Sector management of regulatory document changes STAR project deliverable 8

Transcription

1 Sector management of regulatory document changes STAR project deliverable 8 Date: 20 June 2014 Author: Dr Christopher Querée Owner: TAP Phase Two Project Team Client: TAP TSI Steering Committee Version: V1-0

2 1. Document history 1.1 Document location This document is available in the member s area of the TAP TSI project extranet. 1.2 Revision history This document was revised as follows: Revision date Version Summary of changes Changes marked 20/06/14 V1-0 Release version None 1.3 Approvals The approval for this document is as follows: Name Title Approval Issue date Version Project Team TAP Steering Committee 1.4 Distribution Project manager, workstream leaders Joint chairmen This document is distributed to: Approved 20/06/14 V1-0 Name Remark Issue date Version TEN-T Agency TAP Steering Committee Project Team Interested public Official recipients of the STAR project deliverables Chairs, members and alternates All members of the Project Team On TSI.uic.org 1.5 Document maintenance This document is published by the TAP TSI Phase Two Transition team. Any reader detecting errors or needing clarification should contact the TAP TSI Phase Two project team. Page 2

3 2. Table of contents 1. Document history Document location Revision history Approvals Distribution Document maintenance 2 2. Table of contents 3 3. Introduction Purpose of the document 4 4. Sector management of change requests Change management constraints Administration Decision making by members Change management process Reconciliation of ERA Technical Documents and UIC Leaflets 9 Page 3

4 3. Introduction 3.1 Purpose of the document This document is deliverable number 8 for the STAR project. At the time of defining the project, there was to have been a regulatory service managed by the TSGB known as the document management service and this document was to have been the detailed description of that service. With the agreement of the TAP TSI SteCo, this service has been removed from the TSGB. In consequence, the document now describes in detail the equivalent sector process of preparing the sector position on TAP CCM CRs, the sector in this case being railway undertakings and ticket vendors The process is not subject to TSGB governance although it clearly has close links to it, particularly where CRs may lead to changes to the regulatory services made available by the TSGB The process is founded on the tripartite agreement between the ERA, CER and the UIC. This tripartite agreement sets out inter alia the rights and responsibilities of the parties in respect of TSI change management The document makes reference to the ERA-UIC Technical Agreement. When that Agreement comes into force it will have an important bearing on the coordination of the contents of UIC Leaflets and ERA Technical Documents. The Agreement also contains provision for ERA-UIC meetings and where these are related to the TAP CCM process then the CER Speakers will need to have an involvement This document defines the roles of all the parties involved and in consequence provides a clear view of how the sector input to change management is to take place. It will be reviewed annually and updated in the light of experience. Page 4

5 4. Sector management of change requests 4.1 Change management constraints The change management process must respect the regulatory role of the CER as Representative Body in the TAP CCM The change management process must respect the regulatory role of the UIC as an expert body in respect of retail TAP Technical Documents The change management process must respect the expertise sitting in the UIC technical sub-groups in respect of the retail TAP Technical Documents. 4.2 Administration The sector administration of TAP CCM CRs will be the responsibility of the lead CER Speaker The leaders of UIC technical sub-groups, subject to the mandate given by the members of the technical sub-groups, will be responsible for the conduct of technical studies and business case assembly UIC technical sub-group membership will be extended to include ticket vendors under conditions agreed by the Commercial and Distribution Forum Decisions about stakeholder positions on CRs will be taken at the TAP Technical Group (currently called the TG Action Group). The membership of this group will be: all CER Speakers and Deputies all TV Speakers and Deputies the chair of the UIC Technical Group all leaders of UIC technical sub-groups TSGB General Manager The leaders of UIC technical groups dealing with accounting leaflets will be invited to attend as non-voting observers The TAP Technical Group will be chaired by the UIC Technical Group chair. It will take place either face to face or remotely, according to the level and complexity of business and as determined by the chair Code list CRs may be submitted directly by UIC Experts with rights to the TAP CCM CR system All other CRs will be submitted by CER or TV Speakers unless delegated to appropriate UIC Experts CER Speakers will represent the rail sector in the TAP CCM. TV Speakers will represent the ticket vendor sector. 1 Efficient administration requires a single person to be in charge. The two CER Speakers decide between themselves who will be the lead CER Speaker. Page 5

