Colin Buchanan and Partners

Introduction

COLIN

BUCHANAN
AND PARTNERS
Planning, Transport, Economics Software, Market Research

European Commission Vehicle Identification and Registration Final Report

Project No: 60751 May 2003 Newcombe House, 45 Notting Hill Gate London W11 3PB Telephone: 020 7309 7000 Fax: 020 7309 0906 email: CBP@CBUCHANAN.CO.UK

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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 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 3. ANALYSIS OF EXISTING SYSTEM 3.1 Legal Compliance 3.2 Placing Vehicles in Service 3.3 Numbering Systems 3.4 Functions of Numbering Systems 3.5 Vehicles Owned by non-UIC Members 3.6 Access Rights to Systems 4. COMPARISONS 4.1 Objective and Terminology 4.2 Comparison Philosophy 4.3 Other Transport Modes 4.4 Other Industries 4.5 Railway Systems Elsewhere 4.6 Conclusions and Parallels 5. INDUSTRY’S VIEWS AND PROPOSALS 5.1 Overview of Section 5.2 Commission’s Proposals in RWP II 5.3 Industry Views 5.4 The Vehicle Numbering System 5.5 CODIRAIL 5.6 RICS Study 5.7 The Steria Study 6. OPTIONS FOR CHANGE 6.1 Key Objectives 6.2 Key Questions 6.3 Placing Vehicles in Service and Allocating Identifiers

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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

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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 8. CONCLUSIONS 8.1 Organisational 8.2 Technical 9. RECOMMENDATIONS 9.1 Organisational Recommendations 9.2 Technical Recommendations

LIST OF APPENDICES A. B. C. D. E. F. G. H. I. J. K. L. EC STUDY SPECIFICATION PARTIES CONSULTED BIBLIOGRAPHY COUNTRY STUDY – FRANCE COUNTRY STUDY – GERMANY COUNTRY STUDY – GREAT BRITAIN COUNTRY STUDY – POLAND USES OF VEHICLE NUMBERS IN FREIGHT SYSTEMS IT SYSTEM TYPES TO WHICH ACCESS IS REQUIRED VALUES USED IN COST BENEFIT ANALYSIS CODING OF RECOMMENDED RUNNING IDENTIFIER LIST OF ABBREVIATIONS

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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 relation to current EU legislation. Analyse and describe current registration systems. Assess current reform projects Develop proposals for a European coding and registration system. 1.1.4 The Commission’s specification for this study is included as Appendix A to this Report; providing a full description of its requirements.

1.2 The Study Team 1.2.1 The Consortium consisted of the following members: Colin Buchanan and Partners (UK/Ireland) Pegasus Transconsult (UK) SchlumbergerSema (France/UK) Patricia Leefmans (The Netherlands)

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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 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 acceptance of hauled rolling stock, if it accords to agreed standards, the conclusion of international contracts for use and the numbering and other markings borne by vehicles. 1.3.4 The exchange of traffic between states requires a specific legal structure to govern applicable law, rights and obligations and the resolution of disputes at an international level. The first international treaty was signed in 1890. Its successor is the COTIF Treaty. These treaties are concluded by Governments and take effect through national law. A substantial revision, COTIF 1999, is in the process of being ratified. This new treaty extends the scope of COTIF to new areas including the adoption of mandatory standards for railway equipment and the technical approval of equipment. 1.3.5 The relative importance of rail as a mode has declined sharply in Europe for both passenger and freight traffic over the past half century. This is shown, for the last thirty years, in terms of traffic volume in Figures 1.1 and 1.2, and in terms of modal share in Figures 1.3 and 1.4. Rail’s performance for international traffic is particularly disappointing; measured across Europe the modal share for international traffic is lower than for domestic traffic, which is counter-intuitive. Poor information exchange and international control plays a major part in this state of

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affairs1. The role of vehicle identification systems needs to be seen within this context. Figure 1.1 EU15 Goods transport - billion tonne kilometre 1970 – 2000
3500
Road Rail Inland waterway Pipelines Sea Total

3000

2500 Billion tonne kilometres

2000

1500

1000

500

0 1970 1980 1990 2000

Source EU Energy and Transport in Figures 2002, European Commission (for figures 1.1 – 1.4)

Figure 1.2 EU 15 Passenger transport - billion passenger kilometres 1970 - 2000

5000 4500 4000 Billion passenger kilometres 3500 3000 2500 2000 1500 1000 500 0 1970 1980 1990 2000
Car Bus, coach, tram & metro Rail Air Total

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See for example, the major study examining this issue The Integration of National Conventional Rail Systems, Symonds Travers Morgan, May 1997.

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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

1.3.6 To counter this sharp decline the Commission has spearheaded a process that had already been started by several national governments to liberalise the rail industry and to create a Single European rail market. The process was set out in the Commission’s White Paper 2 on the revitalisation of rail in 1996 and reinforced in January 2002 in the

2

See EC White Paper A Strategy for Revitalising the Community’s Railways, COM(96)421 final.

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Commission’s communication on the integration of rail3. 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; 96/48/EC, on the interoperability of the trans-European High-Speed rail system; 2001/12/EC, amending Directive 91/440/EEC on the development of the Community’s railways; 2001/13/EC, on the licensing of railway undertakings; 2001/14/EC, on the allocation of railway infrastructure capacity and the levying of charges for use and safety certification; 2001/16/EC, on the interoperability of the trans-European conventional railway system. It is noted that the first, fourth and fifth of the above directives have been amended or replaced by the so called infrastructure package comprising Directives 2001/12/EC, 2001/13/EC and 2001/14/EC. 1.3.8 The two interoperability Directives have the greatest relevance to this study. When fully implemented these will make significant differences to the process of placing rolling stock in service, with a new method of assessing conformity through certification by independent notified bodies. Once a piece of equipment has been accepted by an accredited notified body in one EU State it must be accepted by those in
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Towards an integrated European railway area, COM (2002) 18 Final, 23.1.2002.

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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 Specifications for Interoperability (TSIs), which are currently being drawn up by the Association Européenne pour l’Inteoperabilite Ferroviaire (AEIF). These are supported by the detail contained in the 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 to be removed. The processes and systems used to register and identify railway vehicles therefore require examination; this fits into the context of removal of barriers to fair competition for the suppliers of railway equipment and between railway undertakings. 1.3.11 A further important issue in the context of this study is the requirement for a Register of Rolling Stock in Article 24 of Directive 2001/16/EC, which would appear to require a high degree of commonality in the form and format in which data is held.

1.4 Study Methodology 1.4.1 The study has been undertaken in six stages as follows: 1 2 3 4 5 data collection and research; assessment/interface with current reform projects; analysis; formulation of appropriate solutions/identification of measures; evaluation of options for change/cost benefit analysis;

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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 found.. The EAG consisted of the Commission, OTIF, the UIC, UNIFE, 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 existing processes for placing vehicles in service and allocating them with numbers, the overall legal and legislative context within which these systems must exist and current reform projects. In the course of this process, interviews were held with over thirty interested parties and over one hundred questionnaires were sent out to others, to gather information and to obtain views on the way forward. The bodies canvassed included governmental and regulatory bodies, safety bodies, infrastructure managers, railway undertakings, vehicle owners and leasers, representative bodies and the rolling stock manufacturing industry. 1.4.5 To highlight the issues the general pan-European research was supplemented by four detailed case studies in France, Germany, Great Britain4 and Poland. These were selected in association with the Commission to provide a reasonable cross section of the issues encountered in states with differing circumstances and national approaches. These case studies can be found in Appendices D to G. 1.4.6 Similar issues faced by other transport modes and industries were also examined to consider if any lessons can be learnt that may be applicable to the rail industry.

4

Not the United Kingdom, because the railways of Northern Ireland are entirely separate in organisation, control, orientation and operate in entirely different circumstances and face quite separate issues.

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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. 2. 3. 4. 5. 6. 7. 8. 9. Introduction Current Arrangements Analysis of Existing System Comparisons Industry’s View and Proposals Options for Change Analysis of Options Conclusions Recommendations

1.6.2 Additional information is contained in the Appendices to this Report, which can be found in a separately bound volume.

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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; 8. identify appropriate number series for vehicle(s); 9. design process; 10. formal design approval; 11. let construction contract; 12. construction and supervision of construction; 13. obtain certificate of compliance; 14. number allocated and applied to vehicle, in association with acceptance into fleet of rail haulier/licensed undertaking which is prepared to attach it to its fleet; 15. permanent contract for use concluded between owner/keeper1 and rail haulier/licensed undertaking (non-railway owned vehicles). A flow chart illustrating this process can be seen in Figure 2.1.

1

The term keeper is used herein to refer to the person or body in legal charge of the vehicle and its use, which may or not be the owner of the title to the vehicle.

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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 and acceptance in principle by rail undertaking.

Formal design approval. National railway or in future notified body approves design of vehicle in accordance with standards/TSI.

Tenders issued for construction. Contract let Construction process. Overseen by approved Conformity check with original design. Can be performed by manufacturer when it has appropriate internal procedures and is approved by notified body.

Number painted on body of vehicle. Manifests acceptance of vehicle into fleet of rail undertaking and that it is fit to run.

Permanent contract for use with schedule of vehicles to which it applies

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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 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. 2.1.5 In the case of traction, whilst the process is essentially the same it is more complex. Approval to operate traction across borders generally requires a check of the compliance of the vehicle with each of the national infrastructures involved. The primary complications being the differing track:train interfaces for the signalling and control system and differences in electrification systems, such as pantograph width and contact strip material as well as voltage. At present no international standards exist and none are likely until the appropriate TSIs have been drawn up. Technical Approval 2.1.6 The process for technical approval of vehicles varies considerably around Europe, as does the relationship of the party responsible for the process to the rest of the railway industry and the difference between approving vehicles for international operation with those restricted to solely domestic use. 2.1.7 The increasingly complex technical environment of Europe’s railway system has resulted in vehicle approval becoming more complex, lengthy and expensive. The significant technical divergence that has occurred both between and within states has fuelled differing approaches to vehicle approval. Acceptance testing has become important to maintain overall system safety, because of the complex interaction

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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 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 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. 2.1.10 Liberalisation is changing the responsibility for technical approval of vehicles. Some states such as Germany, Sweden and the UK have moved to independent agencies and/or governmental bodies, whereas in others such as Belgium and France responsibility remains with the national railway. The introduction of notified bodies under the interoperability directives can be expected to increase the independence of those undertaking technical approvals from former national railway undertakings. 2.1.11 The full and proper implementation of TSIs and notified bodies is therefore expected to make the technical approval neutral for manufacturers, railway undertakings and vehicle owners/keepers. Administrative Aspects 2.1.12 Once a vehicle has been accepted technically it still has to be issued with a number and formally accepted into traffic. 2.1.13 At present the process of issuing a number permitting normal domestic use generally remains with the national railway undertaking, even in states which have liberalised the technical approval process (see below under Case Studies). There are exceptions to this, however, such as in Great Britain, where an independent body known as the Rolling Stock Library issues numbers and places vehicles on the national register.

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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 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 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 current arrangements, it is necessary for the keeper to have an understanding with a UIC rail undertaking to ensure that an appropriate legal structure is in place, that the vehicles are maintained while in service and to ensure their acceptance in other states. This is called the contract for use. The contract provides for undertakings by the keeper to keep his vehicle safe and by the rail undertaking to provide services, an agreement on liability to avoid case by case disputes and a structure for providing services away from the home state. This formula has been retained in the 1999 COTIF as the CUV, Appendix D to the Convention. 2.1.17 In practice the contract has a number of parts which include: agreement of the owner/keeper not to modify the vehicle; a maintenance schedule for the vehicle; traffic/usage obligations, for example, what happens when the vehicle has been unloaded. Under this arrangement the vehicle keeper undertakes or contracts for maintenance to be performed on its vehicles 2.1.18 This arrangement fits into a chain of responsibility where a private owner/vehicle keeper is responsible to the rail undertaking for ensuring that the vehicle is maintained in accordance with agreed

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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 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 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 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. 2.1.21 The traditional approach can also mandate where and by whom maintenance can be undertaken as a part of placing the vehicle into service. The innovative arrangements now used in a liberalised market in Britain are discussed below under Case Studies. Although this is only one possible solution and it does not relate to wagons that are used internationally. Insurance 2.1.22 The same process of attaching vehicles to the fleet of a UIC member railway undertaking is used to provide mutual insurance for international operations. In essence, for vehicles owned by UIC members the railway undertaking with possession of the vehicle is regarded as being responsible for it and therefore liable for both accidents it causes and damage it sustains. The contract for use provides for a more complex arrangement for privately owned2 freight wagons in which UIC railway undertakings in effect pass all the liability for incidents caused by wagons to owners/keepers and then agree to take it back again in return for the payment of an indemnity premium. For damage caused to wagons, the railway undertakings accept liability. The fact that a vehicle bears a number issued by a railway undertaking is taken as proof that a contract for use is in place.
2

Including those of non-UIC member railway undertakings attached to the fleet of a UIC member railway undertaking.

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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 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 EU’s objectives in the rail sector are to be realised and also some of the inequalities that exist between national and ex-national railway undertakings and other vehicle keepers. 2.1.27 Of the four France represents the most traditional, with the technical approval and the administrative activities associated with placing vehicles into service being entirely in the hands of SNCF. The infrastructure provider (RFF) stated that it had no involvement in the process and directed all enquiries to SNCF. The interviews with other parties revealed no plans to alter current responsibilities; there appears to some doubt whether this will be compliant with Directive 2001/16/EC. Technical approval is facilitated in France by construction to “highest common factor” international railway specifications, with specifications following the normal UIC model. All privately owned vehicles used on the national rail system are attached to SNCF’s fleet, which therefore approves the maintenance arrangements, using facilities approved by SNCF only. On the other hand SNCF, having accepted the maintenance arrangements, carries the liability for technical failures of vehicles itself, although this is understood to be under review. 2.1.28 In Germany and Britain, by contrast, the process of liberalisation is further advanced, although there are some interesting contrasts between them. In both States, technical approval of vehicles is undertaken by completely independent bodies. In Germany by a single governmental body and in Britain by one of a number of private sector

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Vehicle Approval 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 Stock 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. 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 either have vehicles hauled on a DB train or internationally need to have these vehicles attached to the DB fleet. The rights to do this are enforced by Government, although all those interviewed for this study still found the process unsatisfactory. Other railway undertakings are free to create their own registers, allocate their numbers and use their own systems for vehicles that run on their own trains. 2.1.31 The above cases raise significant issues (and contrasting approaches) to the confidentiality of systems using vehicle numbers as a data field. These issues are discussed further on in this Section. 2.1.32 Innovative arrangements have been created in Britain for the maintenance of vehicles, the maintenance regime being approved by the technical approval body. Work can be carried out by the vehicle owner, lessee, maintenance contractor, railway undertaking, or by any combination of these in varying degrees. In the context of the innovative safety regime this works well. Insurance is required under British law. 2.1.33 Poland has made great strides in aligning its law and practice to EU principles. Vehicle approval is by a wholly independent body closely modelled on the German EBA although in practice there are few independent railways and most private participation in the industry is by conventional private wagon owners. The process for allocating numbers is administered by PKP.

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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 of vehicles. The differing systems that are currently used around Europe are discussed below. In essence numbering systems can be of two types: structured or 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 systems numbers are allocated in blocks, with specific blocks relating to particular types or batches of vehicles, although there is no coding of information within the number format. In some cases this system is sufficiently clear for the number to be regarded as semi-structured, for example SNCB Class 27 locomotives are numbered 2701 to 2760 inclusive. Current European International Systems Overview 2.2.4 The UIC/OSJD numbering system is used for all vehicles in international traffic between railway undertakings that are members of UIC or OSJD3; in practical terms the whole of Europe and large areas of Asia. The UIC system uses twelve digits. However, although OSJD are party to the agreements, in practice vehicles involved in international movements over the former SZD network retain their eight digit Soviet era numbers. 2.2.5 The UIC system is defined in a set of three UIC leaflets dealing with the numbering of all rail vehicles. They had their origins in 1971 at the time when the widespread availability of commercial data processing equipment began to provide a logic for structured numbers. The
3

Организация Сотрудничества Железных Дорог (Organisation for the Cooperation of Railways), sometimes also referred to as the OSShD.

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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 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 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 makes allowance for this. Under all the systems defined in all three leaflets the number is structured. The structure is such that numbers are unique and from the number the type of vehicle and many of its characteristics may be defined. Hauled Freight Rolling Stock 2.2.9 The system defined in leaflet 438-2 is structured as follows: Digits 1 & 2 Digits 3 & 4 Digits 5 to 8 Digits 9 to 11 Digit 12 exchange regime code railway to which the vehicle is attached vehicle type vehicle serial number within the criteria above check digit

These codes are briefly described below. 2.2.10 The regime of use indicates whether a vehicle is owned privately or by a railway. This information currently determines who has the right to decide on the next use of the wagon or coach and if there are restrictions on its use. The regime of use may also indicate if it is approved for international use or if it is equipped to run on railways with different gauges. Responsibility for its maintenance and for incidents caused by a vehicle also depends on its status. Only regimes of use

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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 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 which wish to use their wagons internationally have to attach them to the fleet of a UIC/OSJD member, even if they are in direct competition. In practical terms it is very difficult, although possible, to operate internationally without recognised twelve digit numbers. 2.2.13 The vehicle type is a code for the type of vehicle. More than one four-digit code is necessary for populous vehicle types to allow all of them to receive unique serial numbers. This part of the number allows vehicle ordering systems to specify the vehicles that are required to meet traffic demands. Staff become familiar with vehicle numbering sequences and the coding system is a real aid to ground level operations. In the case of RIV wagons, wagon type is a factor in the process of determining hire charges. Many railway undertakings and infrastructure managers use the vehicle number to drive other railway computer systems, for example to check that technical data input is consistent with the declared vehicle type. 2.2.14 Wagon type is also identified by a “literal” which is composed of up to twelve letters, possibly suffixed with a number. The letters have standard meanings as defined in leaflet 438-2 (for example, ss means able to run at 120 km/h) and for railway owned wagons they are marked on the vehicle. The codes are intended to differentiate wagons in a meaningful way; indicating the capacity and length and speed characteristics and the types of fittings. These letter codes are widely used in the industry and by customers to identify vehicles for loading. One or more four digit number series is identified with each literal. More

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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

2.2.16 The existing arrangements require numbers to be recorded frequently by manual means. To reduce the likelihood of errors when

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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 11" system4. 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 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 sequence). With two exceptions it only reflects technical characteristics. The technical criteria which determine the choice of a code include whether a vehicle is: • • • • • adaptable to run on different gauges (and which gauges); air conditioned or not; pressure tight; not a passenger vehicle; and whether it is a service vehicle.

Further criteria include whether vehicles are limited to domestic traffic and whether they are operated in joint pools (which affects the “compensation” arrangements). The allocation of numerical values is as consistent as possible but the characteristics are not as immediately obvious from the code as is the case for freight vehicles. 2.2.20 The code for the railway to which the vehicle is attached is identical to that for freight vehicles.

4

In this process the digits in the odd numbered positions of the twelve digit number are summed ignoring carrying over of second order of magnitude terms. The digits of the first five even numbered positions of the twelve digit number are summed after multiplying each by two, ignoring second order of magnitude terms at each stage (and subsequently). The two numbers derived are then added together and subtracted from 11; the result provides the check digit.

