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TSI Telematics must fully embrace the spirit of the Rotterdam Clause

The sharing of data to plan, forecast, track and trace the movement of goods within a supply chain must be possible without administrative, legal, contractual and prohibitive investment barriers. The creation of a digital solution to prevent negative competitive impacts for Road-Rail Combined Transport in the EU is essential. UIRR calls for a full implementation of the “Rotterdam Clause” in the European Commission’s new proposal on TSI Telematics. The concept of “selective open data sharing” between all stakeholders is of crucial importance. However, making all data publicly accessible is not necessary and is contrary to business confidentiality, competition rules and especially the interests of the intermodal freight sector and especially the interest of its clients.. UIRR appreciates the intention of a joint digitalisation regulation for both passenger and freight, provided that both matters can be effectively combined and settled together in due time.

The Rotterdam Clause^[1] has been integrated into the current Telematics Application for Freight (TAF TSI) to reflect the need and right to access and share relevant data of the movement of goods and units during the rail leg of a transport chain, in a comparable way to standard practices in other transport modes. Its comprehensive and compliant implementation would improve the exchange of information with intermodal customers, and ultimately enhance the attractiveness and competitiveness of intermodal freight transport. The primary objective is to ensure that the required sharing of relevant data is the norm rather than the exception, thus reducing reliance on excessive and unnecessary bilateral agreements.

Building on the above, UIRR’s position on the central data sharing assumptions in the TSI Telematics is as follows:

• TSI Telematics must be designed to support the spirit of the Rotterdam Clause, with minimum constraints or limitations regarding a) the process for identifying all stakeholders involved in a complete door-to-door supply chain, and b) the technical means used for data exchange. The Rotterdam Clause is intended to facilitate the tracking and tracing of transport units, thus allowing shippers to monitor the status of their goods. This feature is fundamental to delivering high-quality services. However, its implementation to date has not lived up to expectations.

• TSI Telematics does not fully specify the content of the information that is required to be shared. UIRR recommends a measured reduction in both the depth and frequency of data sharing.

• • Reduced depth directs the focus on the minimum vital data elements to be shared in order to avoid conflicts with legitimate legal, commercial, security or safety concerns.
  • Reduced frequency means that not all recipients need to receive every published status updates. If all stakeholders streamline their communication and decision making in both directions, this would allow to move forward faster and to increase, therefore ease implementation and acceptance.

The following two use cases of Combined Transport demonstrate the urgent need for a) harmonised legal clarity, and of b) faster implementation:

a) Shippers or LSPs want to plan or optimise a road leg

If shippers or LSPs want to use intermodal rail freight, they are currently required to tag every container or other loading unit with intelligent devices. When all shippers rely on their own individual solutions, the standardisation and cost-efficiency of cross-border intermodal transport chains suffer, and the existing costly EU-funded transport infrastructure fails to serve its intended purpose. Rather than investing in specific - and therefore often non-interoperable -  Internet of Things (IoT) hardware and software, the sharing of data from infrastructure managers (IMs) and railway undertakings (RUs) alongside with information from intermodal freight terminals, would be more cost-efficient, energy efficient, and interoperable.

b) A consignee needs reliability of its transport chain and precise reporting of irregularities

The consignee requires clear visibility of the arrival schedule of goods at the intermodal freight terminals in order to effectively coordinate collection, plan detailed production activities, and accurately determine when finished products will become available. Consignees are increasingly requesting confirmation of schedule progress through regular update messages. In the event of delays, estimated time of arrival (ETA) messages or disruption notifications are equally relevant. Status updates on loads and position of goods can be sufficient to increase confidence in intermodal rail freight transport. Currently, however, this is only partially achieved and depends on individual initiatives of the parties involved in the logistics chain. The availability of such information as an intermodal industry standard has not been realised despite nearly nine years having passed since the integration of the Rotterdam Clause.

Intermodal freight terminals and intermodal operators both require extensive data sharing with their railway subcontractors. Intermodal operators bridge the information sharing with the logistics service providers and, indirectly, with the owners of the goods. Therefore, facilitating a standardised flow of data is essential in order to enhance the attractiveness of European intermodal freight transport.

Request from the Combined Transport Community

As representatives of the intermodal freight sector, we propose that two key amendments be incorporated into the TSI Telematics.

1. Improved data sharing free from administrative, commercial, unfair and biased restrictions

UIRR’s position is to support the establishment of harmonised data exchange rules across the end-to-end transport chain, which includes secondary (or indirect) recipients of information who can access data provided by railway stakeholders (such as that from the RNE TIS application).

TSI Telematics aims to implement data sharing in a wide — perhaps overly wide — interpretation. The TSI Telematic Regulation must address the Gordian knot of little progress in achieving the minimum level of relevant information sharing from the customer’s perspective, within the chain of legal contracts (legal view), thereby in fulfilling the targets set by the Rotterdam Clause of 2016. However, the solution should also encompass IT platform providers contracted to manage the information flow. Particular attention must be paid to ensuring that the digital data exchange of schedules, estimates, status and disruptions notifications is not subject to separate pricing. The costs for distribution and storage should be limited by reducing both the frequency and the content of exchanged data, since not all intermodal stakeholders require to exchange and to store every status change.

2. Selective open data sharing to facilitate digital information flow between stakeholders

At a minimum, it must be possible to share, without any specific contractual or legal restrictions, scheduling, forecast and status information of the freight trains transporting loading units that contain shipper’s goods. UIRR is actively working to define the minimum required data set, data exchange standards and IT platform interoperability that need to be achieved to operationalise and avoid potential confidentiality litigation.

The IT systems involved must be capable of limiting data sharing to match the customer requirements (intensity) and of restricting the open dissemination of potentially sensitive information (e.g. safety or security-related information that is not relevant to non-rail operations stakeholders).

The conditions for the minimum set of data elements to be shared, along with the measures for their enforcement, should be specified in the TSI Telematics (refer to level 3 in the graphic above). The delineation and achievements of Level 2 may be an objective for future development.

[1] Under the coordination of UIRR and RNE, the Rotterdam clause has been inserted in the chapter 4.2 of the current TAF TSI. The full clause is as follows: “In addition to the provisions from the Chapter 4 and its sub-chapters every stakeholder may exchange the messages according to Chapters 4.2.2.3 (only during operation or preparation of train operation), 4.2.4.2, 4.2.4.3, 4.2.5.2, 4.2.6.3 and 4.2.6.4 with other stakeholders involved in the same freight service, under the condition that the stakeholders are identifiable. These exchanges of messages may be charged by the sender.”