and their operations, including the acceptance of vehicles into service and their numbering. 1.3.2 The provision of services across national boundaries required a degree of co-operation between railways. Accordingly, railways and their governments began to agree the arrangements for exchanging traffic and the outline specifications of vehicles permitted to run on the networks of other states. A notable milestone was the 1882 Bern Technical Union, which inter alia defined the standard “Berne” loading gauge. This co-operation led to the railways founding the International Union of Railways (UIC) in 1922, following intergovernmental conferences in Portorosa and Genova. 1.3.3 Amongst the issues covered by UIC agreements is the mutual
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Introduction
affairs1. The role of vehicle identification systems systems needs to be seen within this context. Figure 1.1 EU15 Goods transport - billion tonne kilometre 1970 – 2000 3500 Road Rail
3000
Inland waterway Pipelines Sea Total
2500 s e r t e m2000 o l i k e n n o t n 1500 o i l l i B
1000
500
0 1970
1980
1990
2000
Source EU Energy and Transport in Figures 2002, European Commission (for figures
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Figure 1.3 EU15 Goods Transport - Market share by mode 1970 -2000
Figure 1.4 EU 15 Passenger Transport - Market share by mode 1970 2000
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Commission’s communication on the integration of rail 3. In many Member States this process will require considerably greater liberalisation in the sector, which in turn will make many of the current arrangements, responsibilities and processes inappropriate. 1.3.7 A number of key pieces of legislation have become European Law in furtherance of this strategy to improve the performance of Europe’s railways (some which also cover a range of other industries), including the following EU Directives and Decisions:
91/440/EEC, on the development of the Community’s railways;
93/38/EEC, co-ordinating the procurement policies of the water energy transport and telecommunications sectors ;
93/465/EEC, concerning the modules for the various phases of the conformity assessment procedures and the rules for the affixing and use of the CE conformity marking, which are intended to be used in the technical harmonisation directives ;
95/18/EC, on the licensing of railway undertakings ;
95/19/EC, on the allocation of railway infrastructure capacity and the charging of infrastructure fees ;
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Introduction
all others, subject only to assessment of conformity with specific aspects of national railway systems that have been agreed as being problematic. This is expected to improve considerably the Single Market for railway equipment, provide a non-discriminatory approval regime and facilitate interoperation and international services. 1.3.9 The basic prerequisite upon which the process of pan-European approval by notified bodies takes place is the creation of common European standards in the form of Technical of Technical Specifications for Interoperability (TSIs), which are currently being drawn up by the Association Européenne Européenne pour l’Inteoperabilite Ferroviaire (AEIF). These are supported by the detail contained in the relevant Euro relevant Euro Norms (ENs) drafted by CEN, CENELEC and ETSI. The TSIs for high speed interoperability under Directive 96/48/EC came into force in December 2002 and the first batch of drafts under Directive 2001/16/EC were issued in September 2002. These will come into force in due course once the drafting process is complete and they have been approved. 1.3.10 The objectives furthered by the TSIs will only be achieved if the entire process of placing a vehicle in service meets Single Market criteria. If there are any other steps between that of technical approval and the commencement of day-to-day operations that could be used to frustrate the objectives of EU policy then these need need to be removed. The
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Introduction
development of recommendations.
1.4.2 To assist and advise the Consortium the Commission assembled an Expert Advisory Group (EAG), with whom four meetings were held at critical stages of the study to discuss arising issues and advice on future progress. The minutes of the three meetings held prior to preparation of this Report can be found in Appendix Error! Reference source not Commission, OTIF, the UIC, UNIFE, found.. The EAG consisted of the Commission, the AEIF, the UIP and the CER. In addition, meetings were held with all of the members of the EAG on a one-to-one basis to obtain their individual views. 1.4.3 The study considered the entire process of placing vehicles in service, however the prime focus has been on vehicle identification and the systems and processes associated with it. The process of technical approval has been briefly considered for completeness, but this has not been a major focus of the work. Consideration has also been given to systems that use vehicle numbers in service where these impact on either vehicle identification or the way in which vehicle data is or will be held on registers, databases, etc. 1.4.4 Data gathering and research encompassed investigation of the
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Introduction
1.4.7 The options for change were evaluated against a matrix to determine which solutions appear to offer the most appropriate ways forward, this included a cost-benefit analysis. At this stage the views obtained from interested parties in the consultation process were again taken into consideration as were those of the EAG.
1.5 Assistance Provided
1.5.1 The Consortium would like to formally record their gratitude to all those who assisted them in the course of this study, a list of these parties can be found in Appendix B to this Report.
1.6 Structure of Report
1.6.1 This Report is structured in nine sections as follows: 1.
Introduction
2.
Current Arrangements
3.
Analysis of Existing System
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2. CURRENT ARRANGEMENTS
2.1 Placing Vehicles in Service
Outline of Process 2.1.1 Current arrangements for placing vehicles into service consist of a set of linked processes that are undertaken sequentially or in parallel. These are: 1. commercial concept to construct vehicle(s); 2. establishment of commercial case for vehicle(s); 3. outline design process; 4. development of technical specification; 5. discussions with rail haulier/licensed undertaking; 6. discussions with infrastructure provider(s)/manager; 7. obtain acceptance for vehicle(s) in principle;
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Figure 2.1 Bringing a Rail Vehicle into Service Commercial idea originated to meet a need
Commercial case made. Includes an outline design of the vehicle with a technical specification. Implicit or explicit discussion with rail undertaking. If vehicle is outside normal specifications then discussion with Infrastructure Manager.
Agreement in principle. (Vehicle meets standards or is containably outside them)
Vehicle designer looks for appropriate number series. Vehicle type may not be catered for. Formal process exists for requesting a number series
Formal design approval. National railway or in future notified body approves design of vehicle in
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2.1.2 The process is broadly similar whether a vehicle is owned by a rail undertaking or by some other entity, but with one significant difference. Where a rail undertaking is bringing its own vehicle into use then many of the actions may be internal or implicit. Where a vehicle is not owned by the rail undertaking itself, but needs to be attached to its fleet, a "contract for use" is agreed. 2.1.3 For private wagons Article 2 (Acceptance of wagons for international traffic) of the RIP (Regulations concerning the International Haulage of Private Owners' Wagons by Rail, Annex II to Appendix B to the Convention concerning International Carriage by Rail (COTIF) of 9 May 1980) has served as the sole legal basis for technical approval in international rail traffic. This article stipulates: "To be accepted for international traffic, wagons shall be registered in the name of a private party (whether an individual, a firm or a corporate body) by a railway to whose lines the Uniform Rules apply and shall be marked by that railway with the distinguishing mark". 2.1.4 The arrangements discussed above relate to an item of hauled rolling stock for international international operation. In the case of vehicles to be used for purely domestic operation, there can be differences in the final three steps of this procedure, which are discussed further below.
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Current Arrangements
between sub-systems and need to verify that new equipment interfaces appropriately with existing equipment. This increasing rigour has also been driven by the need to move to higher levels of safety in line with increasing public expectations and the greater performance and functionality required of assets, placing greater demands on them for safe and reliable performance in service. 2.1.8 International approvals are considerably simpler for hauled rolling stock running under the RIC or RIV regime than for traction. Compliance with common UIC technical specifications for hauled rolling stock facilitates and mandates mandates mutual acceptance. This process will be strengthened once the TSIs supersede the UIC leaflets. 2.1.9 The acceptance process for hauled rolling stock is in any case simpler than for traction, because it is technically simpler and has less potential for adverse reaction with the infrastructure. For the reasons reasons discussed above the technical approval process for traction has become increasingly complex and costly. Particular problems occur with approval for international operation because of technical diversity and the lack of agreed international standards. Thalys is an extreme example of these difficulties and is something that a single independent railway undertaking would have found impossible to implement.
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2.1.14 If a vehicle is to be placed in normal international use, the number has to be allocated by a UIC-member railway (with a few exceptions the national or former national railway) and then attached to its fleet, this process is discussed below under “Vehicle Numbering Systems”. There are no automatic rights to this, and at present a UIC member railway undertaking accepts significant potential liabilities in accepting a vehicle into its fleet. However, few examples examples of anticompetitive behaviour have emerged or UIC-member railways behaving irresponsibly. Legal challenge to unreasonable refusal may theoretically be possible. 2.1.15 Other important issues need to be resolved before a vehicle can enter service. Arrangements need to be made so that the vehicle is appropriately maintained. The keeper needs to carry sufficient insurance insurance or other suitable means of underwriting liability so that if damage is caused to persons or property by a vehicle defect appropriate recompense can be paid. Finally, a railway undertaking or undertakings have to be prepared to use the vehicle. Contracts for Use 2.1.16 If a privately owned vehicle is to be used internationally, under
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standards, and the rail undertaking is responsible to the infrastructure manager for assuring the safety of any train that it operates. Maintenance 2.1.19 Traditionally verification that vehicles are maintained to appropriate standards has been dealt with by attaching vehicles to the fleets of national railway undertakings (or similar), which mutually recognise each other’s standards and competence. They in turn turn agree/dictate maintenance standards and insurance arrangements with/to vehicle keepers. In general this still occurs, although there is an increasing recognition in the industry that this is inappropriate in a liberalised environment. 2.1.20 Under this traditional model the maintenance regime is therefore mandated or agreed as a part of placing a vehicle vehicle into service. The regime may be reviewed and updated over time as circumstances change. The enforcement of standards is in the hands of the railway undertaking to whose fleet the vehicle vehicle is attached. In a more open liberalised market alternative arrangements need to be found to verify that all vehicles in circulation are maintained to appropriate standards, whatever their origin.
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2.1.23 No standard arrangements exist for tractive stock or carriages that are either privately owned or are owned by non-UIC member railway undertakings. These are agreed on an ad hoc basis as part of the process of placing a vehicle in service. 2.1.24 The clear distinction which the number makes between railway and privately owned vehicles and the identification of the railway to which a vehicle is attached allows this system to work effectively at present. 2.1.25 There are now anomalies anomalies in this process. For example, in Germany, where the national railway undertaking does not require vehicle keepers to hold insurance and carries this risk itself it has now been forced to attach vehicles owned by rival railway undertakings to its fleet and consequently holds a risk without a benefit. Case Studies 2.1.26 The four country case studies (See Appendices D to G) provide interesting contrasts in the attitude and progress towards liberalisation and reform. They also reveal some practical problems that will need to be resolved in the overall process of placing vehicles into service, if the
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Vehicle Approval Bodies. Bodies. These approaches differ yet both would appear to require little effort to fit into the notified body framework. 2.1.29 However, the administrative arrangements for placing vehicles in service differ markedly between Germany and Britain. In the latter, the vehicle is entered onto a national database and numbers are allocated by the Rolling the Rolling Stock Library, Library, an independent body jointly funded by the whole industry, whose management and operation is contracted out. Once this happens a vehicle is free to travel anywhere on the national rail network (subject only to technical restrictions) used or hauled by any railway undertaking and its owner/keeper has access to all national railway operating IT systems. systems. The only exception is when vehicles are allocated with international numbers. Because of the way in which the UIC system works and restrictions in the Channel Tunnel usage contract, all British freight vehicles in international service must be attached to EWS’s fleet and access to international IT systems is obtained is also via EWS. 2.1.30 In Germany, however, there is no national database and railway undertakings allocate their own numbers, DBAG has retained control of the administration of the combined national and international numbering system and all railway operating IT systems that feed off them. Accordingly, in practice all other railway undertakings which wish to
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2.1.34 Maintenance is not prescribed by PKP; owners/keepers are required to adhere to standards set by the UIC and prescribed by Polish law, however, provision of overhaul facilities is entirely private.
2.2 Vehicle Numbering Systems
Number Formats 2.2.1 Railway vehicles are currently identified by means of numbers painted on the sides sides of vehicles. The differing systems that are currently used around Europe Europe are discussed below. In essence numbering systems can be of two types: structured or structured or unstructured unstructured . 2.2.2 A structured number is where the number is coded so that it conveys information about the vehicle, which is used for operational, administrative or other purposes. 2.2.3 A totally unstructured number is where numbers are allocated “at random”, generally in chronological order as vehicles are placed on the register. In most unstructured unstructured systems numbers numbers are allocated in blocks,
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numbering system is consistent across all three UIC leaflets and consistent with the OSJD system insofar that a vehicle number unambiguously identifies the vehicle type, its origin (and in most cases somewhat more) for any vehicle in the geographic area covered. 2.2.6 The system is defined (for UIC railways) in UIC leaflets 438-1 (hauled passenger stock), 438-2 (freight rolling stock) and 438-3 (tractive stock). Coaches formed into multiple units are commonly numbered in the tractive stock range, rather than the hauled passenger stock range defined in the UIC leaflets. Baggage vans, mail mail vans and car carrying vehicles used in passenger trains are numbered as passenger stock. 2.2.7 Changes to the system have been proposed by the RICS working group. Fuller details are provided in Section 5 of this Report. At the time of writing the UIC had approved the changes for freight vehicles but in practice none of the changes have yet been been implemented. Proposed changes for passenger vehicles have yet to be ratified and those for traction renumbering have not yet been presented. 2.2.8 Vehicles used purely for domestic purposes also tend to be numbered in the international sequence to avoid having two systems in use. The system system makes allowance for this. this. Under all the systems defined
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covered by the RIC, RIV and their equivalents in OSJD States are currently provided for; there is no “other” regime. 2.2.11 The regime of use is therefore currently a mixture of commercial, operating and technical criteria. It distinguishes bogie and axle vehicles, vehicles equipped to run on non-standard gauge railways and vehicles fully or partially meeting RIV technical standards (technical criteria). It currently distinguishes vehicles in railway owned pools (operating criterion) and it distinguishes privately owned from railway owned vehicles (commercial/operating criterion; responsibility for its repair and for incidents caused by by a vehicle currently depend on its status). Lastly, it distinguishes vehicles able to operate internationally from those limited to domestic traffic (this may be a technical, operating or commercial criterion). 2.2.12 The railway to which the vehicle is attached is a two-digit code for the railway undertaking which owns the vehicle or, in the case of a privately-owned vehicle, to which the vehicle is attached. It normally indicates where a vehicle is to return to in the absence of orders and which railway should be contacted in case of an incident or requirement for maintenance. Only UIC and OSJD railway undertakings are currently covered. Accordingly, other railway undertakings undertakings which wish to use their wagons internationally have to attach them to the fleet of a
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than one four-digit code is necessary for populous vehicle types to allow all of them to receive unique serial numbers; these numeric type codes are normally but not necessarily contiguous. 2.2.15 The serial number is simply the unique serial number identifier, within the vehicle type, for the vehicle itself. Photograph showing the twelve digit number and literal
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these numbers are input into systems or manually transcribed, the current system incorporates a check digit as the twelfth character of the number. The mechanism for the calculation of the check digit is defined in UIC leaflet 913; it is designed to detect incorrect digits and also transposition of correct digits. It uses the "modulus "modulus 11" system system 4. 2.2.17 The Photograph above provides an example of this numbering system and the other information displayed on the vehicle. Hauled Passenger Rolling Stock 2.2.18 The system defined in leaflet 438-1 is similar in format to that for hauled freight rolling stock: twelve digits divided into six groups, two digits for the operating regime, two digits for the railway to which the vehicle is attached, two groups each of two digits for the operating and technical characteristics of the vehicle, three digits for the serial number of the vehicle within the category and lastly a single single check digit. These fields are dealt with individually below. 2.2.19 The operating regime field can take values 50 to 79 (thus not duplicating the freight or traction numbering numbering sequence). With two exceptions it only reflects technical characteristics. The technical criteria
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2.2.21 The first digit of the operating characteristics field indicates the basic type of vehicle (sleeping car, First Class, etc), values are provided for vehicles owned by others5 and for vehicles of “special design”. The second digit essentially indicates the size of the vehicle in terms of its carrying capacity. In the case of privately owned owned vehicles and specially designed vehicles, this second digit provides more information about the type. Staff become sufficiently familiar with the coding structure to interpret the type of vehicle from the number. 2.2.22 The technical characteristics field indicates the speed regime of the vehicle and the train-lines (for heating and services) with which it is equipped. As heating and air-conditioning equipment, for example, become more standardised, many of the code values will become redundant and it will be possible to use this section to indicate other parameters. 2.2.23 The remaining fields are identical to those for hauled freight rolling stock. Traction 2.2.24 The numbering system for locomotives and other tractive units
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Digits 6 to 11 -
running number (unstructured)
Digit 12
check digit
-
2.2.27 The second check digit allows the last seven digits of the number at the twelve digit level to be the same as the number at the last seven digit level. 2.2.28 A distinction is made between locomotives and power-cars in the coding structure but otherwise railway undertakings are invited to number tractive units how they wish within a twelve digit system in which in practice only six plus a check digit are active. The full twelvedigit system maintains the same structure of owning railway and check digit is preserved. Other International Systems Used in Europe 2.2.29 As noted above the broad gauge railways of the CIS still use Soviet era eight digit numbers. Vehicles are numbered in series; accordingly CIS rail staff can interpret vehicle characteristics from numbers. CIS computer systems continue to be run by RZD (Russian (Russian Railways) on behalf of all the CIS states but changes have been made to
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2.2.32 The current numbering systems used in each state, for vehicles that are not used internationally, are shown in Table 2.1. Table 2.1 – Current Numbering Systems Numbering System Locomotives State
Belgium Denmark Germany Spain France Greece Ireland
Semistructured 4 digit Various1 Various2 Structured: 3+3+1 digit Semi-struct, 6 digit UIC 438-3³ Unstructured:
Multiple Units
Semi-struct 4 digit (dmu)/ unstructured 3 digit (emu) Various Various2 Structured: 3+3+1 digit Struct: 1 letter + 2 to 5 digit Semi-struct 3 digit Unstructured:
Hauled Passenger Vehicles
Hauled Freight Vehicles
UIC 438-1
UIC 438-2
Various Various2
Various Various2
UIC 438-1
UIC 438-2
UIC 438-1
UIC 438-2
UIC 438-1
UIC 438-2
Unstructured:
Unstructured:
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Numbering System Locomotives
Multiple Units
+ 4+3 digit/3 alphanumeric + 3 to 4 digit Structured: 2 letter + 3 digit + 3 digit UIC 438-3 3+3 digit Various8 Structured: 2 letters + 3 to 4 digits 2+3 digit 2+4+1 digit SZD6
or 4 letter + 3 digit
State
Poland Slovakia Slovenia Switzerland Norway Bulgaria Romania CIS Notes:
Structured: 2 letter + 2 digit + 4 digit UIC 438-3 3+3 digit Various
Hauled Passenger Vehicles
UIC 438-1
UIC 438-2
UIC 438-1 UIC 438-1 Various8
UIC 438-2 UIC 438-2 UIC 438-2
Structured: 2 + 3 digit 2+3 digit 2+4+1 digit SZD7
Hauled Freight Vehicles
UIC 438-2 UIC 438-1 UIC 438-1 SZD
1. DSB use a structured 2 letter + 3 or 4 digit alpha-numeric alpha-numeric system; other railways also use alpha-numeric systems.