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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 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 under UIC leaflet 438-3 is more tentative than those defined in the parallel leaflets 438-1 and 438-2. Coaches and wagons require a complex coding structure to identify type, return arrangements, terms for payment for use etc. None of this is necessary for tractive stock because of limited interoperation in traditional European operation. Historically international operation of traction in Europe has been both rare and subject to highly specific agreements. 2.2.25 In contrast to leaflets 438-1 and 438-2, few railway undertakings currently follow the requirements of leaflet 438-3 completely. 2.2.26 The system defined in leaflet 438-3 allows railway undertakings to use a “national number” composed of six or seven digits and many railway undertakings use this in effect as the sole vehicle number. Otherwise the structure is structured as follows: Digits 1 Digits 2 powered vehicle indicator (always 9) check digit railway to which the vehicle is attached differentiation between locomotive and unit

Digits 3 & 4 Digits 5 -

Vehicles attached to UIC member railways fleets that are owned by non-UIC railways and private owners.

5

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Digits 6 to 11 Digit 12 -

running number (unstructured) 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 Railways) on behalf of all the CIS states but changes have been made to accept twelve digit numbers. The CIS community is not prepared to embark on renumbering however unless it can be convinced there will be stability in any pan-European system adopted. National/Domestic Systems 2.2.30 Although the UIC international system is in widespread use throughout Europe there are numerous systems used within individual states. Some of these are national systems whereas others are in more restricted use, for example by new open access railway undertakings. This Report considers only the permitted systems for vehicles that are commonly used on the national network. 2.2.31 The majority of the systems used are entirely numeric. However some systems, for example that most commonly used for Swedish traction, are alpha-numeric. Other systems are officially alpha-numeric but only display only the numeric part on the rolling stock, as for example for Finnish traction.

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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 Multiple Hauled Units Passenger Vehicles Semi-struct 4 digit (dmu)/ UIC 438-1 unstructured 3 digit (emu) Various Various Various2 Various2 Structured: UIC 438-1 3+3+1 digit Struct: 1 letter UIC 438-1 + 2 to 5 digit Semi-struct 3 UIC 438-1 digit Unstructured: Unstructured: 4 digit 4 digit Various struct Various alphanumeric4 Semi-struct 4 UIC 438-1 digit Semi-struct 3 UIC 438-1 to 4 digit Structured: UIC 438-1 4+3+1 digit Semi-struct 4 UIC 438-1 digit Unstructured: 4 digit Various Structured: 3+3 digit Unstructured: 4 digit UIC 438-3 Various SZD7 SZD7 UIC 438-3/3 Unstructured: 5 digit Various Unstructured: 4 to 6 digit Unstructured: 2 or 3 digit UIC 438-1 Various SZD SZD UIC 438-1

Locomotives State Semistructured 4 digit Various1 Various2 Structured: 3+3+1 digit Semi-struct, 6 digit UIC 438-3³ Unstructured: 3 digit Various struct alphanumeric4 Semi-struct 3 to 4 digit Semi-struct 3 to 4 digit Structured: 4+3+1 digit Semi-struct 4 digit Semi-struct 2 to 4 digit Various5 Structured: 2+3 digit Unstructured: 3 digit UIC 438-3 Various SZD6 SZD6 Struct: 1 letter

Hauled Freight Vehicles UIC 438-2 Various Various2 UIC 438-2 UIC 438-2 UIC 438-2 Unstructured: 5 or 6 digit Various UIC 438-2 UIC 438-2 UIC 438-2 UIC 438-2 5+1 digit/2 letter + 6+1 digit UIC 438-2 Unstructured/ Semi-struct: 6 digit n/a UIC 438-2 Various SZD SZD UIC 438-2

Belgium Denmark Germany Spain France Greece Ireland Italy Luxembourg The Netherlands Austria Portugal Finland Sweden United Kingdom (Great Britain) United Kingdom (N. Ireland) Czech Republic Estonia Latvia Lithuania Hungary

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Locomotives State + 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

Numbering System Multiple Hauled Units Passenger Vehicles or 4 letter + 3 digit Structured: 2 letter + 2 digit + 4 digit UIC 438-3 3+3 digit Various Structured: 2 + 3 digit 2+3 digit 2+4+1 digit SZD7 UIC 438-1 UIC 438-1 SZD UIC 438-1 UIC 438-1 UIC 438-1 Various8

Hauled Freight Vehicles

Poland Slovakia Slovenia Switzerland Norway Bulgaria Romania CIS
Notes:

UIC 438-2 UIC 438-2 UIC 438-2 UIC 438-2 UIC 438-2 UIC 438-2 UIC 438-2 SZD

1. DSB use a structured 2 letter + 3 or 4 digit alpha-numeric system; other railways also use alpha-numeric systems. 2. DBAG use UIC System (438-1, 438-2 and 438-3). 3. Renumbering from 1 letter + 3 digit system has just commenced. 4. For locomotives, FS use 1 letter + 3 or 4 digits + 3 digits; for multiple units they use 2 or 3 letters + 3 + 4 digits. 5. SJ constituents use structured 2 letter/3 alpha-numeric/3 letter 3 digit + 3 or 4 digit system. 6. Structured: 1 digit + 1 to 3 alphanumeric + 1 to 2 digit + 1 alphanumeric 7. Structured: 2 alphanumeric + 1 to 2 digit + 1 to 2 alphanumeric. 8. SBB are moving to UIC 438-3 for locomotives and use 438-3 for hauled passenger vehicles, as do BLS.

2.2.33 It can be seen that in the case of most states the system used for hauled rolling stock in domestic service is identical to the current international one. There are, however, some significant exceptions, particularly the isolated networks of the British Isles (Ireland and the UK) and for independent and open access operators in Germany for stock that is not interchanged with DBAG’s railway undertakings. 2.2.34 In the case of traction the system is rather more mixed, with a disparate variety of systems in use, some of which comply with the rather loose requirements of UIC leaflet 438-3 but many do not. Furthermore, in a significant number of states the system used for locomotives differs from that used for multiple units. There are even some states which have more than one system in use.

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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 for rolling 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 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 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 for traction varies between the four States. The only common feature is that all of the systems used are structured. French and DBAG locomotives use the system described in UIC leaflets 438-3. Although French multiple units use a unique national system and other German railway undertakings use their own systems. Unique national systems are used in Britain and Poland. The Polish system is as an example of one of Europe’s alphanumeric numbering systems. 2.2.38 The use of an unstructured system for hauled rolling stock and structured systems for traction in Great Britain provided an opportunity to compare the operation of two systems side-by-side. The first point is that vehicles with unstructured running numbers are rarely renumbered (although this does occur, for example, when a vehicle transfers from the revenue earning fleet to railway internal use). In contrast, it is more common to renumber traction, which has structured numbers, for example, when it is modified into a different sub-class, or even into an entirely new class, for example, some Class 47s into more powerful rebuilt Class 57 locomotives. The second point is that intensive operation and close control of wagon diagramming is possible with unstructured numbers if the operating systems used are designed around them.

2.3 Railway Coding Systems 2.3.1 Railway coding systems have a close relationship with railway data systems. Information technology requires coding systems and the

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coding only 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. These ambitious 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 SDR6. 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 and North Africa had a code, even where there was no sensible exchange of traffic (for example, Japan). Given the all purpose nature of the codes, shipping lines (involved in tickets and revenue sharing) also needed codes. The allocation of the codes has traditionally been determined by the railway’s RIV status (non-member, full member, partial member etc). For some long-forgotten reason, initially only codes in which the second digit was equal to or less than the first were allocated (for example, 88 was allocated, but not 89). This coding structure is defined in UIC leaflet 920-1. 2.3.4 This system worked well for some twenty years during which other organisations developed standard coding structures (for example ISO 3166 for currency codes, ISO 4127 for country codes). However, at the beginning of the 1990s it became clear that the range of 99 available codes would no longer suffice. The political changes in the Balkans and former Soviet Union were spawning new railways and at the same time there was a need to reflect the restructuring of a number of railways into operators and infrastructure managers together with a need to allow for open access. 2.3.5 Ad hoc measures have been adopted to provide short-term solutions to the shortage of numbers in the current coding system: ISO
6

Special Drawing Rights: an international reserve asset valued on the basis of a basket of key currencies.

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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 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 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). Directive 2001/12/EC 2.4.2 One of the main requirements of the Directive is to clarify the separation of accounts between infrastructure managers and rail undertakings by revising the requirements of Article 6 of Directive 91/440/EEC. While this has no significant implications for this study in itself, one of the factors underlying the separation of railway undertaking and infrastructure manager accounts is the need to clarify and attribute costs, and where there is a monopoly situation, ensure that charges for services are appropriate. 2.4.3 One of the major elements of the Directive is the extension of access rights for individual railway undertakings. First to operate international rail freight services over a defined network until 2008 and second, after that date over the whole of the EU rail infrastructure. The requirements in the Directive relating to access rights are contained in Article 10; in the context of this study particular note should be made of the requirements of paragraphs 1, 2, 3, 5, 6 and 8, which are discussed below. 2.4.4 Paragraphs 1 to 3 indicate the clear intention to create access rights to railway infrastructure and that this access must be equitable. For this to be achieved, it is essential that other operational impediments do not exist. A vehicle identification system is essential for the free operation of

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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. 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 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, and therefore the minimum area over which the identification system must be able to accommodate additional railway undertakings. However, the fact that the feeder lines can be almost anywhere means that in practice the vehicle identification system needs to be able to satisfy the requirements of Article 10 over virtually the entire European rail network from March 2003. 2.4.8 The Directive prohibits (in Annex II) railway undertakings from certain functions that are defined as “essential functions”, because they determine access to the rail infrastructure. These are defined as follows: “preparation and decision making related to the licensing of railway undertakings including granting of individual licenses”; “decision making related to the path allocation including both the definition and the assessment of availability and the allocation of individual train paths”: “decision making related to infrastructure charging”; and “monitoring observance of public service obligations required in the provision of certain services”. It is of note that none of these explicitly covers the vehicle identification system and therefore do not prevent a railway undertaking from performing this function; however please refer to the legal analysis below.

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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 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. 2.4.12 Article 5 and Annex II lists the services that should be made available to railway undertakings, amongst these, point 1(e) of Annex II is relevant to the study. This requirement appears to impose an obligation on the infrastructure manager to verify that the rolling stock can operate over the route requested and that this verification is included in the minimum access charge for the use of the infrastructure. 2.4.13 Article 7(3) requires charges for the minimum access package and track access to service facilities to be set at the cost that is directly incurred as a result of operating the train service. Depending on how strictly this is interpreted, or even as a result of their own interest in reducing costs, infrastructure managers could take a greater interest in the wear caused by different types of vehicles and set charges to take account of this. This would require use of the vehicle identifier in some way. Directive 2001/16/EC 2.4.14 The procedures for certifying that a sub system is interoperable (by notified bodies) are defined in Article 18 and the verification procedure is described in Annex VI. This includes the following requirements: “verification of a subsystem7 shall begin at the design stage and cover the entire manufacturing period through to the
7

An item of rolling stock in this instance.

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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”. 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 and the vehicle identification 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: it requires the establishment of registers of rolling stock and infrastructure. Specifically it requires that: 1. “The Member States shall ensure that registers of infrastructure and of rolling stock are published and updated annually. Those registers shall indicate the main features of each subsystem or part subsystem involved (e.g. the basic parameters) and their correlation with the features laid down by the applicable TSIs To that end, each TSI shall indicate precisely which information must be included in the registers of infrastructure and of rolling stock. 2. A copy of those registers shall be sent to the Member States concerned and to the joint representative body and shall be made available to the public.” The rolling stock register needs to contain specific and accurate information in the required level of detail. The TSIs must each specify the information to be included in the register. It is clear that the requirement for registers only to be updated annually would make them insufficient for use for operational purposes where information would need to be completely up to date. No such register currently exists. 2.4.17 Annex II lists the subsystems comprising the rail system. Section 2.5 and in particular part b) cover vehicle identification.

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2.4.18 Annex III, section 2.7.1 lists “the essential requirements for telematics 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”.

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 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 Railway Package (RWP-II) will bring about. RWP II is discussed in more detail in Section 5. EU Legislation Introduction 2.5.2 EU railway legislation contains several obligations in the field of registration, numbering and information provision. However, the legislation does not invariably make it clear who has to register what, in which way, when and on behalf of whom. This sub-section is confined to the provisions that currently contain an obligation to register certain data. Directive 2001/16/EC 2.5.3 At present only Directive 2001/16/EC contains an obligation for Member States to create a rolling stock register. It lays down rules for interoperability on the Trans-European conventional network. After amendment by RWP-II the scope of Directive 2001/16/EC will change and the entire European conventional rail system will come under its provisions. RWP-II will also change the Directive on the interoperability of the trans-European high speed network (Directive 96/48/EC). The
8

COTIF 1980 is in force; however, the changes brought by the 1999 revision, which are primarily discussed herein, are expected to come into force in 2004. The UNIDROIT convention has been signed but requires ratifications to come into force.

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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 stock9. This rolling stock 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 important requirements that this must include: 1. the main features of the rolling stock (“the basic parameters”); and 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 register11. 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 made available to the public and has to be sent to the Member States concerned and the AEIF. 2.5.7 The wording of the Directive does not state clearly who will manage the rolling stock register. Unlike the provisions on the national register (see Commission proposals in RWP-II) the Directive does not indicate either that the register relates to “vehicles put into service” or that the manager of the register has to be an independent body (these requirements should be contrasted with Article 14 paragraph 4 of the directives as proposed by RWP-II). 2.5.8 A possibility could therefore be to register vehicles at an earlier phase than “putting into service” (for example directly after the assessment by a notified body) and by a different body (for example the notified bodies, the railway undertakings, the contracting entity, or the infrastructure manager). International Legal Obligations Unidroit Convention on International Interests in Mobile Equipment 2.5.9 Under the aegis of Unidroit13 the Convention on International Interests in Mobile Equipment has been concluded (Cape Town, 2001).
9

Required under Article 24. For a complete definition see Annex I point 2. 11 Article 24 paragraph 1 12 See Article 23 paragraph 3 of Directive 01/16/EC.
10

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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 provision for the possibility of the Regional Economic Integration Organisations, such as the European Union, to be a party to the Convention and analogous provisions are contained in the draft Rail 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 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 collateral14. The asset must be “uniquely identifiable”15. A holder of an international interest will be able to register its interest in an international registry16 which, with minor exceptions, will secure its priority over later registered interests and international interests which are not registered. The holder of the international interest will be granted certain specific remedies to repossess the asset concerned in case of default or bankruptcy. 2.5.12 Operation of various aspects of the Convention, including the international registry, will be supervised by a Supervisory Authority, which it is understood will probably be different for each transport mode. The Supervisory Authority is responsible for appointing and dismissing a Registrar who will operate and administer the International Registry17. The draft Rail Protocol envisages that OTIF will act as the Supervisory Authority18 in the rail sector. 2.5.13 The draft Rail Protocol creates the possibility that a designated entity may be stipulated by the Contracting States in a closed geographical area to act as an access portal to the International

13

The International Institute for the Unification of Private Law, an intergovernmental organisation based in Roma. 14 Article 2 of the Convention 15 ibid 16 Article 16 of the Convention. 17 Article 17 of the Convention 18 Article XI

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Registry19. 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. 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 vehicle21. 2.5.15 The International Registry has to be operated and administered on a twenty-four hour basis22. It is proposed that all registration and searches will be conducted through the Internet. Any designated entity has to operate “during working hours in its territory”23. 2.5.16 Under the Treaty “any person” is entitled access to the information registered at the international registry and will receive a search certificate24. The draft Rail Protocol prescribes that the Supervisory Authority will establish the search criteria25. COTIF 2.5.17 If the EC becomes a contracting party to COTIF it will be bound to its provisions, and its appendices insofar as it does not derogate from those that allow derogation. Any rules of Community law will have to be in conformity with COTIF and should not jeopardise in any way its further development. 2.5.18 Conversely the EC is not allowed to bind itself internationally to rules that might be contrary to the EC Treaty (those with particular relevance to this study are Articles 81 and 82). A conflict with the EC Treaty would make it legally impossible to transpose international obligations into the European legal order, as the EC Treaty has
19 20

Article XIII paragraph 2. Article XIV 21 Article V(1) 22 Article XIII paragraph 1. 23 Article XIII paragraph 2. 24 Article 22 of the Convention 25 Article XV paragraph 2.

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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 choose 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. 2.5.21 As long as the EC is not a party to the COTIF, this could cause a complicated legal situation26. Member States (which have individual membership of the COTIF and are therefore bound by COTIF rules) could be faced with contradictory obligations if EC legislation deviates from the international rules or if international rules conflict with the EC Treaty. It is therefore important that Member States consider their EU obligations when ratifying the new COTIF and/or perhaps make use of the possibilities that Article 42 of COTIF offers. In practice, however, the policy co-ordination arrangements within the EU (if Member States reach consensus) and the fact that, if voting en-bloc, the EU States form a substantial minority, mean that the EU will be able to have a strong influence on COTIF policy. Emphatically so if candidate States are taken into account. 2.5.22 A greater risk may be if the EC decides to join but to derogate from the technical appendices. In doing so it would be denied a voice in drawing them up. This could leave the situation in which COTIF technical standards apply in one part of Europe and EU standards in another, without any guarantee that they would be the same. 2.5.23 The scope of COTIF is broad: to promote, improve and facilitate international railway transport, consequently the scope of Appendix F (APTU) and Appendix G (“Uniform Rules concerning the Technical
26

The Commission announced a policy of joining COTIF in its Communication Towards an integrated European railway area in January 2002.

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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 contain information about railway vehicles “admitted to circulation or use in international traffic”. Paragraph 3 makes it clear that the sole 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 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 authorities” to OTIF. In all cases the competent authorities will have to provide notice of the following necessary data: withdrawals from service; official immobilisations (sic); withdrawals of admission to operation (sic); and modifications to a vehicle which derogate from the admitted type of the construction. 2.5.26 The logic of the data bank is that it acts as a list of approved vehicles to support the requirement that these must be accepted in international traffic. It is not clear if supplementary information (for example, whether the maintenance-due date has been exceeded) will be held. 2.5.27 COTIF specifies that the only data that may be stored is that which the Committee of Technical Experts (CTE) decides is necessary. Indeed the text of the ATMF states that: the competent authorities have to send the necessary data; the CTE will decide which data has to be sent; the data will include that stated by the CTE Accordingly CTE can only put an obligation on the authorities to send other data if it is “necessary” (for keeping a database on approved vehicles). The Consortium therefore considers that under the strict wording of the COTIF the necessary data cannot include all of the information required by other legal and operational requirements.

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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 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 additional data is my no means excluded. Indeed OTIF (through the CTE) is obviously prepared to require additional data to be provided. Assurances provided by OTIF to the Consortium 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 updated. It appears that this aspect still 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. 2.5.31 Access to the register is permitted under Article 13 paragraph 4 Appendix G for the following: the Contracting States; railway undertakings engaged in international traffic and having their place of business in a contracting state; infrastructure managers having their place of business in a Contracting State and on whose infrastructure international traffic runs; manufacturers of vehicles, but only as it concerns their vehicles; keepers of railway vehicles but only as it concerns their vehicles. Another committee (the Revision Committee) will decide what data these bodies will have access to and under what conditions27. The Requirements of Competition Law 2.5.32 In considering new legislation, the Commission and Member States have to take into consideration the legal restrictions imposed by Articles 81 and 82 of the EC Treaty and Regulation 1017/68 (as amended) in the field of competition law. In short, these restrictions
27

Article 13 paragraph 5 Appendix G.

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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, precautions 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. 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? 2.5.35 To assess whether a “competition risk” will occur, one has to make an analysis of the markets (product and geographical markets) in which the competitors operate. In this process attention should be paid to the character of these markets. For example, if one of these markets has an oligopolistic character (that is few sellers, high barriers to entry, relatively little product differentiation possible, etc) an exchange of information will cause more problems than in a more open and competitive market.

