Technical specification for interoperability relating to the telematics subsystem of the rail system

This comment is entered by Søren Sørensen, a smart mobility consultant and MaaS ambassador. I am project lead on a multinational planning, booking and payment system based strictly on open mobility data as regulated through the MMTIS regulation sourced through 4 national Access Points.

Hamburg Port Authority as Infrastructure Manager for the public rail infrastructure within the Port of Hamburg has been actively supporting electronic data exchange in rail freight transport for many decades. Thus we have been supporting TAF TSI and continue to do so. It is good that the current EN07 moves some not fully clarified subjects to open points instead of pushing "half-finished" solutions into legislation.

The European Commission's latest Telematics Technical Specification for Interoperability (TSI) Regulation 2025 aims to enhance data exchange and digital integration in the European rail sector. Not taking into account the legal framework of the draft and proposed regulation our impression is that its implementation plan appears overly ambitious, and its data-sharing framework, particularly in freight transport…

The European Union Agency for Railways (ERA) published recommendations for the TAF/TAP TSI in January 2022 after four years of work, based on the TSI revision mandate (Decision 2017/1474). An initial interim revision was incorporated into the TAP TSI in 2021.

The MaaS Alliance is happy with this initiative. We do have a concern about a realisation and Open Mobility Ecosystem and the Mobility Silo`s that are kept in tack. Within the: - MPMF: Multimodal Pasenger Mobility Forum and - MDMS: Multimodel Digital Mobility Services, we aligned and addressed the minimal functions to have FRAND in place, to create an Open Market without lock-in and issued the recommendations to…

DB shares the European Commission's view that booking train tickets in Europe for passengers should become easier. Thanks to the improvements that DB and many other railways are implementing for passengers in Europe within the CER Ticketing Roadmap, booking international train tickets will become much easier already in 2025.

ALLRAIL, the Alliance of Passenger Rail New Entrants, is a non-profit association representing independent passenger rail companies (e.g. rail operators, ticket vendors, and rolling stock lessors) in Europe. ALLRAIL advocates for faster market opening in passenger rail in order to accelerate modal shift to rail and achieve the ambitious climate change reduction goals of the EU Green Deal in the transport sector.

Annex 3.1.1 Electronic Consignment note bearing electronic signatures In accordance with the Telematic TSI Annex Appendix F, no special requirements other than ‘technical compatibility’ are imposed on consignment note data. It is therefore unclear why the content of the ConsignmentOrderMessage (COM) alone needs to be signed electronically, whereas other messages and objects do not. This appears inconsistent.

Filed in German · English published by the European Commission

Deutsche Bahn shares the European Commission's view that booking train tickets in Europe for passengers should become easier. Thanks to the improvements that DB and many other railways are implementing for passengers in Europe within the CER Ticketing Roadmap, booking international train tickets will become much easier already in 2025.

UIRR is the voice of the intermodal freight in Europe and represents the interests of the intermodal freight operators and the terminal managers in Europe. UIRR welcomes the initiative of the Commissions draft Implementing Regulation on TSI Telematics, which aims at intensifying and improving the digital data sharing among the telematics stakeholders based on standardised data messages and alternative access options…

FS Italiane would like to highlight the following key aspects, crucial for the Regulation's effectiveness: - Implementation Deadlines and Realistic Timeframes: Deadlines set out in the regulation appear unrealistic, particularly given the delays in the revision process and the introduction of new requirements.

CER signed joint positions with EIM, UIP, ERFA and UIC, CIT on the revision of Telematics TSI / OSDM. The positions are attached. On the revision: ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool.

The European Union Agency for Railways (ERA) published recommendations for the TAF/TAP TSI in January 2022 after four years of work, based on the TSI revision mandate (Decision 2017/1474). An initial interim revision was incorporated into the TAP TSI in 2021.

Adif welcomes and considers positive the initiative to increase the share of rail transport that digitalization can bring. In addition, it should be mentioned that we are working, as other stakeholders, for a long time on the implementation of the current TAP/TAF TSI regulations. We would like to take the opportunity of the Public Consultation to present our comments.

