Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the Regions on interoperable electronic fee collection systems in Europe
Date: 1998-12-21
Institutions: European Commission
Subjects: charges for use of infrastructure, motorway, new technology, toll, transport infrastructure

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 21.12.1998 
COM(1998) 795 final 

COMMUNICATION FROM THE COMMISSION 

TO THE COUNCIL, THE EUROPEAN PARLIAMENT, 
THE ECONOMIC AND SOCIAL COMMITTEE 
AND THE COMMITTEE OF THE REGIONS 

on 

INTEROPERABLE ELECTRONIC FEE COLLECTION 
SYSTEMS IN EUROPE 

1. 

2. 

3. 

4. 

5. 

SUMMARY 

Electronic  Fee  Collection  (EFC)  systems  offer  the  possibility  of  charging  road 
vehicles  in  a  highly  flexible  way.  This  enables  the  implementation  of  charging 
policies  for  the  use  of  infrastructure  to  improve  transport  efficiency,  allowing  the 
recovery of costs and/or the management of traffic.  It is important that such systems 
be  interoperable  across  national  borders  to  avoid  creating  new  obstacles  to  traffic 
flows in Europe, in accordance with the Single Market provisions of the Treaty. 

Ultimately, interoperability should enable users to pay tolls without changing their on 
board  equipment  or reverting to manual payment when they cross the boundaries of 
different  EFC areas.  At the present time, however, EFC is at very different  stages of 
implementation  in  various  European  countries  and  the  Council1  has  requested  a 
strategy for convergence of EFC systems to an appropriate level of interoperability in 
the European Union (EU). 

In the  intermediate  convergence period,  the degree of interoperability  between  EFC 
systems  may  be  different  between  countries.  Equally,  the  methods  by  which  this 
intermediate  degree of interoperability  is achieved, and the corresponding  costs may 
be different.  However, the long term objective is that all European EFC systems will 
enable the use of interoperable on-board equipment by traffic moving from one system 
to another. 

In addition, the use of EFC for road pricing or access control to manage traffic  is being 
considered  by many  as  a possible  contribution  to  a solution  for  the  growing  traffic 
congestion  in urban  agglomerations  in  Europe.  Interoperability  between  urban  and 
interurban  applications  therefore  needs to be taken into account in the development 
and implementation of EFC systems. This will mean close co-operation between those 
responsible for  achieving cross-border  interoperability,  and those dealing with  urban 
schemes. 

This Communication examines the issues involved in developing a framework for the 
timely  deployment  of  interoperable  EFC  systems  in  Europe  able  to  support  the 
implementation of current and future agreed charging policies while allowing national 
It  proposes  the  best  approach  in  resolving  these  issues, 
and  regional  variations. 
allowing in particular the implementation  of the Commission proposals in the White 
Paper  "Fair  Payment  for  Infrastructure  Use"2  on  distance  related  charging  with 
differentiation  of rates according to vehicle and geographical characteristics. 

a) 

First  major  issue  :  Technical  interoperability.  Existing  EFC  systems  for 
motorway tolling make use of Dedicated Short Range Communication (DSRC) 

Council Resolution 97/C 194/03 of  17.6.1997 on the development of telematics in road transport in particular 

with respect to electronic fee collection, OJ C 194 of 25.6.1997 

2 Commission White Paper COM(98) 466 final of 22.07.1998 on Fair Payment for Infrastructure Use: A phased 

approach to a common transport infrastructure charging framework in the EU. 

between the roadside and the vehicle.  The feasibility  of the DSRC technology 
has already been demonstrated, and European pre-standards have been agreed, 
which are not always compatible with the existing systems. 

An  alternative  system  being  considered  makes  use  of  satellite  location 
(GNSS3)  and  mobile  telephone  technology  (GSM).  The  individual  basic 
technologies  for  satellite  location  and  mobile  telephone  communication  are 
well  proven,  but  tolling  applications  based  on  the  combination  of  these 
technologies are not advanced.  The technology chosen will depend ultimately 
on  the  specific  requirements,  the  timetable  involved  and  the  state  of 
technological development. 

The  first  task  should  be  the  definition  of  a  common  minimum  level  of 
functionality  for systems to enable drivers to use their onboard payment device 
on  the  networks  of  all  the  operators  in  the  system.  The  scope  for  the 
development of equipment able to use both technologies needs to be examined. 

Second  major  issue  :  Contractual  interoperability.  The  availability  of 
technically  interoperable  equipment  needs  to  be  accompanied  by  contractual 
agreements between operators, and also between operators and other possible 
issuers of payment means.  All relevant issues are being examined within EU-
sponsored  projects  with  a  view  to  the  conclusion  of  a  Memorandum  of 
Understanding  by the relevant actors. 

Non-equipped  users  : An  issue  of particular  importance  is  the treatment  of 
users who  are not  equipped  with  the necessary  electronic  on-board  payment 
device.  Within  realistic  expectations  for  non-discrimination,  EFC  systems 
need to be designed  so that  such users  are not  subjected  to cumbersome and 
time  consuming  alternative  payment  procedures  or  to  penalising  prices. 
Within these constraints Member  States introducing EFC systems may apply 
the options best suited to their circumstances for the treatment of non-equipped 
users. 