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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 Railcars & Hauled Multiple Passenger Units Vehicles 701 3 501 466 918 2 402 14 715 1 006 4 310 2 175 15 694 85 517 62 372 1 522 11 937 34 146 1 845 2 742 362 3 468 333 1 399 112 1 012 220 1 030 11 255 3 088 122 966 77 181 141 346 1 266 361 114 253 165 82 5 252 241 702 563 3 232 9 761 2 273 461 3 255 918 2 099

Locomotives State Belgium Denmark Germany Spain France Greece Ireland Italy Luxembourg The Netherlands Austria Portugal Finland Sweden United Kingdom (Great Britain) United Kingdom (N Ireland) Czech Republic Estonia Latvia Lithuania Hungary Poland Slovakia Slovenia Switzerland Norway Bulgaria 969 187 7 254 988 4 983 159 110 3 175 79 120 1 201 256 623 910 1 873 4 2 713 117 252 278 1 107 4 027 1 209 186 1 407 127 680

Hauled Freight Vehicles 13 385 2 236 200 578 19 754 46 359 3 526 2 811 74 795 2 201 3 331 18 525 3 931 12 292 15 000 29 624 0 47 768 4 154 7 326 10 117 10 444 94 355 22 175 5 952 13 069 2 446 24 910

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Locomotives State Romania European CIS Other UIC Total 1 809 16 027 6 868 59 698

Numbering System Railcars & Hauled Multiple Passenger Units Vehicles 151 4 037 9 971 41 937 1 744 16 253 38 398 155 955

Hauled Freight Vehicles 58 000 547 796 173 555 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 years28. This 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.

2.7 Uses of Numbering Systems Recording Numbers 2.7.1 The numbers are painted on the side of the vehicle. It is useful to establish an understanding of the occasions when vehicle numbers are currently recorded. In the case of wagons for example these include: on loading: on the consignment note (written or IT based) (the note is always provided by the customer, the number is either provided by the customer if he loads the vehicle himself, or by the rail undertaking if it loads the vehicle); transferral of number to rail undertaking’s operating system; marshalling yards: used for correct attribution of the wagon; removal from the train due to malfunction: used for billing for repairs (settled on an aggregated basis between rail undertakings);
28

It is noted that the age profile of the current fleet is not compatible with these figures; due to the decline of the industry and historic factors, investment in new equipment has been limited, resulting in an ageing fleet across Europe as a whole.

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train list: compiled by rail undertaking and an abstract is supplied to the infrastructure manager; dangerous goods: to ensure that the vehicle is appropriately configured; arrival at destination: input to the receipting process; repositioning for next customer: contact to the wagon keeper to identify the next customer; accounting system: uses consignment number and wagon number; maintenance: used by keeper and/or 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, accounting, engineering and legal functions. The nature of freight 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 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 appropriate ones are required to move the type of traffic on offer over the route to be taken. These requirements all place much greater demands on the numbering system than passenger traffic. 2.7.3 In passenger traffic the number is likely to be used only for identifying vehicles for a consist list, charging for use, identifying vehicle type in a reservation system, for maintenance purposes, for defect reporting and repair, and in the event of an accident. Uses in IT and Other Systems 2.7.4 Vehicle numbers are used in numerous systems; these include both IT and manual systems. The structure of the number is therefore both embedded in physical systems and in the intellectual processes of staff. Systems that use vehicle numbers include: operating and traffic management systems; tracking and tracing systems; vehicle maintenance systems; billing and accounting systems for both railway undertakings and infrastructure managers; customers’ systems;

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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. The costs and implications of changing 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 discrete life span and the liberalisation that is occurring in the industry is rendering many of the current systems obsolete or is demanding their substantial revision to cope with a multi-operator environment. This point was illustrated clearly in the four national case studies that were undertaken for this Report. In the British case study, the national operating system29 has been opened up to multiple access by railway undertakings and other interested parties (with variable levels of access rights), the lack of confidentiality filters and some inconsistencies in the level of access rights are causing some difficulties. 2.7.8 Accordingly, two issues come into play when considering the impact on IT and manual systems of changing the numbering system. First, the impact on these existing IT and manual systems, and second, to what extent do these systems have to change in any event because they are inappropriate for the current environment? This issue is also discussed further in Section 7 of this Report. It is understood that the EC are currently providing funding for the development of new international rail freight information exchange systems. It is important that the minimum dataset requirement of any vehicle database is mutually compatible with those exchanged by these new systems.

29

TOPS (Total Operations Processing System).

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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 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 goes. The system acts as a funnel to limit and channel legal relationships; each railway has agreements with “its” vehicle keepers and has rights and obligations deriving from membership of international bodies. 2.8.4 All of these agreements are standard and avoid keepers having to have understandings with every railway undertaking. Evidence for the wagon being attached to the fleet of a railway undertaking and the subject of an Agreement is provided by the wagon being numbered in the number series of the railway undertaking. This system has worked well in practice. 2.8.5 The keeper:railway undertaking relationship is preserved in the 1999 COTIF. The CUV, Appendix D to the Convention, sets down optional general conditions for use for all vehicles (not just wagons). There are a number of important differences from the UIC arrangements however. The CUV is not mandatory; COTIF contains no requirement for a vehicle to be attached to a railway undertaking at all although, when interviewed in the course of the Study OCTI staff believed that a contract for use, implicit or explicit was essential. Furthermore the CUV does not mandate the terms of the contract but simply defines what will apply unless the parties agree something else. The CUV does not deal with the question of maintenance (that is dealt with by Article 15 of the ATMF). Likewise the issue of liability is dealt with as a principle without the complex provisions of the UIC formula, more intended to resolve

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practical questions. The CUV requires the home railway to 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 of gauges, the 1524mm gauge of the former 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 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, when interviewed for this study, OSJD declared that RZD would be prepared to move towards a standard European solution if they could be assured that such a system would be stable.

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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”, while COTIF has a more limited purpose. 3.1.3 Although each of the rules has a limited scope and in itself leaves little room for “broadening” the registration regime, they do not contain any legal barriers for Member States (or the railway industry) to fulfil their obligations on: setting up a register; using data for the set purpose; appointing an authority to manage the register; obliging actors to provide data; giving entry to the register to specific actors. 3.1.4 However, other legal barriers resulting from EC legislation, the EC Treaty and COTIF have to be taken into account (see below). EC Law Directive 2001/16/EC 3.1.5 The interoperability Directive 2001/16/EC contains an obligation to keep a rolling stock register (Article 24). Although no such registers

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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 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 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 with certain functions that relate to infrastructure. These functions, which are “determining equitable and non-discriminatory access to infrastructure”, are (see Annex II to the Directive): preparation and decision making related to licensing, including granting individual licenses; decision making related to path allocation including both the definition and assessment of availability and the allocation of individual train paths; decision making related to infrastructure charging; and monitoring observance of public service obligations associated with service provision. 3.1.8 Although the function of numbering and registration of vehicles is not explicitly listed in Annex II, a close link clearly exists between this function and the infrastructure functions mentioned in the Annex. It is therefore questionable whether a situation in which numbering and registration is assigned to railway undertakings is compatible with the basic concept of separating transport and infrastructure functions. 3.1.9 In this respect it should be noted that it is not clear whether the Directive allows Member States to prohibit other functions than the ones mentioned in the Annex. The question of whether the list is exhaustive or not is left open by the text of the Directive.

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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 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 undertakings concerned access to data containing recent, sensitive and individualised information. COTIF 3.1.12 When COTIF 1999 comes into force, an “international database of rolling stock” will be required. At present no such database exists. Legal Conclusions 3.1.13 To conclude, the Consortium considers that the present system is not completely compatible with legislative requirements, once the interoperability directives and the new COTIF have come fully into force. The following aspects of current arrangements appear to be problematical: apparent lack of commitment to the independence of notified bodies from national railway undertakings in some states; the involvement of national railway undertakings in the processes of allocating numbers to vehicles and maintaining the national database in numerous states, with consequent concerns under Article 82 of the EC Treaty; the need to attach a vehicle to the fleet of a UIC member railway (in the main national railway undertakings) to operate a vehicle internationally under the prevailing rules, with consequent concerns under Article 82 of the EC Treaty in particular; the attachment of vehicles to the fleet of a UIC railway undertaking where these are either privately owned or owned by another railway undertaking gives rise to serious concerns on data confidentiality

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grounds: the ability to “see” 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 will be shortly be required by Directive 2001/16/EC; a future problem is likely since there is currently 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 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 databases are required. Indeed, as noted in Section 2, the interviews undertaken with the responsible authorities. in the course of this study revealed a willingness to adopt a pragmatic approach to this issue. 3.1.15 The issues of technical compatibility between any standards that are mandated under the COTIF and those required under the TSIs are far more complex and may be considerably more difficult to resolve, however, detailed consideration of this issue is outside the scope of this study. The relationship between the revised COTIF and EU law is somewhat complex and has been discussed in Section 2 of this Report, to which reference should be made. 3.1.16 Otherwise sitting the International Registry required under the Unidroit Rail Protocol (see paragraph 2.4.12 et seq) alongside the other two registers appears to present few difficulties. However, it requires a “unique identification criterion” on a vehicle to enable a potentially permanent interest in the asset to be registered. In practice, this may be difficult to achieve without some kind of permanent identifier, something that cannot be guaranteed under the structured numbering system that is currently widely used in Europe (see below). It is to be noted that the Unidroit Rail Protocol register will be publicly available to all via the Internet1.
1

Art. 22 of the Cape Town Convention and letter from Chairman of Rail Working Group to Consortium 29 July 2002.

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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 bodies2: allocation of vehicle identifiers; management of vehicle database/register3; arrangements for international use, where these are not tied to a particular railway undertaking (for example in wagonload operations); agreement/specification of maintenance standards, where not mandated by TSIs (and inspection and enforcement); verification of insurance arrangements (including self-insurance where appropriate). 3.2.4 The present system of attaching vehicles to UIC member railway undertakings “who can be trusted”, provides important safeguards that vehicles are maintained to appropriate standards and that liability cover exists. If, as recommended, this is no longer mandated to gain access to the Single Market suitable alternative arrangements will need to be provided to verify that vehicles are in an appropriate standard of maintenance and that suitable liability insurance is provided when injury and/or damage is caused by vehicle defects. 3.2.5 The issue of insurance needs to be examined in parallel with Article 9 of Directive 95/18/EC, which requires that railway undertakings have some type of insurance cover as a condition of their licence. However, the level of cover and the terms of the insurance are not
2

These could include governmental bodies, infrastructure managers, regulatory bodies, independent commercial organisations or joint bodies established by industry with open membership and equal rights for all. Also proposed under RWP II, which also requires independence from any infrastructure manager: see Section 5 of this Report.

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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 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 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 in use are structured. With these systems, when changes occur to a vehicle, for example its keeper or its operating regime, the vehicle number changes in 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. 3.3.3 It therefore appears difficult for a structured running number to provide a permanent identifier that could meet the needs of the International Registry. Issues of temporal co-incidence between the running number marked on the vehicle and the information held in the registry, the possibility of errors or fraud when vehicles are renumbered and also the reuse of numbers, as occurs under the present system, can make it hard to establish the identity of the original asset. 3.3.4 An unstructured identifier merely needs to be unique, apart from that it could be a random number. Any additional information that relates to it is contained in a database and is accessed using the identifier. Because a structured identifier has information about the item embedded within it and, because of the need for it to allocate specific codes to attributes which can then not be used for items not satisfying those attributes, the utilisation of codes is less efficient than with an unstructured identifier. With a structured identifier, the length of the code is determined by the number of attributes to be identified and the number of items sharing attributes whereas with an unstructured identifier the number of codes and the consequent length of the identifier need simply be the total number of items.

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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 of these issues are relevant. It should be 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 is to 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 practice in this area. 3.3.7 Rebuilding and re-engineering of railway vehicles is not uncommon, occurring most frequently for locomotives, because of their cost, and for wagons, to carry different commodities and meet changes in the market. These can vary from minor refurbishment, which would not normally trigger alterations to a structured number4, to construction of a new wagon chassis and body around the existing running gear (which generally comprises about 70% of the asset value for a wagon), which may or may not trigger a renumbering. The problems that arise for an owner seeking to permanently identify a particular asset can be seen from the following list of examples: minor refurbishment; re-engineering retaining the chassis and major components; replacement of vehicle body; replacement of vehicle body and some parts of the chassis; replacement of vehicle body and chassis; a number of identical wagons are refurbished simultaneously, efficient process means that the major components do not go back on the vehicle that they came from;
4

Although it can do, for example, changes to doors.

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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 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: to provide permanent identification of the vehicle structure for the following reasons: - to provide identification for legal reasons; - to provide legal title (claim on ownership); - to enable legal charges to be made (ownership or mortgage by financier); to identify vehicles and vehicle parts5 (this is required in case of either damage caused by or to the vehicle); commercial functions, as follows: - identity for CIM consignment note purposes (it is necessary to say which vehicle is carrying which goods); - charges: (hire or infrastructure) where these are based on type of vehicle, ownership/responsibility, capacity, maximum load, etc; - internal accounting systems (for example, maintenance cost analysis); tracking and tracing;

5

At present only wheelsets are individually accounted for.

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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; for fleet management; indicating what is permitted to be carried in a vehicle.

3.5 Vehicles Owned by non-UIC Members 3.5.1 In addition to those issues discussed above, although the UIC system as it relates to privately owned vehicles has worked well to date, there are a number of quite evident problems with its structure. These are: completeness; maintenance provisions; liability arrangements; and access to data. 3.5.2 As noted in Section 2, the current arrangements relate solely to privately owned wagons and no UIC provisions exist for the relationship between keepers of privately owned coaches or locomotives and nonmember railway undertakings. 3.5.3 It is increasingly inappropriate for the railway undertaking to whose fleet the vehicle is attached to supervise maintenance

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arrangements; the system does not encourage fleets composed of wagons based in different states. This is considered to have a deleterious impact on the proper operation of the Single Market in railway vehicle maintenance services. Nevertheless the 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 pool. Equally the 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 discussions indicate that owners/keepers want standard terms signed once with one railway which would then apply everywhere. Existing arrangements for owners/keepers (in the form of the UIP) and railways (in the form of the UIC) to discuss and agree contractual conditions are likely to continue. (It is worth noting that the dispositive nature of the CUV protects both parties from unreasonable contractual demands). It would also seem, however, that there is an option to have a “free” vehicle (known in the aviation world as a “white tail”); if so these free vehicles must have a right to a standard number. 3.5.7 The Consortium considers, therefore, that whilst it is clear that a vehicle attached to a railway undertaking will have to have that marked on the side; there is no supportable requirement for vehicles to be numbered in the railway undertaking’s own series of numbers. There can therefore be no requirement for the process to be carried out by a railway undertaking or a UIC member. 3.5.8 The possibility of vehicles without a relationship to a railway undertaking raises public policy and railway operating questions. Under current circumstances liability issues are resolved between keepers and the whole of the railway community by the UIC-433 contract for use, it seems clear that this cannot be a suitable model for the future. Further consideration of this issue lies outside the scope of this study but it is known that work on the issue has already commenced. Likewise, arrangements for repair of wagons are funnelled through mechanisms set up by the contract for use, to the extent that fleet operators do not enter

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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 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 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 undertakings and infrastructure managers as the integration between the two functions is loosened. Similarly, there are issues associated with which party in a liberalised environment owns IT and other systems that were developed under monolithic state organisations. 3.6.4 As noted above there are significant difficulties associated with vesting inherited IT systems in national railway undertakings or their successors, not least legality under Community competition law. The alternative is to vest all essential national vehicle databases, operating and similar systems either with the infrastructure manager, a regulatory body, or some other neutral body and to open access to these systems to all railway undertakings, vehicle owners, vehicle keepers, etc. 3.6.5 The case studies revealed Britain as an example of a country which has, to an extent, adopted the latter approach for many key systems, including the national vehicle database. The national operating system has insufficient confidentiality within it, permitting railway undertakings to monitor each other’s operations, should they so wish. Nevertheless whilst this situation is undesirable, Britain has experienced growth in passenger kilometres of over 35% and freight tonne kilometres of 50% since liberalisation, figures which are contrary to the EU15 trend. It can therefore be seem that whilst achieving appropriate commercial confidentiality is important it is demonstrably less important than market liberalisation. However, even here there are problems with differential

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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 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. Examples include serial numbers, production numbers and international standard number series. The term operating identifier is used to denote a 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; examples include vehicle registration marks or classification systems.

4.2 Comparison Philosophy Selection of Comparators 4.2.1 Identifiers are used in all areas of human activity. Examples include road vehicles, aircraft, domestic and industrial equipment, books, retail products and computer software. They may be used to identify the specific asset, to identify property rights, to enable batches to be identified in case of defects, to provide information on the item such as its composition or to prevent fraud. 4.2.2 There some railway vehicle characteristics that determine the need for and application of identifiers, which may differ from those required by identification systems for applications in other industries and modes. The key attributes of rail vehicles are that: they are mobile, they have to conform to appropriate technical standards, they can be valuable, they are often unaccompanied, and they have a wide range of important characteristics, some of which limit their scope or method of operation. Information about the asset and its characteristics must be readily available, and the information required by different bodies varies.

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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 the attributes of these 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 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 field are harder to find. In many cases, a 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 identifier to carry any information. The identifier could, however, indicate information such as origin point or date of consignment to avoid the need to look these up in a database. Nevertheless some examples have been identified that may be of interest for different aspects for example, international usage, use of two different identifiers. 4.2.5 The parallels that can be drawn with railways in other parts of the world are somewhat easier to make, since similar issues are faced to those covered in this Report. The Consortium thought three examples were worthy of comparison: North America, Southern Africa and Australia. Facets Explored 4.2.6 The main uses of railway vehicle numbers were discussed in Section 2 of this Report. These fall into five main areas: permanent identification of item; identification of liability; commercial functions; tracking and tracing; and operational functions.

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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 4.3.1 For a vehicle manufacturer to be able to sell a vehicle in Europe a European whole vehicle Type Approval certificate is required, depending on the category of vehicle. There are around fifty technical directives in total to be complied with. As a large majority of vehicle components are manufactured or assembled by suppliers to the vehicle industry it is often necessary for these components to be separately approved. 4.3.2 The Type Approval procedure is essentially the same for a vehicle as for a component. This procedure is defined in Directive 70/156/EEC and subsequent amendments. Both the item and the production process must be approved, the latter known as Conformity of Production (CoP) assessment. 4.3.3 The client provides the documents specified in the Directive together with the required number of sample products for assessment and testing. The client, with advice if required, prepares a "worst case" analysis of the product range together with a draft test plan. This analysis is assessed in a "worst case review" meeting with the Technical Service. 4.3.4 Where the product is a single component, this meeting may simply be a document exchange. Where a number of products are derived from a basic design they are assessed to identify a worst case version for testing in order to limit the amount of test work to be carried out. A documented worst case assessment is produced for the approval body as

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a record of the agreement. The test plan is finalised and the 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 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. 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 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 the manufacturer at its discretion to identify attributes of the vehicle. In the USA position 9 of must be used as a check digit. 4.3.10 The VIS occupies the last 8 characters of the VIN and the last four of these must be numeric. 4.3.11 In addition to the permanent identifier, a government authority also allocates an operating identifier, its registration number, to road vehicles. This is to a national standard format and is usually fixed to the front and rear of the vehicle. The two numbers will be linked in a database and both appear on the vehicle's registration document. The identity number of the major component (the engine) is also recorded in the vehicle’s registration document and database, this serial number also being stamped on the engine. 4.3.12 Fees have to be paid, generally on an annual basis, to register the vehicle for use on the road network; this is signified either by annual change of registration plates or the supplementary display of an official marker either on the registration plates or in the car windows. This is also linked to the registration and VIN numbers in official databases so that the relevant authorities can verify legality of use in real time. The advent of number plate reading devices is enabling the enforcement of annual payments and procedures to be automated.