6 UIC Speakers will provide expert advice to all Speakers in the TAP CCM in respect of the CRs, not only to CER Speakers Where the ERA wishes to hold a separate technical discussion about a CR, it will ask the lead CER Speaker to organise such a meeting. The lead CER Speaker will organise this meeting with the ERA and the relevant UIC technical sub-group experts. All Speakers and Deputies must be informed and will be free to attend Where the ERA and UIC wish to hold meetings not related to specific CRs but related to TAP CCM business then all CER Speakers and Deputies must be informed and will be free to attend. 4.3 Decision making by members Recommended positions in respect of each CR will be based only on the commercial business cases of railway undertakings and ticket vendors. General public benefits such as consumer surplus will not be used. The process for generating recommendations is defined in detail below All UIC members are free to participate in UIC technical sub-groups and to contribute to the work and recommendations of the sub-group. Subject to the agreement between the TSGB and the UIC, all TSGB Licencees are free to participate in UIC technical subgroups and to contribute to the work and decisions of the sub-group Speakers may request reasonable further study of CRs where they consider it would be difficult to justify the recommended position in the TAP CCM Any recommendation that requires mandatory expenditure by one or more UIC member must be confirmed by the UIC Commercial Group and the Commercial and Distribution Forum All recommendations must be reported to UIC Commercial and Technical Group members and to the members of the UIC Commercial and Distribution Forum. 4.4 Change management process The effort and process needed to assess the impact of a CR must reflect its complexity and the commercial impact on stakeholders. The process recognises four classes of CR: codelist change not requiring any system change optional change to existing specification mandatory change to existing specification new specification or other business process change The classes have different commercial impacts on stakeholders and the technical studies and commercial business case development must be adapted accordingly UIC technical sub-group leaders, working with the members of the technical sub-groups, will manage the technical studies and the business case assembly UIC members and TSGB Licencees may use the information in the technical studies to study the impact on their own organisation. They may contribute to the overall commercial business case, subject to competition law and stakeholders individual policies on commercially confidential business information. This information supply provides the objective information needed for decision making. This will ensure that Page 6

7 discussions in the TAP CCM are based on commonly agreed facts and will minimise the costs of collecting such facts For the rare cases of significant pan-industry business process change, a migration project may be required in order to coordinate the change across all stakeholders. Depending on the significance of the change, these projects will vary in size and scope, although in some cases they can be expected to last several years. The requirement for a change-related project shall be submitted to TAP CCM as information relevant to its decision-making process Where a CR is submitted to the TAP CCM CR system directly by a party not involved in this process the lead CER Speaker will assign the responsibility for processing the TAP CCM CR to a single UIC technical sub-group leader. If this proposal is not accepted by all sub-groups (for example where a CR affects more than one Technical Document) then the CER lead Speaker shall request the UIC Technical Group chair to determine the correct sub-group leader Where a potential CR comes from a UIC technical sub-group, for example as a result of a stable and beneficial change to a UIC leaflet, then the leader of that sub-group will be responsible for processing the TAP CCM CR, including seeking UIC approvals for the preparation of the CR The sector change management process is summarised in the following table: Stage Requirements Outline Business Case Technical Study Process The promoter of the change prepares a paper defining the business requirement in manner that provides sufficient detail for it to receive a preliminary assessment. The first stage of the assessment is the Outline Business Case. The sub-group classifies the CR type: 1. codelist change not requiring any system change 2. optional change to existing specification 3. mandatory change to existing specification 4. new specification or other business process change The sub-group associates the CR to other CRs, if any, to be assessed together. The sub-group makes an estimation of the technical changes needed to meet the business requirement and prepares a high-level estimation of the industry costs of the change. For CR Type 1 the sub-group drafts the revised codelist document. For CR types 2, 3 and 4, those with the greatest impact, the assessment continues with a Technical Study. This stage is skipped for CR type 1, for which the Outline Business Case is sufficient. The Technical Study is carried out by the sub-group, led by its leader. The scale of the work undertaken by the sub-group will match the level of impact of the CR. The outputs of the Technical Study are: 1. identification of commercial business requirements and potential business benefits 2. summary of technical response 3. outline project plan for implementing CR including the identification of any proposed mandatory dates for using the new specifications 4. identification of which parts of the CR will be subject to the TAP TSI obligations and which parts are not subject the Regulation 5. proposal for the circumstances in which the new specifications are mandatory under the Regulation and any consequent changes to the Basic Parameters 6. proposed changes to impacted Technical Documents including Application Guides 7. proposed revisions to other documents such as user guides, etc Page 7