Classification  : Vehicle classes used in each country do not themselves require 
harmonisation  in  order  to  achieve  interoperability,  although  such  class 
harmonisation would facilitate comparability and simplify users' understanding 
of  charges.  An  acceptable  set  of  vehicle  attributes,  which  can  be  used  for 
classification  purposes, is essential and needs to be agreed.  Work on this has 
already  started  within  EU-sponsored  projects  under  the  4th  Framework 
Programme  and  the  Trans-European  Transport  budget.  Work  is  also  well 
advanced in the European Standardisation bodies for drawing up a standard  on 
classification  parameters.  To  enable  EFC  systems  to  fulfil 
the  likely 
requirements of future  charging and pricing legislation, this set could include 
in addition to the usual vehicle  characteristics, environmental  attributes, such 
as emission  and noise characteristics.  As some of these attributes  cannot be 
measured  dynamically,  they  need  to  be  stored  in  the  vehicle  on-board 

b) 

c) 

d) 

3 GNSS : Global Navigation Satellite System. 

e) 

f) 

equipment  and  interoperable  EFC  systems  must  be  able  to  handle  them. 
Member  States may  elect to charge vehicles using  any combination  of these 
declared attributes and / or the usual measured characteristics. 

Enforcement  : Failure to enforce  payment negates the policy objectives, and 
results  in  loss  of  credibility  for  the  operators  as  well  as  loss  of  revenue. 
Enforcement must therefore  form an integral part of any fee collection system. 
At  present,  the  technical  integration  of  system  components  to  enable  fully 
automatic enforcement  in multi-lane  systems presents a challenge in meeting 
operational  reliability  requirements.  Effective  cross-border  information 
exchange and prosecution of offenders  needs agreement on forms of evidence 
and  on  procedures.  The. potential  for  successful  enforcement  through  the 
establishment  of  close  links  and  co-operation  between  tolling  enforcement 
agencies and national registration data bases should be explored. 

Fraud  : The incidence of fraud  may increase as interoperable  systems extend 
over wider geographical areas.  Until an acceptable degree of system security is 
achieved,  operators  may  wish  not  to  enter  into  the  contractual  agreements 
which  are necessary  for  systems  interoperability.  On the  other  hand,  users 
need  to  be  assured  of  an  acceptable  degree  of  data  protection  and  privacy, 
which may vary  according  to  different  national  approaches  and  traditions as 
well as according to requirements of individual users or user groups. 

The  aim  is to  define  a  strategy  and  actions which  give  satisfactory  answers  to the 
issues  above  : the objective  is that  EFC  systems  in Europe  should  converge to "an 
appropriate  level  of  interoperability".  In  determining  what  is  to  be  considered  as 
appropriate, it is necessary to take into account many factors.  These include EU and 
national policy requirements, requirements of operators for system resistance to  fraud, 
the desire of some users for anonymity, the extent of deployment of existing systems, 
the cost of changes to these systems, and the agreed timetables. 

This strategy will be developed respecting EU and national legislation and principles, 
like non-discrimination between users and data and privacy protection.  In the medium 
term  it  seems  most  probable  that  each  country  according  to  its  own  national 
requirements  will  deploy  its  own  EFC  system  but  with  sufficient  common 
functionality  to  enable  drivers  to  use  their  on-board  equipment  at  least  in  several 
countries. 

tie 

for 

implementation  need 

in  with  policy  priorities 

for 
to 
Priorities 
introducing/developing  charging  systems.  This means that immediate  action should 
be undertaken to implement  such systems for certain  classes of vehicles, like Heavy 
Goods Vehicles (HGVs), to which EU charging rules already apply4, and also to long 
distance coaches.  This is the category for which the single market arguments for both 
a  common  approach  to charging,  and  international  interoperability  are strongest.  A 
further  advantage of starting with HGVs is that  enforcement,  privacy protection and 

6. 

7. 

8. 

4  Council Directive 93/89/EC of 25 October 1993 on taxes and charges on HGVs, OJ L279/32 of 12 November 

1993 

the  question  of  non-equipped  users  could  be  easily  solved.  However,  in  giving 
priority to charging systems for HGVs and long distance coaches, no obstacle should 
be placed in the way of wider interoperability of systems. 

9. 

An EU strategy to achieve interoperability of  EFC systems, allowing for convergence 
of existing and future  systems  will therefore require a phased approach.  This is also 
in  line  with  the  phased  approach  for  infrastructure  charging  put  forward  by  the 
Commission in its White Paper. 

10.  Main  actions  in  the first phase  (1998 to  2000) will  be based  on the  following  key 

assumptions: 

i. priority will be given to interoperability of EFC systems for HGVs and long-distance 
coaches used on the Trans-European Road Network (TERN). This will need to provide 
the means  to  implement  decisions  on  EU  wide  charging  policies.  The  Commission's 
White  Paper  proposed  application  to  commercial  operators  of  greater  cost-related 
charging, differentiating by time, vehicle characteristics, route and so on', by 2004. 

ii.  interoperability  between urban  and inter-urban  applications  also needs to be  given 
priority in the development  and implementation of EFC systems 

iii.  an  open-system  architecture  will  be  necessary,  capable  of  responding  to  policies 
developed at EÙ pr national levels, of integrating further  operational and technological 
developments,  and  enabling  commercial  opportunities.  Such  an  architecture  would 
require consideration of dual or multi-mode equipment which would  permit the use not 
only of  DSRC technology but also of GNSS-based systems or other technology, where 
appropriate, in  response to policy  need  or operational  convenience.  The  architecture 
should  also  allow  the  potential  exploitation  of  EFC-based  technologies  for  traffic 
management and value-added services.  „ 

Achieving these objectives will require action by the Commission, the Member States, 
local and regional authorities, concessionaires, and by the standards bodies. 