UIC 438-2 UIC 438-2 SZD
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Case Studies 2.2.35 The case studies illustrate the sharp distinction between traction and hauled rolling stock in the degree of commonality between the numbering systems used in the four countries. 2.2.36 Naturally all four examples use the systems described in UIC leaflets 438-1 and 438-2 438-2 for rolling stock stock in international use. The same system is used for all stock in domestic service on the national rail network in France and Poland. In Germany, as noted above the system system is used by DBAG and AAE rolling stock (the vast majority of national rolling stock, at present) but it is not available to other railway undertakings unless they attach their wagons to its fleet, they therefore have their own systems systems and number series. In Britain historic isolation means that a unique national system of unstructured numbers is used It is interesting that solutions have been found to enable this to work quite satisfactorily alongside the international numbering system in IT systems, etc. However, this is aided by the limited range of international vehicles that can run in Britain, due to technical differences. 2.2.37 The system used used for traction varies between the four States. The only common feature is that all of the systems used are structured.
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coding only makes makes sense when there is capacity to process it. It is not surprising therefore that railway coding dates from the period when commercial computer systems began to be widely available. The UIC/OSJD railway coding system dates from 1 January 1971 when the standard system of numbering vehicles was introduced. Whilst the primary purpose was vehicle numbering, the coding system was intended to be all-purpose and thus to cover operating, commercial, financial, information technology, etc, purposes. 2.3.2 Railway codes are used as an indication of fleet ownership of vehicles, on tickets to show issuing railway undertaking, on consignment notes to identify the stations, in data messages to identify recipient and for many other purposes. purposes. These ambitious objectives objectives caused a certain amount of ad-hoc allocation of codes. The codes were needed for example not only for a railway undertaking but also for the relevant country and currency, extra codes were therefore necessary for currencies without a railway, such as the US dollar or SDR 6. 2.3.3 Railway undertakings are allocated two digit codes from 01 to 99. Each of the mainline UIC/OSJD members possesses a code and indeed some quite small railway undertakings with a vehicle fleet (such as the Aarus Alstätter Eisenbahn) have codes. The minor Swiss railways share a code however. Originally all UIC member railways in Europe, Asia Asia
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three letter currency codes have allowed UIC codes simply required for currencies to be liberated, combinations such as 89 are now used and a few railway undertakings (such as the Budapest Local Railway BHEV) have been deprived of their code. Separate series for the African and American railways have also been set up.
2.4 Relevant EU Directives
Overview 2.4.1 In the context of the study the infrastructure package comprising Directives 2001/12/EC, 2001/13/EC and 2001/14/EC and the interoperability Directives 2001/16/EC and 96/48/EC are the most pertinent pieces of EU legislation. These Directives built built on earlier legislation and sought to remove many of the technical, legal, operational and administrative barriers to a functioning Single Market for rail services. This sub-section describes the main main relevant requirements and objectives of these Directives and assesses implications of these for the study (Directive 96/48/EC is not specifically discussed, since the requirement for a vehicle database emerged in Directive 2001/16/EC).
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services and exchange of vehicles and therefore these paragraphs imply the need to ensure that the vehicle identification system does not impede the use of the access rights created. 2.4.5 Paragraph 5 requires a railway undertaking using the access rights created under paragraphs 1 to 3 to conclude the necessary agreements with the relevant infrastructure managers. managers. Infrastructure managers will wish to ensure the compatibility of rolling stock with their infrastructure and these characteristics need to be accessible through the vehicle identifier. In view of this it is important that infrastructure managers must also find the identification system acceptable and that it must adequately satisfy their needs 2.4.6 Paragraph 6 requires that terminals and ports must also accept freight rolling stock on their rail infrastructure from railway undertakings using the access rights rights created by paragraphs 1 to 3. The vehicle identifiers are therefore likely to be important to them and thus consideration needs to be given to their interfaces with any system. 2.4.7 Article (10a) describes the Trans European Rail Freight Network, which defines the minimum network on which a single railway undertaking will have the right to offer international rail freight services,
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Directive 2001/13/EC 2.4.9 This Directive makes a number of technical amendments to the requirements of Directive 95/18, which relates to a Community licence for a railway undertaking. The Directive does not not appear to contain any elements that are of relevance to this Study. Directive 2001/14/EC 2.4.10 This Directive addresses the areas of railway infrastructure charges and capacity allocation. However, in so doing, it impinges on a number of other areas. 2.4.11 The rights of access to the infrastructure are defined in Article 3. One of the conditions is likely to be an appropriate identifier on the vehicle to assure the infrastructure manager of its conformity with the infrastructure and of the identity of its keeper. The absence of such an identifier is likely to result in the infrastructure manager imposing more onerous conditions on the use of the vehicle. In setting out the nature of the infrastructure available, the infrastructure manager should ensure that it is relatively straightforward for a railway undertaking to assess the conformity of its vehicles with the infrastructure.
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acceptance stage before the subsystem is put into service. It shall also cover verification of the interfaces of the subsystem in question with the system into which it is incorporated” and “the technical file … must contain all the necessary documents relating to the characteristics of the subsystem and, where appropriate, all the documents certifying conformity of the interoperability constituents. It should also contain all the elements relating to the conditions and limits of use and to the instructions concerning servicing, constant or routine monitoring, adjustment and maintenance”. maintenance” . This therefore places obligations both on the process of placing a vehicle in service and implicitly on either the vehicle identification system or the database within which vehicle data is held and requires its exchange for interoperability. 2.4.15 A further implication is that there is a clear linkage between the TSI for freight telematics, the approval and interoperability information generated by notified bodies bodies and the vehicle identification system. system. The Directive therefore obliges “joined up thinking”. It should be further noted that, under Article 23, the freight telematics TSI is listed as a priority action, to be drawn up no later than 20 April 2004. 2.4.16 Article 24 is crucial in the context of this study: study: it requires the establishment of registers of rolling stock and infrastructure. Specifically it requires that:
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2.4.18 Annex III, section 2.7.1 lists “the “ the essential requirements for telematics applications”; applications” ; this has important requirements for vehicle identification and its associated databases by requiring that: “databases, software and data communication protocols are developed in a manner allowing maximum data interchange between different applications and operators, excluding confidential commercial data” and “easy access to the information for users”. users” .
2.5 Legal Obligations
Overview 2.5.1 This sub section of the Report is an inventory of the obligations to register rolling stock under under EC law, COTIF and Unidroit. It goes on to briefly list the legal requirements under competition law that have to be met by a railway identification and registration system. It primarily considers the legislation currently in force and that, which has been agreed internationally8, but it also pays attention to the changes that the adoption of the new new Railway Package (RWP-II) will bring about. RWP II is discussed in more detail in Section 5.
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same obligations on the registration of the rolling stock will be included in Directive 96/48/EC (see “Commission proposals in RWP-II”). 2.5.4 In terms of scope the Directive, at present, obliges Member States to keep (with a parallel infrastructure register) a register of rolling stock 9. This rolling stock register covers register covers all stock that is likely to travel on all or part of the conventional rail network for international as well as for national/domestic use10. There are two two important requirements that this must include: 1. the main features of the rolling stock (“the ( “the parameters”); parameters”); and
basic
2. their compliance (or otherwise) with the TSIs. 2.5.5 Each TSI will have to indicate precisely what information must be included in the register 11. The basic parameters of conventional rolling stock will be determined by the “Article 21 committee” 12. 2.5.6 The Directive requires that the register be published and updated annually. A copy of the register has to be be made available to the public and has to be sent to the Member States concerned and the AEIF.
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The “Joint Unidroit/OTIF Committee of governmental experts” is preparing a Protocol to this Treaty which specifically covers railway rolling stock (the “Rail Protocol”). 2.5.10 It is anticipated that Unidroit/OTIF will convene a diplomatic conference to complete and sign the Rail Protocol in late 2004 or in 2005. The Convention makes makes provision for the possibility of the Regional Economic Integration Organisations, such as t he European Union, to be a party to the Convention and analogous provisions are contained in the draft Rail Protocol. Protocol. The Commission was represented at the Convention in Cape Town and expects shortly to receive a mandate to sign the Treaty. It is understood that that the Commission will request a mandate in due course to start negotiations in respect of the draft Rail Protocol. 2.5.11 The aim of the Convention is to provide creditor protection at an international level, protecting the property rights (defined as “international interests”) of a vendor selling an asset with the reservation of title, of a lessor leasing an asset to a third party and of a financier financing an asset by the way of a loan agreement and taking an interest in the rolling stock as collateral 14. The asset must be “uniquely identifiable”15. A holder of of an international interest will be able to register its interest in an international registry16 which, with minor
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Registry 19. This entity could be the ERA for example. The unique identification criteria proposed by such a designated entity would be accepted by the Supervisory Authority if they were consistent with the operation of the international registry and the intent of the Rail Protocol. There is also unresolved discussion of certain contracting States being able to designate an autonomous registry authority which would then be outside the jurisdiction of the Supervisory Authority and would not be part of the international registry.20 2.5.14 The Convention leaves it to each industry Protocol to determine what data should be registered at the international registry and the appropriate unique identification criteria. criteria . The draft Rail Protocol leaves it to the Supervisory Authority to prescribe in regulations “such identification criteria as will enable an item of railway rolling stock to be uniquely identified” and contemplates that different criteria may be prescribed for different classes of railway vehicle 21. 2.5.15 The The International Registry has to be operated and administered on a twenty-four hour basis 22. It is proposed proposed that all registration and searches will be conducted through through the Internet. Any designated entity has to operate “during working hours in its territory” 23.
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precedence over EC legislation. The EU Member States and the European Commission will have to take account of this fact when developing further COTIF rules through the COTIF committees (see below). 2.5.19 Article 3 of the COTIF on international co-operation should also be noted, although in the view of the Consortium this merely accepts that the Community has certain powers in the area of rail policy. However, Article 3 does not stop the EC or Member States needing to use Article 42 on declarations and reservations if they choose not to apply certain treaty obligations. If a Member State ratifies COTIF (and COTIF comes into force) and no Article 42-declaration is made, when the COTIF comes into force it will be bound to COTIF obligations, Article 3 does not change that. 2.5.20 The COTIF permits the option of not applying certain treaty obligations, including parts of the appendices. Article 42 covers that possibility. Therefore, in principle the EC could could choose not to not to participate in the international register discussed below. Nevertheless when signing the new COTIF in Vilnius in 1999 no EU Member State expressed any reservation to any of the appendices.
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Admission of Railway Material used in International Traffic”, otherwise known as the ATMF) is confined to railway equipment to be used “in international traffic”. 2.5.24 Article 13 of Appendix G requires a data bank to be set up under the responsibility of OTIF. The vehicle data bank will will contain information about railway vehicles “admitted to circulation or use in international traffic”. Paragraph 3 makes makes it clear that the sole objective objective of the data bank is to provide evidence that the vehicle has been technically approved (for the infrastructure in question). The actually data necessary for this purpose are to be defined by the Committee of Technical Experts but it might be surmised that very little data is necessary for this somewhat somewhat limited purpose. It is not self evident for example that vehicle weight, length or braking characteristics are a necessary part of this information. 2.5.25 The “data necessary” for the purposes of the ATMF must be transmitted by “the competent competent authorities” to OTIF. In all cases the competent authorities will have to provide notice of the following necessary data: data:
withdrawals from service;
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2.5.28 This would seem to exclude both the possibility of a “variable geometry” file holding additional data from those states able to provide it, as well as the extension of the file to include further data that is useful for operational and safety purposes. Two hierarchical files could could however satisfy this requirement, the first holding COTIF administrative data on technical approval and the second data for day to day use. 2.5.29 It should be noted that the view of OTIF is that Article 13 paragraph 2 of the ATMF only specifies the minimum requirements and that the holding of of additional data is my no means excluded. excluded. Indeed OTIF (through the CTE) is obviously prepared to require additional data to be provided. Assurances provided by OTIF OTIF to the Consortium during during the course of the Study suggest that a pragmatic attitude will in fact be taken. Accordingly extension of the file to include further data that is useful for operational and safety purposes can be envisaged. 2.5.30 The wording of Appendix G does not include any stipulation about the frequency with which the register will be be updated. It appears that this aspect still has has to be worked out. The Appendix places responsibility for the international register with OTIF, OTIF themselves however have made it clear that it is a task which they would seek to delegate.
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prohibit abuse of a dominant position and anti-competitive agreements between competitors. 2.5.33 When considering abuse of a dominant position, pre cautions have to be taken to prevent measures that would enable an undertaking to abuse its dominant position. This could for example be the case if an established railway undertaking was allowed to manage the register with the consequent risk that it would favour its own undertaking to the detriment of competitors. competitors. Another risk could arise when giving railway undertakings unlimited access to vehicle information. This might enable established railway undertakings to use the information in some way at the expense of newcomers. 2.5.34 When considering the issue of agreements between competitors, one risk would be the mutual exchange of information between competitors through the register (for example between railway undertakings or between manufacturers). If such an exchange potentially leads to a distortion of competition, it is in principle prohibited under the rules of competition law. Exceptions to this principle will have to bear among other things, the test of proportionality: is there no conceivable alternative measure that achieves the required purpose (safety, interoperability, exchange of stock, etc) which has a less negative effect on competition?
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2.6 Number of Vehicles
2.6.1 The most reliable data available to the Consortium indicates that the number of vehicles in each state that would be affected by any renumbering scheme is shown in Table 2.2 (it is based on UIC figures and only includes UIC members, the totals for other railway undertakings and privately owned vehicle are unknown, except in the case of Great Britain, Sweden, Romania and for German and Swiss wagons where the national total has been obtained by responses in the information collection process): Table 2.2 – Number of Vehicles Effected Numbering System Locomotives State
Belgium Denmark Germany Spain France
969 187 7 254 988 4 983
Railcars & Multiple Units
701 466 2 402 1 006 2 175
Hauled Passenger Vehicles
3 501 918 14 715 4 310 15 694
Hauled Freight Vehicles
13 385 2 236 200 578 19 754 46 359
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Numbering System Locomotives State
Romania European CIS Other UIC Total
Railcars & Multiple Units
Hauled Passenger Vehicles
Hauled Freight Vehicles
1 809 16 027 6 868
151 9 971 1 744
4 037 41 937 16 253
58 000 547 796 173 555
59 698
38 398
155 955
1 470 415
2.6.2 Although the above numbers should be treated with caution, approximately 1.5 million European rail vehicles are or shortly will be numbered using the UIC/OSJD system. 2.6.3 Assuming that, on average, locomotives, multiple units and carriages should have an economic life of 30 years and that wagons should have an economic life of 20 years 28. This would would mean that, at the present fleet size and composition (see Section 7 of this Report for a discussion of this issue) that approximately 1,800 locomotives, 1,200 multiple units, 4,600 carriages and 65,000 wagons enter service each year.
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train list: compiled by rail undertaking undertaking and an abstract is supplied to the infrastructure manager;
dangerous goods: goods: to ensure that the vehicle is appropriately configured;
arrival at destination: input to the receipting process; process;
repositioning for next customer: customer: contact to the wagon keeper to identify the next customer;
accounting system: uses consignment consignment number and wagon wagon number;
maintenance: used by keeper and/or person person contracted to perform maintenance.
Roles 2.7.2 A unique identifying number has a number of potential uses for the railway industry. These include operational, operational, accounting, engineering engineering and legal functions. The nature of freight operations operations means that freight train operators are likely to make considerably more use of the identification number than do passenger operators. Freight vehicles need to be be sent singly or in different sized batches to differing destinations. Billing is an issue and damage is more likely. Vehicle types are more varied and
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databases and registers of ownership/responsibility;
customs and other official systems.
The current uses are not exhaustive and vary from state to state; further valid uses for vehicle identification systems could undoubtedly be found, particularly through more advanced IT applications. 2.7.5 Uses of the vehicle number tend to be more numerous for wagons and the rail freight business than for other types of traffic; Appendix H examines the mechanics of the use of wagon numbers in various freight systems in more detail. 2.7.6 There is a diverse range of IT systems around Europe, the overwhelming majority of which are discrete national systems. The four country reports included as Appendices D to G give outline details of the national systems used in each. If these are multiplied by the twenty-eight EC, CEEC and EFTA states with national rail systems and customers' and other systems are added in, the investment in the current numbering system can be seen. seen. The costs and implications of changing numbering numbering systems are discussed in Section 7 of this Report. 2.7.7 It should be noted, however, that IT and other systems have a
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2.8 Particular Issues for non-UIC Members
2.8.1 Under current arrangements the UIC mandates UIC leaflet 433 (Standard General Conditions for the introduction into service and operation of privately owned wagons) for the relationship between its member railway undertakings and keepers of privately owned wagons. No UIC provisions exist for the relationship between owners/keepers of privately owned coaches or locomotives and non-member railway undertakings. 2.8.2 The UIC leaflet provides a template contract for the relationship between the vehicle keeper and a railway undertaking. The contract provides for the keeper to ensure that the vehicle is properly maintained and is not modified without approval. 2.8.3 There are terms which lay down a framework for liability for damage caused to or or by the wagon. The railway undertakes to ensure the wagon will be accepted by other railway undertakings and that “Good Samaritan” repair arrangements are in place outside the home country. Within the railway community the mutual inter-railway obligations of the UIC and RIV ensure that the contracting railway undertaking’s obligations can be honoured everywhere the wagon wagon goes. The system
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practical questions. The CUV requires the the home railway to be be marked on the vehicle, where applicable, but is silent on the question of numbering.
2.9 Interface with OSJD
2.9.1 The OSJD (which in role is something of a combination of OCTI, the UIC, RIV and RIC) looks after railway issues in the former COMECON States. As such it represents railways with a number number of gauges, the 1524mm gauge of the former f ormer Soviet Union, the 1435 network of the PRC and PDRK and the metre gauge networks of Vietnam (and indeed the 1435mm railways of the former COMECON states in Eastern Europe). In practice interchange of vehicles between the gauges is rare, although the 1524mm 1524mm network is operated almost as one system. The scope of this report is logically limited to the 1524mm network contiguous with the 1435mm network. 2.9.2 The CIS railways abutting the Western European railways use their own numbering system inherited from SZD. RZD which continues to manage rolling stock issues on behalf of the Commonwealth have a pivotal role in determining future policy. As noted above, above, when interviewed for this study, OSJD declared that RZD would be prepared to
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3. ANALYSIS OF EXISTING SYSTEM
3.1 Legal Compliance
Overview 3.1.1 The following represents the Consortium’s analysis of the legal compliance of the existing system. As the texts of RWP-II and the UNIDROIT Rail Protocol on Matters specific to Railway Rolling Stock are not yet definite, this section does not consider compliance with these rules. Comparison of Specific Rules on Numbering and Registration 3.1.2 The specific rules on registration (under COTIF and the interoperability directives) are, in principle, not mutually irreconcilable. They however contain different principles and requirements. Directive 2001/16/EC, for example, states that “databases are developed in a manner allowing maximum data interchange between different applications and operators”, operators” , while COTIF has a more limited purpose.