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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 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 insurance. Mutual recognition of these standards applies throughout the EU and 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 on a 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 the format is similar, in combination with the state of registration, the registration number will be unique. The registration number 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 the vehicle changes ownership or its keeper changes his address whereas in others the registration number normally stays with the vehicle throughout its life. Technical Inspection 4.3.16 In 1977 the European Community adopted a Directive on the technical inspection of vehicles, which was amended in 1992 to include private cars. A later amendment details the items that must be checked on a vehicle when it is inspected. All the requirements have been consolidated in Directive 96/96/EC. The competent national authorities must inspect commercial vehicles at least once a year and private cars at least every two years, although Member States may require more frequent testing if they wish.

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Table 4.1- Performance of Main Identifier Functions: Road Vehicles Function Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions
VIN. Based on operating identifier. May be based on operating identifier. Not required. Based on operating identifier or fleet number. Operating identifier neutrally operated although not harmonised. Yes. Checked before allocation of operating identifier. Not intrinsic to identifier, but can be linked to issue of other identifying mark, for example, on an annual basis. A database with information on the operational identifiers can also store this information and trigger requests.

How Performed

Permits Single Market to Function Yes. Permanent identifier harmonised.

Conformity with Standards Ongoing Conformity with Standards

Civil Aviation Approval 4.3.17 Independent state agencies ensure compliance based on the Joint Aviation Rules issued by the Joint Aviation Authorities (JAA). Technical standards are agreed by the JAA and there is a resulting mutual recognition of airworthiness certification. Within the EU this is assured by Regulation 3922/91/EEC. Identifiers 4.3.18 For a civil aircraft a permanent identifier is the construction number, allocated by the manufacturer and permanently fixed to the airframe. The position of fixing varies by aircraft type. The serial numbers of the major components, such as the engines are also recorded. Registration of legal interests is facilitated by reference to this permanent identifier (see the reference to UNIDROIT in Section 2 of this Report).

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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 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, registration marks are never reused, even if the aircraft has been scrapped or 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 the FAA in the USA. 4.3.22 In normal operation an aircraft will be accompanied by crew who are familiar with and have manuals for the aircraft, thus there is no requirement for the identifier to indicate its technical characteristics. For most other operational requirements, the model designation provides adequate information. In any event each aircraft is under the control of a single operator which is fully aware of the characteristics and capabilities of each type of aircraft that he operates and therefore will only deploy aircraft on appropriate services and routes.

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Table 4.2 - Performance of Main Identifier Functions – Civil Aviation Function Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions How Performed
Airframe construction number. Based on operating identifier, can be confirmed by airframe number. May be based on operating identifier. Not required. Based on operating identifier. and harmonised internationally.

Permits Single Market to Function Yes. Operating identifier neutrally operated Conformity with Standards Ongoing Conformity with Standards
Yes. Checked before allocation of operating identifier. Not intrinsic to identifier, but database with information on the operational identifier can store this information and trigger requests.

Shipping Background 4.3.23 Because of the international nature of the shipping industry, action to improve safety in maritime operations is more effective if carried out at an international level rather than by individual countries acting unilaterally. A United Nations conference in 1948 adopted a convention establishing the International Maritime Organisation (IMO). From the very beginning, the improvement of maritime safety has been one of IMO's most important objectives. IMO promotes measures to achieve its objectives; these include conventions, protocols, codes and recommendations concerning maritime safety among other matters. One of the first was the International Convention on Safety of Life at Sea (SOLAS) which covers a wide range of measures designed to improve the safety of shipping including rules relating to construction and a harmonised system of survey and certification.

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Classification 4.3.24 Commercial vessels are classified according to the type of journeys that they are capable 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 to the materials used. The design is thoroughly assessed to 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. 4.3.27 Within the EU, Council Directive 94/57/EC as amended sets out which bodies are approved to perform inspection, survey and certification of ships in order to ensure effective application of the international Conventions. Those approved bodies are: American Bureau of Shipping (ABS); Bureau Veritas (BV); China Classification Society (CCS); Det Norske Veritas (DNV); Germanischer Lloyd (GL); Hellenic Register of Shipping (HR); Korean Register of Shipping (KR); Lloyd’s Register of Shipping (LR); Nippon Kaiji Kyokai (NK); Registro Italiano Navale (RINA); Maritime Register of Shipping (MRS).

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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 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 and 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. For example, 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; original documents of sale such as bills of sale, invoices, builders certificate, that cover the last five years; certificate of survey for tonnage and measurement issued by a classification society; certificate of incorporation (if a company is applying); registration fee. 4.3.31 The ship owner proposes a name for the vessel that will only be allocated once the registry has confirmed that it is not already in use. Lloyds Register of Ships 4.3.32 Lloyds Register maintains on a commercial basis a register which records the details of all merchant ships of the world over 100 gross tonnes, which are self-propelled and sea-going, regardless of classification. Vessels are listed alphabetically by their current name and their entries provide the following details: place of build; ship type; rig (for sailing vessels);

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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. 4.3.33 The current register contains details of approximately 87 000 ships and is available on CD-Rom and to subscribers via the Internet. Enforcement 4.3.34 There are international conventions, codes and protocols concerning ship safety and marine pollution as agreed by the International Maritime Organisation. The conventions and codes, which are statutory surveys, usually stipulate inspection and issuance of certificates as part of enforcement. Fourteen different types of certificate relate to different classes of vessel. Some are issued by the classification agency with others by the national registry authority. 4.3.35 In addition, many Member States instigate national regulations which incorporate IMO standards and apply them to their own and visiting foreign vessels. 4.3.36 Council Directive 95/21/EC concerns the enforcement, in respect of shipping using EU ports and sailing in the waters under the jurisdiction of Member States, of international standards for ship safety, pollution prevention and shipboard living and working conditions. The purpose of this Directive is to improve maritime safety in Community waters by enforcing compliance with international standards. It applies

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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 an obligation to inspect at least 25% of the vessels flying other countries' flags that enter their ports. Selection criteria for deciding which 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 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 be carried out on certain categories of higher risk vessels. Table 4.3 - Performance of Main Identifier Functions: Shipping Function Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions How Performed
Via continuous updating of international register of operating identifiers. Based on operating identifier. Might be based on operating identifier. Not required (continuously crewed). Based on operating identifier.

Permits Single Market to Function Yes. Conformity with Standards Ongoing Conformity with Standards
Yes. Checked before allocation of operating identifier. Regular checks under Port State Control regime.

ISO Containers Identifiers 4.3.38 ISO intermodal containers move goods throughout the world in a complex and extensive transport system, and each year there are over 500 million container movements, a number that is typically growing in deep-

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sea trade at 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 as a 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 freight car 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 only results in damage to the consignment and consequent loss 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 of insurance 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 since 1972 by the International Organisation for Standardisation (ISO). It forms an essential part of the ISO 6346 standard: Freight Containers Coding, Identification and Marking. This standard also describes some complementary features such as size and type code, state code and various operational marks). Only ISO Alpha-codes for identification of container owners registered with BIC may be used as the unique marking of containers in all international transport and customs declaration documents and are used in 110 states by about 1 200 owners or operators representing approximately 90% of the world container fleet. 4.3.41 The code comprises: an owner/operator code of four letters, the last one being “U”; a six number serial; a seventh digit (check digit) providing a means of validating the recording and/or transmission accuracy of the data. 4.3.42 The code provides a unique identification for the container. It permits both the identification of the owner or principal operator, and the identification of the unit by its owner or operator in his own database. The six serial numbers are not allocated by BIC but by the owner or operator.

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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 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 transport. The code may 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 Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions How Performed
No, unless there a manufacturer’s serial number is also provided. If appropriate, based on operating identifier. Based on operating identifier. Based on operating identifier. Based on operating identifier. and harmonised. No. No.

Permits Single Market to Function Yes, operating identifier is neutrally operated Conformity with Standards Ongoing Conformity with Standards

4.4 Other Industries Cataloguing and Numbering Systems 4.4.1 A multitude of cataloguing and numbering systems exist in different industries. Some examples include International Standard Book Number (ISBN), International Standard Serial Number (ISSN), International Standard Music Number (ISMN), International Standard

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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 (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. International Standard Book Numbers 4.4.4 The International Standard Book Number (ISBN) was approved as ISO standard 2108 in 1970. The purpose of the international standard is to co-ordinate and standardise the international use of ISBNs to uniquely identify a single title or edition of a title, published by a specific publisher. The original standard has been revised as book and book-like items begin to appear in new forms of media, although the basic structure of the ISBN, as defined in that standard, has not changed and is in use today in some 150 countries. The international administration and coordination of the ISBN system occurs through the International ISBN agency in Berlin. 4.4.5 An ISBN consists of ten digits preceded by the letters ISBN. The ten-digit number is divided into four parts of variable length, which must be separated clearly by hyphens or spaces, e.g. ISBN 0 571 08989 5 or ISBN 90-70002-04-3. 4.4.6 For purposes of data processing the ten-digit string is used without hyphens or spaces. Interpretation and human legible display is effectuated by means of the tables of group numbers and publisher identifier ranges. 4.4.7 The number of digits in the first three parts of the ISBN (group identifier, publisher identifier, title identifier) varies. The number of

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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 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. 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 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 up to seven digits. Publisher identifiers are 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 specific edition of a publication of a specific publisher. A title identifier may consist of up to six digits. As an ISBN must always have ten digits, blank digits are represented by leading zeros. 4.4.11 The check digit is the last digit of an ISBN. It is calculated on a modulus 11 with weights 10-21. 4.4.12 The number of digits in each of the three parts of the identifier is variable, although there are always nine digits, which with the check digit, make up the ten-digit ISBN. 4.4.13 For ease of reading, the four parts of the ISBN are divided by spaces or hyphens. The position of the hyphens is determined by the publisher identifier ranges established by each group agency in accordance with the book industry needs. The hyphens are generated by a hyphenation output programme, which helps reduce work at input, reducing the number of characters, eliminating manual checking of hyphenation, and ensuring accuracy of format. Library Classification 4.4.14 While ISBNs uniquely identify publications, they provide no information about the content. When searching in a library for
1

See description in footnote in Section 2.

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information about a particular field it is necessary to have a means of pointing to publications that 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 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, 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 organisation tool that is continuously revised to keep 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 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, 663.224 concerns making sparkling wine. Codes from 600 to 699 cover technology and applied sciences. Codes from 660 to 669 cover chemical engineering and related technologies. Code 663 denotes beverage technology while 663.2 is specific to wine and wine making and 663.22 narrows this down to making grape wine. The final digit distinguishes white, red or sparkling wine. More relevantly Codes from 620 to 629 cover engineering. Code 623 denotes military and nautical engineering (!) whilst 623.6 is specific to military transport technology and 623.63 narrows this down to railways. The final digit distinguishes rolling stock from trackwork . There is an occasional revision of the system to take account of new concepts and the Dewey system is currently in its 21st edition. 4.4.17 Both identifiers facilitate identification of a specific publication, but from very different initial information. In general libraries have a searchable database listing their contents with both ISBN and for example DDC. Starting with either of these it is possible to ascertain publishers, authors and titles of relevant publications. Using an operational identifier (for example, DDC) enables the user who requires a publication in a certain area to narrow that search down to a few publications in a large library without knowing anything about who wrote or published them. On the other hand knowledge of the ISBN enables the immediate identification of the author, publisher and other characteristics without knowing anything of the subject matter. Although it is structured, it would be difficult to recognise more than the geographic area from the ISBN.

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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 Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions
ISBN If appropriate, ISBN Based on ISBN Based on ISBN in commercial applications Based on operating identifier harmonised. Allocation of codes is neutrally operated. No. No.

How Performed

Permits Single Market to Function Yes. Permanent and Operating identifiers are

Conformity with Standards Ongoing Conformity with Standards

Product Codes Selection of Example 4.4.19 Identifiers are widespread in widespread use in the retail trade. Virtually all products are bar-coded with a product code. These can have various forms. These unique identifiers are likely to be used in collaboration with other systems of retrieving products. EAN-UCC codes 4.4.20 With the expansion of global trade and computerisation, plain language descriptions of products and services need to be replaced by identification systems that are usable in all trade and industry sectors world-wide. The EAN-UCC system has been developed to meet this need by providing solutions that guarantees unique and unambiguous identification. Manufacturers, exporters, importers, hospitals, wholesalers, retailers, etc, can use the system to communicate information regarding the goods or services they trade.

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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 or GTIN for 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 and a brief description is provided of the numbering structure used for trade items intended to cross the retail point of sale. 4.4.25 Once assigned, the GTIN can then be bar coded onto the trade item using the EAN/UPC structure. All identical trade items use an identical GTIN and bar code. Any item which crosses the retail point of sale should be bar coded using the EAN/UPC structure. The two most widely used numbering structures for this are the EAN/UCC-13 and UCC-12. The GTIN is constructed as follows:
EAN/UCC-13 identification number (GTIN) EAN•UCC company prefix ------------------------------> EAN/UCC-13 N1 N 2 N3 N4 N5 N6 N7 N8 N9 N10 N11 N12 N13 Item reference <-----------------------------Check digit

UCC-12 0 N1 N 2 N3 N4 N5 N6 N7 N8 N9 N10 N11 N12

4.4.26 EAN•UCC company prefix: any company wishing to identify their products will be allocated an EAN-UCC company prefix upon joining an EAN Member Organisation or the UCC. The company prefix is variable in length and is normally determined by the capacity of GTINs required (10, 100, 1,000, etc).

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4.4.27 Item reference: this part of the numbering structure is allocated by the user company. Each different trade item is allocated a 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 Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions
Probably based on warehouse or supermarket aisle location harmonised. No. No. Yes - UPC If appropriate, based on UPC Can be based on UPC

How Performed

Permits Single Market to Function Yes. Identifier is neutrally operated and Conformity with Standards Ongoing Conformity with Standards

4.5 Railway Systems Elsewhere North America Background 4.5.1 The North American situation is instructive. The most notable characteristic of North American railway operation is the almost total delegation of the national sovereign functions of the three principal states (USA, Canada and Mexico) to the railway industry. In this way the trade association, the Association of American Railroads (AAR), exercises a number of quasi-regulatory roles on behalf of the US Federal Railroad Administration (FRA). It sets standards and polices them on behalf of the community with little or no intervention by the governments themselves. American railroads benefit from almost ideal conditions for

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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 them. 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. 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 are rare. New 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 4.5.4 The states of North America have a common numbering system organised by the Association of American Railroads, The railroads have standardised rolling stock and a single system of rolling stock management. Widespread use is made of information technology for all railway processes and in particular fleet management, operations control, accountancy and billing. Sophisticated customer information systems are in place. 4.5.5 The AAR system makes use of a code comprised of two to four letters to identify the owner of the vehicle, this code is in the main mnemonic, for example, BNSF for the Burlington Northern Santa Fe Railway. An X as the last character identifies a vehicle that belongs to a private owner rather than a railroad, for example, GATX. (U and Z as the last characters are reserved for containers and road trailers). Some 36 000 of the theoretical 405 000 combinations are used. Control over the letter codes is held by the National Motor Freight Traffic Association although administration of railroad codings is undertaken by RAILINC2 on behalf of the AAR. Allocation of a letter codes is conditional on approval as a railroad by the US Department of Transportation and a commitment to the vehicle being entered on the vehicle master file (see

2

A subsidiary company of the AAR with responsibility for the neutral administration of industry-wide IT systems (for example UMLER).

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below). In the case of hauled rolling stock the remainder of the number comprises up to six digits as a serial number and is defined by the owner. 4.5.6 The code 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. 4.5.10 Traction follows an essentially similar principal, the same letter code of up to four letters followed by up to four digits. Although the structures of locomotive and hauled stock numbers clearly overlap, controls are in place to ensure that numbers are not duplicated. It should be noted that whereas the letter code is always marked on hauled stock, it is normally omitted on locomotives. UMLER 4.5.11 The UMLER (Universal Machine Language Equipment Register) file is the AAR master file of vehicle characteristics, UMLER has a long history and was originally issued annually in paper form and is still publicly available in this form. At present the file includes approximately 1 500 000 freight vehicles plus a further 2 300 000 containers. Locomotives and passenger rolling stock are also included. The file is managed by RAILINC. In managing this file, RAILINC is in part providing an operating tool for the railway community and in part exercising a para-statal activity on behalf of the Federal Railroad Administration. 4.5.12 The file is keyed by vehicle running number which is not a permanent attribute of the vehicle (since it changes with the sale of a vehicle from one company to another). There is no permanent identity information on the file and indeed if a change of number takes place, the new record is not associated with the old. The record for each piece of

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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 or stolen. Vehicles that are 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 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 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. Again the systems to check compliance are internal to the industry and rely extensively on internal audit. The AAR does not perform external audits; however it is understood that quality systems similar to those of ISO 9001 are required, which are audited and if problems are encountered accreditation is lost. 4.5.15 The FRA also holds extensive regulatory powers over railroads, with the power to enforce action on safety or even to suspend railroad operations.

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Table 4.7 - Performance of Main Identifier Functions: North American Railways Function Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions
No If appropriate, based on operating identifier Based on operating identifier Based on operating identifier Based on operating identifier harmonised (Also satisfies US legislation) In part, owners and builders make separate undertakings to comply with standards. No

How Performed

Permits Single Market to Function Yes, identifier is neutrally operated and Conformity with Standards Ongoing Conformity with Standards

Australia Background 4.5.16 Australian railways work to a number of gauges; the interstate network, however, is to 1435mm gauge and represents a parallel with European operations. The remarks below refer only to the interstate network. Australian railways have been restructured to a model which closely resembles the British one. Infrastructure and operation are therefore entirely divorced. 4.5.17 A substantial part of the trunk route infrastructure belongs to or is operated by the Australian Rail Track Corporation, a Commonwealth Government organisation; however, State owned infrastructure continues in New South Wales and Western Australia. A number of private operators provide freight services and a mixture of state owned, franchised and private operators provide passenger services. Australian freight operations form a series of point to point flows without much pretence of being a network.

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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 type, subtype, bogie and braking system. The allocation of a single character for the owner reflects the fact that privately owned wagons are rare in Australia. The structure of the maximum of five digits which follow the letters is not specified in the standards, some operators use them to identify vehicles within the letter code, others as an independent accession number. 4.5.22 Given that passenger vehicles tended to captive within their states, no overarching numbering system was imposed on them and they remain numbered to a mixture of standards, normally numeric but otherwise with little in common. Some states use structured numbers, within vehicle class or as a function of the multiple unit to which they belong, other states merely use an accession number. 4.5.23 Likewise traction rarely crosses state frontiers and there is therefore no need for a common standard for numbering it. Again a variety of numbering systems have evolved, normally structured by class and then serial number, although class itself is numeric in some systems, alphabetic in others. Some states use accession numbers with the class identifier rather than a serial number within class. Computer System 4.5.24 Each railway undertaking has its own computer system to organise its own traffic. In addition infrastructure managers have their own systems (which accept details of traffic moved by all the operators).

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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 Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions
No Yes, based on identifier Based on identifier Based on identifier where provided (railway undertakings provide their own services) Based on identifier harmonised (also compliant with Australian competition legislation) Yes. Checked before allocation of operating identifier No

How Performed

Permits Single Market to Function Yes, identifier is neutrally operated and

Conformity with Standards Ongoing Conformity with Standards

Southern Africa Background 4.5.26 The railways of Southern Africa: those of South Africa itself, Botswana, Congo, Mozambique, Namibia, Swaziland, Tanzania, Zambia, and Zimbabwe, are independent state-owned railways with a common gauge and very similar operating conditions. It will be evident that the countries are at different stages of economic development. South Africa

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is the economic powerhouse of the region and traffic to and from South Africa predominates. Nevertheless traffic is 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. 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 terminals over the whole of Southern Africa and in effect is an international railway operating and commercial control system. It both distributes vehicles to where they are needed and calculates the charges for their use. Vehicles are in process of being fitted with automatic vehicle identification tags to automate this process. 4.5.30 This system provides an interesting example of a wholly integrated solution using dissimilar numbering structures. Whilst all the numbers are structured, there has been no attempt to rationalise them, and the only integrating feature is the Sprint computer system. This model depends on having a single system to control all movements. It works well in the circumstances of having a single powerful railway with satellites but is difficult to visualise in a pan-European context. Enforcement 4.5.31 Each state operates its own enforcement regime, reinforced by checks at frontiers for vehicle compliance.