These actions will be : 

a) 

b) 

to define and agree a common minimum level of functionality  at the EU level 
(ie the'basic features needed in order to achieve interoperability, e.g. capacity to 
distinguish types of vehicle, methods and arrangements to effect  payments etc), 
reflecting policy and operational requirements.  This will be based on work done 
within  EU-sponsored  projects  under  the  4th  Framework  R&D  Programme 
particularly  on  Transport  Telematics  Applications  and  of  the  Trans-European 
Network -  Transport Programme.  Any additional actions will be undertaken in 
the 5th Framework Programme. 

to enable these common functions  to be performed,  CEN (Comité Européen de 
Normalisation)  should complete its work on EFC on the basis of Mandate 270 
from the European Commission, developing, validating and adopting  standards 
on DSRC  and  other  areas, where  appropriate.  These  standards  should  enable 
multilane operation and the introduction of  traffic  management and other value-
added services,  using the same technology. 

c) 

d) 

e) 

The  Commission  will  help  all  interested  parties  to  complete  the  wprk  on 
contractual interoperability by promoting the signature of a Memorandum of 
Understanding between them, based on an EU framework agreement. 

The Commission will explore ways to facilitate cross-border enforcement and to 
adequately cover privacy and data-protection issues. 

The Commission will co-operate with cross-national groups of urban or regional 
authorities  considering  the  introduction  of  road  pricing,  so  as  to  offer  a co 
ordinated  approach  between  local  systems  and  between  them  and  inter-urban 
services. 

11. 

The Commission will put  forward  proposals for actions in subsequent phases on the 
basis of the results obtained in the first phase, and ongoing policy developments. The 
aim will be to achieve a convergence strategy for interoperability of EFC systems as 
requested  by  the  Council.  Failure  to  achieve  interoperable  EFC  systems  will  cause 
disbenefits  for  the  European  citizens,  especially  long  distance  drivers  who  will  be 
confronted  with artificial borders between the different  Member States, obliging them 
to use different  cards or onboard units, or to stop and pay cash at toll booths. European 
industry  will  loose  a  competitive  advantage  on  the  world  market,  due  to  the 
proliferation  of proprietary systems, and the resulting absence of economies of scales. 
Finally,  road  operators  will  also  suffer  because  of  increased  equipment  costs  and 
restriction on their freedom of choice. 

12. 

In  the  meantime,  the  Commission  recommends  that  decisions  by  national  and  local 
administrations  or  private  concessionaires  on  EFC  systems  should  be  based  on  this 
Communication. 

The Commission therefore asks the Council and the Parliament to endorse this first stage in a 
convergence strategy for EFC systems in Europe and the assumptions on which it is based. 

TABLE OF CONTENTS 

1. 

INTRODUCTION 

~ 

2.  EVOLUTION OF SYSTEMS 

3.  THE CHALLENGE OF INTEROPERABILITY 

3.1 
3.2 
3.3 
TOLLING SCHEMES 

GENERAL 
DEFINITION OF A COMMON MINIMUM FUNCTIONALITY FOR EQUIPMENT 
INTEROPERABILITY OF MOTORWAY TOLLING SYSTEMS WITH URBAN APPLICATIONS AND OTHER AREA 

1 

3 

4 

4 
6 

7 

9 

9 
10 
11 

12 
13 

.......14 

15 

4.  THE ISSUES 

4.1 
4.2 
4.3 
4.4 
4.5 

NON-EQUIPPED USERS 
CLASSIFICATION ISSUES 
ENFORCEMENT ISSUES 
ISSUES CONCERNING DATA PROTECTION AND SYSTEM SECURITY 
PRIVACY ISSUES 

5.  PREREQUISITES FOR CONVERGENCE 

6.  CONCLUSIONS 

\ti 

1. 

INTRODUCTION 

13. 

14. 

15. 

16. 

17. 

,  Many  road  authorities  now  seek  the  recovery  of  construction,  operation  and 
maintenance costs of roads through tolls or other road use charges.  In addition, many 
governments  and city  authorities  are  also  considering  some  form  of road pricing to 
manage  traffic  demand  and to  reduce  the negative  impacts  of  transport  in  terms of 
congestion,  accidents  and pollution, thereby  improving  the  safe  and  efficient  use of 
existing road infrastructure. 

These  trends  associated  with  substantial  increases  in  road  traffic  lead  to  the 
consideration  of charging systems which are able to levy road charges automatically 
and without the need for drivers to perform any additional actions beyond those related 
to normal driving activities.  The systems should enable the collection of such charges 
at normal highway speeds and without creating obstacles to traffic flow as a result of 
lane segregation. 