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are kept currently, implementation of this obligation is required before 20 April 2003. Directive 91/440/EEC 3.1.6 Directive 91/440/EEC (as amended by Directive 2001/12/EC) creates (limited) equitable and non-discriminatory access rights for railway undertakings to railway infrastructure. Certain aspects of the current numbering and registration process appear to be in conflict with the basic assumptions assumptions of the Directive. UIC members effective monopoly in the allocation of international numbers and the obligation to enter into a contract for use are clear examples of impediments for nonUIC members to exercise their rights and get vehicles accepted into service and numbered for for international operation. The same goes for requirements for non-UIC members to attach their vehicles to a fleet of a UIC member. 3.1.7 Furthermore Directive 91/440/EEC requires a separation of accounts of railway undertakings and infrastructure managers. The Directive prohibits bodies or firms that provide railway transport services to be entrusted entrusted with certain functions functions that relate to infrastructure. These functions, which are “determining equitable and non-discriminatory
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Article 82 of the EC Treaty 3.1.10 Even if Directive 91/440/EEC stills leave scope for the present arrangements (see above), EC competition rules could give rise for concern. Upholding the present practice of numbering and registration by, in general, national railway undertakings, seems to increase the risk of acting contrary to (Article 10 in conjunction with) Article 82 (abuse of a dominant position) of the EC Treaty. Article 81 of the EC Treaty 3.1.11 Another cause for concern could be the compatibility with Article 81 of the EC Treaty. Exchange of confidential data data between competitors could lead to a distortion of competition and therefore be in conflict with Article 81. Under the current arrangements vehicles that are privately owned or owned by a non-UIC railway undertaking have, in practice, to be attached to the fleet of a UIC railway undertaking to be able to operate internationally. This could enable the undertaking undertakingss concerned access to data containing recent, sensitive and individualised information. COTIF
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grounds: the ability to “see” what what competitor’s vehicles are doing via data access rights within railway operational systems is not considered to be compatible with Article 81 of the EC Treaty;
there is currently no rolling stock register as register as will be shortly be required by Directive 2001/16/EC; a future problem is likely since there is currently no International no International Registry of international interests as will be required under the UNIDROIT Protocol on Matters specific to Railway Rolling Stock; there is currently no international database of rolling stock as will be required under the ATMF (COTIF).
3.1.14 As noted above registers of equipment/rolling stock of vehicles in international service are required under Directive 2001/16/EC and Appendix G of of the revised COTIF. The information that is required differs substantially between Directive 2001/16/EC and the COTIF. Accordingly, as the legislation currently stands, separate registers will be required to meet each of these legal requirements. Whilst this is unfortunate it is not considered to be an insuperable difficulty and could be met by reporting options under defined (and differing) access rights from a single database, even if under the strictest interpretation of the phraseology separate separate databases are required. Indeed, as noted in
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3.2 Placing Vehicles in Service
3.2.1 The technical approval process should become neutral for manufacturers, railway undertakings and vehicle owners/keepers, given full and proper establishment of independent notified bodies working to appropriately drafted TSIs. 3.2.2 There are however, other potential impediments to appropriate operation of the Single Market in the process of placing vehicles in service. The primary concerns are processes that are either only undertaken by established railway undertakings or involve attaching vehicles to the fleets of established railway undertakings in order to gain access to a particular market, be it domestic or international. 3.2.3 It is considered that the following functions in the process of placing vehicles in service should be controlled by neutral bodies 2:
allocation of vehicle identifiers;
management of vehicle database/register 3;
arrangements for international use, where these are not tied to a particular railway undertaking (for example in wagonload operations);
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defined in the Directive: the Commission has neither looked into appropriate levels of cover, nor, it is understood would Member States have agreed to any harmonisation of these.
3.3 Numbering Systems
3.3.1 There are a variety of numbering systems, differing substantially in format, presently in use in Europe. The greatest differences occur with the systems used used for traction (locomotives and multiple units). In many cases even the running number format used for locomotives and multiple units differs within the same state. The greatest degree of commonality commonality exists for hauled rolling stock, where the overwhelming majority is numbered under the UIC/OSJD systems, although there are still some significant exceptions. 3.3.2 The majority of the systems systems in use are structured. structured. With these systems, when changes occur to a vehicle, for example its keeper or its operating regime, the vehicle number number changes in response. response. The more complex the numbering system, the greater the instance of running number changes. Where unstructured numbers are used it is much rarer for vehicles to be renumbered, although this still occurs on occasion.
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3.3.5 There are also practical considerations in defining what comprises a vehicle before any new numbering system can be imposed. There are four primary issues here:
the numbering of multi-element vehicles;
major vehicle rebuilds;
innovative concepts: and
which vehicles should be included?
In considering these issues a distinction needs to be drawn between the requirements of a running identifier and those of a permanent identifier, to which the majority majority of these issues are relevant. It should be noted noted that, dependent on the option(s) selected, the definitions adopted for the two types of identifier need not necessarily coincide. 3.3.6 As noted in Section 2 the UIC convention is to renumber the complete vehicle whereas the British one one is to number number the chassis. This results in a British multi-element/articulated vehicle having more than one number whereas elsewhere in Europe it would only have one. Whilst, normally, the only event that results in multi-element/articulated vehicles being reformed is major accident damage, this is still possible. Thus, issues of permanent asset identification are aided by British
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as above but some of the wagons require new bodies and chassis in whole or in part.
There are, of course, an almost infinite number of steps between these and none of the above examples is uncommon. It can be seen that the process of allocating the identity to the chassis makes the process of defining the continuous existence of a vehicle easier, but even then there are questions of degree degree to be resolved. Furthermore, if the chassis is to hold a vehicle’s identity that raises questions about a structured number that in part is determined by its body. 3.3.8 Some innovative concepts have troubled conventional numbering systems, for example, road:railer systems, where the bogies and bodies are randomly disposed and are continually rearranged in use. It is clearly impossible to be prescriptive in this area and the only appropriate approach is to arrive at pragmatic solutions, as presently occurs.
3.4 Functions of Numbering Systems
3.4.1 The functions requiring vehicle identification are as follows:
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to permit staff to identify vehicles (for example, to enable traincrew to find the vehicle to which they have been rostered, defect rectification, etc);
to locate the vehicle for allocation to its next duty, in this context it helps operational staff if the number is of a recognisable type;
as access to systems containing characteristics of a vehicle:
- to enable the infrastructure manager to verify that it is permitted to operate on the infrastructure;
- to enable a rail undertakings to calculate how to operate it in a train;
- for the regime to know what to do with the vehicle next; - to establish vehicle configuration in a reservation system; - for charging between rail undertakings; - for charging customers; - maintenance history and management;
as a contact function;
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arrangements; the system does not encourage fleets composed of wagons based in different states. This is considered considered to have a deleterious impact impact on the proper operation of the Single Market in railway vehicle maintenance services. Nevertheless the Consortium Consortium considers it to be imperative that any (future) system “ensures” that all vehicles in use on Europe’s rail system are maintained to an appropriate standard. 3.5.4 The liability arrangements, which can make railway undertakings liable for the faults of all vehicles attached to their fleet, when in international operation, are not appropriate for railways which do not work in a co-operative co-operative pool. Equally the Consortium Consortium consider it important that whatever system is provided in future it enables proper recompense to be obtained for injuries and damage caused by defective vehicles. 3.5.5 The legal concerns in respect of inequality of access to data have been discussed above. 3.5.6 When the new COTIF takes effect, the simpler provisions of the CUV are likely to influence owners/keepers and railway undertakings to review contractual terms. The Consortium’s Consortium’s discussions indicate that owners/keepers want standard terms signed once with one railway which
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into these arrangements they voluntarily accept the need to make other arrangements
3.6 Access Rights to Systems
3.6.1 The study has highlighted the issues of equality of access to and confidentiality of data systems which use and hold vehicle details and numbers. The problem stems from the historic structure of the rail industry, where monolithic organisations were in complete charge of national rail systems. Accordingly, the architecture of IT systems systems used by railway undertakings and infrastructure managers does not provide internal confidentiality filters. 3.6.2 In time, information systems can be modified or replaced so that they act in a neutral manner manner for all participants. However, this process will inevitably take time and the problem has to be faced in the interim. It is considered that, in general, insufficient attention is being given by the rail industry to development of neutral systems that hold and make use of vehicle information. 3.6.3 There are also issues of confidentiality between railway
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access rights; the former parts of BR have greater access rights to data than other players in some competing areas.
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4. COMPARISONS
4.1 Objective and Terminology
4.1.1 Comparable systems that are used in other modes, in other industries and in other parts of the world have been examined. The objective is to identify requirements that are similar in part or whole to those in the European rail industry and to explore whether there are lessons, systems and concepts that can be learned from these other case studies that could be applicable to rail vehicle vehicl e identification and registration systems in Europe. 4.1.2 The term identifier is used to indicate a coded means of identifying items. A distinction is made between permanent and operating identifiers. The term permanent identifier is used to denote an identifier that uniquely identifies an item and is unchanging. unchanging. Examples include serial numbers, production numbers and international standard number series. The term operating identifier is used used to denote a means means of classing items to enable their retrieval or identification for operational reasons. These may refer to a unique item or to a small class of items;
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4.2.3 To provide an appropriate comparator for rail vehicles an industry needs to exhibit similar needs or operational requirements to those that arise for vehicles in the rail system, at least in part. Other transport modes share, to a greater or lesser degree, the majority of these characteristics, and thus provide some of the most relevant potential comparisons; some examples are aviation, road transport and deep-sea containers. The extent to which which the attributes of these modes modes match rail varies. For example, from this group, only deep-sea containers normally travel unaccompanied. However, there is little or no need for them to be subject to any kind of agreed maintenance regime. On the other hand, the registration process for aircraft and road vehicles includes technical certification to ensure that agreed international and national standards are met. Both these modes modes also have periodic re-certification requirements to verify that the asset remains in a safe condition; there are safeguards to prevent operation without such approval, via the registration process. Despite their imperfect comparability these modes also show some clear similarities in terms of information and mobility that enable useful comparisons to be made. 4.2.4 Relevant examples outside the transport transport field are harder to find. In many cases, a single single permanent identifier is used. In the field of express parcels, unique identifiers are used for the package, but there is no requirement for a permanent identifier, nor an overriding need for the
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4.2.7 In addition a number of essential attributes for the identification system as a whole have also been identified. These can be described in general terms as:
permits operation of the single market;
verification of conformity of item with initial standards; and
verification of continuing conformity of item with standards during its life.
4.2.8 The different identifiers will be assessed to understand how they perform the first five functions listed above. The systems considered will be measured against their ability to satisfy the subsequent three system attributes.
4.3 Other Transport Modes
Road Vehicles Vehicle Approval
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a record of the agreement. The test plan is finalised and the Type Type Approval fees are confirmed. Testing is carried out on the sample product(s) with the Technical Service witnessing the test work as necessary. 4.3.5 Test reports are prepared and the Technical Service provides a complete set of technical documentation and test reports to the approval authority. Subject to a satisfactory review of the submitted submitted documents and CoP assessment, the approval body issues a type approval certificate which authorises the manufacturer to put the "e" mark, or "E" mark, on the product(s). 4.3.6 The following diagram produced by the UK Vehicle Certification Agency illustrates the type approval process:
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Identifiers 4.3.7 Road Vehicles are provided with a unique Vehicle Identification Number (VIN) by the Manufacturer. This is fixed to the chassis on a plate which also usually contains other information about the vehicle for example, model and colour. A Directive makes the use of VINs compulsory for powered vehicles in the EU although a year digit or factory code is not mandatory. mandatory. The format of VINs is described in ISO 3779 and comprises three elements: World Manufacturer Identifier (WMI), Vehicle Descriptor Section (VDS) and Vehicle Identifier Section (VIS). If a year code is used then ISO recommends that that this should be in position 10 while if a factory code is used this should be in position 11. VINs may use capital letters A to Z except I, O and Q and numbers 0 to 9. 4.3.8 The WMI is described in ISO 3780 and occupies the first three positions of the VIN. It is alphanumeric, the first character defines a geographical region, the second a specific country, the third defines the manufacturer. Specific arrangements exist where a manufacturer produces less than 500 vehicles per year. 4.3.9 The VDS occupying positions 4 to 9 of the VIN may be used by
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4.3.13 In most states, including all EU States, vehicles over a set age have to undergo annual safety checks. In some cases this is linked to an annual taxation process which also requires proof of valid insurance before the annual taxation disc disc can be obtained. In other cases (for example, France), insurance is controlled by an insurance vignette on the windscreen. Where there is a linkage, the annual element of the process imposes a check on whether a vehicle is maintained to appropriate standards and is carrying appropriate appropriate insurance. Mutual recognition of these standards applies throughout the EU and a nd Europe. 4.3.14 The VIN is intended to be permanent, and tampering with it will usually be detectable. It is used for definitive identification of the vehicle as well as for reference in case of servicing, recall, etc, with the engine number being used used on a supplementary supplementary basis. The registration number is used for identification of the vehicle in normal use. 4.3.15 Registration numbers differ between states although similar formats exist in different states. However, even where where the format is similar, in combination with the state of registration, the registration number will be unique. unique. The registration number may may contain additional data such as year of registration and/or locality where the vehicle is registered. In some states the registration number changes when when the vehicle changes ownership or its keeper changes his address whereas in
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Table 4.1- Performance of Main Identifier Functions: Road Vehicles Function
How Performed
Permanent Identification
VIN.
Identification of Liability
Based on operating identifier.
Commercial Function
May be based on operating identifier.
Tracking and Tracing
Not required.
Operating Functions
Based on operating identifier or fleet number.
Permits Single Market to Function
Yes. Permanent identifier harmonised. Operating identifier neutrally operated although not harmonised.
Conformity with Standards
Yes. Checked before allocation of operating identifier.
Ongoing Conformity with Standards
Not intrinsic to identifier, but can be linked to issue of other identifying mark, for
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4.3.19 There will also be an operating identifier (the registration mark) allocated by the national aviation regulatory authority painted on to the aircraft exterior. The format is defined in the international standard ICAO Annex 7, so for example the lettering is required to conform to the English alphabet while other requirements relate to size of the characters, colour, slant and position. A fireproof metal plate is also fixed to the aircraft bearing the registration mark of the aircraft. 4.3.20 The format of these registration marks comprises a national identification code, of one or two letters separated by a dash from a following unique code code for the aircraft. Aircraft registration marks do not have to be allocated sequentially, although in many cases they are. It is possible for aircraft owners to request a specific mark, for example incorporating the initials of their company. As an aircraft moves from one operator to another, the registration mark may change, even within the same state. In the UK, for example, example, registration marks are never reused, even if the aircraft has been scrapped or lost. lost. Normally registration marks must be shown but in a few special circumstances (for example preserved ex-military aircraft) some dispensations are possible. 4.3.21 The information linking the registration mark, the construction number of the aircraft, the owner and other relevant information is held by the relevant aviation authority, for example the CAA in the UK and
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Table 4.2 - Performance of Main Identifier Functions – Civil Aviation Function
How Performed
Permanent Identification
Airframe construction number.
Identification of Liability
Based on operating identifier, can be confirmed by airframe number.
Commercial Function
May be based on operating identifier.
Tracking and Tracing
Not required.
Operating Functions
Based on operating identifier.
Permits Single Market to Function
Yes. Operating identifier neutrally operated and harmonised internationally.
Conformity with Standards
Yes. Checked before allocation of operating identifier.
Ongoing Conformity with Standards
Not intrinsic to identifier, but database with information on the operational identifier can store this information and trigger requests.
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Classification 4.3.24 Commercial vessels are classified according to the type of journeys that they are capable of of undertaking. Classifications exist at both national and EU level with some overlap. 4.3.25 The rules relating to ship construction and maintenance are subject to constant revision and updating in line with changes and developments in ship building and current research. Classification sets and maintains standards of quality and reliability. A vessel must conform to the standards required by published rules, and periodic surveys must be carried out, if a vessel is to be classed and class maintained. 4.3.26 The complete process of construction of a vessel must conform to the rules, from the plans plans to the materials used. used. The design is thoroughly assessed to ensure ensure it will cope with likely loads and deformations. This assessment includes 3D finite element analysis and simulation of events such as ingress of water. Every part of the vessel is inspected and approved, from the steelwork to the electrical systems. Any modifications or conversions during its life must also be approved.
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Registration 4.3.28 Registration is a requirement of international maritime law and is the responsibility of national registration authorities. For example, the the official British registration authority is the Registry of Shipping and Seamen in Cardiff and this maintains the central register of UK merchant ships, fishing vessels and pleasure vessels down to a nd including small yachts. .A simplified register is available to private owners of pleasure vessels. 4.3.29 Additional reasons for registering a vessel are to prove its nationality and to use it as security to obtain a marine mortgage, which in turn is registered. When applying to register a vessel, ownership details are therefore fully investigated. investigated. For example, purchasers purchasers of British registered ships can obtain a Transcript of Registry which shows the registered owners of a ship and whether there are any outstanding Mortgages lodged against that vessel. When a vessel is registered, any changes that would affect the Certificate of Registration must be notified. 4.3.30 To register a ship in the UK it is necessary to supply, in addition to the application to register:
declaration of eligibility;
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classification;
shipbuilder;
former names;
survey dates;
date of build;
official number;
navigational aids;
call sign;
cargo facilities;
destined voyage;
speed; manager;
port of registry and flag;
dimensions;
machinery; and
owner.
Comparisons
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to all merchant shipping and crews using a seaport of a Member State or offshore terminal or anchored off such a port or installation. 4.3.37 The Directive places an obligation on Member States to establish and maintain national maritime administrations ("competent authorities") for the inspection of ships in their ports or in the waters under their jurisdiction. Each Member State is under under an obligation to inspect at least 25% of the vessels flying other countries' flags that enter their ports. Selection criteria for deciding which vessels vessels to inspect are laid down. No further inspections are carried out on ships that have been inspected within the previous six months. A list of the certificates and documents documents to be inspected and of the types of inspection to be carried out is laid down, together with the rules to be followed if a more detailed inspection proves necessary. Enhanced controls must must be carried out on on certain categories of higher risk vessels. Table 4.3 - Performance of Main Identifier Functions: Shipping Function
Permanent Identification
How Performed Via continuous updating of international register of operating identifiers.