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Table 4.9 - Performance of Main Identifier Functions: South African Railways Function Permanent Identification Identification of Liability Commercial Function Tracking and Tracing Operating Functions
No Yes Yes Yes Yes

How Performed

Permits Single Market to Function No, presumes state railways Conformity with Standards Ongoing Conformity with Standards
No

4.6 Conclusions and Parallels General Points 4.6.1 None of the non-rail comparative examples discussed exhibits the full range of requirements that have been identified for rail vehicle identifiers. Nevertheless different aspects of the identifiers and systems are worthy of note. These are discussed below. 4.6.2 One significant factor in defining what is required of an identifier is whether the item is accompanied or whether the identifier must provide information without human intervention. In the case of three of the transport examples considered, the items to be identified will in general be accompanied. 4.6.3 In the case of the three examples from rail systems in other parts of the world, none of them does all that would be required from a comparable new European system. The North American system is the most interesting, particularly in regard of the UMLER vehicle database. Again the points that are worthy of note are discussed below.

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Permanent 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 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 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 4.6.6 In many of the cases where a permanent identifier is used, the identifier is structured. Often part of the identifier indicates the manufacturer of the item. The allocation of production numbers within the overall identifier is often left to the manufacturer themselves, with the system of self-regulation by manufacturers working well. 4.6.7 Since the permanent identifier only conveys a limited range of information, most of the detailed information required relating to the item is actually contained in databases maintained by the various actors. International Aspects 4.6.8 For permanent identifiers used internationally, in general, an international agreement or standard determines the format of the identifier. Frequently this forms an ISO standard. There is often an office responsible for allocating the first parts of the codes, which identifies the responsible party. A fee generally must be paid for this registration but in general no fee is payable for individual identifiers issued. Compatibility 4.6.9 Permanent identifiers are usually a defined length, although in the case of UPCs, the systems have been devised to enable different length

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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 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 as one would expect the three non-European rail systems studied use them. The fundamental difference with other transport modes is that they are required for the railway industry’s own purposes and are therefore allocated by the rail industry itself rather than Government. Form 4.6.13 Most operating identifiers have at least a simple structure, enabling basic assimilation of the place where the asset is registered or the owner, if little else. In the case of other rail systems sometimes (as in the Australian example) limited technical information is also contained within the structure of the number, although this is emphatically not the case for North America. 4.6.14 As with (the linked) permanent identifier the limited range of information conveyed means that most of the detailed information required relating to the item is actually contained in databases maintained by the various actors. International Aspects 4.6.15 In the case of aircraft there is an international agreement covering the format of the operating identifier, while in the case of road vehicles, the format traditionally varied from state to state.

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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 falls 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 world the UMLER database in North America provides an example of an international database for North America and Sprint for Southern Africa. Standards 4.6.20 For an identifier to be accepted sufficiently widely to become a standard, it must either be so good as to replace others through the choice of users, or it must be mandated by a body with sufficient authority to ensure its use. 4.6.21 For the majority of the identifiers considered in the comparison, an international standard exists, prepared by the International Standards Organisation. In the case of aircraft, there is an international standard but it was prepared by the International Civil Aviation Organisation. 4.6.22 In contrast the rail industry is notable for the lack of international standards defining identifiers, international adoption of particular numbering systems has only really occurred through international industry organisations such as the AAR, the UIC and the OSJD, each with geographical constituencies. Whilst there has been co-operation between the UIC and OSJD, there has been no attempt to develop a world-level numbering system. In consequence the systems selected have limited compatibility with each other (see below).

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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 codes simply 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; there should be no disadvantage to an entity arising from the form of identifiers allocated to it; essential data systems should be available on an equal basis to all users. Verification of Conformity 4.6.25 The verification of conformity with standards (for example, technical compatibility or the holding of insurance cover) prior to allocation of an identifier or during its validity will usually only arise where there are strong reasons, for example public safety issues. These can occur in the transport field and it is no surprise that both road vehicles and aircraft are subject to these checks. 4.6.26 The verification of conformity with standards, both initially and during the asset's life essentially comprises slightly different aspects of a similar task. It is difficult for an indicator alone to indicate this satisfactorily since taken alone it is unverifiable. Effective verification requires an information system enabling the identifier to be linked to data indicating checks of conformity. The information system must itself be operated by a reputable independent body. In two of the other transport modes considered, databases are maintained by governmental bodies to confirm compliance. It is vital that the system enables auditing of the process to verify compliance.

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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 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 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 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 system have 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 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.

5.2 Commission’s Proposals in RWP II Interoperability Directives 5.2.1 Directives 96/48/EC and 2001/16/EC lay down rules for the interoperability on the Trans-European high speed network and the Trans-European conventional network respectively. After amendment by RWP-II the scope of Directive 2001/16/EC will change: the complete European conventional rail system will come under the provisions of the Directive. 5.2.2 The Commission’s proposals for the interoperability directives will contain two registration undertakings that are relevant for this study. These are firstly the rolling stock register and secondly the national register. 5.2.3 The requirement for a rolling stock register for conventional rolling stock has already been discussed as part of the narrative on Directive 2001/16/EC. The proposal is that the same register will become obligatory for high-speed rolling stock (in accordance with

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article 22bis Directive 96/48/EC after amendment by RWP-II). The register will cover both conventional stock and high-speed stock1. 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 for the rolling stock 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 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”. 5.2.7 The details of the content of the register have to be included in common specifications that will be adopted by means of Article 21 procedure, on the basis of a draft prepared by the ERA2. The Draft Directive specifies the data that it is mandatory to record3, which is: references to the EC declaration of verification and the issuing body; references to the register of rolling stock contained in Article 24 and Article 22bis respectively; identification of the owner of the vehicle and of the railway undertaking using it; any restriction on how the vehicle may be used; and data relating to the state of maintenance of the vehicle. The Draft Directive further prescribes that registration has to take the place of the “alphanumeric identification code” that has to be assigned to each vehicle when authorised to enter service4.

1

See for a full definition of the latter: Annex I point 2 of Directive 96/48/EC, to be amended by RWP-II. 2 See Article 21 paragraph 2 of the Directives. 3 Article 14 paragraph 5 as proposed by RWP-II. 4 Article 14 paragraph 4 as proposed by RWP-II.

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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 should depend 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 drafting the 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 undertaking5. 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 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 register will exist for: the authorities designated in Articles 12 and 18 of the Safety Directive, it is noted however that it was probably intended to refer to Articles 15 and 20, which refer to national safety authorities and investigating bodies; the national regulatory bodies (to be assigned by the Member States on the basis of Article 30 of Directive 2001/14); the ERA; infrastructure managers; and railway undertakings. It is proposed that more limited rights of access will exist for: safety authorities and investigating bodies, but only insofar as it concerns “information concerning railway safety”; and for any other party with a “legitimate interest”.

5 6

Article 14 paragraph 4. Article 15 paragraph 3 of the draft Directive. 7 Article 15 paragraph 4 of the draft Directive.

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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 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. 5.2.14 The Draft Directive does not state how often the register has to be updated. The ERA regulation, however, states that the national authorities (in this case the safety authorities) responsible for issuing the documents (for example safety certificates) will have to notify the ERA within one month of each individual decision to issue, refuse or withdraw a document9. 5.2.15 The ERA Regulation requires the ERA to keep a public list (also referred to as public register of documents and public database) of issued safety certificates10.The register will be open for public scrutiny. ERA Regulation 5.2.16 The draft ERA Regulation refers to a number of registers established or to be established by other Directives or draft Directives, as follows: a public register of licenses and safety documents11; a public register of interoperability documents12;
8 9

Article 11 paragraph 3 of the draft ERA Regulation. Article 11 paragraph 2 of the draft ERA Regulation. 10 Article 11 paragraph 1 sub b of the draft ERA Regulation. 11 Article 11 draft ERA Regulation.

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a national register13. 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; authorisations for putting assets or vehicles into service, including the associated registration numbers; and registers of infrastructure and rolling stock. 5.2.19 In the national register information must be kept as described above for the Interoperability Directives. 5.2.20 In respect of the register of licenses and safety documents national authorities responsible for issuing the documents, will have to notify the ERA within one month of each individual decision to issue, refuse or withdraw a document14. 5.2.21 ERA Regulation does not contain a provision about the frequency with which the register of interoperability documents must be updated. 5.2.22 The ERA will be responsible for the public registers and national authorities (which must be independent of infrastructure managers and railway undertakings) will be required to keep national registers up to date. Whilst the former will be open for public scrutiny, access to the national registers is limited as noted above.
12 13

Article 19 draft ERA Regulation. Article 18 draft ERA Regulation. 14 Article 11 paragraph 2.

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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. 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 stock manufacturers stated that different railways interpreted specifications differently. Given the likely impact of the Interoperability Directives in resolving many of the foregoing issues, 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. 5.3.3 Manufacturers had no strong views on numbering per se nor on the concept of the VIN. The manufacturers interviewed had no strong objections about being involved in the process of defining and allocating VINs, should this be required. 5.3.4 UIC member railway undertakings pointed out that reconsideration of the numbering structure was already taking place within the UIC (see section 5.4 et seq). They emphasised that this was being driven by changes to the wagon regimes themselves changing as a result of liberalisation. They pointed out that the current arrangements offered clarity and simplicity and any new arrangements should do the same. They were prepared to accept alternative arrangements provided they offered similar clear relationships and in particular provided that the costs and disruption of change were not too great. No railway undertaking objected to change on the grounds that they would be paying for changes that would benefit third parties. 5.3.5 Non UIC member railway undertakings responses varied as a function of the traffic they operated. Most were reasonably satisfied with the process of approving vehicles but some were concerned by the conditions for operation. They drew attention to the problems of operating their own fleet of vehicles without the benefit of twelve digit international numbers, where these are denied to them.

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5.3.6 Wagon owners’ responses were less consistent than other parts of the industry. The same comments were made as made by manufacturers about the timescales, costs and differing emphases in the approval process. By contrast there was general satisfaction with the relationship with railway undertakings although there was a strong demand for greater international freedom away from national 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 it might involve. They strongly supported a permanent VIN, given the problems under current circumstances of tracing wagon histories as they were successively renumbered. Owners also supported the concept of an international database whilst recognising the problems of confidentiality. They favoured any such database being under independent control. 5.3.8 Regulatory authorities’ responses were amongst the most incisive, although responses were only received from states where the process of liberalisation had gone furthest. They identified the problems of the development of open access in the climate of a structure operated by a trade association and designed for a limited number of large railways which did not compete. All the respondents had already developed their own national technical approval systems although the details of these varied quite considerably. They had considered how this could be linked in with vehicle numbering. There was general support for a structured twelve digit system with a country code. There was less support for a VIN. Most respondents thought the systems for numbering vehicles ought to be run by the state, perhaps delegated. The exception, Great Britain, thought that an industry scheme was to be preferred provided it was transparent and independent. 5.3.9 The only issue on which universal consensus appears to exist is that if VINs are adopted, they should be applied before the vehicles leave the manufacturer’s facility when first built or when reconstructed. The necessity for this, who should allocate it and the information that it should contain are, however, issues where wildly disparate views exist.

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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 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. 5.4.3 Railned accordingly made a proposition to the UIC in late 1997 to resolve this issue in the short term and to provide a possible solution in the longer term. Their final report was tabled in September 1998. Methodology and Findings 5.4.4 The VNS report saw the objectives as being to accommodate the vehicles of new railway undertakings simply and without putting the costs of doing so on UIC members. 5.4.5 The solution proposed by the VNS was simple: to allocate four codes from amongst the unused exchange regime codes to identify vehicles from non-UIC members and then use the “parent railway” code to indicate the home state of the licensed railway undertaking. In this way every organisation involved with the movement of vehicles would recognise them as being outside the normal regimes and would treat them accordingly. Two of the regime codes were intended for passenger vehicles and two for freight. The report pointed out that a similar initiative could be adopted for traction. 5.4.6 The proposal was overtaken by the continuing work on CODIRAIL which recommended four digit coding of railway organisations to allow every railway undertaking an explicit code (see below). This implied extending carriage and wagon numbers to fourteen digits. When the implications of a change to fourteen digit numbers

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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 in the new railway environment. Its solution was simple and neat. It made the implicit 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 official mark of acceptance. Both these 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 in Section 2 of this Report. The CODIRAIL project was set up to look at the longer term problem of accommodating large numbers of railway businesses within each country in the coding structure again with the intention of providing a code for all railway purposes. 5.5.2 Views on the coding of railway organisations proved to be disparate: at the extremes, some railway undertakings were in favour of quite complex systems involving up to six characters whilst others thought that the national clearing house (required in any event for national inter-railway transactions) could accommodate international issues without any change to the coding structure. The final solution decided in 1997 was to adopt an unstructured four digit code. Existing railways with two digit codes would retain these but preceded by two zeroes. In this way, it was intended that every business in the restructured environment would have its own code to be used for all purposes 5.5.3 Steps were taken to introduce this new coding structure in the accounting function first, which perhaps had the most pressing need to discriminate between rail businesses. 5.5.4 The implications of this four digit structure on vehicle numbers were only realised slowly; it implied a move to fourteen digit numbers. This brought with it changes to almost every computer system and a long

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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 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 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. 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 requirements but preserved as much continuity as was possible. 5.6.2 By the time the project commenced, however, it was becoming clear that the whole philosophy of numbering of vehicles by railway undertakings was being called into question. The study accordingly specifically acknowledged interoperability, the requirements of open access, the technical approval process, creation of the ERA, new commercial relationships and changes within the RIV. Methodology and Findings 5.6.3 The study looked at freight vehicles first, since these are both the most numerous and were considered to be the priority, in view of the numbers exchanged. Passenger vehicles and tractive units were to be considered by the study, but only after the freight vehicle study was complete. The study is still in progress at the time of writing and the work that still has to be undertaken is summarised below. 5.6.4 The study was set up in 2001 by the UIC with seventeen representatives from the principal interests (infrastructure managers, railway undertakings, coding specialists, IT specialists, finance specialists and the UIC itself). It was chaired by SNCF. The OSJD was also represented. Its terms of reference included: that vehicle numbers must be unique;

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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. The paragraphs below deal with each of these issues in turn. Operating Regime 5.6.7 As noted in Section 2 of this Report, the operating regime field, the first two digits of the current UIC/OSJD numbering system, is currently a mixture of commercial, operating and technical criteria. This field is therefore somewhat mixed. The current practice of the parent railway allocating the number has masked the extent to which its contents are not “pure”. 5.6.8 The RICS study proposed to make this first field “interoperability”, in line with this philosophy the distinction between exchangeable axles/bogies and single gauge wagons would continue to be made. The distinction between bogie wagons and axle wagons would continue to be made and the distinction between vehicles fully compliant and partially compliant with TSI/RIV standards would be made. 5.6.9 The study’s objective of making this field simply a function of technical characteristics was however compromised by the desire not to see change and the need to accommodate distinctions currently needed in railway operations. Distinctions between the way different types of vehicle are operated need to be indicated in the wagon number and this is the only field available for it. Accordingly, the recommendation was that

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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 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 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 not be retained since many railway undertakings cannot have UIC twodigit codes. The study recommended that this field became the country “in which the wagon was registered” rather than parent railway. 5.6.13 There are a number of issues following from this, not the least the meaning of “registered”, which could, for example, refer to the state in which technical approval took place, where a vehicle was manufactured, where the owner or keeper has his principal office, the state in which an owner/keeper chooses to base his wagons because of a favourable fiscal regime or the state from which the vehicle habitually operates. Important issues arise from each of these choices. 5.6.14 There are two key issues: first, that this field is actually used in railway operations and; second, the question of how the numbers actually get onto the wagons. 5.6.15 On the first question, the railway code is used as a surrogate for “home” in railway computer systems, for confidentiality criteria in IT systems and in myriad other applications. If this were to mean home state then many (but not all) of these problems would go away. Home state would have a meaning similar to that used for personal taxation, where normally resident. 5.6.16 To identify the wagons, an authority has to choose and allocate the numbers; allocation of numbers on approval will clearly produce

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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 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. It is unclear if the study believes this will be the 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 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. 5.6.18 The RICS study team informed the Consortium that the sale of a vehicle from one state to another would not entail a change of number. This together with the fact that the state holding the record may well not be the state in which a vehicle is actually based raises operational issues. In most railway operating IT systems digits 3 and 4 of the number are used as an indication of destination when repatriating a wagon. This information would have to be fed to operating systems from another source, requiring major IT systems revision. However, this potential problem is also indicative of the lack of sophistication of most railway operating systems; nevertheless although this lack of sophistication may be insupportable in the abstract, in practice the need to replace or upgrade existing IT systems is a severe impediment to implementation of the recommendations. Vehicle Type Code 5.6.19 The RICS study considered that the type code field had proved satisfactory and that is an adequate range of numbers to accommodate future designs, therefore no change was proposed. Serial Number 5.6.20 The RICS study proposed no change to current practices. Note that since the number format only allows 999 digits, where there are

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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 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, unless the 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 were accepted by the UIC Freight Commission in November 2002 together with commensurate changes to UIC leaflet 438-2. Given the present study, for the UIC railway community to agree change in the short term might be thought premature. The study was undertaken with the support of the OSJD and also has their approval 5.6.24 The first draft proposals for passenger stock were produced in January 2003 and a discussion document was produced for traction renumbering at the same time. The same principles of a desire to avoid renumbering and an acceptance of a governmental role in the process have guided their work. The plan is that the study team will now move on to develop proposals for tractive stock. Passenger Vehicles 5.6.25 The RICS group’s proposals for passenger stock follow the general lines adopted for freight. The number remains structured; the first field becomes an indication of interoperability overlain with technical characteristics, the second field state of registration, the third vehicle type, followed by serial number and check digit as before. The RICS group proposals are similar to those made by the consortium in Appendix K. The RICS group expect to pass their proposals through UIC bodies to get approval for implementation on 1 January 2004

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Traction 5.6.26 The RICS group has produced an interim discussion paper on numbering traction. It observes that despite the UIC principles (which in any event leaves considerable flexibility), a diverse variety of traction numbering systems are in use. It notes that traction is 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, and digits 6 to 11 are series and subseries identifiers and serial 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 in making the 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. Summary of RICS Study 5.6.28 Much of the work of the RICS group has now been done and the general principles that have been followed appear to be clear. The Consortium considers that the RICS study has been diligent in accommodating the needs of a restructured and more liberalised railway industry. The proposals of the RICS study however still leave a large number of, and perhaps too many, unresolved questions.

5.7 The Steria Study 5.7.1 In mid-2001 the UIC invited tenders for a project to design a centralised rolling stock database. The project had been inspired partly by comparing the European approaches with the North American database UMLER. Indeed, preparatory work had already been done by a seconded specialist from the US. An impetus for the work also came from a realisation that EU and OCTI requirements would mandate the creation of a database at some level and there might be value in having a single database to satisfy all requirements as effectively happens in the US.