We, the European Rail Infrastructure Managers (EIM), fully support initiatives aimed at enhancing the efficiency of standardized data exchange between relevant stakeholders to boost the competitiveness and reliability of rail transport.

We, the European Rail Infrastructure Managers (EIM), do support activities that are aiming at improving efficiency in the exchange of standardized data between relevant actors to increase the competitiveness and reliability of rail transport. However, we have significant concerns as regards several proposed measures in the current legal draft text.

We support the initiative’s aim to improve communication in rail logistics through digitalisation and standardisation. However, this must not have the effect of influencing competition or endangering the security of critical infrastructure by publishing sensitive data.

Filed in German · English published by the European Commission

essenscia, the sector federation for chemical and life sciences, represents one of the most significant export sectors and a key rail freight customer. We fully support the principal idea of this initiative to enhance data sharing in rail freight transport through improved digitalization and standard-setting.

We, the International Union of Wagon Keepers (UIP), do support activities that are aiming at improving efficiency in the exchange of standardized data between relevant actors to increase the competitiveness and reliability of rail transport. However we have significant concerns as regards several proposed measures in the current legal draft text.

The European Union Agency for Railways (ERA) published recommendations for the TAF/TAP TSI in January 2022 after four years of work, based on the TSI revision mandate (Decision 2017/1474). An initial interim revision was incorporated into the TAP TSI in 2021.

The importance of a gap- and benefit analysis The draft text of the Telematics TSI does not only merge two regulations, but also extends the use of data exchanges and introduces new concepts. Trafikverket welcomes ERAs Advisory notes, but will still consider that the Advisory notes does not replace an impact assessment and it is worth noting that this merge and addition of regulation has not been examined by an…

ANEC supports advancing data interoperability requirements to facilitate rail transport for consumers. Interoperability, including cross-border functionality, is necessary for all of Europe and fundamental to the success of future transport systems. Data standards relating to traffic infrastructure and coordination can lay down the baseline for an open, interoperable and integrated service provision.

Until all rail operators have bicycle spaces, it should be easier to fins the ones that already have it and plan trips with these operators. Today, rail operators do not give that data by default so consumers cannot see in the main booking platofrm (In Sweden it is SJ) whether the operators/departures offer bike spaces.

SZCZ has 4 very important comments on the text of the TSI Telematics and asks the EC to accept and deal with them before voting on the TSI. No Impact Assessment has been prepared. There are too many questions and comments (see 11 Factsheets). SZCZ supports the position of CER and the Joint Sector Group (JSG). All comments submitted by the Joint Sector Group (JSG) must be answered before voting on the TSI.

DSB would like to submit the following feedback. The European Union Agency for Railways (ERA) published recommendations for the TAF/TAP TSI in January 2022 after four years of work, based on the TSI revision mandate (Decision 2017/1474). An initial interim revision was incorporated into the TAP TSI in 2021.

The BDI welcomes the overall objective of the Implementing Regulation to improve data exchange in rail freight and to increase its interoperability. However, as it stands, there are legal concerns and regulatory uncertainties that require a revision of the current draft with a greater involvement of the railway sector.

Filed in German · English published by the European Commission

DB InfraGO timetabling and operations departments fully support the goal of TAF/TAP TSI and Telematics TSI to harmonize and improve data communication between telematic stakeholder in the railway area. We are in the process of implementing the necessary adaptions to our systems and highly encourage other stakeholders to do the same in order to achieve better competiteveness of the railway sector as a whole.

Feedback regarding 1.5.1 (3), 1.5.2 (4), 1.5.3 (5), 1.5.5 (3) Annex ‐ TSI Telematics (ST16EN07) The data quality criteria are not realistic and impractical, as they require an accuracy, completeness, consistency and uniqueness of 100%. This imposes a de facto impossible obligation on the addressees concerned that cannot be complied with.

České dráhy would like to submit the following feedback: ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool. As first output an intermediate revision was included by amendment in TAF TSI in 2021.

In order to be able to correctly link Energy Metering Data coming from on-board Energy Measurement Systems (EMS) with the correct train and thus with the correct consumer, Infrastructure Manager shall know the European Vehicle Numbers (EVN) of the Traction Units part of the train run. This is possible by making the Train Composition Messages mandatory as proposed in this Commission Implementing Regulation.

ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool. As first output an intermediate revision was included by amendment in TAF TSI in 2021. Nevertheless DG MOVE did not support the recommendations.

Since 2 years and after 7 versions of the Telematics TSI, UIC does not qualify this last revision as a significant improvement, for the following reasons: Change of nature of the TSI, which is now about making freight rail data public, instead of allowing the exchange and make available the necessary sufficient confidential informations between the related stakeholders; it is due to very general wording, a strong…

I have been working in rail distribution for 20 years, including experience with the European Union Agency for Railways (ERA). Initially, I worked for a large third-party distributor, and I am now a consultant, dedicating 50% focusing on rail distribution with OSDM. My involvement began 12 years ago through the "Full Service Model," a sector-wide initiative involving both railways and third-party distributors.

ERA published the TAF/TAP recommendations in January 2022 after four years of collaborative work by the ERA TAF and TAP working parties, following the TSI revision mandate (decision 2017/1474). These recommendations aimed to improve interoperability and efficiency in rail data exchanges. An intermediate revision was included by amendment in TAF TSI in 2021.

We support the initiative’s objective to improve transparency in rail freight transport. Making the processes in the complex rail system more manageable and optimised by sharing data is an important prerequisite for strengthening rail freight transport. However, sharing of data must not have the effect of influencing competition or endangering security.

Filed in German · English published by the European Commission

Joint comments from DB Fernverkehr AG (DB F) and DB Regio AG (DB R) General on changes to the TTT requirements and formats: In Germany, the TAF/TAP TSI implementation, which DB F and DB R expressly welcome, already presents significant challenges for the sector, as demonstrated by the postponement of the TAF/TAP TSI implementation, which has since been initiated several times by DB InfraGO.

Filed in German · English published by the European Commission

On behalf of benerail I would like to submit the following feedback: ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool. As first output an intermediate revision was included by amendment in TAF TSI in 2021.

The Commission has published a draft for the TSI Telematics Implementing Regulation. Nederlandse Spoorwegen has read the documents with great interest. We will try to respond succinctly. ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM…

ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool. As first output an intermediate revision was included by amendment in TAF TSI in 2021. Nevertheless DG MOVE did not support the recommendations.

The position of SNCF on the Telematics TSI EN07 is following. ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool. As first output an intermediate revision was included by amendment in TAF TSI in 2021.

The Commission has published a draft for the TSI Telematics Implementing Regulation. ProRail (the Dutch Infrastructure Manager) has read the documents with great interest and welcomes initiatives for more transparency and uniformity in the sector. In the annex, we have provided for feedback in detail.

The Snälltåget supports the Commission’s proposal in broad terms. We consider it particularly important that the distributor has access to neutral data of timetables and products/prices and that the timetable search can take place as described in EU 782/2021.

Filed in Swedish · English published by the European Commission

Considering the nature of this regulation (TSI), this draft regulation (published as ST16EN07) should, if possible, include all general features of such regulation, as well as sector-specific features, and also features which are not or cannot be included in another legal document.

Ladies and Gentlemen, as the German oil industry company, almost all of our transports are covered by dangerous goods legislation. According to 1.10 RID, there are security obligations for dangerous goods, in particular when transported in tanks. Publication of all information (UN number, station of departure, receiving station, etc.) for the public will be contrary to the security obligations under 1.10.

Filed in German · English published by the European Commission

Dear Sir/Madam, We object to the following points of the Telematics TSI Revision: 1.Public Data The new Telematics TSI provides for the publication of both the timetable data and the operational data of freight trains. This is unacceptable.

Filed in German · English published by the European Commission

First of all, I would like to commend this act for its potential positive impact on the future of the European railway system. Thank you! I have a few comments that could further enhance the text: 1) The requirement to set up APIs is excellent. However, there is no specification regarding the type of API (e.g., SPARQL, JSON, GraphQL, SOAP, gRPC, XML-RPC, OData) or the quality and availability of API documentation.