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sea trade at approximately approximately 5.5% per annum. To facilitate this there are numerous databases, for example for port planning, ship stowage and loading programmes. Many of these utilise container numbers numbers as a basic basic field. 4.3.39 ISO containers have many similarities with rail freight wagons in their method of use and the international codes used were designed to be compatible with AAR AAR freight car codes. codes. The container is transported, unaccompanied, using different powered vehicles and is subject to transhipping at various points on its journey. Backloads may be arranged and there is a need for owners to be able to manage their pool of assets. However, containers have low capital cost, short operational lives and do not require much maintenance. Poor maintenance generally generally only results in damage to the consignment and consequent consequent loss for for the owner. The rugged simplicity of the standard design also means that, other than in a few specialised cases such as tank containers, there is little prospect of a technical failure of the container causing consequential losses to vessels, infrastructure or other containers. Thus the holding holding of insurance by by the container owner or shipper is of little consequence to shipping operators, vessel owners or port authorities. 4.3.40 The International identification code of containers proposed by the Bureau International des Containers (BIC) has been standardised
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4.3.43 BIC does not monitor the positions of containers, or register the individual serial numbers allocated by companies; its database simply contains details of the companies companies registered. A payment must be made by a company to register for a four digit code, of which there are 17 576 possible combinations. 4.3.44 The serial number facilitates international use and temporary admission, and the control of containers, manually or automatically by computerised and/or remote control systems at any stage of the supply chain and especially in intermodal intermodal transport. The code may be be linked in databases with other information for example the contents of the container the stacking position or the origin or destination. Table 4.4 - Performance of Main Identifier Functions: ISO Containers Function
How Performed
Permanent Identification
No, unless there a manufacturer’s serial number is also provided.
Identification of Liability
If appropriate, based on operating identifier.
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Recording Code (ISRC), International Standard Work Code (ISWC), International Standard Audiovisual Number (ISAN), and Digital Object Identifier (DOI). In addition, URNs URNs (Uniform Resource Names) are being developed as an umbrella system for internet use that can accommodate any of the existing identifier systems. 4.4.2 There is considerable similarity between these different systems. Usually each has an international office responsible for allocation of the high level part of the identifier, while individual identifiers are allocated by the body that has registered. In addition an ISO standard usually covers the format of the identifier. Book Identification Systems Selection of Example 4.4.3 Book identification systems have been selected as an example because of their extensive international use, the interplay that exists between them and library cataloguing systems and the way that they have been able to successfully evolve as technology and the market has changed.
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digits in the group number and in the publisher identifier is determined by the quantity of titles planned to be produced by the publisher or publisher group. Publishers or publisher publisher groups with large title outputs are represented by fewer digits. 4.4.8 The first part of the ISBN is a group identifier, identifying a country, area or language area participating in the ISBN system. system. Some members form language areas (for example German language group: 3) or regional units (for example South Pacific: 982). A group identifier may consist of up to five digits. All group identifiers are allocated by the International ISBN Agency in Berlin. 4.4.9 The second part of the ISBN identifies a particular publisher within a group. The publisher identifier usually indicates the exact identification of the publishing publishing house and its address. If publishers exhaust their initial contingent of title numbers, they may be allocated an additional publisher identifier. The publisher identifier may comprise comprise up to seven digits. Publisher identifiers are assigned assigned by the ISBN group agency responsible for the management of the ISBN system within the country, area or language area where the publisher is officially based. 4.4.10 The third part of the ISBN is the title identifier, identifying a
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information about a particular field it is necessary to have a means of pointing to publications that may may be of interest. Different library classification systems have evolved; two well known systems are Library of Congress Classification (LCC) and Dewey Decimal Classification (DDC). 4.4.15 In the LCC system the first character is a capital letter and denotes a broad area such as Law or or Agriculture. Each of these is subdivided by a second capital letter into more discrete subject areas and these are then further subdivided by the addition of numbers for discrete areas. For example, QA76.4 denotes analogue computers, computers, where Q denotes Science and 76 denotes electronic computers. 4.4.16 The Dewey Decimal Classification system (DDC) is similar to LCC but purely numerical. It is a general knowledge knowledge organisation tool that is continuously revised to keep pace pace with knowledge. The system was conceived by Melvil Dewey in 1873 and first published in 1876. DDC is the most widely used library classification system in the world. It is used in more than 135 countries and has been translated into over thirty languages. DDC aims to classify books and other material on all subjects in all languages in every kind of of library. There are one thousand codes for specific areas and then these are further sub divided in a hierarchical manner after a full stop. So for example, 66
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4.4.18 Determination of the different elements of the ISBN is performed by different bodies: ISBN agency, group agency and publisher. Table 4.5 - Performance of Main Identifier Functions: Book ID Systems Function
How Performed
Permanent Identification
ISBN
Identification of Liability
If appropriate, ISBN
Commercial Function
Based on ISBN
Tracking and Tracing
Based on ISBN in commercial applications
Operating Functions
Based on operating identifier
Permits Single Market to Function
Yes. Permanent and Operating identifiers are harmonised. Allocation of codes is neutrally operated.
Conformity with Standards
No.
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4.4.21 These unique identification numbers can be represented by bar code symbols. This enables inexpensive and accurate data capture thus providing the required information at all points of the supply chain. 4.4.22 One of the main concepts of the EAN-UCC system is that any item (product or service) upon which there is a need to retrieve predefined information and that may be priced or ordered or invoiced at any point in any supply chain can be allocated a unique identification number: the Global Trade Item Number Number or GTIN for short. short. 4.4.23 A GTIN can be constructed using four numbering structures depending upon the exact application and bar code structure to be used. However, in databases all GTIN are unique and unambiguous when right justified in a fourteen-digit field. Shorter numbers simply have zeros placed in the left most positions of the identifier. 4.4.24 A number of different arrangements exist, with variations for example, trade items intended to cross the retail point of sale, trade items not intended to cross the retail point of sale, small items and North America. The systems are all fundamentally similar similar and a brief brief description is provided of the numbering structure used for trade items intended to cross the retail point of sale.
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4.4.27 Item reference: this part of the numbering structure is allocated by the user company. company. Each different trade item is allocated a different different number and, for ease of administration, it is recommended that companies do this sequentially (001, 002, 003, etc). 4.4.28 Check digit: EAN- UCC has a standard check-digit algorithm for all GTINs. This is calculated using the preceding digits. Table 4.6 - Performance of Main Identifier Functions – Product Codes Function
How Performed
Permanent Identification
Yes - UPC
Identification of Liability
If appropriate, based on UPC
Commercial Function
Can be based on UPC
Tracking and Tracing Operating Functions
Probably based on warehouse or supermarket aisle location
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the creation of standards; the railroads operate across two countries with largely uniform laws, a single language and similar operating conditions. Mexico in effect has to accept the standards of Canada and the US and largely does so by buying second-hand equipment from the m. Acceptance into Service 4.5.2 Vehicle builders are certified by the AAR as being competent to construct vehicles. Manufacturers, railroads and car owners are all required to sign agreements that vehicles will be built and maintained to comply with AAR technical standards. standards. These standards all include quality systems, so controls on vehicle compliance are all audit based controls with few physical inspections. 4.5.3 North American vehicle designs and the components used in vehicle manufacture are highly standardised, much more so than in Europe. Consequently new designs designs are rare. New designs designs and components are specifically approved by AAR committees on the basis of tests carried out (notably at the railroad Technology Test Center in Pueblo, Colorado) Numbering System
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below). In the case of hauled rolling stock the remainder of the number number comprises up to six digits as a serial number and is defined by the owner. 4.5.6 The code guarantees guarantees unique identification of the vehicle. It permits the identification of the owner or principal operator, and the identification of the vehicle in railroad databases. 4.5.7 The AAR master file is notably comprehensive; this issue is addressed in detail below but of particular interest is the mandatory inclusion of owner (as distinct from the operator) and the cost of the vehicle when new. 4.5.8 The number is used as the key when interchanging equipment between railroads and as a key to extract information for determining the safe load of a vehicle, calculating train weight and length, scheduling maintenance and accounting purposes. 4.5.9 Data from the master file is used in railways’ own railway operating systems, for example when containers are carried on flat cars, the rail wagon and container data both are extracted from the master file for operating purposes.
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equipment contains some 700 characters, highly coded and so a considerable amount of data is held in the file for each vehicle. The majority of the data is physical and permanent. The file also includes ephemeral technical data (for example the brake test date) and commercial data such as exceptional charging information. From the viewpoint of the present study the inclusion of first cost and ledger value of the vehicle is interesting as well as the mandatory requirement for owner as well as operator to be included. A special flag indicates vehicles that are lost lost or stolen. Vehicles that are prohibited prohibited from exchange by the FRA are also indicated. 4.5.13 In summary therefore this file, designed primarily for the purposes of railway operation, is also a lso used for quasi regulatory purposes. It includes both permanent and volatile data but makes no use of a permanent vehicle identifier. Whilst it appears to break several several rules of good practice it nevertheless works. Enforcement 4.5.14 The Agreement to observe AAR standards signed by manufacturers, railroads and car owners likewise commits them to keep vehicles properly maintained. maintained. Again the systems systems to check compliance
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Table 4.7 - Performance of Main Identifier Functions: North American Railways Function
How Performed
Permanent Identification
No
Identification of Liability
If appropriate, based on operating identifier
Commercial Function
Based on operating identifier
Tracking and Tracing
Based on operating identifier
Operating Functions
Based on operating identifier
Permits Single Market to Function
Yes, identifier is neutrally operated and harmonised (Also satisfies US legislation)
Conformity with Standards
In part, owners and builders make separate undertakings to comply with standards.
Ongoing Conformity with Standards
No
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Acceptance into Service 4.5.18 The various operators are required to warrant that their train operations are safe and to register their rolling stock. 4.5.19 Rolling stock is approved by infrastructure managers. Each infrastructure manager works to slightly different standards although there is substantial mutual recognition of equipment and an on-going process (almost complete) of aligning standards to achieve a single Commonwealth set of standards. Numbering System 4.5.20 Despite the fact that the discrete nature of the various operators’ freight services means that numbers need only to be relevant to the operator in question, freight stock is required to be numbered to a common system using the former Railways of Australia system, a system specifically designed to facilitate interchange of vehicles. 4.5.21 The numbering system comprises four letters followed by up to five numbers. The four letters have the meaning owner, main main type, subtype, bogie and braking system. The allocation of a single character for
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The infrastructure managers systems are largely designed to raise charges for infrastructure use. Enforcement 4.5.25 Continuing maintenance is overseen by operators themselves. Operators are required to warrant that equipment is keep in good order and do so using their own systems, normally by a formal quality management system. There is no requirement however for a quality management system. Table 4.8 - Performance of Main Identifier Functions: Australian Railways Function
How Performed
Permanent Identification
No
Identification of Liability
Yes, based on identifier
Commercial Function
Based on identifier
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is the economic powerhouse of the region and traffic to and from South Africa predominates. Nevertheless traffic is exchanged exchanged between all the railways and the majority of the wagon fleets are interchangeable. Passenger rolling stock operates internationally; traction tends not to, but in exceptional cases can do (for example the need to provide hotel power to passenger rolling stock). Acceptance into Service 4.5.27 Each of the states has its own vehicle approval process with common standards agreed under the aegis of the Southern African Railway Association. Approvals are mutually recognised. recognised. Numbering System 4.5.28 Each of the railways concerned numbers all of its vehicles in its own series. All these number series are structured, however the structures are not the same and there has been no attempt to rationalise the numbering sequences between railways. 4.5.29 All vehicles, whatever the number format, are entered on Spoornet’s (South African Railways) computer system Sprint . Sprint has Sprint has
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Table 4.9 - Performance of Main Identifier Functions: South African Railways Function
How Performed
Permanent Identification
No
Identification of Liability
Yes
Commercial Function
Yes
Tracking and Tracing
Yes
Operating Functions
Yes
Permits Single Market to Function No, presumes state railways Conformity with Standards Ongoing Conformity with Standards
No
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Permanent Identifiers Identifiers Use 4.6.4 Across a range of industries permanent identifiers appear to be more commonly used than either operational identifiers or a combination of the two. Most of the transport transport examples discussed illustrate the use of both types of identifier, the notable exception being the rail sector, where the only permanent identifiers are manufacturer’s serial numbers, which have no real official recognition as such. 4.6.5 Virtually all products have unique serial numbers in addition to the types of identifiers described above. The need for a permanent identifier has been solved in the case of road vehicles and aircraft by having a plate fixed to the structure in a manner which makes makes tampering apparent. The use of separate permanent and operating identifiers is particularly notable in the automotive sector, where official government databases handle tens of millions of records linking the two numbers together and holding a wide variety of associated data and where the permanent identifier (VIN) is used for fraud detection, etc. Form
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codes to be recognisable and compatible. Although, for example, North American automotive VINs provide more information than European ones the two systems are still compatible because the extra information is contained in digits that are left for manufacturers’ use elsewhere. Operating Identifiers Use 4.6.10 In other transport modes operating identifiers are common and are usually allocated by State bodies, this being the case for three of the examples considered. 4.6.11 Operating identifiers are less common in non-transport industries, there being no need need in most cases. Indeed none of these other industries considered uses operating identifiers, with the arguable exception of library classification systems. 4.6.12 The character of rail operations means that operating identifiers are de rigueur and rigueur and as one would expect the three non-European rail systems studied studied use them. The fundamental difference with other transport modes is that they are required for the railway industry’s own
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4.6.16 Of the examples considered for railway systems in other parts of the world only North America and Southern Africa involve international operation and in both of these cases disproportionate power has enabled the most powerful state to effectively dictate standards to its neighbours. Compatibility 4.6.17 Compatibility between operating identifiers and the systems that used them is normally achieved by having a standard format, often structured. Databases and Registers 4.6.18 In the examples for other transport modes described, there is in general no international database kept. Instead a national register is kept in each state relating to road vehicles and aircraft. However, in the case of containers, which are unaccompanied, an international database of owners was created. Lloyds Register of Shipping Shipping falls somewhere somewhere between the two being a purely commercial register, which only covers vessels over a set size. 4.6.19 In the case of the examples for rail systems elsewhere in the
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Compatibility Issues 4.6.23 In some of the cases considered for other modes and industries, compatibility issues arise, either from the use of different length identifiers or their containing different amounts of information. Compatibility has been assured between the different formats in these cases. The case of UPCs is interesting, where shorter shorter codes simply have have additional zeros inserted at the left end of the identifier to complete the standard size. A similar system could be posited for rail vehicles which would enable two numbering systems to co-exist without confusion. Systems Issues The Single Market 4.6.24 The requirement for the identifier not to hamper the operation of the single market translates into a number of requirements. From the examples that have been described these can be defined as:
the allocation of identifiers and their management must be performed by a neutral body; the identifier should enable an entity to identify its own assets;
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4.6.27 A potential solution would be for a master database, where the relevant information relating to the vehicles is stored, to be run independently of the users users of the vehicles. If based on a permanent identifier, this database then separately receives from the relevant parties, data on the vehicle from its owner, data indicating insurance from the insurer, and data on technical conformity from the notified body, and these are linked within the database it is possible to effectively check conformity.
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5. INDUSTRY’S INDUSTRY’S VIEWS AND PROPOSALS
5.1 Overview of Section
5.1.1 To date this Report has mainly discussed the current position when placing vehicles in service and identifying them. However, there are a number of potential changes changes that need to be considered. Some of these concern potential changes in the legislative environment, which will require the current arrangements to be amended, where appropriate, and which any proposed revisions to the system for other reasons will need to take account of. Other changes to the the system have been been proposed or are being proposed by interested parties to deal with perceived weaknesses in the system. 5.1.2 This section of the Report commences with a discussion of the proposed legislative changes. This is followed by a summary and discussion of the views obtained on the t he present system and proposals for change in the consultation exercise undertaken as a part of the Study. Finally, some of the schemes to reform the system that have been proposed are briefly discussed.
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article 22bis Directive 96/48/EC 96/48/EC after amendment by RWP-II). The register will cover both conventional stock and high-speed stock 1. 5.2.4 The basic parameters for high-speed rolling stock can be found in Annex II point 3 of the high speed directive (for example, axle loading, maximum train length, gauge of rolling stock, minimum braking characteristics, etc). The requirements requirements for the rolling stock register (e.g. register (e.g. frequency of publication, access rights, etc) are otherwise identical to those already discussed under the current requirements for Directive 2001/16/EC. 5.2.5 The only other, relevant, substantive change is that it is proposed that a new European Railway Agency (ERA) will take over the role of the AEIF. 5.2.6 The requirements for national registers are given in Article 14 paragraph 4 of Directive 2001/16/EC and Directive 96/48/EC, after amendment by RWP-II. The national register covers register covers the same type of vehicles as in the rolling stock register , however in this case the Draft Directive makes it clear that the registration concerns “vehicles put into service”.
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5.2.8 The Draft Directive does not mention how frequently the database will have to be updated. It is considered to be logical however that this this should depend upon upon the purpose of the register. If the register has to play a role in day-to-day operational acts, a corresponding content will obviously be needed; therefore, there will be a requirement to keep the register up-to-date. It is recommended that when when drafting the common common specifications of the register attention should be paid to this aspect. 5.2.9 The body responsible for keeping the register up-to-date must be independent of the infrastructure manager or of any railway undertaking 5. 5.2.10 The draft Safety Directive requires that “national safety authorities” supervise that rolling stock is duly registered and that safety related information in the national register is “accurate and kept up-todate”6. However, the Draft Directive does not not clarify whether the safety authorities would be expected to manage the register by themselves or can delegate. It merely prescribes that the safety authorities are not allowed to transfer their tasks to any infrastructure manager or railway undertaking7. This matches the wording of the interoperability directives (as proposed by RWP-II). 5.2.11 The proposal in the draft legislation is that access rights to the
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Safety Directive 5.2.12 It is proposed that the Safety Directive will apply to the whole European railway system (all sub-systems, including rolling stock). The explanatory memorandum indicates that the directive aims at harmonising safety rules, removing obstacles to a functioning internal market, providing transparency and information about safety issues and investigating accidents and incidents. 5.2.13 The Draft Directive determines, amongst other things, common standards for certification of safety management systems of railway undertakings. The safety certificates issued issued by the national safety authorities will be valid throughout the EU. Safety certification information will be included in a public register maintained by the ERA. When national safety authorities issue, renew, amend or revoke certificates, they will have to inform the ERA. This information that they are required to disclose will be name and address of the railway undertaking, the issuing date, scope and validity of the certificate and in case of revocation, the reasons for the decision. Whilst this does not appear to be directly relevant to the present study the ERA may add to this public list any document or link relevant to the objectives of ERA Regulation8.