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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 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 that this represents a logical base line; current rules are well understood and changes can 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 database is expected to be to initialise a wagon’s technical details before each journey, a task which is primarily operational and safety related. 5.7.5 The recommendations are for a centralised database holding technical details of all freight wagons attached to UIC member railways’ fleets fed and interrogated by individual railway undertakings. It is proposed that variable architecture is provided, holding core data for all vehicles but enabling some railway undertakings to provide more and for the database to be extended as necessary. Within the core element, only technical data will be held, including permanent technical data and volatile data such as the date that the next overhaul is due. Within the optional element multipurpose data such as the identity of a long-term hirer or private wagon owner could be held. There is no intention to hold journey or traffic data; thus, the file will not develop (as has the US file) into an all-purpose railway database for operational and commercial purposes. 5.7.6 As a technical report, the report was silent on proposals for managing the database and who could participate but that there is an intention to open it to the entire railway industry is clear. Confidentiality criteria are foreseen but not defined. The report provides significant detail for freight vehicles but in explaining that the need for data for passenger vehicles and tractive stock to be exchanged at the international level is slight, however, it provides no details of passenger and tractive solutions.

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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 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 must meet a number of high level objectives. These high level objectives can be disaggregated into two sets of requirements: absolute requirements and important 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; be cost effective; provide no constraints for new railway undertakings; cover all types of rail vehicles. 6.1.3 Considering the system as a whole, it is considered that the important requirements are as follows: flexibility for the future; ability to accommodate technical innovation; ability to accommodate new operating and working practices; provides no constraints for new contractual structures in the industry; maximal acceptability for all geographic areas; facilitates good customer interfaces; facilitates good interfaces with regulatory, control and government authorities; facilitates good interfaces between service providers. 6.1.4 The overall objective is to find a system of placing vehicles in service, allocating them with numbers and then storing, accessing and

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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 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? What form should vehicle identifiers take? Is there a need for a separate VIN? If a VIN is required: - Who should allocate it? - What relationship should it have to the running identifier and its database? - What form should it take? - Should a database also include serial numbers for major vehicle components, if so what components? If vehicles are no longer attached to the fleet of UIC-member railway undertakings, how is it to be verified that vehicles are appropriately maintained? Similarly, without attachment to the fleet of a UIC-member railway undertaking, how is it to be verified that vehicles are appropriately insured? 6.2.2 Each of these key questions is considered in turn (grouped by subject) and the options available for each are listed. The options are then analysed in the next Section.

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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, 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; by any state of the vehicle owner or keeper’s choice; by an independent body jointly owned by the rail industry, with membership automatically available to all; by any licensed railway undertaking; by an infrastructure manager.

6.4 Database and Register Issues 6.4.1 In holding vehicle information digitally the first issue that emerges is what should the structure of the database/register be? The fundamental architecture choice is between holding data in a single central database or distributing it in a series of different databases, for example national databases, that are linked together and can exchange information between them. At the extreme some data (for example maintenance data) could be held digitally on board each vehicle and read/reset locally. 6.4.2 A further problem is the differing information requirements demanded by the Interoperability Directives, Unidroit, the

1

The term state relates to a neutral governmental department or body.

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Options for Change

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. 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 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 Databank, necessary 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 database or databases, which would do little more than meet international legal obligations and provide an international reference; individual national databases linked to pan-national database(s), through which all exchange of data would be undertaken; individual national databases with no linkages between them. 6.4.4 Once the broad architecture of the database(s) has been determined the next decision that has to be made is who should run it? To an extent this is governed by the option selected, in the case of an international database the main options are considered to be as follows: by an international supra-governmental organisation (for example the ERA or OTIF); by an international railway organisation (for example the UIC); by an independent body jointly owned by the rail industry, with membership automatically available to all.

2

For example none of the legal requirements include important railway operating data such as vehicle capacity. Furthermore railway operating data needs to be kept continuously up-to-date.

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Options for Change

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 systems3. 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 confidentiality. Where a decision has to be made between equality of access and maintenance of confidentiality comparison of the case studies for Germany and Great Britain indicates that liberalisation of access to systems is more important than restriction of access to confidential information. 6.4.6 As noted previously the international legal obligations define those who should have access to the information held on the international vehicle databases and registers, for example having to be publicly available in the case of the rolling stock register and the International Databank for example. Nevertheless it is considered that mandatory access rights are essential to all national railway operating, etc, systems that use vehicle data for all licensed railway undertakings and vehicle keepers. Naturally, these access rights must be equal and nondiscriminatory. This is considered to be an essential pre-requisite to achieve EU policy in the sector and is discussed further in Section 9.

6.5 Definition of a Vehicle 6.5.1 As has already been noted in Section 2 there are two issues where the meaning of “vehicle” needs to be clearly defined: what is defined as
3

See Appendix I for a definition of what “vital operational IT systems” comprises.

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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 Working Group established in drawing up the UNDROIT convention has been developing 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. 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 Without VIN With VIN

Numbering System No change to present numbering systems Universal1 UIC 12 digit Universal modified UIC 12 digit2 Universal OSJD 8 digit Universal AAR 10 character Universal 8 digit structured Universal 10 digit structured Universal 12 digit structured (non-UIC based) Universal 14 digit structured Universal unstructured 8 digit Universal unstructured 12 digit

X X

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Numbering System 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 retain their old numbers) – unstruct. 12 digit system Vehicle keepers free to choose between a system of their own and modified UIC system Vehicle keepers free to choose between a system of their own and OSJD system Vehicle keepers free to choose between a system of their own and AAR system Vehicle keepers free to choose between a system of their own and structured 12 digit system Vehicle keepers free to choose between a system of their own and structured 14 digit system Vehicle keepers free to choose between a system of their own and unstructured 8 digit system Vehicle keepers free to choose between a system of their own and unstructured 12 digit system Free choice of system for vehicle keepers

Without VIN

With VIN

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Notes:

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 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 obtained from respondents interviewed in the course of the study for the concept that TSI compliant vehicles should be instantly identifiable by their number, it is proposed that this is indicated within the first two digits. These three changes are referred to as the “modified UIC twelve digit system”. 6.6.4 If a structured system is selected a decision has to be made about what information should be/needs to be coded into the number. Possible information includes: compatibility with TSIs or other technical standards; vehicle characteristics; owner/fleet manager responsible; state of ownership/use; charging information; usage regime (“can I use it”); maintenance regime (“who should maintain it”); liability regime; serial number of vehicle; check digit.

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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 this information 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 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 of no 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. 6.7.2 The issue of VIN allocation is wider than operation on the European rail system, as some vehicles will fall outside the need to allocate running numbers as foreseen for this Study. For example vehicles used internally by industrial customers or used on railways not forming part of the European rail system. These vehicles may subsequently appear on the European rail system and also are assets which financiers need to track and thus need VINs. It is therefore considered that any mandatory requirements for VINs apply more widely than the purview of the Interoperability Directives, COTIF, etc. 6.7.3 It is considered that the possible options for the bodies responsible for allocating VINs are as follows: vehicle manufacturers/rebuilders; by a supranational authority; by vehicle approval body; by the state of vehicle manufacture/rebuild; by national infrastructure manager or safety authority; by an independent body jointly owned by the rail industry, with membership automatically available to all.

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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 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. 6.7.5 The form of a VIN also impinges on the technology used; a VIN might not be a conventional number at all but could be an electronic tag or a bar code for example. One of the key functions of a VIN is to attempt to prevent fraud; in particular wagons can wander over almost the entire European rail system (and beyond) without supervision from their keeper. Thus if a VIN consists of a number painted onto a vehicle it is entirely conceivable that these numbers could be adulterated and the vehicles misappropriated. VINs therefore need to be tamperproof, to the extent that it is both practicable and cost effective. Thus if one discounts painting VINs on a vehicle (other than as a secondary means of identification), the possible options include: stamp VIN into vehicle structure; permanently affix cast plate to vehicle bearing VIN; irremovable self-adhesive label bearing VIN, possibly incorporating other security devices such as holograms and/or barcodes; electronic tag, possibly also used to store other vehicle data. 6.7.6 The fundamental measure to provide value in the system is to provide a searchable database enabling vehicles to be identified and sought. This implies a need for a database which links VINs with running numbers, however the database is managed. It is considered that there are only two credible options for the management of the database:

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as a part of the overall database(s) of vehicle numbers and data; discretely as an International 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 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 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. 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 been lost and are, in any case, of differing formats. The following options for allocating VINs to existing vehicles appear to exist: use manufacturer’s works number; base VIN on current running number; allocate an entirely new sequence of numbers. It is recommended that preserved vehicles that are over forty years old be excluded from any requirements to apply VINs retrospectively.

6.8 Maintenance and Insurance 6.8.1 As noted in Section 2 the present system provides safeguards that vehicles are appropriately maintained at least insofar as vehicles in international operation are concerned. Changes to the system for placing vehicles in service, changes in the arrangements under which vehicles operate in traffic and liberalisation and open access all mean that the

4

For example, manufacturers state that a wagon chassis and body only comprises around 30% of its cost, which if sophisticated bogies are fitted can be less than the value of the bogies alone.

5

It should also be noted that it is also necessary for owners and maintainers to be able to identify components for traceability in the safety audit process. However this is considered to be a separate issue, with the exception that it is plainly appropriate to use the same component numbers for both purposes.

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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 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 vehicle maintenance systems to flourish and give owners, keepers, etc, appropriate freedom of choice. It is strongly recommended that prescriptive standards are not adopted, except where these are both absolutely essential and entirely non-controversial. 6.8.4 It is considered that the solution lies in requiring vehicle keepers to have their maintenance regime and practices audited either by a notified body or the independent national railway licensing/safety authority and to lodge an annual deposition from the relevant body to the effect that an audit has been carried out and that these are still satisfactory. In the event that this deposition is not lodged all vehicles under the responsibility of the keeper concerned would be prohibited from normal use on the European rail system. This has a further implication that it must be possible to instantly identify vehicles from a “rogue keeper” either via the vehicle identifier or through the vehicle database. There are a number of options for managing this, as follows: by a supranational agency (for example the ERA);
6

The Consortium is not altogether comfortable with this approach however, for example, vehicle leasing companies should be able to provide any vehicles freely for hire by any party or railway undertaking and without a railway undertaking to whose fleet it is attached being able to track its movements. Nevertheless it will become international law and the Consortium’s concerns are therefore of little consequence.

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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. 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 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 manage this process, as follows: a supranational agency (for example the ERA); national rail safety authorities; national infrastructure managers; whoever manages the vehicle database; self-regulation. 6.8.7 It should be noted that this proposed solution is similar to that required for road vehicles where, generally, each vehicle has to undergo a government technical inspection every year and to have its insurance documents submitted for inspection. However, in rail the result would be considerably simpler and less bureaucratic in operation, since rather than the tens of millions of individual vehicles and their details being inspected every year, as happens for road vehicles, it would only be necessary to inspect the bona fides of each vehicle keeper and railway undertaking to be verified, amounting to a few thousand checks in a liberalised environment.

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Analysis of Options

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 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). Technical and Practical Analysis 7.1.3 The use of a supranational authority to allocate numbers and place vehicles in service, whilst it may be the arrangement most likely to guarantee neutrality and independence it is also the one which is most likely to prove bureaucratic, inflexible and to have costs that are hardest to control. It also has the disadvantage of being physically remote from applicants in another state; however as the function is primarily administrative in the age of digital communications this is of little importance. Potential language difficulties need careful thought for cases in which a discussion is needed or when standard forms do not suffice1. Conversely a single authority should enable more rapid responses to changes in technology or working practices, since only a single body would need to change, rather than trying to co-ordinate simultaneous changes by upwards of thirty independent national bodies. 7.1.4 The points made above in respect of bureaucracy, inflexibility and difficulty of controlling costs apply to all of the options involving governmental bodies undertaking the tasks, albeit to a slightly lesser extent. The problems of independent national bodies jointly reacting to change have been discussed above.

1

At a quick count, approximately twenty-two different main languages are involved.

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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 6 there are a number of options: the state of manufacture, 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. 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 body might become a “closed shop”, excluding new entrants. However this is merely a risk; which could be excluded by providing an appropriate constitution and structure for the body. 7.1.7 From a practical viewpoint, although the option of allowing any licensed railway undertaking to accept vehicles into service and allocate numbers would represent a liberalisation of the present system it would still tie vehicle keepers to particular railway undertakings even if the vehicle is only to be used domestically2. The system would also only work if a railway undertaking code is to continue to be a part of the identifier, something that appears to be difficult to achieve in a liberalised environment with a proliferation of railway undertakings if a twelve digit number is to be retained (see below), otherwise duplication of numbers is practically inevitable. This option is also likely to be one that will find it hardest to respond to change; co-ordinating and implementing changes in the system where there are several thousand railway undertakings is a task bordering on the impossible. 7.1.8 Allocating the tasks to the infrastructure manager would appear to be more appropriate than allocating them to railway undertakings not least because, generally, there should only be one per state, avoiding the proliferation of agents. If all infrastructure managers become genuinely independent from national railway undertakings this option can be
2

Although if the vehicle concerned is to be used internationally the 1999 COTIF requires this anyway, despite the Consortium’s competition concerns.

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Analysis of Options

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 undertakings and to give equitable and non-discriminatory access rights to applicants. 7.2.2 Of the options discussed in Section 6, holding data in a single database is not in line with the requirements of the interoperability directives. These lay down national rolling stock registers and national registers on the placing in service (after RWP-II). 7.2.3 The other options are considered to be compatible with EC law. Technical and Practical Analysis The Starting Point 7.2.4 The railway industry benefits from having a significant number of existing databases. Whilst these are designed to different standards and hold differing amounts of information with differing arrangements for management, updating, etc, in general the data held is to a common standard. Field lengths and meanings are common (for example tare weights of vehicles are always in kilograms, lengths over buffers in decimetres, etc). This standard approach makes the job of constructing an international database easier and permits distributed solutions which otherwise would not be possible.

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Analysis of Options

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 and 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. It has been 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 them use vehicles efficiently and safely and include (for example) vehicle capacity and the presence of train heating circuits. It is also clear that the design of the database must consider the design approval process as this feeds the initial record into the database. Likewise it is considered that administrative supervision of maintenance and liability will need to be closely linked to vehicle records held on the database. Relationship to Unidroit 7.2.8 It appears that Unidroit register of interests will have to be a separate database, both because its legal and management status implies that and also because uniquely it is a register of interests rather than a register of rolling stock. That it is a separate database does not prevent links being created between it and any other master file (see further comments below under “Vehicle Identification Numbers”). National Databases 7.2.9 The future of national databases comes into the question of the design of the international configuration. In most EU states “national databases” are in fact controlled by national railway undertakings being linked into operating systems that they also control and integrated into their business fabric. These databases need to evolve to assist liberalisation by being opened to other operators. It would seem most likely that there will be a move towards national databases including all

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Analysis of Options

vehicles with the active encouragement of supervisory authorities in the states in question3. 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 of course prevent the smaller or more closely linked states in Europe from running common systems and databases in conjunction with each other or with other states. An analogy can be seen in North America where despite the central systems provided by Railinc (including 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 in the state in 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 7.2.12 A single central master database, whilst superficially seductive, would raise the issue of how data would be fed to it and how it would in turn supply data. The question would be what value the central database would add. It is difficult to avoid the conclusion that there would be duplication in having an international database holding the same data as national databases. This would raise questions of which was authoritative and in all probability it would be the national databases, which would be the primary sources of data and therefore authoritative. Links to and from a central database also need to be considered and the question of the value added by transfer of data to and from a central database would have to be answered. Linkages Between Databases 7.2.13 For a European system based on national databases to work effective linkages between them are essential, so that they appear to users as a single database. Responsibility for holding the record of a vehicle would need to lie with the state indicated as the state of registration in the third and fourth digits of the running identifier. The central element to the database would thus be conceptual rather than physical, enquiries could be made via any national database which would then pass them forward as necessary.
3

The obligation on Member States to prepare registers under Directive 2001/16/EC is significant in this respect.

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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 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. This could possibly be undertaken by the ERA. Migration Analysis General Comments 7.2.17 Migration issues are a significant determinant of the optimum database strategy. In making the necessary changes to existing systems, there are two imperative requirements: firstly rail systems must operate properly and continuously during the transition period, secondly the benefits sought must be delivered as cost effectively as possible. National Database Option 7.2.18 The initial assumption must be that the responsibility for the management of the national database, both freight, passenger and traction, will pass to some independent national organisation. This could consist of national authorities constructing a database from new or taking over an existing system. This does not prevent any organisation retaining its own database, but it could no longer be regarded as the authoritative database for official purposes. 7.2.19 The migration would therefore consist of the enhancement of those databases, firstly to include all types of vehicles (some existing databases exclude passenger or tractive equipment). Secondly databases need to be enhanced to include all the data required for official purposes

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Analysis of Options

(such as details of technical 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. In view of 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 adoption of a central database model would imply the construction of a new system. This need not of itself be complex but arrangements so that it always has the most up to date information would need to be put into place. Particular difficulties would reside in the question of keeping national and central data consistent. 7.2.23 Migration to a central system would involve the construction of national databases as described above to fulfil the obligations placed on the states of having their own databases. The same stages of populating the national databases would have to take place and then finally the subset required internationally and responsibility for it would be transferred to the central system. A management structure and responsibility would need defining and training of staff would be required. In modern terms the central system need not be that large, for purposes of comparison both the British national datafile and the US UMLER file currently have about seven hundred characters of information for each vehicle. 7.2.24 The alternative of a simple central system with just reference data and message switching software would paradoxically have the greatest programming complexity. The same stages of development would need to take place, as discussed above, save that the physical transfer of data to a central site would not be needed.

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Analysis of Options

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 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 and unstructured numbers. 7.3.4 Possibly the greatest drawback of a structured number is that because vehicle attributes are coded into the number, every time that these change the number changes. Accordingly a structured number cannot be a permanent identifier and thus a separate VIN will be required to give a permanent identifier. Meaning that every vehicle will carry two numbers and which need to be linked together in databases and registers. 7.3.5 In contrast an unstructured number can be permanent, meaning that a vehicle need only carry one number. However, the number itself conveys no information other than being a unique identifier. This is not a problem for a modern database and IT system which could instantly produce the details coded in the present number (and more), but it would produce problems for most national railway IT systems in Europe (outside Finland, Ireland and the UK) which make use of the structure of the conventional twelve digit number for hauled rolling stock, undoubtedly leading to resistance to change from many quarters, making the option of unstructured numbers unattractive. 7.3.6 Further problems with unstructured numbers arise where no access to a modern IT system is available to staff “on the ground”, as applies in many locations outside the eastern border of the EU, meaning that staff are unable ascertain anything about a vehicle from its number. However, this concern is only relevant to wagons operating in wagonload and part

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Analysis of Options

trainload operations and most information contained in the number is available by studying the markings on the side of wagons and the consignment 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 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. In contrast if structured numbers are retained multi-operator environments can be dealt with through national clearing house type arrangements “piggybacked” onto existing systems. A Change from Twelve Digits 7.3.8 As can be seen in Appendix H twelve digit numbers for hauled rolling stock are deeply embedded in the national IT systems of the states where twelve digit numbers are the common national system. This effectively means all EU states with the exception of Finland, Ireland and the United Kingdom and all CEEC states with rail systems with the exception of the Baltic States. 7.3.9 Changes in the number of digits would have a more profound effect than changes in the structure of a twelve digit system (which would still necessitate IT system modifications and changes in the intellectual investment in staff). Accordingly to change from a twelve digit system in there would have be benefits achieved by such a change that outweighed the costs of change and which cannot be achieved by a modification of the twelve digit system. Considering the EU and CEEC states alone, the Consortium cannot find any such benefits. This would imply that the running identifier should remain at twelve digits. 7.3.10 There is one other factor to consider; it is clearly desirable to harmonise the numbering systems of Western and Central Europe and the CIS. As noted the OSJD system is an eight digit system and there are more railway vehicles running in the CIS and “its satellites” than in the remainder of Europe. It could therefore be argued that it would be more appropriate to adopt a universal eight digit system throughout the entire European area. Set against this however is the fairly rudimentary nature of IT systems “on the ground” throughout the CIS area. The cost benefit analysis has indicated that the costs of adopting a twelve digit system in

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Analysis of Options

the CIS area would be less than that of an eight digit system in Europe, which also has a greater functionality. This is 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 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 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 co-exist; this is a migration issue, discussed below. This family of options, however, relates to the long term retention of existing systems alongside any new system. 7.3.13 The advantage of this option is that no vehicles need to be renumbered as only new vehicles adopt the new numbering system. There are a number of downsides, however, these include: the need to keep existing IT and manual systems running alongside new systems, with consequent complex interface issues, problems in constructing a workable database with vehicles numbered under different systems, the non-sustainability of the existing UIC system and the potential for confusion. 7.3.14 Accordingly continuing existing systems alongside a new one while superficially attractive and likely to go down well with existing owners it is not considered that is a feasible option. Giving Owners/Keepers Freedom of Choice 7.3.15 Giving owners/keepers complete freedom of choice has the virtue of complete liberalism; unfortunately it is also a recipe for confusion, duplication of numbers and an unworkable proliferation of incompatible systems. What might happen if owners/keepers have complete freedom of choice can be discerned from the example of Germany (see Appendix E), where the proliferation of railway undertakings and the retention of the international numbering system by the state railway has led to a

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Analysis of Options

proliferation of numbering systems. Although 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 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 7.3.19 The only information which is unquestionably required in a unique serial number to identify the vehicle, indeed in an unstructured number that is all that the number consists of. The other options for the information that is included within the number are matters for debate. 7.3.20 The consultation process for the study has indicated widespread support for the concept that vehicles’ interoperability characteristics/TSI compliance to be coded into the running identifier. If a structured number is adopted it is considered that this is possibly the most important attribute that should be coded into the identifier, probably as a part of the first two digits. 7.3.21 As noted in Section 2, the first two digits in the existing UIC numbering system for hauled vehicles are the exchange regime code and is currently a mixture of commercial, operating and technical criteria. Whilst it is not appropriate to distinguish privately owned vehicles, so that they can be treated and charged differently it is appropriate that there are different exchange and charging regimes, freely selectable by vehicle owners/keepers. Whether this needs to be coded into the number is an issue that is more open to question, the desirability of doing this is driven by the integration of current charging codes with this field. The same comment applies to technical information such as whether the vehicle is a bogie vehicle or not.