In some countries with a long established tradition of motorway tolling, Electronic Fee 
Collection  (EFC) systems have  already been introduced,  alongside manual payment 
methods using toll booths. This was a response to the wishes of motorists for a faster 
and  more  efficient  service  and  of  the  operators  for  a more  cost-effective  operation. 
With the  expansion  of EFC  systems, either newly  introduced  or as replacements of 
previous  manually  operated  toll  systems,  the  need  for  interoperability  becomes 
increasingly pressing. 

Interoperability from the point of view of users is the ability to travel throughout the 
Union without having to adopt procedures different from those of their own countries 
and without having to install extra equipment when changing from one charging area 
Interoperability  is  an  important  factor  in  serving  Single  Market  and 
to  another. 
sustainable transport policy objectives, and contributing to the creation of the internal 
market  for  industry  and the development  of the  Information  Society.  This justifies 
action at the EU level to achieve interoperability between EFC systems. 

In  1993, when  the first harmonised  Community  approach  on  vehicle  taxation  and 
tolling  for  Heavy  Goods Vehicles  was  established5,  the  Council  requested  Member 
States intending to introduce electronic toll systems to bear in mind the desirability of 
interoperability  between  systems. 
In  order  to  address  the  issues  raised  by  this 
requirement,  CARDME6 was  established  to promote  consensus  on medium  to  long 
term  strategies  for convergence to full  interoperability of EFC systems on European 
roads. 

18. 

Later,  and  in the light of  ever increasing traffic  congestion,  environmental  pollution 
and transport accidents, the Commission presented in 1995 its Green Paper on Fair and 

5  Council Directive 93/89/EEC of 25.10.1993 on the application by Member States of taxes on certain vehicles 
' used for the carriage of goods by road and tolls and charges for the use of certain infrastructures,  OJ L 279 
of 12.11.1993 

6 Concerted Action for Research on Demand Management in Europe 

Efficient  Pricing in Transport7.  In it the Commission put forward the view that prices 
paid  for  individual  journeys  should  be  better  aligned  with  the  real  costs  of  these 
journeys.  As costs differ  across time, space and transport modes, this implies  a need 
for  more  differentiation  and transparency,  which  can  only  be  met  by  some  form  of 
electronic  road pricing.  However,  the Green paper says that care  should be taken to 
avoid  the  deployment  of  incompatible  systems  and to  establish  European-wide  rules 
for interoperability.  The Commission has now put forward more concrete proposals in 
a White Paper for transport infrastructure charging.  This takes the form of a coherent 
framework  on infrastructure charging in different  modes.  Its main relevance  for EFC 
is that it sets out â timetable for implementation,  and gives clear priority to action on 
HGVs, leading towards a differentiated kilometre charging system. 

19. 

20. 

Last year,  the European Commission  adopted  a Communication8  to the  Council  and 
the  European  Parliament  on  a  Community  Strategy  and  Framework  for  the 
Deployment  of  Road  Transport  Telematics  in  Europe.  In  its  proposals  for  initial 
actions  the  Commission  has  identified  EFC  as  one  of  the  priority  areas  in  road 
transport  telematics  at  EU  level,  where  action  is  needed  in  order  to  devise  and 
implement  a  strategy  to  achieve  convergence  between  existing  and  new  systems  in 
order to ensure an appropriate level of interoperability Europe-wide. 

The Council of Ministers adopted a Resolution9 on the deployment of Road Transport 
Telematics,  with  particular  emphasis  on  EFC  systems.  This  again  stresses  the 
importance of developing a strategy for convergence of EFC systems in Europe taking 
into  account  already  existing  systems  and the  work  of  the  European  standardisation 
bodies in order to achieve an appropriate level of interoperability at a European level. 

This  Communication  examines  the  obstacles  to  interoperability  of  EFC systems  and 
sets out a recommended approach to.achieve an appropriate level of interoperability at 
European level.  It is not its aim to examine any aspect corresponding to the charging 
policies of the Member States or the EU for road transport, like for instance variation 
of charges by road type, or time.  The assumption is that interoperable systems should 
enable all agreed policies to be implemented. 

The  international  dimension  of  road freight transport  in  the  EU,  the  Single  Market 
logic  which  precludes  the  creation  of  barriers  to  intra-Community  transport  and 
commerce  by  road,  the  plans  for  new  inter-urban  EFC  systems,  as  well  as  the 
Commission proposals for road pricing, starting with commercial transport, all point to 
the need to give priority in our work at EU level to EFC systems intended for use on 
the TERN and applied to HGVs and long-distance coaches and buses. 

7  COM(95)691  final  of  20.12.1995  Towards  fair  and  efficient  pricing  in  transport  -  Policy  options  for 

internalising the external costs of transport in the European Union 

8  COM(97)  223  final  of  20.05.1997  on  a  Community  strategy  and  framework  for  the  deployment  of  road 

transport telematics in Europe and proposals for initial actions 

9 Council Resolution 97/C 194/03 of 17.6.1997 on the development of Telematics in road transport in particular 

with respect to Electronic Fee Collection, OJ C 194 of 25.6.1997 

21. 