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a national register 13.
5.2.17 Under the proposed requirements for a register of licenses and safety documents the ERA must keep lists/registers of the following:
licenses issued in accordance with Directive 95/18/EC;
safety certificates issued in accordance with the Safety Directive;
inspection reports forwarded to the ERA in accordance with the Safety Directive;
national provisions notified to the Commission in accordance with the Safety Directive; and
any document or link that the ERA may deem relevant to the objectives of the ERA Regulation.
5.2.18 Under the requirements for a register of interoperability documents the ERA will be required to hold a list of the following documents:
declarations of verification of subsystems;
declarations of conformity of constituents;
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5.3 Industry Views
5.3.1 A wide variety of views were obtained in the interviews and questionnaires undertaken for the Study, although in the main these could be anticipated from the relative position of the respondents in the railway industry and were reasonably consistent within each part of the industry. In some cases, however, views from different parts of the industry were diametrically opposed. 5.3.2 Manufacturers of rolling stock pressed for unification of procedures and standards. standards. There was a balance of view on whether standards should be prescriptive or whether the objective should be defined but not the means of meeting it. Manufacturers acknowledged that the majority of railway undertakings follow UIC specifications closely but pointed out that in many areas (particularly for tractive stock) specifications and practices are not particularly firm. For hauled rolling rolling stock manufacturers stated that different railways interpreted specifications differently. Given the likely impact of the Interoperability the Interoperability Directives in resolving many of the foregoing issues, i ssues, manufacturers’ principal complaint however was over the timescales, cost and sheer over-burden of the approval process which they pointed out is an impediment to the industry’s competitiveness.
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5.3.6 Wagon owners’ responses were less consistent than other parts of the industry. The same comments were were made as made by manufacturers about the timescales, costs and differing emphases in the approval process. By contrast there there was general satisfaction satisfaction with the relationship with railway undertakings although there was a strong demand for greater international freedom away from national constraints. constraints. This was manifested in particular by a demand to be able to maintain vehicles outside their parent country and for freedom of choice in the maintenance of their vehicles. Concerns were also expressed about the competition implications of attaching their wagons to the fleets of railway undertakings and the consequent ability of railway undertakings to get details of their major customers and flows by tracking through railway IT systems. 5.3.7 Vehicle owners were not in favour of changing the numbering logic because of the costs costs it might involve. involve. They strongly supported a permanent VIN, given the problems under current circumstances of tracing wagon histories as they were successively renumbered. renumbered. Owners also supported the concept of an international database whilst recognising the problems of confidentiality. confidentiality. They favoured any such database being under independent control. Regulatory authorities’ responses were amongst the most incisive,
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5.4 The Vehicle Numbering System
Background 5.4.1 The Vehicle Numbering Study (VNS) was undertaken by Railned, the independent Dutch infrastructure manager. It identified problems linked to the process of UIC railway undertakings providing numbers. The problem identified was that there was no provision for a licensed railway undertaking which was not a member of the UIC with its own two digit code to get twelve-digit numbers for its vehicles without going to such a railway and and presenting these as private vehicles. There was no guarantee that a railway could be found that would accept such vehicles. 5.4.2 Furthermore the apparent status: “private vehicle” was inappropriate and could lead to problems in competition law. Railned noted that in practice twelve digit numbers were essential because the overwhelming majority of railway systems used them. The issue, as perceived by Railned, was to find a solution which preserved enough of the existing structure to be accommodated in existing systems but which allowed these vehicles to be recognised without having to attach them to the fleet of a UIC member.
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(perceived as having significant costs but offering few benefits) became clear, the Railned initiative was taken up again and its author formed one of the group which prepared the RICS study (also see below). Summary of VNS 5.4.7 It is considered that the VNS report was accurate in identifying the problems allocating numbers numbers in the new railway environment. Its solution was simple simple and neat. It made the implicit assumption assumption however that the existing system of allocating numbers for UIC members would continue and that the number was allocated within the industry rather than being a quasi quasi official mark of acceptance. Both these assumptions assumptions are now under examination. Furthermore it did not suggest how the numbers within the series reserved for non-UIC railway undertakings would be allocated, which might be contentious.
5.5 CODIRAIL
5.5.1 The problems with the inadequacy of the current UIC/OSJD railway coding system and the short term palliatives that have been applied have been discussed discussed in Section 2 of this Report. The CODIRAIL
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transitional period in which there would be numbers of differing lengths. Railways were convinced that costs and dislocation would be significant and were likewise convinced that there would be little if any benefit to the commercial business of of running the railway. It was decided therefore not to proceed with allocating fourteen digit numbers to vehicles but instead study if the effects of railway restructuring could be carried through to twelve digit numbers with the specific objective of avoiding mass renumbering of of vehicles. This study became the RICS study which is discussed below.
5.6 RICS Study
Background 5.6.1 The RICS (Railway Interchange Coding System) project emerged from the CODIRAIL project. project. The study was set up to investigate how vehicle numbering could respond to the implications of liberalising the railway industry. The impetus for the project had come from UIC member railways’ refusal on the grounds of cost and disruption to accept a mass renumbering of vehicles to accommodate four digit railway codes. Instead they wanted a twelve digit system which reflected the new
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the number must indicate the organisation which allocated it;
the number should be “meaningful”, it should allow the characteristics of a wagon to be immediately recognised; and
the costs of change should be containable.
5.6.5 Given the driver of a strong resistance to the costs of mass change, it was not surprising that the study reiterated two basic principles:
vehicle numbers should remain at twelve digits and mass renumbering was to be avoided; and
the structure of the number should remain the same as currently with fields for operating regime, parent location, type code, serial number and check digit.
5.6.6 Two further conclusions qualified these findings:
the operating regime field would require to be redefined as an “interoperability” field primarily to indicate compliance with TSIs; and the parent railway undertaking field would be redefined to be the parent state rather than the parent railway undertaking.
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the existing distinction between privately owned and RIV railway owned wagons be continued (under current conditions arrangements for control of these wagons are different). They did however however recognise the possibility of wagons not being part of a RIV railway’s fleet. 5.6.10 The study also recognised the disappearance of railway-owned wagon pools. Some way of indicating vehicles for domestic use use only is also required and the study recommended that this be retained. To the extent that the domestic use is for reasons other than technical, the question of who will allocate numbers and how arises. 5.6.11 The Consortium further note that if the recommendations of the RICS study are adopted, traffic vehicles which are demoted to service use or restricted to domestic operation will still require to be renumbered. This immediately runs counter to the principal of permanence, which the study also recommended. Parent Railway Undertaking 5.6.12 As discussed in Section 2 of this Report, the third and fourth digit of the number is currently the railway undertaking to whose fleet the vehicle is attached. The RICS study recognised that this principle could
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different results from allocating numbers on manufacture. Allocation based on the vehicle’s fiscal home could be logical; it might likewise be logical to use the keeper’s place of business but a mechanism needs to be provided to allow the local competent body to act. Issues of “flags of convenience”, taxation and others have simply been overlooked in the RICS study. For example, the process of numbering by a competent authority clearly implies an ongoing policing role of maintenance and similar issues. This will self-evidently be a problem if the numbering numbering is distant from operation (for example, the vehicle has been approved in Greece but habitually operates in Scandinavia). 5.6.17 The text of the RICS report referring to the state “in which the wagon is registered” would appear to be merely the state in which the official record of the vehicle is held. held. It is unclear if the study study believes this will be the country country of initial technical approval. If it is linked to approval then the issue of how to treat subsequent approval of modifications arises. If it is not linked to approval, the issue issue of how numbers will in practice be allocated becomes acute: if the number is a function of state of approval then issues arise if the vehicle is modified, if it is not linked to approval then the issue of deciding how the number is allocated has to resolved and what policing mechanism there will be. The RICS study team informed the Consortium that the sale of a
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currently more than one thousand wagons of a given type (quite often the case for standard types) additional type codes have to be allocated. Check Digit 5.6.21 No changes were proposed. Allocation of Numbers 5.6.22 The RICS study recognised that it was no longer appropriate for railway undertakings to allocate numbers; it likewise recognised the variety of approaches to railway regulation in the various states and proposed therefore that states devise their own solution to vehicle numbering. This might be numbering numbering by the state itself, by an agency of the state or indeed by the railway industry subject to safeguards which the state might apply. As outlined above, above, unless the process process of numbering is linked to that of approval, the means of allocating numbers will need careful definition. Status of the Study 5.6.23 The recommendations for freight vehicles summarised above
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Traction 5.6.26 The RICS group has produced an interim inter im discussion paper on numbering traction. It observes that despite despite the UIC principles (which (which in any event leaves considerable flexibility), a diverse variety of traction numbering systems are in use. It notes that traction is increasingly increasingly expected to cross frontiers and that the numbering system ought to take account of that. It proposes that any system should create unique numbers but at a minimum cost of migration. 5.6.27 The discussion paper proposes three possible variants, in each case the first digit is 9 (the “traction digit”), the third and fourth digits are the state of registration and the last digit a check digit. The first of these variants is the status quo in which the second digit is a second check digit, the fifth a general type code, c ode, and digits 6 to 11 are series and subseries identifiers and serial numbers. numbers. The second option makes the second digit a general type code and the fifth digit a secondary characteristic code. The last variant is similar similar in making the second second digit a general type of vehicle but this time digits 5 to 11 are allocated to series, sub-series and serial number. The RICS group do not believe that standardisation in the series, sub-series fields is likely to be worthwhile but they see merit in a general type code which indicates traction type and whether a locomotive or unit, etc.
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5.7.2 The remit for the study included design of the functional specification, the data to be held, the overall architecture and the provision of financial estimates. The remit recognised the pre-eminence of freight in the study but also that passenger and tractive stock needed to be taken into account. The contract was placed by the UIC IT department under the tutelage of the Freight Department. The contract for the study was won by the French IT group Steria and the study took its name. 5.7.3 The study had a strongly technical orientation to resolve such issues as the size of files, the structure of the data, transmission protocols etc. Questions of how the proposed database might might mesh into the framework of official databases and how the various parties might have their interests protected were not to be examined by the study although it did take note of the requirements set down in the ATMF. 5.7.4 The study presumed current operating practices, conventional relationships between railway undertakings and the application of existing rules (for example those of the RIV). The Consortium considers considers that this represents a logical base line; current rules are well understood and changes can be be factored in relatively easily. A full analysis of the needs of UIC members, their customers and third parties (for example customs) was made. If implemented, the single largest use of the
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5.7.7 From the viewpoint of the present study, the Steria study provides some pointers to what the railway industry wants to see in a database and how a railway database might be configured in technical terms. It does not, however, address the more fundamental question of whether a single database can adequately respond to official and railway industry needs, the official needs imposed by Directives and COTIF and the railway industry needs for for a real time technical database. Nor does it address the question of how such a multi-purpose database might be managed to reconcile the interests of all the stakeholders.
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6. OPTIONS FOR CHANGE
6.1 Key Objectives
6.1.1 Any system of placing vehicles in service, allocating them with numbers and then storing, accessing and using vehicle data that makes use of the number number must meet a number number of high level objectives. objectives. These high level objectives can be disaggregated into two sets of requirements: absolute requirements and important requirements. requirements. No system which fails to meet every one of the former set can be accepted, whereas it is merely desirable that each of the latter set of requirements is met. 6.1.2 Considering the system as a whole, it is considered that the absolute requirements that the system must meet are as follows:
reconcilability with EC Law;
compatibility with COTIF;
does not obstruct appropriate operation of the Single Market;
be practicable;
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using vehicle data making use of the number that meets every absolute requirement and best meets the important requirements.
6.2 Key Questions
6.2.1 In deriving a system that meets the objectives set there are a number of important questions that must must be answered. These include:
Who should allocate vehicle identifiers?
In what form should vehicle identifiers and data be stored?
How can a database of vehicle information be reconciled between the differing requirements of EC law, other international legal obligations and railway operational requirements?
Who should manage any vehicle database(s)?
What should be the structure of any vehicle database(s)?
Who should have access to what vehicle data?
What constitutes a vehicle?
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6.3 Placing Vehicles in Service and Allocating Identifiers
6.3.1 The issue of technical approval has already been settled by the Interoperability Directives, Directives, thus the key issues are the procedure for allocating identifiers and placing vehicles in traffic. Specifically who allocates numbers and undertakes the administrative necessities associated with placing vehicles in traffic, and safeguarding that this is performed in a neutral and non-discriminatory manner. 6.3.2 It has already been found (see Section 3) that it is inappropriate that the allocation of identifiers and associated processes are undertaken by national railway undertakings in a liberalised environment and that this is considered to be incompatible with Community Law. Accordingly there appear to be nine possible ways that these could be allocated:
by a supranational authority;
by the state1 of vehicle manufacture;
by the state of vehicle approval;
by the state in which the vehicle is used;
by the state in which the vehicle is owned;
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ATMF/COTIF and railway operational requirements2, in particular the specific prohibition on any additional information in the ATMF to that required by the Committee of Experts. Experts . This raises further questions on whether separate databases are required for each and the extent to which these can be linked together, or whether the requirements can be met by differing reporting options from a single database or linked set of databases. Since the option of of a common database or databases meeting each of the above requirements is plainly preferable and is considered by the Consortium’s legal team to be capable of complying with EC and international law only this option has been taken forward. 6.4.3 There are considered to be five main options for the structure of the database(s), as follows:
single central pan-national database;
single central pan-national database, which would drive other pannational databases each forming a discrete register/database meeting a specific requirement (for example rolling stock register , International International Databank , Databank , necessary data, data , railway operating database, etc);
individual national databases linked together to transfer information between them and which also would be linked to a pan-national
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In the case of national databases the main options are considered to be as follows:
by national governments or governmental bodies (for example national rail safety agencies);
by the national infrastructure manager;
by an independent body jointly owned by the rail industry, with membership automatically available to all;
by some other independent national body.
6.4.5 Equitable access rights to information held on vehicle databases and other railway IT systems has emerged as a key issue from this study, there is an important need to balance openness against the needs to restrict access to information that is genuinely confidential. The Consortium have few doubts that there is a tendency on the part of several national railway undertakings to claim that almost anything is confidential and to use this as a protectionist tool to prevent would-be rivals gaining access to vital operational IT systems 3. It is therefore considered vital that firm legal definitions are imposed on the information that can be considered confidential (see Section 9 of this Report for proposed definition). There is a trade-off between access and
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a single rail vehicle and the retention of identity after major rebuilding. The draft TSI for conventional rolling stock provides no definition of what constitutes a vehicle accordingly it is considered that one is needed. It is understood however that the Railway the Railway Working Group established in drawing up the UNDROIT convention has been devel oping a definition of a rail vehicle. 6.5.2 The Consortium does not consider that it is appropriate to list a range of options in this area, accordingly only a recommended definition is given in Section 9.
6.6 Form of Identifier
6.6.1 There are an infinite number of potential numbering systems however it is considered that the list of those that are plausible is limited to those given below in Table 6.1. 6.1. In this table a spot means that the option is plausible/possible, whereas a cross indicates that it is not and has not therefore been considered further. Table 6.1 – Potential Numbering Systems
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Numbering System
Without VIN
With VIN
New system for new vehicles only (existing vehicles retain their old numbers) - modified UIC system
New system for new vehicles only (existing vehicles retain their old numbers) - OSJD system
New system for new vehicles only (existing vehicles retain their old numbers) - AAR system
New system for new vehicles only (existing vehicles retain their old numbers) - structured 12 digit system
New system for new vehicles only (existing vehicles retain their old numbers) - structured 14 digit system
New system for new vehicles only (existing vehicles retain their old numbers) - unstructured 8 digit system
New system for new vehicles only (existing vehicles
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1. Universal means applied to all vehicles operating on a national rail system in Europe. 2. First four digits modified to make non-discriminatory (see below).
6.6.2 In the case of an unstructured system it is assumed that the number will be permanently allocated to a vehicle, it is therefore illogical to combine this with a separate VIN. Accordingly in Table 6.1 for systems where every vehicle in Europe has an unstructured number the options which include an additional VIN have not been included. 6.6.3 It is considered that there are three areas where the current UIC twelve digit system would benefit from modification to better meet Single Market objectives: these are the exchange regime code (first two digits), the railway undertaking identifier (third and fourth digits) and the need to identify TSI compliant vehicles. In the first case a coding system that separately identifies railway owned and privately owned vehicles and demands that they be treated and charged differently has clear problems from a Single Market perspective (whichever way the advantage falls), all vehicle keepers should be able to select their operating regime and charging system. Secondly, as discussed discussed in Section 2, there are insufficient railway undertaking codes for a liberalised environment, the most logical solution appears to be to change the UIC member code to a national identifier. Thirdly, widespread support was
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6.6.5 Whatever numbering system is adopted it is considered that it should be accompanied by symbols and lettering describing the vehicle characteristics as at present. Accordingly there are no alternative options in this regard. However, the extent to which which this information meets meets the needs of the information that would otherwise be contained in any structured number must be considered.
6.7 VIN Issues
6.7.1 If VINs are applied to vehicles it may be appropriate for them to be allocated by different bodies bodies to running numbers. For security reasons it is considered appropriate that any VIN is allocated at the earliest possible stage of a vehicle’s life. It is further considered that it is unimportant whether all vehicles which are allocated VINs are actually built or not; cancellation of orders may result in gaps in number sequences but this is considered to be be of no consequence. consequence. Similarly it is not material whether particular vehicles are approved for operation or not; even if a vehicle is ultimately refused technical approval to operate anywhere on the European rail system it is still an asset on the books of its owners and it also needs to be recorded as a non-compliant vehicle for future reference.
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6.7.4 It is a fundamental principle of a VIN that a number is only allocated once, so that when a vehicle is scrapped, this is marked against the number and it is retired. As there are getting on for two million vehicles in Europe it is clear that an eight digit number would provide a sufficient number of combinations for well over a century into the future. However, if it is desired to structure the number to convey information a greater number of digits will be required to provide the necessary number of combinations. Information which could be be coded within a VIN includes:
manufacturer identity;
plant of manufacture;
state of manufacture;
date of manufacture;
lot or batch information;
state where orderer is based;
type of use manufactured for;
serial number.
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as a part of the overall database(s) of vehicle numbers and data;
discretely as an an International Databank meeting Databank meeting the requirements of Unidroit, but linked to the other database(s).