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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 and fourth 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. 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. 7.3.25 It is considered that there is little case to code in any information that is not currently provided, with the extent of TSI compliance. More advanced searchable databases are postulated by the study, which can be expected to gradually reduce the need to code information within the number structure4; the principal need to do this is mainly driven by the need to keep existing IT and manual systems running. 7.3.26 The recommended information that should be included within the number and its format can be found in Section 9. Migration Analysis General Comments 7.3.27 Two basic sets of solutions may be identified, those that essentially modify the present twelve digit structure only slightly and those that make a fundamental break with the past. In the first group come the proposals for allocating vehicle numbers by state of ownership or use coupled with the allocation of a VIN. In the second group come the solutions involving permanent unstructured numbers and solutions
4

One exception to this is the national coding, which if the recommended option of using individual national databases to store vehicle data, the national code will be required to find the appropriate national database to search.

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Analysis of Options

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. 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 can start. Fortunately the changes currently being made to the RIV system seem likely to align the regimes for railway owned and privately owned vehicles. Nevertheless, the 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 to be no longer coded in). The software changes will require a database to be consulted for basic characteristics of a vehicle every time that a decision on how to deploy it is to be made. Secondly because the ability of staff to recognise characteristics from number series will have gone, alternative means will have to be found. As explained in Appendix H, use of the literal is an inadequate replacement for numeric codes for some aspects of manual use. Some additional hardware provision (such as more computer screens in freight terminals) will also therefore be required to be installed before a radically different system which reduces the amount of information coded into the number can be introduced. 7.3.30 Given the preconditions noted above it will be possible to start allocating numbers to new vehicles on the new basis. 7.3.31 For options requiring vehicles to be numbered to a new structure (for example following the AAR or CIS system). The adoption of a fundamentally new system presumes the renumbering of existing vehicles and it will be possible to start that immediately. There will pressure to reduce the time that two numbering formats are in use to the minimum. Nevertheless it would seem impossible in practical terms to reduce this below the general overhaul cycle of up to some six years. During this period the characteristics of vehicles can be derived from the database.

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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 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 to the new 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 of allocation of new numbers. Some new hardware is also required. In addition to the changes in IT 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 the current number format will need to be redesigned and issued. Once these changes have been put into place, new numbers 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. Structured Twelve Digit Options 7.3.35 This family of solutions represents an evolution of current numbering systems. The nature of the twelve digit structures would continue but certain fields would be redefined. This existing structured numbering system is currently used for operating, commercial and technical purposes (as explained in Section 2). 7.3.36 Depending on the exact variant chosen, limited reprogramming of railway computer systems may be necessary before any renumbering can start. This reprogramming will affect such fields as regime of use and railway undertaking to which the vehicle is attached. In most cases this reprogramming is in any event required to permit liberalisation. Fortunately the changes currently being made to the RIV system seem likely to align the regimes for railway owned and privately owned vehicles. The software changes will also require characteristics which are at present implicit (such as state in which the vehicle is based) to be held explicitly in databases. Retention of the structure however allows the logic of the type code and everything following from it (such as charging and allocating for new loads by type) to be retained “as is” in computer systems and thus avoid significant work.

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7.3.37 Following these software changes, new vehicles may be numbered to the new standards. Some existing vehicles 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 of some vehicles (with the numbering considerably depending on the option, from 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 7.4.1 See comments above for the specific procedure for allocating numbers and placing vehicles in service. Technical and Practical Analysis VIN Allocation 7.4.2 Of the options discussed in Section 6, it is considered that the option of allocating VINs by manufacturers is significantly preferable to the other options, for the following reasons: the importance of allocating any VIN at the earliest stage of a vehicles’ life, something which the manufacturer is considerably better placed than any of the other parties to do; the overwhelming view expressed during the consultation process for the study that the manufacturer should perform this task; the acceptance, in principle, of the task by the manufacturers interviewed during the course of the study; successful previous experience with this approach in other transport modes (see Section 4).

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7.4.3 The allocation of numbers by manufacturers does not mean that involvement by 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 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. 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 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. 7.4.6 Since most vehicle manufacturers are now part of large multinational corporations it may also be beneficial for the plant of manufacture to be included in any VIN as well. Partly because it will make subsequent tracing easier and partly for reasons of administrative efficiency, since VINs could be issued more expeditiously autonomously by a plant than by referring the matter to and from a corporate headquarters, possibly based in a different state. However, the alternative to this would be for manufacturers to allocate vehicle numbers to particular plants in blocks. 7.4.7 Of the other possible information that could be coded in, as discussed in Section 6, it would be an unnecessary duplication to code in the state of manufacture if the plant of manufacture is coded in, as recommended. All of the other information listed could be held in the vehicle file in the registry/database, if required, and would appear to have little added value within the VIN itself. VIN Technology 7.4.8 There is no way to mark a vehicle such that a determined thief cannot deface the identifying mark, rather the purpose of the mark is to establish rights in case of doubt or after multiple changes in the running number. Permanent and undefaceable marking is a desirable but probably unachievable goal. Nevertheless it is considered that every

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Analysis of Options

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 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 with the concept 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 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 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 more secure. Welded or bonded plates can still be ground off or otherwise adulterated however, and issues with the potential to propagate stress fractures with welded-on plates exist. 7.4.11 Adhesive label technology has improved considerably over recent years and security can be provided relatively inexpensively by superadhesive brittle plastic labels that cannot be removed without destroying them. Further security can be provided by use of holographic images and controlled suppliers5 Based on quotes received the cost of such labels will be around 25-50 cents (€0.25-0.50). Further added value can be provided through features such as bar coding, if required. The major weakness of this solution is that for maximum security the labels would have to be affixed to bare metal and the danger of them being painted over, which would necessitate a large label size because of inevitable over-painting around the edges. None of these drawbacks is considered to be serious and overall this is considered to represent the best option of displaying numbers. 7.4.12 The other way that identifiers can be applied is to affix an electronic tag to vehicles. This has the advantages of being proven technology (being applied to virtually all North American wagons for

5

Preferably no more than three in number, appointed periodically by tender.

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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 VIN7. Likewise the operational identifier is a property of the VIN in the database. Paradoxically however the logic of the prime use of the database being in terms of operational identifier (for example, “is this vehicle acceptable on my infrastructure?”) means that the most logical prime key within the databases is likely to be operational identifier. A clear parallel with motor vehicle practice is apparent here. 7.4.15 The detailed structure of national databases will be a function of national preference and whilst there may be opportunities for exchange of views on best practice, there is no compelling reason why each should be identical. Indeed since individual states have longstanding requirements for individual national data items there is every reason to expect diversity. The only essential requirement is for seamless exchange of data between them to create a virtual pan-European database, subject only to legitimate confidentiality controls. 7.4.16 As noted above, despite the fact that the key to vehicle identity is the VIN in all probability most enquiries to the database will be made using the running number. 7.4.17 The suggested process for creation of a record is for the manufacturer which has issued a VIN for a vehicle (or VINs for a series
6

For example the ability to interface directly with IT systems, cutting out the manual interface, and the ability to hold additional data, for example technical data about the vehicle, maintenance data, etc. 7 This of course provides for exports and non-compliant vehicles to have VINs and is a necessary condition of the Unidroit register.

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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 chosen will, as appropriate, provide operating numbers and enter the vehicles on its database. In this way freedom of choice for technical 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 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. 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 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 vehicles that appear on it that are constructed and run outside Europe and vehicles that will appear on European registers/databases which will not appear on the International Register. As VINs will be unique and permanent there are no data compatibility issues, other than data entry errors and notification of the end of vehicle’s life, which it is considered is something that is most effectively handled by liaison between the respective database managers. Allocation to Existing Vehicles 7.4.21 The system of allotting numbers to existing vehicles is one that is principally governed by migration issues; it is inconceivable that two million vehicles can be renumbered overnight, on the other hand for the system to work it is important that vehicles’ VINs can be identified at an early stage and certainly not by waiting six years for the scheduled general repair process to have (theoretically) completed a cycle. Accordingly it is important the VINs allocated to existing vehicles can be identified before they are physically applied to them. This immediately rules out the option of allocating a completely fresh sequence of numbers. Similarly use of manufacturers’ serial numbers can be discounted, since in many cases these will not be obvious, or indeed always marked on the vehicle, a further issue is that of duplication of numbers. Accordingly it is considered that the only valid system is one based on the existing running identifier; see Section 9 for a recommended system.

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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 including those of liability, maintenance and insurance. 7.5.2 The supervision on the maintenance and insurance regime of vehicle keepers could be modelled in a variety of forms (see paragraph 6.8.2 et seq). From a legal point of view none of these is preferable to any other.

Maintenance 7.5.3 Within the maintenance area there are a number of facets to consider. Firstly any numbering and database system has to support the process of maintenance and secondly there must be provision for the audit processes which are chosen. 7.5.4 The process of maintenance is becoming ever more sophisticated. Maintenance schedules are increasingly part of the process of technical approval (as implied by Article 10 paragraph 2(a) of COTIF ATMF). Increasingly they are linked to the performance of the vehicle and thus rely on records of the work the vehicle does. To the extent the work is international so must the data. Likewise the maintenance schedule itself is built up from experience of wear and failure in service, this data too comes from railway data systems. Vehicle operators therefore need access on a non-discriminatory basis to this data. There may be problems

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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 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 clearly only refers to that vehicle and the format of the number and the nature of the database is irrelevant. By contrast, establishing the 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 be undertaken anywhere. Provision of maintenance records by the vehicle keeper to the contractor poses no problems but where maintenance has been done outside the home state, some means of updating the record of maintenance in a controlled way will be necessary. This might be simple: supplying certificated paper records to the national database controller, or direct electronic updates under controlled conditions. 7.5.8 The monitoring of maintenance is itself likewise increasingly a monitoring of systems to verify that those who hold responsibility for maintenance have systems in place to initiate maintenance, to check standards and organise follow up action. The audit arrangements therefore do not check vehicles themselves but rather the process. This is a much more effective means of verifying compliance. The audit process depends therefore on the systems described in the previous paragraph being in place and audits their completeness, accuracy and the promptness of the information 7.5.9 The logic of a system where vehicles are accepted into traffic and have numbers allocated by national authorised bodies of the state of ownership of the vehicle/of the state chosen by the owner/keeper implies that it is the authorities of this state that have the mandate to monitor that maintenance is undertaken in accordance with the standards laid down and approved in the technical approval. It should be noted that the state

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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 are otherwise self-insuring. To be 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 that for a number 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 need to monitor the insurance status of rolling stock. It is quite conceivable that rolling stock could be insured for limited or all international movements or indeed just domestic movement. The vehicle record in these cases will need to reflect that. Again it is logical that the national authorities of the state of registration will have the responsibility to monitor compliance. 7.5.13 Creating the record of insurance does require enhancement of national databases. Whilst logically insurance records will be held at the level of vehicle, input is equally logically likely to be needed at the level of operator. Provision for updating and flagging an absence of update is also required.

7.6 Cost Benefit Analysis Outline 7.6.1 Cost Benefit analysis (CBA) is a method of assessing investment projects taking into account social, rather than just financial, costs and benefits. In doing so it aims to identify and measure gains and losses of economic welfare. This sub section, therefore, aims to set out: • the key costs and benefits of a new system of placing vehicles in service and identifying them;

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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 majority are either impracticable or fail to comply with the relevant Directives and Regulations and many are similar in concept. It would also be unfeasible to undertake a sensible analysis for each one. Therefore the cost benefit analysis has been undertaken for a short list of four options, namely: • Base Case; • random 12 digit number; • two number option; • 14 digit plus unique number; 7.6.4 The base case is the modified UIC 12 digit option whereby the third and fourth digits that presently indicate which railway undertaking the vehicle is attached to is replaced by two digits that identify the country that the vehicle is attached to. 7.6.5 The first variant involves allocating unstructured permanent twelve digit running numbers to all vehicles, which would be used in operating systems. As new vehicles enter the fleet the number they are allocated will be unstructured and therefore it will not be possible to discern any information about the vehicle form the number without accessing a database. Access to a database could be once on the arrival of a vehicle on each railway (with storage of data) or every time a vehicle was handled. Use, ownership, etc, of the vehicle could then change without any change to its number.

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Analysis of Options

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 number. The running 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 and new with the former still being used till change over day and the latter thereafter. 7.6.10 For the gradual approach it is assumed that numbers are changed over a six year period as vehicles (are scheduled to) complete standard maintenance cycles. 7.6.11 For the new vehicle option it is assumed that only new vehicles are numbered under any new regime with the remainder of the fleet being renumbered between years 7-12. This would ensure that between a quarter and a third of the railway fleet would not need to be renumbered. 7.6.12 From the above the relativities of the cost and benefits of all the other options can be derived. Identifying Costs 7.6.13 The main costs of railway vehicle renumbering have been identified as follows: • physically renumbering the vehicle: covers the cost of putting a new number on the vehicle, entering that number into the railway’s databases, the cost of affixing a VIN and overall management of the process;

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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 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. Identifying Benefits 7.6.14 The key benefits of a new system should be: • competition: ability to obtain an international number and hence to operate internationally will increase competition; • synergy with other regulatory changes: difficult to quantify but another step in radically changing Europe’s railways by allowing open access and competition and changing historic railway operating practices; • opportunity benefits: amending software or introducing new hardware may provide opportunities to improve operational and business efficiency; • enhancement of European integration: common European-wide numbering system embracing countries of central and eastern Europe; • VIN: may increase number of institutions prepared to provide financing for railway equipment. 7.6.15 It should be noted that not all of these are dependent on the format of the number, but will in fact be due to changes in the system for placing vehicles and allocating them with numbers (for example competition benefits, opportunity benefits), which therefore generate constant benefit for all numbering system options.

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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. For example, if any new numbering 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 incurred. However, if it was proposed to transfer 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 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 three timing periods considered and two scenarios with regard to benefits. The minimum benefit scenario takes a cautious approach and assumes a minimal increase in competition arising as a result from the new numbering and registration scheme. The maximum benefit scenario takes a more robust approach and assumes that the new system is one of the last steps to liberalisation and could therefore deliver the types of growth in freight traffic that has been achieved in Sweden and Great Britain. In both scenarios the costs are the same but the benefits differ by a factor of ten. The analysis shows the net present value in 2003 prices of the cost and benefits over a twenty year time horizon using a discount rate of 10%

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Analysis of Options

Table 7.1- Evaluation of Number Format Minimum Benefits (€ net present value) Base Option
Gradual Big Bang 18,000,000 150,000,000 132,000,000 New Vehicles 13,000,000 150,000,000 137,000,000

Random 12 Digit
Gradual 124,000,000 150,000,000 26,000,000 Big Bang 144,000,000 150,000,000 6,000,000 New Vehicles 93,000,000 150,000,000 57,000,000

Total Cost Total Benefit Net Benefit

15,000,000 150,000,000 135,000,000

Two Numbers
Gradual Big Bang 123,000,000 212,600,000 89,600,000 New Vehicles 56,000,000 187,500,000 131,500,000 Gradual 156,000,000 187,500,000 31,500,000

14 Digit
Big Bang 234,000,000 212,600,000 -21,400,000 New Vehicles 75,000,000 187,500,000 112,500,000

Total Cost Total Benefit Net Benefit

62,000,000 187,500,000 125,500,000

Table 7.2- Evaluation of Number Format Maximum Benefits (€ net present value) Base Option
Gradual Big Bang 18,000,000 New Vehicles 13,000,000

Random 12 Digit
Gradual 124,000,000 Big Bang 144,000,000 New Vehicles 93,000,000

Total Cost

15,000,000

Total Benefit 1,500,000,000 1,500,000,000 1,500,000,000 1,500,000,000 1,500,000,000 1,500,000,000 Net Benefit
1,485,000,000 1,683,000,000 1,487,000,000 1,376,000,000 1,557,000,000 1,407,000,000

Two Numbers
Gradual Big Bang 123,000,000 New Vehicles 56,000,000 Gradual 156,000,000

14 Digit
Big Bang 234,000,000 New Vehicles 75,000,000

Total Cost

62,000,000

Total Benefit 1,875,000,000 2,126,000,000 1,875,000,000 1,875,000,000 2,126,000,000 1,875,000,000 Net Benefit
1,813,000,000 2,003,000,000 1,819,000,000 1,719,000,000 1,892,000,000 1,800,000,000

7.6.19 Under the Minimum benefit scenario the option with the highest net present value is the base option for new vehicles. This is due to costs being minimised. With the Maximum benefit scenario the permanent VIN and 12 digit modified UIC numbering system performs best. Whilst

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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) on road hauliers. The benefits would accrue mainly to non-UIC 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 a central reference data base with links to national databases A virtual central base created by links from national databases

The present value costs of each database option ignoring all common operating costs, is broadly estimated as follows: • • • Central full populated database €3.6m central reference database €3.4m virtual database €2.4m

7.7 Evaluation of Identification System Options 7.7.1 Table 7.2 is an evaluation matrix for the options defined in Section 6 for the system of placing vehicles in service, allocating them with numbers and associated issues involving the use numbers in service. This uses the Key Objectives defined in Section 6.1.

