The TAP TSI Regulation will be amended and republished in autumn 2013 to introduce the deliverables from the Phase One project, including the proposed long-term governance. The revised Regulation will place an obligation to establish and run in perpetuity a TAP TSI governance structure. The main objective is to ensure that regulatory services are available in a non-discriminatory way to those parties that need them, for instance in order to be compliant with the law. Such regulatory services, without which individual company’s compliance cannot be achieved, are notably:
- A registry (facilitating requests such as “Where do I find Eurostar’s timetable data?” for instance)
- Reference data (e.g. standardised location information and code lists)
- Data quality checking (allowing railways to have their data checked against the regulatory quality requirements)
- Accompanying technical document management and administrative tasks
Over the last half year, a working group of railway and third party ticket vendor representatives, together with the TAP Phase Two project team, have been evaluating structural options for such governance and for an appropriate hosting environment. The working title is “TSGB - TAP TSI Regulatory Services Body”. In order that the TSGB can make sure that the services are available, they need to be defined in sufficient breadth and detail so as to ensure they are limited to regulatory requirements only, avoiding encroachment on non-regulatory business, and to allow for them to be procured or quoted in supply agreements.
The working group has been investigating a whole range of structural options ranging from tasking established industry associations or the European Railway Agency with TAP TSI governance services to setting up a lean new legal entity in a European member state.
Subject to further analyses, a positive vote of the multi-stakeholder TAP TSI Steering Committee and eventual approval by the European Commission, the working group favours the establishment of a new legal entity such as a Belgian AISBL so as to respect the rights and obligations of parties that are not members of any existing stakeholder organisation and in order to minimise liability issues. The entity would be very lean with a budget of a few hundred thousand euros p.a. and a very limited number of headcount (mainly a part-time general manager). As recommended by the working group, it would otherwise draw on existing working structures and technical solutions such as provided by the UIC, thus safeguarding the interests of the rail sector. The governance structure would be financed by licences, estimated to cost less than 3,000 euros p.a. per licencee.
The regulatory services will be brought into operation in Phase Two (“development”, commencing with the republication of the Regulation) and will provide the TAP TSI eco-system overseen by TAP Governance in Phase Three onwards (“deployment and operations”).