6.7.7 A VIN would be allocated to a vehicle structure, however, a considerable proportion of the value of a vehicle is invested in its components4. There is therefore a case for major components, which which are transferable to be separately identified and linked to the main VIN in the database, a link which would only be changed if the components were resold or legally exchanged5. The list of components that the Consortium considers should be included is given in Section Sec tion 9. 6.7.8 If a system of VINs is applied it will be desirable to apply them to existing vehicles, so that the system as a whole is “watertight” and workable and so that interests can be registered without need to recall vehicles for marking. marking. Many vehicles already have unique identifier in the form of a manufacturer’s works number, which is often either stamped into the vehicle chassis, painted on the vehicle, or affixed to a plate. However, some of these numbers have have been lost and are, in any case, of differing formats. The following options options for allocating VINs to existing vehicles appear to exist:
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methods of verifying that vehicles are appropriately maintained must be reviewed. 6.8.2 It is considered that the concept of requiring vehicles to be attached to the fleet of a UIC member railway undertaking is incompatible with the free operation of the Single Market. The 1999 COTIF however presumes a contract for use with a railway undertaking to regulate the many interfaces between the parties. This provides a potential legal conduit to funnel the many relationships including those of liability and maintenance6. For example this relationship provides a means to funnel back information on the work the wagon does so that the fleet operator can base his maintenance maintenance on the work the wagon does. It is not yet clear however whether new contracts between keepers and railway undertakings will have universal applicability. If contracts do not cover the entire railway industry then new arrangements are required. The TSIs on maintenance do not appear to provide the necessary safeguards either, for example the high-speed maintenance TSI being concerned with the interfaces with toilet discharge systems and with water and power connections. 6.8.3 Accordingly it is considered that arrangements are put into place providing consistent European rules to verify that vehicles are appropriately maintained, but which also enable a Single Market in
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by the national rail safety authority;
by whoever manages the vehicle database;
self-regulation;
“British solution”, see Appendix F for a description.
Options for Change
6.8.5 The issue of making sure that every vehicle circulating on Europe’s rail system carries sufficient insurance to pay for incidents and damage that they might cause is closely linked to the issue of verifying that vehicles are appropriately appropriately maintained. As has been noted in Section 2 the present indemnity arrangements have become inappropriate for national railway undertakings as they have moved onto more commercial footing. A conventional insurance solution appears inevitable. 6.8.6 It is considered that the solution lies in making each keeper produce a certificate of valid insurance covering the next twelve months, annually. There are a number of bodies which could could manage this process, as follows:
a supranational agency (for example the ERA); national rail safety authorities;
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7. ANALYSIS OF OPTIONS
7.1 Placing Vehicles in Service
Legal Analysis 7.1.1 EC law does not explicitly require a specific procedure for allocating numbers and placing vehicles in service. It merely puts some some limiting conditions on the arrangements. The procedure will have to be neutral and non-discriminatory for all applicants whether UIC-members or not and whether private owners or not. 7.1.2 The question of who should allocate the numbers and place vehicles in service is to be answered by taking into account these same principles. If the body or state that will be charged with the numbering and placing in service is also responsible for safeguarding the neutrality and non-discrimination, this will be difficult to reconcile with the duties of an infrastructure manager (see also RWP-II) and with railway undertaking activities (see especially Directive 91/440/EEC).
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7.1.5 If a system is adopted which operates on a national basis, the issue of which state is actually responsible in each case is a significant one which needs to be clearly defined. As defined in Section Section 6 there are a number of options: options: the state of manufacture, approval, approval, use, ownership, or by any state chosen by the vehicle owner/keeper. Viewed from one perspective it can be argued that it does not particularly matter which option is adopted as long as the matter is clearly defined, since in every case the body will be a responsible governmental organisation. However, the Consortium consider that some options are preferable to others; the option of vehicle keepers selecting an approval state might lead to accusations of “flags of convenience”, however this should also facilitate the Single Market, giving owners/keepers an option if there is problem with the independence of the body responsible in a particular state. It is further considered that there are slight interface advantages if the state concerned is either the state of ownership or the state of use. 7.1.6 The use of an independent body jointly owned by the rail industry as a whole has a number of advantages; the example of Great Britain (see Appendix F) shows just how well such a system can work. work. Potentially it combines the advantages of a pan-European supra-national body with greater flexibility, responsiveness and control over costs. The disadvantages lie in the possibility that a joint industry i ndustry body might become a “closed shop”, shop”, excluding new entrants. However this is merely merely
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considered to be similar to the options of using national governmental bodies from a technical and practical standpoint. Migration Analysis 7.1.9 It is not considered that there are any particular migration issues associated with any of the options; the new organisations or departments can be set up and the associated systems put into place and rapidly introduced, without any impact on any other aspects of the rail industry or any disruption to IT systems, etc.
7.2 Database and Register Issues
Legal Analysis 7.2.1 This issue is closely linked with the numbering and placing in service (see above). If the numbering and placing in service is undertaken by railway undertakings themselves, the institution of an independent body will be required to manage the database, to safeguard the neutrality and non-discriminatory behaviour of the railway
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7.2.5 Technical data for vehicles has been exchanged between railway computer systems for some twenty years to support international freight train operation, albeit not as effectively and universally as would be desired. It is understood that this issue is currently being addressed by a separate research project funded by the EC. Objectives 7.2.6 Different members of the railway industry require differing data to different levels of abstraction abstraction and updated updated to differing standards. The question of an international database therefore needs to be studied as a matrix of different requirements measured against different users. 7.2.7 In designing a database system the objectives of not duplicating data, keeping users close to data and reducing data transfer to a sensible minimum have been adopted. adopted. It has been assumed assumed that in addition to official needs (databases defined under interoperability legislation, those required under COTIF legislation and any needs identified to monitor maintenance and liability) there is a need for railway undertakings and infrastructure managers to have a ready source of authoritative information. This information is to help help them use use vehicles efficiently and safely and include (for example) vehicle capacity and the presence of
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vehicles with the active encouragement of supervisory authorities in the states in question 3. 7.2.10 It is axiomatic that whatever solution is adopted for the international database, railway interests will want to retain a national one for national purposes. It is also most likely that access to databases (to enquire or update) will come from within the state itself. This does not not of course prevent the smaller or more closely linked states in Europe from running common systems and databases in conjunction wit h each other or with other states. An analogy can be seen in North America where despite the central systems provided by Railinc (including UMLER) UMLER) Class 1 railroads all run their own systems. 7.2.11 The option of using national databases would mean that each would have a twin function of being a storehouse of all the data for vehicles from its own state and a temporary storehouse for data for vehicles from other states temporarily temporarily in the state in question. question. The logic of the temporary record being to allow the state with the vehicle the authority to update its record in the case of repair or maintenance work. Single Central Database
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7.2.14 Unless permanent (unstructured) running identifiers are used, the master key to the records will be the VIN (see below). The operating identifier would then be a secondary key. It is to be expected expected that the majority of updates to technical files would be based on the VIN, but the majority of enquiries would be based on the operating identifier. 7.2.15 If permanent unstructured identifiers were adopted the system described above would be practically unworkable, since there would be no national identifier to indicate who should maintain the record and on which database it could be found. Database Management 7.2.16 Management of such a database is clearly an issue that needs to be addressed. EU legislation places the primary duty on Member States and COTIF on its Central Office (but with the power to delegate). The question will be determined by the database structure adopted, however the option of using linked national databases is consistent with this. Nevertheless some supranational management, with real power, is imperative to forge effective links between the national databases and thus make the system work. work. This could possibly be undertaken by the ERA.
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(such as details of technical approvals approvals and compliance records). Lastly the databases need to be enhanced to include all such data that the EC, regulatory bodies, railway undertakings and infrastructure managers consider to be necessary (although most will have been derived from systems which already have this). Input from such groups as the AEIF group on “telematics” can be expected to form a major part of this work. Note that these databases need not be identical in design, but they would need the same “international” functionality. functionality. In view of previous previous poor performance in this area, mandatory specification and enforcement of interfaces will be required. 7.2.20 The programming of appropriate standard data-exchange protocols, the construction of standard confidentiality filters, creation of interfaces with industry partners, documentation and training would follow. 7.2.21 All vehicles from the state in question including those from new entrant railways would then be loaded on to the database. Single Central Database Option 7.2.22 In contrast to the option of using linked national databases, the
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7.3 Form of Identifier
Legal Analysis 7.3.1 The cast in which any new identifier has to be moulded, is not compulsory instructed by EC law. The Commission proposal on changing the interoperability directives merely prescribes an “alphanumeric identification code” that has to be assigned to each vehicle when authorised authorised to enter service. Accordingly it is considered that any of the options identified in Section 6 is equally capable of being compliant with EC law. 7.3.2 Limiting conditions that need to be considered in the preceding statement are the need to safeguard an equitable and non-discriminatory access to the “identifier”. Technical and Practical Analysis Structured and Unstructured Numbers 7.3.3 Of the twenty-six different systems identified the first fundamental issue that needs to be addressed is that of the relative merits of structured
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trainload operations and most information contained in the number is available by studying the markings on the side of wagons and the consignment documents. documents. This issue turns on the value of coded information beyond this extra information, which is available on inspection. The Consortium are not convinced that the the extra value of a structured number in this context is particularly great, although some changes to existing practices might be required (for example consignment notes on all empty wagons where satisfactory universal IT systems do not exist) these should be relatively simple and cheap to implement. 7.3.7 A more significant problem with a move away from structured numbers is that charging systems for the international use of vehicles work off the structure of the vehicle number and that unstructured numbers would destroy the basis of present charging systems. systems. In contrast if structured numbers are retained multi-operator environments can be dealt with through national clearing house type arrangements “piggy backed” onto existing systems. A Change from Twelve Digits 7.3.8 As can be seen in Appendix H twelve digit numbers for hauled
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the CIS area would be less than that of an eight digit system in Europe, which also has a greater functionality. This is supported supported by the discussions held during the course of the study with the OSJD, which expressed willingness, in principle, to adopt a twelve digit system if an appropriate system can be devised. 7.3.11 The other harmonisation measure that would involve a change from twelve digits would would be to adopt the AAR ten digit system. This would have two benefits in that it would create a world standard and it is a system supported by advanced IT systems available on a proprietary basis, which would would facilitate common European IT standards. However, the downsides are considerable: every vehicle in Europe, the CIS, the UIC and OSJD areas would require renumbering and it is an alphanumeric system which would cause significant problems in areas that do not use the Latin alphabet. Continuation of Existing Systems Alongside a New System 7.3.12 It is impractical to renumber over 1.5 million vehicles simultaneously, especially given the geographic area involved and the distribution of vehicles within it. Accordingly old and new systems must must co-exist; this is a migration migration issue, discussed discussed below. This family of
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proliferation of numbering numbering systems. Although since since the international numbering system is still available to owners, where vehicles are exchanged, the situation is less confusing than it might be. 7.3.16 If owners/keepers are to be given freedom of choice, the system can only be workable if there is an agreed common system for vehicles that have to be exchanged or pass between different infrastructure managers. In essence this would would defeat the concept of freedom of choice for most vehicles used on the common European rail system and so it would still be essential that this common system is open and nondiscriminatory. 7.3.17 There appears to be no reason, however, that owners/keepers should not have total freedom of choice for vehicles which are not used on the common European rail system (for example, on isolated lines and networks). Relationship with OSJD System 7.3.18 See above. Information Contained in Operating Identifier
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7.3.22 If a structured number is adopted based on the present twelve digit system one of the obvious characteristics that can be coded in is a national identifier, using the third third and fourth digits digits of the number. The need for a national identifier is governed by two factors: the method of allocating numbers and railway operating practices. If numbers are allocated on a national basis, national coding will be required so that each number is unique. unique. As discussed in Section 2 of this Report national codings are currently used by staff to return vehicles to their “home state” as soon as they are empty. It is however hard to defend the efficiency of this practice, which unquestionably contributes to the poor backload performance of rail. 7.3.23 The next four digits of the existing number are the type code for the vehicle, again these are used by existing IT systems to search for appropriate vehicles to meet traffic needs and their loss is likely to lead to transitional issues. 7.3.24 The extent that the above pieces of information can be accommodated, will be largely governed by the format of the number selected. Sufficient allowance is also required for technical and commercial developments requiring increases in the number of codes required.
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based on AAR or CIS numbering principles. The paragraphs below explain migration paths for those two types of solution. Fundamental Break with the Past 7.3.28 The characteristic of this group of solutions is the abandonment of the existing structured numbering system. system. This existing structured numbering system is currently used for operating, commercial and technical purposes (as explained in Section 2 and in more detail in Appendix H). For this reason alternative means to perform these functions will need to be programmed into railway computer systems before any renumbering renumbering can start. Fortunately the changes currently being made to the RIV system seem likely to align the regimes for railway owned and and privately owned owned vehicles. Nevertheless, the software software changes required to accommodate a change of structure are quite significant, doubly so where the existing twelve digit format is replaced by an alternative format. 7.3.29 If a new number structure also reduces the amount of information held in a number structure as well, the software changes will also require characteristics which are at present implicit to be held explicitly in databases (for example if the state in which the vehicle is based if it were
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7.3.32 Were unstructured numbers to be adopted, given a logic to allocate these numbers, numbers may immediately be allocated to new vehicles. For existing vehicles, given that the database will hold hold details of all vehicles and the logic will be written to extract details from the database rather than rely on structure, there is no need to renumber existing vehicles whether their characteristics change or not. 7.3.33 For options which involve new numbering systems for new vehicles only, whilst new vehicles could use the new system as soon as the appropriate new systems are in place and staff have been trained new vehicles can start be numbered numbered to the new system. system. The problem is that two (potentially incompatible) systems have to run in parallel for several decades, which would cause significant difficulty and cost. 7.3.34 This family of solutions therefore requires significant software work as a precondition precondition of allocation of new numbers. Some new hardware is also required. In addition to the changes in IT systems, systems, staff will have to be trained in their use and in the use of the new numbering system. Existing forms and paperwork which use use the current number format will need to be be redesigned and issued. issued. Once these changes have been put into place, place, new numbers may may be allocated. Some variants require renumbering of existing vehicles, the wholly unstructured variant however is a neat solution in that it requires no renumbering of vehicles.
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7.3.37 Following these software changes, new vehicles may be numbered to the new standards. Some existing vehicles will will definitely be required to be renumbered (such as those operated by minor UIC railways in Italy, Germany and Switzerland). This will need to be put in hand but there is no over-riding reason for accelerated renumbering so the renumbering can be allowed to extend over the full six years of the maintenance cycle. Existing vehicles which are modified or which change their state of registration will require renumbering; this must be done currently because the country and vehicle type elements of the number structure will continue to have meaning. 7.3.38 This family of solutions therefore does not presume significant system changes. They do require renumbering renumbering of some vehicles vehicles (with the numbering considerably depending on the option, f rom perhaps 10 000 to virtually the entire fleet) but over a timescale of six years. Subsequently renumbering will only be required as a function of a change to a vehicle or its circumstances.
7.4 Vehicle Identification Numbers
Legal Analysis
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7.4.3 The allocation of numbers by manufacturers does not mean that involvement by other other parties will not be required. In the first place manufacturers will have to be approved by Government as fit to issue VINs, which in most cases should be a trivial but nonetheless important task. Secondly some other other body will have to gather the VINs from manufacturers and collate them into a register/database (see below). 7.4.4 Some major vehicle construction projects are now delivered through collaborative ventures by consortia of manufacturers. manufacturers. It is therefore necessary to define which manufacturer and plant is responsible for allocating the VIN. It is considered that the manufacturer and plant of final assembly should be responsible for allocating the VIN. Format of VIN 7.4.5 The possible information contained within any VIN will depend to an extent who allocates it. However, if as proposed proposed that these are allocated by manufacturers then it is essential that as a minimum the VIN contains the following:
manufacturer’s ID (identification) code;
unique serial number for the vehicle.
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reasonable and cost effective measure should be taken to make fraudulent misuse of VINs difficult. 7.4.9 In providing a “tamperproof” VIN, stamping the number into the vehicle chassis structure provides the simplest and lowest cost solution. However, some interviewees have expressed reservations about this concept stating that they would resist the measure on the grounds of the potential for stress propagation propagation in aluminium vehicles. It is noted that one wagon lessor interviewed stated that he gets round the problem by stamping the manufacturer’s serial number in the external buffer support gussets. There are two further weaknesses weaknesses with the concept of of stamping. Firstly, the numbers can be difficult to see, particularly once they have been covered by several layers of paint, making casual detection of VINs all but impossible. Secondly, the degree of of fraud prevention is low since it would be relatively easy to deface or remove the original numbers and substitute others. 7.4.10 Well designed cast plates, bearing clear and deep characters, bearing VINs will be more legible, even after a lifetime’s worth of paint has been applied to them. The key to security security lies in the method of fixing: bolted or riveted on plates can be removed easier than even a stamped in identifier, however welded or firmly bonded on plates are Welded or bonded plates can still be ground off or
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Analysis of Options
example), having added value capability6 and being relatively cheap (approximately €100 per vehicle). The disadvantages are that tag readers would need to be installed or issued to staff wherever these needed to be read (albeit these would be far fewer in number than if the tags were used for tracking and tracing), that the tags have a value which would be attractive in some of the less well developed areas where wagons would venture and that the first cost of the tags would be less affordable to users in these areas, particularly as they are unlikely to exploit the additional functionality available. Database Issues 7.4.13 In any database the key issue that needs to be borne in mind is that whilst the VIN of a vehicle many of the other properties associated with it are liable to radical change, for example the running identifier, technical characteristics, etc, in some cases passenger vehicles will even become freight vehicles in the course of their lives. 7.4.14 The concept of VIN that is proposed treats technical approval of a vehicle as a property of a VIN not a condition for the issue of a VIN 7. Likewise the operational identifier is a property of the VIN in the database. Paradoxically however the logic of of the prime use of of the
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Analysis of Options
of vehicles) will then go through the vehicle approval process, as appropriate. The manufacturer must then ask for its vehicles to be registered on the relevant database of its choice providing documentation certifying construction and approval. The database authority authority chosen will, as appropriate, provide operating numbers and enter the vehicles on its database. In this way freedom of choice for technical approval approval is guaranteed, but controls on the status of data being entered on the database are maintained. 7.4.18 Likewise on modification of a vehicle, approval of the modification would be a condition for updating the vehicle record. 7.4.19 The freedom to change state of registration is an important part of a liberal market. In these cases the vehicle vehicle operator will be required to advise both the old and new state, then the record will be transferred and of course a new operating number issued. issued. In compliance with EU and COTIF law no new technical approval will of course be necessary. 7.4.20 It is recommended that the UNIDROIT International UNIDROIT International Register , be entirely separate and free standing, since this will only be required where a financial interest is registered in a vehicle and it is worldwide and needs only the VIN. Accordingly there will be numerous numerous vehicles that appear
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Analysis of Options
Migration Analysis 7.4.22 Apart from the issue of allocating VINs retrospectively to existing vehicles, discussed above, there are not considered to me any particular migration issues in this area, since the introduction of formalised VINs would be a new concept. The issue is merely one of establishing the required systems, databases, etc, which is something that is similar for both options.