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Analysis of Options

Table 7.2 - Evaluation Matrix – Attributes of Identification System Essential Requirements
Accommodates Technical Innovation Flexibility for Future No Constraints for New Rly Undertaks Compatibility with COTIF Cost Effectiveness Covers all Vehicle Types Does not Obstruct Single Market Reconcilable with EU Law

Desirable Requirements
No Constraints for New Contract. St.ruc Maximal accept.abty for all geogr areas Accommodates New Practices Interfaces with Reg. Cont. & Govt Auths

Option Property

Interfaces with Service Providers

Interfaces with Customers

Practicability

Total

Weight Existing System Single Central Central: Driving Other Pan-National Database /Register Linked Individual National: Driving Pan-Nat Database Independent Nat: Driving Virtual Pan National Database Independent No Interfaces Nat:

n/a x x

n/a x x

n/a x

n/a

n/a

n/a x

n/a P

20% 5

10% 7

10% 7

10% 9

20% 8

10% 8

10% 9

10% 9

100% 0% 0% 55%

P P P

P

P

6

7

7

9

8

8

9

9

57%

7

7

8

9

9

9

9

9

83%

x

x

x

-

-

-

-

-

-

-

-

0%

7-29

Running Number Allocation By Option Any State State of Use Supranational Authority Owner’s State State of Manuf Infrast. Manager Property Weight n/a x n/a P x P n/a n/a n/a n/a x
Reconcilable with EU Law Compatibility with COTIF Does not Obstruct Single Market Practicability Cost Effectiveness No Constraints for New Rly Undertaks

Colin Buchanan and Partners

State of Approval

Licensed Rail Und.

Independent Rail Industry Body

Essential Requirements

Analysis of Options

7-30 7 0% 0% 7 6 7 6 7 5 7 55% 61%

n/a

Covers all Vehicle Types

20%

7 5 5 8 6 5 7 5

7 5 5 8 6 6 7 5 62%

7 5 5 8 6 6 7 5 62%

7 5 5 8 6 5 7 5 61%

7 5 5 8 6 5 7 5 61%

8 6 6 8 4 4 8 5 61%

Flexibility for Future

10% 10% 10% 20% 10% 10% 10% 100%

Accommodates Technical Innovation Accommodates New Practices No Constraints for New Contract. St.ruc Maximal accept.abty for all geogr areas Interfaces with Customers Interfaces with Reg. Cont. & Govt Auths Interfaces with Service Providers

Desirable Requirements

Total

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Analysis of Options

Essential Requirements
Accommodates Technical Innovation Flexibility for Future No Constraints for New Rly Undertaks Compatibility with COTIF Cost Effectiveness Covers all Vehicle Types Does not Obstruct Single Market Reconcilable with EU Law

Desirable Requirements
No Constraints for New Contract. St.ruc Maximal accept.abty for all geogr areas Accommodates New Practices Interfaces with Reg. Cont. & Govt Auths

Option Property

Interfaces with Service Providers

Interfaces with Customers

Practicability

Total

Weight Vehicle Identification Number Allocation No VIN By Manufacturer By Approval Body By Supranat Auth By State By Rail Industry

n/a

n/a

n/a

n/a P

n/a

n/a

n/a

20% 5 8 8 7 6

10% 10 10 7 6 7 7

10% 10 8 7 6 7 7

10% 10 10 10 10 10 10

20% 3 6 7 6 7 5

10% 10 10 10 10 10 10

10% 1 6 7 6 7 5

10% 1 4 4 4 5 6

100% 48% 76% 75% 68% 72% 69%

P

7

Key P x = = = Fully meets essential requirement. Does not fully meets essential requirement, but achieves minimum permissible standard, 10% deducted from Total Score. Does not meet essential requirement, option rejected.

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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.

7.8 Evaluation of Numbering System Options Table 7.3 is an evaluation matrix for the numbering system options defined in Section 6 and using the Key Objectives defined in Section 6.1.

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Table 7.3 - Evaluation Matrix – Attributes of Identifier Systems Using Running Numbers Only (No Vehicle Identification Numbers) Essential Requirements
NonDiscriminatory Rights Unique Identifier of Vehicle Struct. Cost Effective Acceptability Unique Identifier for Liability Unique Identifier for Charge

Desirable Requirements
Clear & Logical Structure Indicates Contact Details Indicates Type of Vehicle & TSI Compliant Self Checking Compatible with Previous Systems Compatible with non-EU Systems

Property

Maximum

Option

Facilitates Universal Operations

Total

Weight Existing Systems Universal UIC 12 digit Universal Mod UIC 12 digit Universal OSJD 8 digit Universal AAR 10 character Universal 8 Digit Structured Universal 10 Digit Structured Universal 12 Digit Structured Universal 14 Digit Structured

n/a x x x x x x x x x

n/a x x

n/a

n/a

n/a

15% -

25% -

15% -

15% -

10% -

10% -

5% -

5% -

100% 0% 0% 0% 0% 0% 0% 0% 0% 0%

P P

-

P

P

P P

P x x x P x

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Analysis of Options

Essential Requirements
NonDiscriminatory Rights Unique Identifier of Vehicle Struct. Cost Effective Acceptability Unique Identifier for Liability Unique Identifier for Charge

Desirable Requirements
Clear & Logical Structure Indicates Contact Details Indicates Type of Vehicle & TSI Compliant Self Checking Compatible with Previous Systems Compatible with non-EU Systems

Property

Maximum

Option

Facilitates Universal Operations

Total

Weight Univ. Unstructured 8 Digit Univ. Unstructured 12 Digit New System for New Vehicles Only – Modified UIC system New System for New Vehicles Only – OSJD system New System for New Vehicles Only – AAR system New System for New Vehicles Only – Structured 12 digit New System for New Vehicles Only – Structured 14 digit New System for New Vehicles Only – Unstructured 8 digit

n/a

n/a

n/a

n/a

n/a x P

15% 5 -

25% 4 -

15% 0 -

15% 5 -

10% 1 -

10% 0 -

5% 0 -

5% 10 -

100% 0% 21% 0% 0% 0% 0% 0% 0%

x x x x x

P P P P P P

P P P P P P x P P x

-

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Analysis of Options

Essential Requirements
NonDiscriminatory Rights Unique Identifier of Vehicle Struct. Cost Effective Acceptability Unique Identifier for Liability Unique Identifier for Charge

Desirable Requirements
Clear & Logical Structure Indicates Contact Details Indicates Type of Vehicle & TSI Compliant Self Checking Compatible with Previous Systems Compatible with non-EU Systems

Property

Maximum

Option

Facilitates Universal Operations

Total

Weight New System for New Vehicles Only – Unstructured 12 Digit Own System/Modified UIC Own System/OSJD Own System/AAR Own System/Struct. 12 digit Own System/Struct. 14 digit Own System/Unstruct. 8 digit Free Choice of System Key P x = = =

n/a

n/a

n/a

n/a

n/a P

15% 7 -

25% 3 -

15% 0 -

15% 8 -

10% 1 -

10% 0 -

5% 0 -

5% 0 -

100% 21% 0% 0% 0% 0% 0% 0% 0%

x x x x x x x

P P P P P P x

P P P P P P x

P P x P x x

Fully meets essential requirement. Does not fully meets essential requirement, but achieves minimum permissible standard, 10% deducted from Total Score. Does not meet essential requirement, option rejected. 7-35

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Analysis of Options

Systems Using Separate Running and Vehicle Identification Numbers Essential Requirements
NonDiscriminatory Rights Unique Identifier of Vehicle Struct. Cost Effective Acceptability Unique Identifier for Liability Unique Identifier for Charge

Desirable Requirements
Clear & Logical Structure Indicates Contact Details Indicates Type of Vehicle & TSI Compliant Self Checking Compatible with Previous Systems Compatible with non-EU Systems

Property

Maximum

Option

Facilitates Universal Operations

Total

Weight Existing Systems Universal UIC 12 digit Universal Mod. UIC 12 digit Universal OSJD 8 digit Universal AAR 10 character Universal 8 Digit Structured Universal 10 Digit Structured Universal 12 Digit Structured Universal 14 Digit Structured

n/a

n/a x x

n/a

n/a

n/a P P P

15% 8 2 7 -

25% 9 9 9 -

15% 8 2 10 -

15% 9 3 7 -

10% 10 10 8 -

10% 10 0 10 -

5% 5 0 10 -

5% 10 0 10 -

100% 0% 0% 78% 3% 0% 0% 0% 77% 0%

P

P

P

P x x x P x

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Analysis of Options

Essential Requirements
NonDiscriminatory Rights Unique Identifier of Vehicle Struct. Cost Effective Acceptability Unique Identifier for Liability Unique Identifier for Charge

Desirable Requirements
Clear & Logical Structure Indicates Contact Details Indicates Type of Vehicle & TSI Compliant Self Checking Compatible with Previous Systems Compatible with non-EU Systems

Property

Maximum

Option

Facilitates Universal Operations

Total

Weight New System for New Vehicles Only – Modified UIC system New System for New Vehicles Only – OSJD system New System for New Vehicles Only – AAR system New System for New Vehicles Only – Structured 12 digit New System for New Vehicles Only – Structured 14 digit Own System/Modified UIC Own System/OSJD Own System/AAR

n/a

n/a

n/a

n/a

n/a P x x P x

15% 10 7 10

25% 5 5 5 5 4

15% 8 8 3 1 2

15% 10 7 10 4 2

10% 6 6 6 8 1

10% 4 4 2 0 0

5% 6 7 5 0 5

5% 5 5 0 0 0

100% 60% 0% 0% 52% 0% 38% 3% 0%

P P P

P P P P P

3 1

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Analysis of Options

Essential Requirements
NonDiscriminatory Rights Unique Identifier of Vehicle Struct. Cost Effective Acceptability Unique Identifier for Liability Unique Identifier for Charge

Desirable Requirements
Clear & Logical Structure Indicates Contact Details Indicates Type of Vehicle & TSI Compliant Self Checking Compatible with Previous Systems Compatible with non-EU Systems

Property

Maximum

Option

Facilitates Universal Operations

Total

Weight Own System/Struct. 12 digit Own System/Struct. 14 digit Mod UIC System, VIN Tagged Electronically OSJD System, VIN Tagged Electronically AAR System, VIN Tagged Electronically St. 12 Digit Syst, VIN Tagged Electronically St. 14 Digit Syst, VIN Tagged Electronically Free Choice of System

n/a

n/a

n/a P P

n/a P P

n/a P P P

15% 9 7 7 2 6 -

25% 5 5 9 9 9 -

15% 4 4 8 2 10 -

15% 8 7 9 3 7 -

10% 6 3 10 10 8 -

10% 2 2 10 0 10 -

5% 5 5 8 3 10 -

5% 0 0 10 5 10 -

100% 25% 17% 78% 7% 0% 75% 0% 0%

P

P

P

P x P x

x

x

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Analysis of Options

Key P x = = = Fully meets essential requirement. Does not fully meets essential requirement, but achieves minimum permissible standard, 10% deducted from Total Score. Does not meet essential requirement, option rejected.

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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%); • unstructured 12 digit system (21%); • new system for new vehicles only - unstructured 12 digit system (21%); • vehicle keepers free to choose between a system of their own and 14 digit structured system and VIN (17%); • OSJD 8 digit system (3%); • vehicle keepers free to choose between a system of their own and OSJD 8 digit system (3%). 7.8.2 It is therefore absolutely clear that a twelve digit running identifier plus a VIN is the only logical choice of numbering system. It is also appears that a structured number is strongly to be preferred.

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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 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 with any railway undertakings. 8.1.4 Similarly it is considered essential that the database/register containing vehicle details is managed by an independent body. The requirements of the Interoperability Directives, COTIF and railway operational requirements are not consistent. It is considered possible, however, to meet all of these requirements via differing reporting options within the database structure. 8.1.5 Inequality of access rights to railway operating IT systems which use vehicle numbers and other vehicle data has emerged as a major concern in this study. In some cases these national systems have been expropriated by national railway undertakings, claiming that they are their property and quoting “confidentiality” concerns to prevent other railway undertakings gaining access to these vital systems. This is also considered to be incompatible with EC competition law. It is considered that any such systems should be vested in the infrastructure manager or another neutral body and should operate in a neutral manner, with equal access rights to all (see Section 9). 8.1.6 It is considered that if separate Vehicle Identification Numbers are allocated in addition to running identifiers that these are allocated by vehicle manufacturers. These can be used to meet UNIDROIT requirements.

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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 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. 8.2.4 There are inconsistencies in the way that vehicles are defined between states, which need to be resolved. It is further considered that the matter needs to be thought through from first principals to provide appropriate permanent identification of divisible assets; this need not necessarily alter definitions currently used for vehicle running numbers, if these are taken as an attribute of the permanent identifier. Similarly it is considered desirable to include the serial numbers of major vehicle components in the vehicle master record.

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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 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 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; by a joint industry body. 9.1.3 On balance, it is considered that the option of using independent national government agencies is to be preferred, although both the alternate options are workable. It is considered however to vital that it is clearly defined which state should be responsible in a particular case. A number of options have been put forward in Section 6 for which state should be responsible, of these it is considered that giving the owner/vehicle manufacturer freedom to select a state of his choice is perhaps the best option 9.1.4 Any “contracts for use” required to place vehicles in service should be the same for all vehicle owners and keepers within the geographic area and be open to any owner/keeper on the same terms. These “contracts for use” must not convey extra powers or rights to any individual or groups of vehicle owners/keepers or railway undertakings, either explicitly or implicitly. This need not exclude the availability of alternative “contracts for use” offering a choice of terms, provided that all are open to any owner/keeper and meet these tests. Vehicle Database Management 9.1.5 It is recommended that vehicle databases are managed on a national basis by independent bodies (see below). It is further

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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 Interoperability Directives and COTIF. 9.1.6 It is recommended that 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 fail to open systems up. 9.1.8 The provision of adequate confidentiality filters between users in systems not originally designed for a multi-user environment is important but is considered to be less important than the imperative of permitting the Single Market to operate by providing equal and non-discriminatory access to systems for all those who legitimately need it. 9.1.9 It is recommended a pan-EU definition is made of the information and systems which national railways can consider to be confidential, to stop situations where a wide variety of information is claimed to be confidential as means of frustrating potential rival railway undertakings and thus EU Policy. It is recommended that only the following information and systems can be held to be confidential: internal costs (other than infrastructure costs and charges); internal costing and charging systems; customer lists; joint systems with customers; freight charges; freight charging and billing systems; charter passenger train charges and charging systems;

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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 this work. It is recommended that 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 been obtained on expiry of the previous policy. Again the state of registration will need to be responsible for withdrawing approval for the vehicles concerned should the relevant certification not be produced.

9.2 Technical Recommendations Numbering System 9.2.1 It is recommended that a structured twelve digit number be used, supplemented by a Vehicle Identification Number (VIN) be adopted as the standard European system for all vehicles and that this system be freely available to all who wish to have one. 9.2.2 It is considered that the only credible options for the number format are as follows: universal modified UIC 12 digit system and VIN; universal modified UIC 12 digit system and VIN tagged electronically;
1

International agreement will be required what value “adequate insurance” represents.

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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 would generate the registers and databases required by legislation as reporting options. 9.2.6 The exchangeable datasets in any new pan-European railway information exchange systems need to be compatible with those specified in the vehicle database. Definition of a Vehicle 9.2.7 As noted in Sections 2 and 6 there are two ways in which the meaning of “vehicle” needs to be clearly defined: what is defined as a single rail vehicle and the retention of identity after major rebuilding. 9.2.8 In respect of the first issue it is recommended that a running identifier is allocated to the each element of a vehicle that can be divided and wheeled away on its own set of wheels (which might, for example, include each bogie set for a road:railer train), and for each body or chassis element that is customarily removed from a train or unit formation. It is recommended that permanent identifiers (VINs) are applied more widely: to every chassis/body unit, so that in addition to the above in an articulated unit every section would have a unique VIN2. This should provide clarity of ownership for every removable main
2

If an unstructured number is adopted, not requiring a VIN, the allocation of running numbers would have to follow the recommendations for VINs, thus necessitating more renumbering.

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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 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 issued). 9.2.11 Vehicle Identification Numbers 9.2.12 It is recommended that the following information be coded or indicated within the VIN: manufacturer; manufacturing plant (or other coding of the manufacturer’s choice); serial number. 9.2.13 It is recommended that VINs be allocated by manufacturers, this means that manufacturers need to be certified as fit to issue VINs and be allocated with a code. In view of the pan-national nature of manufacturers this needs to be done at an international level, worldwide international agreement will be required on who does this. It is considered that the best option is to have one regional body responsible for this (for example, for Europe, the Americas, South East Asia, Australasia, etc) and manufacturers active in more than one global region (for example, Bombardier, Siemens, etc) are separately certified and coded for each region. 9.2.14 No VIN number should be used more than once; once a vehicle has been certified as no longer existing the VIN should be withdrawn.

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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

Serial Number

0000

0000

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 that as a new system unconstrained by past practice the future flexibility offered by the nineteen digit number suggested is to be preferred. 9.2.16 UNIDROIT is supposed to be a world-wide system accordingly the actual system will need international agreement, as it is recommended that a single international system is adopted. 9.2.17 If a system of VINs is adopted approximately two million existing European vehicles will require VINs (plus several million in other parts of the world). It is recommended that the existing vehicle running numbers are used, less the check digit, made up to the required length by zeros added to the left of the number. In the case of vehicles bearing twelve digit numbers, it is recommended that the first eleven digits of this number are used as the serial number before being made up with zeros in place of the plant code. In place of the manufacturer code it is recommended that to avoid duplication around the world that a simple code is used to identify the region, so that the various European numbering systems could be prefixed 0100 to 0199, North America to have the range 0200 to 0299 allocated, etc. Manufacturers’ codes would start at 1000 and thus any pre-existing vehicle would be immediately identifiable by its leading zero. 9.2.18 It is recommended that, as a minimum, the unique identification numbers of the following major components are held on official databases (which does not preclude additional information being held on a national basis, if desired):

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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 bogie frames; wheelsets; any removable component assembly costing more than 5% of the first cost of the vehicle. Hauled Freight Stock bogie frames; wheelsets; any major removable component assembly costing more than 5% of the first cost of the vehicle. Scope of Any Renumbering 9.2.19 With the exception of the above states it is recommended that any new numbering system is applied to all vehicles used on the common European rail system. The results of the cost benefit analysis depend on the contribution that liberalisation of the vehicle numbering and entry to service process would be likely to make to the to total benefits anticipated from liberalisation of the rail sector. If a conservative assumption is made that the overall contribution of liberalising these activities is modest, the cost benefit analysis indicates that the option

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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.

9.3 Tabulation of Recommendations 9.3.1 The recommendations are tabulated in Table 9.1, together with the suggested prioritisation of each and the estimated timescale for implementation. Short implementation timescale is defined as that which it is considered can be implemented in less than five years, medium term measures are those which it is judged can be implemented in a five to ten year timeframe and long term measures are those which are likely to take at least ten years to implement.

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Table 9.1 – Summary of Specific Recommendations

Measure Highest Priority Measures Independence of Notified Bodies to be ensured 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. Any contracts for use should be the same for all vehicle owners/keepers and be totally nondiscriminatory. Vehicle databases to be managed on a national basis by independent bodies. Effective interfaces between national vehicle databases to be mandated and enforced by a supranational agency (e.g. ERA). Virtual international vehicle database to be established and managed by an independent supranational body. 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.

Nature of Measure

Timescale for Implementation

Organisational Organisational

Short Short

Organisational Organisational Organisational/ Technical Organisational/ Technical

Short Short/Medium Short Short

Organisational

Short

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Measure 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. Structured twelve digit running number to be adopted, based on a modified version of the current UIC system. 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. 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,. High Priority Measures International Registry required by the UNIDROIT convention to be free standing & separate database. Confidentiality filters to be provided in national IT systems not originally designed for multiuser environments. 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. Exchangeable datasets of any new pan-European IT systems to be compatible with those specified for the vehicle database.

Nature of Measure

Timescale for Implementation

Organisational Technical Technical Technical

Short Medium Short Short

Organisational/ Technical Organisational/ Technical Organisational

Short Short/Medium

Short

Technical

Medium

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