In line with the principles of subsidiarity and proportionality, the approach is designed 
to ensure that necessary progress on EFC has been made to allow  implementation  of 
current  and  future  agreed  charging  policies  while  allowing  national  and  regional 
variations. 

2. 

EVOLUTION  OF SYSTEMS 

22. 

23. 

24. 

25. 

The  original  road  tolling  systems  involved  vehicle  drivers  stopping  at  a barrier and 
paying the toll keeper who then opened the barrier.  This simple procedure was most 
suitable for low traffic densities.  It had the advantage of ensuring that all vehicles paid 
according to their classification  while, at the same time, the privacy of the driver was 
maintained. 

Before  the  advent of  suitable  telematics  technology,  payment was  invariably manual 
and large toll plazas were constructed to avoid queues as drivers stopped to pay.  Toll 
systems  may  be  "open",  where  a  toll  plaza  is  just  a  payment  point  at  a  defined 
location,  or "closed", where the exact  entry and exit  of the motorway  are monitored 
and payment  is  made  at the  exit.  Both  systems  have  advantages  and  disadvantages 
depending on general policy, traffic  flows, land available and other possible items, and 
operators  study  carefully  the  type  used  for  each  section.  With  increasing  traffic 
densities  and technical  progress,  electronic  road tolling  systems,  using  a  microwave 
communication between the vehicle  and the roadside, have been introduced in one or 
more  lanes  of  the toll  plazas.  Even if barriers are often  retained to  ensure payment, 
this allows the flow of the plazas to be increased and reduces the average queuing time 
for the drivers.  Non-equipped drivers still have to pay manually.  The plaza designers 
have usually dedicated some lanes to these electronic systems, to get full advantage of 
the technology, when the number of subscribers was large enough.  These systems are 
referred  to  as "monolane systems".  Due to the lack of any standard, they have been 
developed without any provision for interoperability across concession borders. 

Some EU Member States do not presently apply tolling on their motorways and do not 
wish,  for  a  variety  of  reasons,  to  build  toll  plazas.  Instead,  they  are  considering 
introducing  "multilane"  free  flow  systems  in  which  drivers  passing  toll  collection 
points  do  not  need  to  reduce  speed  and  remain  free  to  change  lane.  Multilane 
applications do not require toll plazas, but at most, only specific  equipment  mounted 
on  gantries  at  the  tolling  points  to  ensure  tolling  functions  :  vehicle  detection, 
classification, payment and enforcement.  The infrastructure required is minimal.  EFC 
systems to deal with these requirements have been demonstrated, but some  questions 
about  overall  reliability  remain to be tested, taking into account  the need  for  vehicle 
classification  and enforcement of payment. 

Two  alternative  technologies  for  electronic  fee  collection  are being  developed  : one 
based  on  microwave  technology  (Dedicated  Short Range  Communications  -  DSRC) 
and  the  other  based  on  satellite  positioning  (GNSS)  and  mobile  telephone  (GSM) 
technology.  The feasibility  of the DSRC technology  in the 5.8  GHz frequency band 
has  already  been  demonstrated  and  European  pre-standards  were  adopted  in  1997. 
Although this basic frequency band has been formally  designated by ERC (European 
Radiocommunication  Committee - Decision of 22 October  1992) for the co-ordinated 
introduction of Road Transport Telematic  systems, it may be necessary to review the 

corresponding bandwidth requirements in the near future  in order to allow for  services 
other  than  EFC.  Further  work  is  currently  in  hand  to  ensure  that  new  industrial 
equipment  of  different  providers  are  compatible  with  each  other.  This  should  be 
completed  by  the  year  2000.  On  the  other  hand,  although  the  basic  technology  for 
satellite  location  and  mobile  telephone  is  well  proven,  and  opens  up  further  options, 
tolling  applications  based  on  a  combination  of  these  technologies  are  not  advanced. 
Satellite location technology will be used to define  whether or not the vehicle is on  a 
charged road, and for payment related to kilometres travelled, to compute the travelled 
distance.  The GSM technology will be used to collect payment.  In case of application 
of  these  technologies  to  a payment  principle  based  on  distance  travelled,  interfacing 
the payment  equipment  to'the digital tachograph,  if  any, should be  considered  as  this 
may  be  an option  for  HGVs.  Further  R&D  work  is required  to prove  the  integrated 
concept. 

26. 

Some EU countries already have developed  or are developing an internal policy  using 
short  range  microwave  technology,  enabling  drivers  to  use  the  same  onboard 
equipment  over  the  whole  national  network.  But  the  drivers  must  revert  to  manual 
payment  when  driving  outside  their  home  countries,  as  there  is  no  cross-border 
interoperability of EFC systems in Europe at present. 

3. 

THE CHALLENGE OF  INTEROPERABILITY 

3.1 

General 

27. 

Interoperability  means that  drivers,  equipped  to pay  motorway tolls  using the EFC 
system in one country or concession area, are able to pay  tolls in any other country or 
concession area without having to use different on-board equipment. It does not mean 
that there would  be  one single supplier,  but that there should be sufficient  technical 
compatibility between different systems, backed up by contractual agreements between 
operators, so  that to drivers, paying  tolls  on different stretches of road  in the Union 
would  be  a seamless  operation.  A  second  objective  is  that  the  on-board  equipment 
(OBE) installed  for payment  of motorway tolls should, if possible, be suitable for  use 
in urban areas for traffic  management and possibly for other payment applications. 