7.5 Maintenance and Insurance
Legal Analysis 7.5.1 The concept of requiring vehicles to be attached to the fleet of a UIC member railway undertaking is considered to have a negative effect on a proper operation of the Single Market in railway vehicle maintenance services and is considered to cause concern under EC competition rules. However, the 1999 COTIF requires vehicle keepers to have a “contract for use” with a railway undertaking (not necessarily a UIC member) to regulate the many interfaces between the parties. This provides a potential legal conduit to funnel the many relationships
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Analysis of Options
of confidentiality, for example where an operator has leased his vehicle to a third party there can be a debate about how much data about the operations of that vehicle he he is entitled to. For example, there have been instances in Great Britain in which railway undertakings have refused journey data to the owners of locomotives they have hired. 7.5.5 The data in respect of the work done by individual vehicles cle arly only refers to that vehicle and the format of the number and the nature of the database is irrelevant. By contrast, establishing the basis basis for maintenance requires data to be collected by vehicle type and possibly sub-type. Collection of data at an international level for a type based in many states may indeed be desirable (given that rolling stock manufacturers are increasingly organised at international level and sell at an international level, maintenance programmes organised at an international level are wholly logical). 7.5.6 Recording of maintenance work on the national database is a clear requirement, where the work is done within the state in question that poses few problems, and in most states is already part of normal practices. 7.5.7 Similarly, the Single Market requires that maintenance work can
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Analysis of Options
undertaking the work of monitoring maintenance might not have been involved in the approval process. 7.5.10 Creating these records for maintenance imposes no particular difficulties, indeed most national systems will already have the necessary functionality. Insurance 7.5.11 Most railway undertakings have stop-loss policies covering them against major catastrophes but but are otherwise self-insuring. To be noted noted is that in Great Britain where there is a formal requirement to insure, most railway undertakings have such large excesses that they are, in effect, self-insured. It is to be expected expected that for a number of of reasons (principally those of cost) that this pattern will continue. 7.5.12 Nevertheless there is increasing reluctance within the industry to accept risk without being able to control it and so the “knock for knock” approaches adopted hitherto are likely to be replaced by requirements for formal insurance, at least to cover major claims. These questions lie outside the mainstream of this study. Answers are still being debated but the acceptance of vehicles into traffic, database and numbering system
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Analysis of Options
•
provide an indication of the scale of those costs and benefits; and
•
broadly assess who bears the costs and who are the main beneficiaries.
7.6.2 It is considered that a CBA is only relevant to two aspects of the system: •
the selection of the numbering system itself; and
•
the form of the database or databases holding the information.
It is not considered that there are identifiable differences in quantifiable benefits and costs between aspects such as who allocates identifiers and VINs, in these cases the appropriate option will be selected by the legal and practical requirements and not by the outcome of any CBA. Numbering Systems Options Evaluated 7.6.3 Section 6 identified twenty-eight plausible numbering systems, which with VIN options added produces a grand total of, roundly, fifty options. However, the vast vast majority are either impracticable or fail to comply with the relevant Directives and Regulations and many are
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7.6.6 The second option provides vehicles with two numbers, the first is a permanent vehicle identification number allocated on vehicle approval and then permanent. It is assumed existing vehicles use their existing twelve digit numbers as the permanent ones. In addition to the VIN vehicles would receive a running running number. The running number number taken in this option is a "modified UIC 12 digit system" one. 7.6.7 The third option is similar again a VIN would provide permanence but in addition there would be a fourteen digit running number allocated by any licensed railway undertaking. 7.6.8 Besides examining different numbering options, three implementation options have been considered: •
“Big Bang”;
•
gradual phased approach;
•
new vehicles only.
7.6.9 The Big Bang approach assumes that all vehicle numbers change on a particular day. On a practical level vehicles could be renumbered over for example, a two year period and carry two numbers both the old
Colin Buchanan and Partners
•
•
•
•
•
•
Analysis of Options
opportunity cost: if a vehicle has to be taken out of service to be renumbered then it is not available for revenue earning work; movement cost: applies if a vehicle has to be moved especially to and from workshops to be renumbered; information systems: vehicle numbers are widely used used for a variety of purposes and if a new numbering system is introduced these systems will need to be reprogrammed or data re-entered, there may also be cases where new hardware or telecommunications are needed to allow rail staff to access data sources; training costs: any new system will require staff training which will depend on the extent to which the new system differs from the existing one; operational costs: a substantially different numbering system may take time to “bed in” causing operational problems such as delay in clearing trains and returning empty wagons leading to lost revenues and business; and database use: interrogating databases has a staff cost and a computer time cost.
Colin Buchanan and Partners
Analysis of Options
Measuring Costs and Benefits 7.6.16 Europe’s national railway systems differ markedly in terms of efficiency, exposure to competition, type of traffic carried and cost structures. This has meant that measuring the costs and benefits attributable to each option is subject to a degree of uncertainty and should be regarded as indicative. 7.6.17 Costs are highly dependent on the speed with which any new system is introduced. introduced. For example, if any new numbering scheme scheme is introduced over a six year timeframe, then vehicles could be renumbered during their standard maintenance cycles and no additional movement costs would be be incurred. However, if it was proposed to transfer between between the present and a new numbering system “overnight” then enormous costs would be incurred in both moving vehicles to workshop and in lost revenues as the total rail fleet was taken out of service. Appendix J sets sets out the costs and benefits and assumptions used in deriving the following results. Results 7.6.18 Tables 7.1 and 7.2 set out the results for the four options and
Colin Buchanan and Partners
Analysis of Options
Table 7.1- Evaluation of Number Format Minimum Benefits (€ net present value) Base Option Gradua Graduall
Total Cost
Big Bang Bang
Random 12 Digit
New New Vehicl Vehicles es
Gradua Graduall
Big Bang Bang
New New Vehic Vehicles les
15,0 15,000 00,0 ,000 00
18,0 18,000 00,0 ,000 00
13,0 13,000 00,0 ,000 00
124, 124,00 000, 0,00 000 0
144, 144,00 000, 0,00 000 0
93,0 93,000 00,0 ,000 00
Total Benefit
150, 150,00 000, 0,00 000 0
150, 150,00 000, 0,00 000 0
150, 150,00 000, 0,00 000 0
150, 150,00 000, 0,00 000 0
150, 150,00 000, 0,00 000 0
150, 150,00 000, 0,00 000 0
Net Benefit
135 135,000,00 ,000
132, 32,000,000
137,00 ,000,000
26,000, 00,000
Two Numbers Gradua Graduall
Total Cost
Big Bang Bang
6,000,000 000
57,0 7,000,000
14 Digit
New New Vehicl Vehicles es
Gradua Graduall
Big Bang Bang
New New Vehic Vehicles les
62,0 62,000 00,0 ,000 00
123, 123,00 000, 0,00 000 0
56,0 56,000 00,0 ,000 00
156, 156,00 000, 0,00 000 0
234, 234,00 000, 0,00 000 0
75,0 75,000 00,0 ,000 00
Total Benefit
187, 187,50 500, 0,00 000 0
212, 212,60 600, 0,00 000 0
187, 187,50 500, 0,00 000 0
187, 187,50 500, 0,00 000 0
212, 212,60 600, 0,00 000 0
187, 187,50 500, 0,00 000 0
Net Benefit
125, 125,50 500, 0,00 000 0
89,6 89,600 00,0 ,000 00
131, 131,50 500, 0,00 000 0
31,5 31,500 00,0 ,000 00
-21, -21,40 400, 0,00 000 0
Table 7.2- Evaluation of Number Format Maximum Benefits (€ net
112, 112,50 500, 0,00 000 0
Colin Buchanan and Partners
Analysis of Options
the Big Bang (that is, rapid introduction of the system) is the best performer given that there is more uncertainty concerning costs than benefits and the practical difficulties it may be more appropriate to go for the new vehicle or gradual introduction options. 7.6.20 If the two number option was chosen then the net present value under the gradual option would range from €125m to €1813m 7.6.21 The costs of any new scheme would fall heavily on existing railway undertakings and (if successful in improving rail’s competitiveness and market share) share) on road hauliers. The benefits would accrue mainly to non-UIC member member railways and to society. The latter arising from increased competition on the rail network leading to reduced haulage costs for users and a reduction in environmental and road congestion costs arising from modal switch from road to rail. Form of Databases 7.6.22 With regard to setting up and operating the requisite database, three options have been considered •
a central fully populated database with links to national databases
Colin Buchanan and Partners
Analysis of Options
Table 7.2 - Evaluation Matrix – Attributes of Identification System
Essential Requirements
Option
Property
Weight Existing System Single Central
r e t s i g e R / e s a b a t a D
h t i w y t i l i b i t a F p I m T o O C C
t c u r t s t e b k O r t a o M n e l s e g n o i D S
n/a n/a
n/a
n/a
x
x
x
x
x
h t i w e l b a l i c w n a L o c e U R E
Desirable Requirements n o i t a s v e o t n a n d I o l a m i c m n o h c c c e A T
w e N s e t a d o m s e c m i t o c c a c r A P
c r r u . o t f S s t . t n c i a a r r t t s n n o o C C w o e N N
y t b s a . a t e p r e a c r c g a o l e a g m l l i a x a r o M f
20%
10%
10%
10%
-
-
-
P
-
-
y t i l i b a c i t c a r P
s s e n e v i t c e f f E t s o C
n/a
n/a
s r k o t a f s r e t d n n i a r U t s l n y o R C w o e N N
e l c i h e V l l a s r e s e v p o y C T
n/a
n/a
x
P
e r u t u F r o f y t i l i b i x e l F
h t i w s s r e e c m a f o t r e s t u n C I
. s g h e t R u h A t i t v w o s G e c & a . f t r e n t o n C I
s r e h d t i i v w o r s P e c e a c f i r e v r t e n S I
Total
20%
10%
10%
10%
100%
-
-
-
-
-
0%
-
-
-
-
-
-
0%
Central: Driving Other Pan-National
P
P
5
7
7
9
8
8
9
9
55%
Linked Individual National: Driving Pan-Nat Database
P
P
6
7
7
9
8
8
9
9
57%
7
7
8
9
9
9
9
9
83%
-
-
-
-
-
-
-
-
0%
Independent Nat: Driving Virtual Pan National Database Independent No Interfaces
Nat:
x
x
x
7-29
Colin Buchanan and Partners
Analysis of Options
Essential Requirements n o i t a v s e o t n a n d I o l a m i c m n o h c c c e A T
w e N s e t a d o m s e c m t o i c c a c r A P
c r r u . t o f S s . t t n c i a a r r t t s n n o o C C w o e N N
y t b a . s a t e p e r a c r c a g l o e a g m l l i a x a r o M f
20%
10%
10%
10%
Supranational Authority
8
6
6
State of Manuf
7
5
State of Approval
7
State of Use
e r u t u F r o f y t i l i b i x e l F
h t i w s s r e e c m a o f r t s e t u n C I
. s g t e h R u A h t t i v w o s e G c & a . f r t e n t o n C I
s r e h i d t i v w o r s e P c e a c f r i e v r t e n S I
Total
20%
10%
10%
10%
100%
8
4
4
8
5
61%
5
8
6
5
7
5
61%
5
5
8
6
5
7
5
61%
7
5
5
8
6
6
7
5
62%
Owner’s State
7
5
5
8
6
6
7
5
62%
Any State
7
5
5
8
6
5
7
5
61%
7
7
6
7
6
7
5
7
55%
-
-
-
-
-
-
-
-
0%
-
-
-
-
-
-
-
-
0%
Option
Property
Weight
y B n o i t a c o l l A r e b m u N g n i n n u R
Desirable Requirements
h t i w e l b a l i c w n a o L c e U R E
n/a n/a
h t i w y t i l i b i t a F p I m T o O C C
t c u r t s t e b k O r t a o M n e l s e g n o i D S
n/a
n/a
Independent Rail Industry Body
y t i l i b a c i t c a r P
s s e n e v i t c e f f E t s o C
n/a
n/a
s r k o t a f s r e t d n n i a r U t s l y n o R C w o e N N
e l c i h e V l l a s r e s e v p o y C T
n/a
n/a
P
Licensed Rail Und.
x
Infrast. Manager
x
x
P
7-30
Colin Buchanan and Partners
Analysis of Options
Essential Requirements
Option
Property
Weight r e No VIN b m u By Manufacturer N n o n i o By Approval Body t a i c t a i c f i o t l l By Supranat Auth n e d A I e By State l c i h e By Rail Industry V
h t i w e l b a l i c w n a o L c e U R E
n/a n/a
h t i w y t i l i b i t a F p I m T o O C C
t c u r t s t e b k O r t a o M n e l s e g n o i D S
n/a
n/a
y t i l i b a c i t c a r P
s s e n e v i t c e f f E t s o C
n/a
n/a
Desirable Requirements s r k o t a f s r e t d n n i a r U t s l y n o R C w o e N N
e l c i h e V l l a s r e s e v p o y C T
n/a
n/a
P
P
n o i t a v s e o t n a n d I o l a m i c m n o h c c c e A T
w e N s e t a d o m s e c m t o i c c a c r A P
c r r u . t o f S s . t t n c i a a r r t t s n n o o C C w o e N N
y t b a . s a t e p e r a c r c a g l o e a g m l l i a x a r o M f
20%
10%
10%
10%
5
10
10
8
10
8
e r u t u F r o f y t i l i b i x e l F
h t i w s s r e e c m a o f r t s e t u n C I
. s g t e h R u A h t t i v w o s e G c & a . f r t e n t o n C I
s r e h i d t i v w o r s e P c e a c f r i e v r t e n S I
Total
20%
10%
10%
10%
100%
10
3
10
1
1
48%
8
10
6
10
6
4
76%
7
7
10
7
10
7
4
75%
7
6
6
10
6
10
6
4
68%
6
7
7
10
7
10
7
5
72%
7
7
7
10
5
10
5
6
69%
Key
P x
= = =
Fully meets essential requirement. Does not fully meets meets essential requirement, but but achieves minimum permissible standard, 10% deducted from Total Score. Score. Does not meet essential requirement, option rejected.
7-31
Colin Buchanan and Partners
Analysis of Options
7.7.2 It can therefore be seen that on the basis of the above that: •
•
•
•
•
continuation with the existing system is not an option (as previously noted); the preferred database option is for a series of independent national databases containing vehicle data linked together to provide a virtual pan-European database; there is a demonstrable advantage in the acceptance of vehicles into traffic and issuing them with numbers being undertaken by a governmental agency either nationally or on a pan-European basis, however there is little difference in score between any of the options for this; there is a clear preference for a separate VIN from a holistic perspective; in respect of the decision on who should allocate VINs, the highest scores were for either the manufacturers or the approval body to allocate it.
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Analysis of Options
Table 7.3 - Evaluation Matrix – Attributes of Identifier Systems Using Running Numbers Only (No Vehicle Identification Numbers)
Essential Requirements
Option
Property
Weight
. t c f u r o t r e S i e e f l u i c q t n i i h e e n d U I V
y r o t a n i m s r t - i c h n s g o i i N D R
n/a
n/a
Existing Systems
x
x
Universal UIC 12 digit
x
x
Universal Mod UIC 12 digit
x
Universal OSJD 8 digit
x
Universal AAR 10 character
x
Universal 8 Digit Structured
r o f r e t y e i i i u f i t l q b i n a e i n d U I L
n/a
y t i l m i b u t a m p i e x a c c M A
s l s e a n t o a s r i t t a i e r l v i e c i a n p F U O
l a c i g o L e r & t u r c a u e t r l C S
s u e i o l b v s i e t a r m p P e m h t i s o t y C w S
e U l b E i n s t a o m p n e m h t i s o t y C w S
e t n p a y & i l T l e p s c m e i o t a h c e C i V I d f S n I o T
s l i a t e D s e t t c a t a c n i d o n C I
g n i k c e h C f l e S
Total
25%
15%
15%
10%
10%
5%
5%
-
-
-
-
-
-
-
-
0%
P
-
-
-
-
-
-
-
-
0%
P
-
-
-
-
-
-
-
-
0%
P
P
-
-
-
-
-
-
-
-
0%
P
x
-
-
-
-
-
-
-
-
0%
x
x
-
-
-
-
-
-
-
-
0%
Universal 10 Digit Structured
x
x
-
-
-
-
-
-
-
-
0%
Universal 12 Digit Structured
x
P
-
-
-
-
-
-
-
-
0%
Universal 14 Digit Structured
x
x
-
-
-
-
-
-
-
-
0%
P
n/a
e v i t c e f f E t s o C
15%
P
n/a
r o f r e e i e i u f t g r q i n a e h n d U I C
Desirable Requirements
7-33
100%
Colin Buchanan and Partners
Analysis of Options
Essential Requirements
Option
Property
Weight
. t c f u r o t r e S i e e f l u i c i q t n i h e e n d U I V
n/a
y r o t a n i m s i t - r c h n s g o i i N D R
n/a
r o f r e t y e i i l i u f i t q n b i a e i n d U I L
n/a
r o f r e e i e i u f t r q n g i a e h n d U I C
n/a
Desirable Requirements e v i t c e f f E t s o C
y t i l m i b u t a m p i e x a c c M A
s l s e a n o t i a s r t i e t a l v r i i e c n p a F U O
l a c i g o L e r & t u r c a u e t r l C S
s u e i o l b v i e s t r a P m p e h t m i s o t y C w S
e U l b E i n s t a o m n p e h t m i s o t y C w S
e t n p a y & i l T l e p s c m e i o t h a c e C i V I d f S n o T I
s l i a t e D s e t t c a t c a i d n o n C I
g n i k c e h C f l e S
Total
n/a
15%
25%
15%
15%
10%
10%
5%
5%
100%
Univ. Unstructured 8 Digit
x
-
-
-
-
-
-
-
-
0%
Univ. Unstructured 12 Digit
P
5
4
0
5
1
0
0
10
21%
-
-
-
-
-
-
-
-
0%
New System for New Vehicles Only – Modified UIC system
x
P
P
New System for New Vehicles Only – OSJD system
x
P
P
P
-
-
-
-
-
-
-
-
0%
New System for New Vehicles Only – AAR system
x
P
P
x
-
-
-
-
-
-
-
-
0%
New System for New Vehicles Only – Structured 12 digit
x
P
P
-
-
-
-
-
-
-
-
0%
New System for New Vehicles Only – Structured 14 digit
x
P
P
x
-
-
-
-
-
-
-
-
0%
P
P
P
-
-
-
-
-
-
-
-
0%
New System for New Vehicles Only – Unstructured 8 digit
7-34
Colin Buchanan and Partners
Analysis of Options
Essential Requirements
Option
Property
Weight
. t c f u r o t r e S i e e f l u i c i q t n i h e e n d U I V
n/a
y r o t a n i m s i t - r c h n s g o i i N D R
n/a
r o f r e t y e i i l i u f i t q n b i a e i n d U I L
n/a
r o f r e e i e i u f t r q n g i a e h n d U I C
n/a
New System for New Vehicles Only – Unstructured 12 Digit
Desirable Requirements e v i t c e f f E t s o C
y t i l m i b u t a m p i e x a c c M A
s l s e a n o t i a s r t i e t a l v r i i e c n p a F U O
l a c i g o L e r & t u r c a u e t r l C S
s u e i o l b v i e s t r a P m p e h t m i s o t y C w S
e U l b E i n s t a o m n p e h t m i s o t y C w S
e t n p a y & i l T l e p s c m e i o t h a c e C i V I d f S n o T I
s l i a t e D s e t t c a t c a i d n o n C I
g n i k c e h C f l e S
Total
n/a
15%
25%
15%
15%
10%
10%
5%
5%
100%
P
7
3
0
8
1
0
0
0
21%
Own System/Modified UIC
x
P
P
P
-
-
-
-
-
-
-
-
0%
Own System/OSJD
x
P
P
P
-
-
-
-
-
-
-
-
0%
Own System/AAR
x
P
P
x
-
-
-
-
-
-
-
-
0%
Own System/Struct. 12 digit
x
P
P
P
-
-
-
-
-
-
-
-
0%
Own System/Struct. 14 digit
x
P
P
x
-
-
-
-
-
-
-
-
0%
Own System/Unstruct. 8 digit
x
P
P
x
-
-
-
-
-
-
-
-
0%
Free Choice of System
x
x
x
-
-
-
-
-
-
-
-
0%
Key
P x
= = =
Fully meets essential requirement. Does not fully meets meets essential requirement, but but achieves minimum permissible standard, 10% deducted from Total Score. Score. Does not meet essential requirement, option rejected.