8 Stage Industry Review Industry Business Case Implementation Project Process 8. identification of any significant audit, legal, or administrative impacts 9. identification of required changes to the TSGB Statutes and/or TSGB Regulatory Services documents 10. estimate of costed changes needed to TSGB regulatory services. The purpose of the Technical Study is to provide sufficient information about a CR for UIC members and TSGB Licensees to make an accurate assessment of the impact on their own business and operations and hence the cost of such change. The study will therefore be larger and in more detail if the expected impacts of the CR are greater. It is the responsibility of the sub-group leader to liaise with the TSGB General Manager to ensure that the TSGB is able to change the TSGB Statutes and the TSGB Regulatory Services documents and is able to fund the document changes and any changes needed to TSGB regulatory services and related projects, in the case that the CR is accepted by TAP CCM. The assessment continues in all cases with the Industry Review. The Outline Business Case and the Technical Study (if prepared) are notified to all UIC members and TSGB Licensees. They are invited to reply on behalf of their organisation with the following: 1. for both the Regulatory and the non-regulatory parts of the CR whether their organisation supports, opposes or is indifferent to the CR where they oppose this will need to include a commercial justification for a rejection or for a delay in implementation 2. any issues they identify with the proposal and any suggestions for improving the technical response. A special meeting of the sub-group can be called if the CR is of significant importance. For CR type 1, parties will be given two weeks to respond. For CR type 2, parties will be given one month to respond. For CR type 3, the period will be three months. For CR type 4, the period will be determined in the Technical Study but will never be less than three months. The final stage of the assessment is the Industry Business Case. All responses from TSGB Licensees are assembled, keeping separate the responses for the Regulatory and the non-regulatory parts of the CR. A separate decision is made for each of the two parts. The sub-group reviews and incorporates all suggestions for improvement where these do not materially change the technical response. Where there is opposition to the CR, the working group engages with those impacted in the hope of achieving a consensus. Once there is consensus for CR types 1 and 2 then the CR is recommended to the TAP Technical Group for approval. If there is no opposition to a CR type 3 then the CR is recommended to the TAP Technical Group for approval. Current and changed specifications remain valid for three years, to allow railways to implement the change within normal budget cycles. If there is no opposition to a CR type 4 then the CR is recommended to the TAP Technical Group for approval. The change is introduced according to the timetable defined in the CR, but current specifications will remain valid for at least three years. If there is any opposition to a CR Type 3 or 4, and the opposition can be supported by TSGB Licensees with verifiable commercial arguments, then the CR is rejected and this is reported to the TAP Technical Group. The matter stays with the sub-group for them to seek a better way to address the business requirements of the CR until the TAP Technical Group requests that the matter is dropped. If the Technical Study for an approved CR has identified the need for changes to TSGB regulatory services then these service changes will be made as a TSGB-funded project. Industry projects associated with an approved CR will be coordinated by the relevant UIC sub-group leader. Page 8

9 4.4.9 The process will ensure that the overlap between versions of a regulatory document is set at a level allowing TSGB Licensees to make the changes at an economically sensible stage of their system refresh and renewal cycles, recognising the time to seek and receive budget approval and the time needed for launching projects. 4.5 Reconciliation of ERA Technical Documents and UIC Leaflets Within the framework of the ERA-UIC Technical Agreement, ERA and UIC will adhere to an annual document publication cycle. In consequence, the text of the common parts between ERA Technical Documents and UIC Leaflets will always be identical for formally released versions In the event that a CR comes from a UIC technical sub-group, but is rejected by the TAP CCM, then the TAP Technical Group will ask the leader of the relevant UIC sub-group to study the matter. If it is feasible to retain the contents of the CR as something available for use by UIC members but outside the regulatory framework then the UIC Leaflet will be amended to include the contents of the CR outside the common parts. If the contents are firmly part of the common parts, then there would be no change to the UIC Leaflet. However, in either case the TAP Technical Group could ask the leader of the relevant UIC sub-group to study the matter further and if possible propose a new CR that was more likely to be accepted by the TAP CCM In the event that a CR is submitted to the TAP CCM CR system directly by a party not involved in this process, and the CR is accepted by the TAP CCM even though opposed by the TAP Technical Group, then the text of the common parts of the equivalent UIC Leaflet will be modified to be identical to the ERA Technical Document. If there is no equivalent UIC Leaflet then nothing further will be done. The TAP Technical Group will ask the leader of the relevant UIC sub-group to study the matter and if possible propose a new CR that would mitigate the unacceptable parts of the original CR. Page 9