28.  Member States have agreed that interoperability is desirable10 and have stated that  "an 
appropriate  level of interoperability between  EFC  systems in the Community must  be 
achieved  so  as  to  provide  an  optimum  service  to  the  user  in  reasonable  economic 
conditions  and  without  creating  any  unnecessary  bureaucracy".11  They  have  not 
defined these concepts in a way which would enable a comparison to be made between 
the net benefits  and the additional costs which might have to be incurred. 

Users  will  benefit  from  interoperability  in  terms  of  convenience,  reduction  in  travel 
time and operating costs as well as the opportunity for added value services. 

10 Council Directive 93/89/EEC  of 25 October 1993 on taxes and charges on HGVs, OJ L279/32 of 12.11.1993 
11  Council  Resolution  on  Road  Transport  Telematics  and  EFC  :  97/C  194/03  of  17.06.1997  previously 

mentioned 

29. 

In  general,  operators  are  concerned  with  maximising  revenue  and  will  experience 
financial benefits  from  interoperability  if  it results in  lower  costs  or  in more  vehicles 
using  motorways  than  would  otherwise  be  the  case. 
If  the  achievement  of  pan-
European  interoperability  requires the involvement of issuers of payment  means  other 
than  the  operators  themselves,  this  may  be  seen  as  a  disadvantage  with  a  possible 
adverse  effect  on the  immediate  cash  flows  of the motorway  operators.  The  charges 
low  to  ensure 
made  by  finance  houses  acting  as  issuers  must  be  sufficiently 
acceptability to users and operators. 

30.  Manufacturers  are  likely  to  benefit  from  the  use  of  standard 

interchangeable 
equipment,  especially  when  convergence  between  new  systems  and  established 
systems  has  been  achieved.  Their  penetration  on  the  market  might  be  significantly 
increased  if  the  equipment  was  providing  other  related  services  in  addition  to  toll 
charging, such as parking payment, access control, plus added value services. 

31.  Work  done by  CARDME  has  concluded  that  interoperability  can only  be possible  if 
appropriate  agreements  are  reached  at  the  technical,  procedural  and  contractual 
levels.  Broadly  speaking,  these  concern  respectively  : the  physical  characteristics  of 
the  communication  between  vehicle  and  roadside  equipment,  the  organisation  and 
processing  of the data which are exchanged  (including the steps and algorithms  of the 
transaction process), and the relations between  users  and  operators  and with  potential 
third parties such as financial  institutions. 

32. 

33. 

34. 

At  the  most  basic  technical  level,  vehicle  on-board  equipment  based  on  DSRC 
technology  must be  able to  communicate  with roadside  or  ground  equipment  in  each 
country  or  concession  area.  The  CEN  pre-standard  for  Dedicated  Short  Range 
Communication  links  (DSRC), which  has recently been  adopted,  enables, rather  than 
guarantees,  communication,  as  system  elements  based  on  different  permitted  choices 
of  technical  parameters  will  not  necessarily  be  able  to  communicate.  Therefore, 
further  agreements on the communication parameters between national authorities and 
operators  in  co-operation  with  industry  will  be  necessary  to  guarantee  technical 
interoperability.  Since  this  CEN  pre-standard  is  not  compatible  with  some  existing 
operational  EFC  systems  in  Europe,  a  strategy  for  convergence  to  pan-European 
interoperability is needed. 

The fact  that systems using satellite navigation  and mobile telephone technologies  are 
being  considered  by  some  countries  adds  to  the  complexity  of  interoperability.  As 
mentioned  earlier,  vehicle  location  in these  systems uses  satellite  location  technology 
while payment  is by means  of  cellular  communication  between  vehicle  and  a  central 
system.  Interoperability is needed not only between different  systems of this kind, but 
also between these systems  and DSRC  systems.  However  contractual  and  procedural 
rather than technical solutions may provide this interoperability. 

Such  technologies,  i.e.  DSRC  and  GNSS/GSM  might  be  used  for  other  applications 
than Electronic Fee  Collection,  like Route  Guidance, Traffic  Management,  Protection 
against  Car  Theft,  Logistic  Fleet  Management...  Systems  and  services  are  already 
under  development  and  testing  in  some  Member  States  as  well  as  abroad.  These 
services  will  increase  the potential  number  of  subscribing  vehicles  and  the  needs  for 
technical interoperability.  They may affect  the technical  design of the equipment, but 
not  the work  already  done  in the  standardisation  bodies, who  considered  applications 

wider  than  EFC. Equipment  for  these  services  should be backward  compatible with 
EFC systems as they are developed. 

35.  At the procedural level, the functionality  of the on-board equipment must match that 
required by the tolling application.  This means that the information  passed between 
the  on-board  equipment  and  the  roadside  during  the  transaction  must  provide  the 
necessary information to enable guaranteed payment to the operator". 

36. 