7-35
Colin Buchanan and Partners
Analysis of Options
Systems Using Separate Running and Vehicle Identification Numbers
Essential Requirements
Option
Property
Weight
. t c f u r o t r S e e i e f l u i c t i q i n e h n d e U I V
n/a
y r o t a n i m s r t - i c h n s g o i i N D R
n/a
r o f r e t y e i i i u f i t l q b i n a e i n d U I L
n/a
r o f r e e i e i u f t g r q i n a e h n d U I C
n/a
Desirable Requirements e v i t c e f f E t s o C
y t i l m i b u t a m p i e x a c c M A
s s e l a n t o s i a r t t e a i l v r i i e c a n p F U O
l a c i g o L e r & t u r c a u e t r l C S
s u e i o l b v i e s t a r m p P e m h t i s o t y C w S
e U l b E i n s t a o m p n e m h t i s o t y C w S
e t n p a y & i l T l e p s c m e i t o a h e C c i V I d f S n o T I
s l i a t e D s e t t c a a c t i n d o n C I
g n i k c e h C f l e S
n/a
15%
25%
15%
15%
10%
10%
5%
5%
Total
100%
Existing Systems
x
P
-
-
-
-
-
-
-
-
0%
Universal UIC 12 digit
x
P
-
-
-
-
-
-
-
-
0%
P
8
9
8
9
10
10
5
10
78%
P
2
9
2
3
10
0
0
0
3%
Universal AAR 10 character
x
-
-
-
-
-
-
-
-
0%
Universal 8 Digit Structured
x
-
-
-
-
-
-
-
-
0%
Universal 10 Digit Structured
x
-
-
-
-
-
-
-
-
0%
Universal 12 Digit Structured
P
7
9
10
7
8
10
10
10
77%
Universal 14 Digit Structured
x
-
-
-
-
-
-
-
-
0%
Universal Mod. UIC 12 digit Universal OSJD 8 digit
P
P
P
7-36
Colin Buchanan and Partners
Analysis of Options
Essential Requirements
Option
Property
Weight
. t c f u r o t r e S i e e f l u i c i q t n i h e e n d U I V
n/a
y r o t a n i m s i t - r c h n s g o i i N D R
n/a
r o f r e t y e i i l i u f i t q n b i a e i n d U I L
n/a
r o f r e e i e i u f t r q n g i a e h n d U I C
n/a
Desirable Requirements e v i t c e f f E t s o C
y t i l m i b u t a m p i e x a c c M A
s l s e a n o t i a s r t i e t a l v r i i e c n p a F U O
l a c i g o L e r & t u r c a u e t r l C S
s u e i o l b v i e s t r a P m p e h t m i s o t y C w S
e U l b E i n s t a o m n p e h t m i s o t y C w S
e t n p a y & i l T l e p s c m e i o t h a c e C i V I d f S n o T I
s l i a t e D s e t t c a t c a i d n o n C I
g n i k c e h C f l e S
Total
n/a
15%
25%
15%
15%
10%
10%
5%
5%
100%
New System for New Vehicles Only – Modified UIC system
P
10
5
8
10
6
4
6
5
60%
New System for New Vehicles Only – OSJD system
x
-
-
-
-
-
-
-
-
0%
New System for New Vehicles Only – AAR system
x
-
-
-
-
-
-
-
-
0%
New System for New Vehicles Only – Structured 12 digit
P
7
5
8
7
6
4
7
5
52%
New System for New Vehicles Only – Structured 14 digit
x
-
-
-
-
-
-
-
-
0%
10
5
3
10
6
2
5
0
38%
Own System/Modified UIC
P
P
Own System/OSJD
P
P
P
3
5
1
4
8
0
0
0
3%
Own System/AAR
P
P
P
1
4
2
2
1
0
5
0
0%
7-37
Colin Buchanan and Partners
Analysis of Options
Essential Requirements
Option
Property
Weight
. t c f u r o t r e S i e e f l u i c i q t n i h e e n d U I V
n/a
y r o t a n i m s i t - r c h n s g o i i N D R
n/a
r o f r e t y e i i l i u f i t q n b i a e i n d U I L
r o f r e e i e i u f t r q n g i a e h n d U I C
Desirable Requirements e v i t c e f f E t s o C
y t i l m i b u t a m p i e x a c c M A
s l s e a n o t i a s r t i e t a l v r i i e c n p a F U O
l a c i g o L e r & t u r c a u e t r l C S
s u e i o l b v i e s t r a P m p e h t m i s o t y C w S
e U l b E i n s t a o m n p e h t m i s o t y C w S
e t n p a y & i l T l e p s c m e i o t h a c e C i V I d f S n o T I
s l i a t e D s e t t c a t c a i d n o n C I
g n i k c e h C f l e S
Total
n/a
n/a
n/a
15%
25%
15%
15%
10%
10%
5%
5%
Own System/Struct. 12 digit
P
P
P
9
5
4
8
6
2
5
0
25%
Own System/Struct. 14 digit
P
P
P
7
5
4
7
3
2
5
0
17%
P
7
9
8
9
10
10
8
10
78%
P
2
9
2
3
10
0
3
5
7%
AAR System, VIN Tagged Electronically
x
-
-
-
-
-
-
-
-
0%
St. 12 Digit Syst, VIN Tagged Electronically
P
6
9
10
7
8
10
10
10
75%
St. 14 Digit Syst, VIN Tagged Electronically
x
-
-
-
-
-
-
-
-
0%
-
-
-
-
-
-
-
-
0%
Mod UIC System, VIN Tagged Electronically OSJD System, VIN Tagged Electronically
Free Choice of System
P
P
x
P
x
7-38
100%
Colin Buchanan and Partners
Analysis of Options
Key
P x
= = =
Fully meets essential requirement. Does not fully meets meets essential requirement, but but achieves minimum permissible standard, 10% deducted from Total Score. Score. Does not meet essential requirement, option rejected.
7-39
Colin Buchanan and Partners
Analysis of Options
7.8.1 Only the following options achieved positive scores (in descending order): •
•
•
•
•
•
•
•
universal modified UIC 12 digit system and VIN (78%); universal modified UIC 12 digit system and VIN tagged electronically (78%); universal 12 digit structured system and VIN (77%); universal 12 digit structured system and VIN tagged electronically (75%); new system for new vehicles only - modified UIC 12 digit system and VIN (60%); new system for new vehicles only - 12 digit structured system and VIN (52%); vehicle keepers free to choose between a system of their own and modified UIC 12 digit system and VIN (38%); vehicle keepers free to choose between a system of their own and 12 digit structured system and VIN (25%);
Colin Buchanan and Partners
Conclusions
8. CONCLUSIONS
8.1 Organisational
8.1.1 It is considered that the present system of allocating vehicle numbers and placing vehicles into service is not compatible with either EC law or EU policy objectives. Furthermore there are no vehicle databases/registers that meet the forthcoming requirements of EC Directives, the COTIF and Unidroit. It is therefore considered that the present system is insupportable and must must change. Accordingly the only issues that need be considered further are what the system must be changed to. 8.1.2 It is anticipated that technical acceptance issues should be resolved once independent notified bodies and appropriately drafted TSIs are in place. 8.1.3 All administrative procedures associated with placing vehicles in service, including the allocation of running identifiers needs to be placed in the hands of independent bodies which have no organisational links
Colin Buchanan and Partners
Conclusions
8.2 Technical
8.2.1 If the requirements to provide a unique identifier are to be met with a single number this can only be accomplished via an unstructured number. If a structured number is to be provided then a Vehicle Identification Number will be required in addition to a running identifier. The VIN would become the official identity determinant of any vehicle and vehicle databases would use the VIN as the file reference in a vehicle record file. 8.2.2 At present the majority of hauled vehicles in the EU carry twelve digit numbers, there are significant costs and migration issues associated with changes to this format. The number is structured and this structure structure is used by current IT and manual systems, for migration reasons it is desirable that this format is changed as little as possible in achieving a system that is legally compliant and has the maximum cost effectiveness. 8.2.3 It is considered that the only sensible form of vehicle database is one which is structured on a national basis with effective links that create a virtual single European database. Whilst each national database should be managed by national governmental bodies it is considered that these links need to be overseen and enforced by a pan-European body.
Colin Buchanan and Partners
Recommendations
9. RECOMMENDATIONS
9.1 Organisational Recommendations
Placing Vehicles in Service 9.1.1 It is recommended that the EC takes steps to ensure the independence of notified of notified bodies in all EU states. 9.1.2 It is recommended that railway undertakings, any subsidiary company of a group containing a railway undertaking, or any staff employed either directly or indirectly by railway undertakings cease to play any role in the process of placing vehicles in service, allocating them with numbers and placing them on databases and common operational systems, other than as an applicant for their own vehicles, and this be expressly expressly prohibited. It is considered that these tasks can only be undertaken by one of the following bodies:
supra-national government agency; by independent national government agencies;
Colin Buchanan and Partners
Recommendations
recommended that effective interfaces between them are supervised and mandated by a pan-national body, such as the ERA, which would also be responsible for ensuring that these drive separate virtual databases required under the the Interoperability Directives and COTIF. 9.1.6 It is recommended that the International the International Registry that is to be required under UNIDROIT is made a free standing and separately managed database. Access to Systems 9.1.7 It is recommended that vital railway national IT systems that make use of vehicle numbers and data (for definition see Appendix I, for example operating systems, capacity management tools, tracking and tracing systems, train planning systems, infrastructure charging systems, etc) be removed from the control of national railway undertakings where this occurs and vested in neutral bodies, such as the infrastructure manager, governmental bodies or joint industry bodies open to all. National railway undertakings should continue to retain any internal commercial systems and management tools associated with these, but this disaggregation should be entirely their own responsibility and failure to do so or to remove confidential information should not be a reason to
Colin Buchanan and Partners
Recommendations
commercial contracts with third parties; business planning systems and information; internal financing information any private systems developed after national operating systems have been vested in a neutral agency and opened to all legitimate users and potential users.
Maintenance and Insurance 9.1.10 In the European Single Market vehicle owners and keepers must have the freedom to determine the maintenance regime for their vehicles and who undertakes undertakes this work. It is recommended that keepers keepers are forced to have the adequacy of their maintenance regime and the maintainer certified by a notified body on an annual basis. The state in which the vehicle is registered would then be responsible for verifying that this has been obtained on the due date and for withdrawing approval for the vehicles concerned should this approval not be obtained 9.1.11 It is considered that vehicle keepers should obtain adequate insurance1 and as with maintenance the state where the vehicle is registered should be responsible for verifying that fresh insurance has
Colin Buchanan and Partners
Recommendations
universal 12 digit structured system and VIN;
universal 12 digit structured system and VIN tagged electronically;
new system for new vehicles only - modified UIC 12 digit system and VIN.
Of these options it is recommended that the first option be adopted. 9.2.3 The precise coding and format of the number recommended by the Consortium is discussed in depth in Appendix K. 9.2.4 For traction it is recommended that a twelve digit numbering system is also adopted and at least the last ten digits are displayed on the vehicle’s sides. The practice of displaying “short numbers”, as occurs in many states, could continue by using larger numerals for these. Database and Register Issues 9.2.5 It is recommended that databases and registers holding vehicle data are structured as a series of independent national (or regional where states which to co-operate) databases, linked together to form a virtual pan-European database. This virtual database database would generate the
Colin Buchanan and Partners
Recommendations
element but would avoid the need for widespread renumbering of articulated units. 9.2.9 This proposal would provide differing definitions of vehicle identity for the running and permanent identifiers. Whilst this is undesirable there is no overriding need for identical definitions of vehicle identity. This is because the permanent identifier would form the vehicle master record and the running identifier would be merely an attribute and thus the VIN would always be definitive, 9.2.10 The issue of defining a continuous identity for an asset is difficult and is inevitably fraught fraught with potential problems. It is recommended that the VIN is allocated to the chassis unit of a vehicle, or if the vehicle is integrally constructed (one without a separate chassis unit) to the body, and that this forms the legal identity of the vehicle. It is recommended that the continuous identity of a chassis be defined as only ending when one of a number of specified events occurs, these being as follows:
manufacturer certifies that vehicle was never constructed;
chassis certified scrapped by the owner;
vehicle is amalgamated with another vehicle (certified by remanufacturer, both existing VINs being cancelled and a new one
Colin Buchanan and Partners
Recommendations
9.2.15 It is important that the format of a VIN is different from that of running identifiers, to prevent the numbers being confused administratively. The need to accommodate existing vehicles dictates an eleven digit serial number (see below), in addition codes of at least four digits will be required for the manufacturer and plant code. The manufacturer and/or plant codes could consist of letters, however, since the Latin alphabet is not common across the geographic area of use, numeric coding is recommended. It is suggested a nineteen digit VIN be adopted which could be in the following form: Manfact. Code
Plant Code
0000
0000
Serial Number
00000000000
If manufacturers were to allocate numbers to their plants in blocks then the four digit plant code could be dispensed with, shortening the VIN to fifteen digits. However, it is considered considered that as a new system unconstrained by past practice the future flexibility offered by the nineteen digit number suggested is to be preferred.
Colin Buchanan and Partners
Recommendations
Traction
prime mover (engine);
transformer (electric traction);
wheelsets;
any removable component assembly costing more than 5% of the first cost of the vehicle.
Multiple Unit Stock
VINs of other vehicles in unit;
prime mover (diesel multiple units);
transformer (electric multiple units);
bogie frames;
wheelsets;
any removable component assembly costing more than 5% of the first cost of the vehicle.
Hauled Passenger Stock
Colin Buchanan and Partners
Recommendations
generating the lowest Net Present Cost is to only apply the system to new vehicles initially and allow existing vehicles to retain their old numbers. However the need to change regime codes to meet Single Market requirements and to indicate TSI compliance is likely to necessitate at least some renumbering of existing vehicles and a phased introduction of a new numbering system on a universal basis over a period of, say, six years is recommended, subject only to the possible exceptions outlined below. 9.2.20 If a new European numbering system is mandated it is recommended that all railway networks which do not form a part of the common European rail system with no regular exchange of vehicles with other parts of Europe (for example, isolated networks and lines, narrow gauge networks, etc) are excluded from the requirements. It is further suggested that consideration is given to excluding states with unique national numbering systems which would be disruptive to change for vehicles which are not exchanged with the remainder of the common European rail system. Similarly, it is recommended. However, it is recommended that VINs are required in all cases, other than for preserved vehicles over forty years old.
Colin Buchanan and Partners
Recommendations
Table 9.1 – Summary of Specific Recommendations
Nature of Measure
Timescale for Implementation
Independence of Notified Notified Bodies to be ensured
Organisational
Short
Process of placing vehicles in service, allocating them with numbers and placing them on databases and common operational systems to be placed in the hands of independent bodies, none of whose staff have either direct or indirect employment link with any railway undertaking.
Organisational
Short
Any contracts for use should be the same for all vehicle owners/keepers and be totally nondiscriminatory.
Organisational
Short
Vehicle databases to be managed on a national basis by independent bodies.
Organisational
Short/Medium
Effective interfaces between national vehicle databases to be mandated and enforced by a supranational agency (e.g. ERA).
Organisational/ Technical
Short
Virtual international vehicle database to be established and managed by an independent supranational body.
Organisational/ Technical
Short
Vital national IT systems that use vehicle data or numbers (e.g. operating systems) should be vested in independent bodies (e.g. infrastructure manager) with equal and non-discriminatory access available to all those legitimately needing access. Accompanied by pan-European definitions of the information on these systems than can be considered to be confidential.
Organisational
Short
Measure
Highest Priority Measures
9-1
Colin Buchanan and Partners
Recommendations
Measure
Nature of Measure
Timescale for Implementation
All vehicle owners/keepers to carry conventional insurance for their fleet, with State of vehicle registration to be responsible for verifying that it is held.
Organisational
Short
Structured twelve digit running number to be adopted, a dopted, based on a modified version of the current UIC system.
Technical
Medium
Separate Vehicle Identification Number (VIN) to be used, to act as official identifier for vehicle, a nineteen digit system is recommended, although a simpler fifteen digit system is also possible.
Technical
Short
The term “vehicle” needs to be adequately defined, in terms of the vehicles to which VINs should be applied, what a single vehicle comprises and the continuous identity of a vehicle,.
Technical
Short
International Registry required by the UNIDROIT convention to be free standing & separate database.
Organisational/ Technical
Short
Confidentiality filters to be provided in national IT systems not originally designed for multiuser environments.
Organisational/ Technical
Short/Medium
State of vehicle registration to be responsible for verifying that vehicle owners/keepers are maintaining their vehicles to acceptable standards. In association with freedom for vehicle owners and keepers to chose the maintenance regime and maintainer for their own vehicles.
Organisational
Short
Exchangeable datasets of any new pan-European IT systems to be compatible with those specified for the vehicle database.
Technical
Medium
High Priority Measures
9-2