The draft  pre-standard  for the definition  of the application interface  between the on 
board  equipment  and  the  roadside  appears  to  offer  the  required  framework  for 
procedural  interoperability  for  DSRC  systems  and  a  similar  interface  definition  for 
systems  using  satellite  location  is  being  developed.  However,  some  on-board 
equipment may conform to the standard but still not have the required functionality  for 
a particular application since choices can be made within the standards.  Therefore, an 
agreement  is required  on a minimum  common  functionality  for  on-board  equipment 
that  is  required  to  be  interoperable.  Agreement  on  a  common  minimum  level  of 
functionality  would  enable  users  with  appropriate  on-board  equipment  to  make 
payments to all operators subscribing to the agreement. 

37.  At  the  contractual  level, agreements  are  required  between  operators  and  possible 
issuers to enable operators to receive guaranteed payment.  Users must be able to use a 
payment  means which  is accepted by the operator  for  each concession  area through 
which they travel12.  At the present time, such interoperability depends on individual 
bi-lateral  agreements  between  operators,  which  is  a  complex  process.  European 
interoperability is unlikely to be achieved solely by means of agreements of this kind. 
The elements of a framework  for the development of interoperable European payment 
methods are now beginning to take shape.  But they will require further  work to take 
into account the difference between laws and regulations in the Member States, as well 
as  to  set  up  principles  for  clearing  between  operators  and  financial  institutions! 
However, the introduction of the EURO should make electronic debiting of accounts 
easier  and more transparent  within  its  area.  The needs of  consumers  must  be  fully 
taken into account in developing these agreements and consumer interest groups might 
be consulted. 

3.2  Definition of a common minimum functionality 

38.  A requirement for all national systems to have the same level of functionality  in order 
to achieve interoperability could  mean some countries being forced to adopt a higher 
level  than  required  for  internal  use,  or  others  being  required  to  lower  their 
requirements.  To  achieve  interoperability,  a  balance  will  need  to  be  struck.  In 
planning  new  systems  operators  will  need  to  take  into  account  the  objectives, 
requirements  and  constraints  of  their  systems  ensuring  that  all  potential  users  are 
offered  acceptable choices for payment.  These might include, for instance, opening a 

12  Users will therefore  require  a contract with  an issuer who in turn will guarantee payment  to the  operator. 
Operators  will  also require a contract  with the  issuer  to provide  the  guarantee  of payment  under agreed 
terms and conditions. The issuer of the payment means may be another operator, or a financial institution. 

credit  account, declaration to a central data base or payment by cash, whichever  is the 
most attractive to the users.  Finally they should provide those users who wish to have 
interoperability with the opportunity to install on-board equipment designed to  support 
common  payment  methods  and  common  EFC  transactions.  Such  interoperable 
equipment  will need  to have  a minimum  common  functionality  which  may be  higher 
or  lower  than  that  required  for  some  national  systems.  Operators  might  charge  if  it 
involves them  in extra costs, but  economies of scale of a pan-European  market  might 
make such charging unnecessary. 

39. 

As a general definition, the common minimum level of functionality  shall comprise all 
the technical  and  contractual  elements  enabling  electronic  toll payment  by  authorised 
subscribers, with the same payment means and equipment everywhere on the networks 
of the operators in the system. 

40. 

Recommended  approach. 

EU projects  should  work  closely  with  the  operators  on  the  definition  of  a  common 
minimum functionality  taking into account, as  a first priority,  cross  border  traffic  of 
heavy goods  vehicles  and long distance coaches.  CARD-ME will be the forum  for  co 
ordination  between  them  on  this  issue.  The  definition  of  a  common  minimum 
functionality  should form  the basis for  a Memorandum  of  Understanding  (MoU) to be 
used 
to  achieve 
contractual  agreements  between  operators  wishing 
for 
interoperability. 

CEN  should  take  into  account  in  its  current  tasks  the  work  on  a  common  minimum 
level of functionality  for  electronic fee  collection systems. 

The strategy for  achieving  common minimum functionality  should  allow  operators  of 
existing  non-interoperable  systems  to  migrate  to  the  interoperable  system  in  a  way 
allowing  them to depreciate their investments in an acceptable way. 

European  and  National  standardisation  bodies  should  finalise  and  approve  current 
work  on  electronic fee  collection  systems  including  the  standardisation  of  a  DSRC 
link,  and  other  systems  such  as  those  using  satellite position  location  with  cellular 
communication,  as soon as possible. 

All  the  actions proposed  to  CEN and  other European  standardisation  bodies  in  this 
document shall  be initiated through European Commission mandate M 270, the results 
of  which  will  be  evaluated  to verify their adequacy with  the recommendations  of  this 
Communication.  Further actions may require a new mandate for  achievement  of these 
objectives. 

3.3 

Interoperability  of motorway  tolling  systems  with  urban  applications  and 
other area tolling schemes 

41. 

The  concept  of  charging  for  the  use  of  urban  roads  as  a potential  means  of  demand 
management  is  gaining  in importance  within  Europe.  While  it  is desirable  to  ensure 
that local urban EFC systems are interoperable with motorway EFC systems, there can 
be considerable  difficulties  in achieving this.  The underlying objectives,  requirements 

and  constraints  for  the  two  systems  may  be  different  and  give  rise  to  different 
solutions:  the  emphasis  of  motorway  tolling  up  to  now  has  been  on  cost  recovery 
compared  with  the  focus  on  demand  management  in  urban road pricing.  However, 
Single Market principles require certain common functionality and interoperability  of 
the equipment used in both systems. 

42. 

Area tolling  systems using  satellite  location  and mobile telephone  technologies  may 
seem  attractive  for  urban  applications  due  to  the  reduced  roadside  infrastructure 
required and the ability to  operate without toll plazas.  They are, however,  relatively 
unproven,  and  interoperability  with  DSRC  based  motorway  systems  is  still  to  be 
achieved.  Dual  mode  equipment  will  almost  certainly  be  needed  if  some  Member 
States were  deciding  to use  the  satellite  location  and mobile  telephone  technologies. 
For  systems  intended  for  heavy  goods  vehicles  and  long  distance  coaches,  with  a 
distance  based  charging  scheme,  an  interface  with  the  digital  tachograph  should  be 
'considered. 

43. 

In  most  countries  little  attention  has  so  far  been  given  to  harmonisation  of  the 
requirements  of  different  cities  or  of  interoperability  between  urban  and  motorway 
tolling systems. 

As a minimum, the developers  of urban charging systems will need to ensure that the 
emerging framework for designing EFC systems, based on work in CEN, is used. 

The  Commission  will,  as  set  out  in  its  White  Paper on Infrastructure  Charging,  co 
operate with  cross-national  groups  of  urban or regional  authorities  that  are  seriously 
considering implementing road pricing, so as to offer a co-ordinated approach between 
local systems and between them and inter-urban systems, and also to ensure that these 
groups can take full  advantage of the research and technical work on EFC which has 
been carried out at EU level. 

44. 

Recommended  approach. 

The  developers  of  urban  charging  systems  will  need  to  ensure  that  the  emerging 
framework  for  designing  EFC  systems  is  used  to facilitate  interoperability.  For 
example, the CEN Standard Application  Interface Definition should be used. 

CEN  should  include  in  the  standardisation  of  systems  using  satellite 
technology, the requirement for  retrieving data on distance travelled. 

location 

CEN  should  also  include  in  the  standardisation  of  the  DSRC  Application  Interface 
Definition  the input of distance  data from  an odometer or satellite. 

CEN  in  co-operation  with  ETSI  should  also  ensure  and  verify  electromagnetic 
compatibility between the different systems implemented around the  infrastructures. 

An  interface  for 
equipment for  heavy vehicles and EFC systems should be specified. 

transmitting  distance  data  between  the  travel  data  recording 

4. 

THE ISSUES 

4.1 

Non-equipped users 

45. 

46. 

47. 

48. 

In this Communication non equipped users include those who have no equipment  and 
those  who  have  equipment  which  is  not  interoperable  with  the  system  in  the 
concession area in which they are travelling. 

Existing toll operators provide EFC as an optional service for those who do not wish to 
pay  manually.  However,  the  market  penetration  of  such  systems  is  currently  small. 
Typically  5%  of  all  users  of  tolled  motorways  have  EFC  equipment  although  the 
figure is considerably higher in Norway and Portugal. 

Countries  that have toll plazas  offer  a variety  of payment  methods.  Drivers  may  use 
cash,  credit  or  debit  cards, various  payment  cards  issued  by  the  operator  for  regular 
travellers,  and  in  some  cases  may  be  able  to  pay  using  an  automatic  machine  rather 
than  a  toll  booth.  They  may  also  use  different  payment  methods  on  different 
occasions. 

One of the serious issues facing  countries introducing tolling systems for the first time 
is how to provide for those users who do not have an acceptable EFC payment method. 
Most countries consider that users have a right to pay by cash, and experience  suggests 
that  users  may  sometimes  choose  to  use  this  method  even  when  equipped  to  pay 
electronically. 

49.  Where  tolling  is being  introduced  for  a  specific  market  sector,  such  as  heavy  goods 
vehicles  (HGVs),  different  issues  arise. 
It  is  feasible  and  simple  to  make  EFC 
equipment  mandatory  for  HGVs,  as  they  are  subject  to  regulation  and  inspection. 
HGVs  are  already  required  to  be  equipped  with  a  tachograph  and  EU  legislation  is 
being  drafted  for  specifying  future  digital distance recording  equipment.  In this case, 
as the vehicles to be tolled  represent  a  small proportion  of the total  traffic,  it  follows 
that  most  users  of  tolled  motorways  will  remain  out  of  the process,  and  will  not  be 
required  to fit on-board  equipment. 
. It  may  also  determine  the type  of EFC  system 
used. 

50. 

Finally,  it  is  important,  especially  from  the  enforcement  point  of  view  that  EFC 
systems should be able to distinguish between non-equipped users who are required to 
pay and those who are exempt (see below).  A possibility is that a Member State could 
require  all  vehicles  be  fitted  with  on-board  equipment.  Exempt  Users would  fit  on 
board  equipment  that  communicated  their  exempt  status.  Non-equipped  users  would 
then be violators. 

51. 

Recommended approach. 

There should be  no direct  or  indirect  discrimination between users on  the  basis  of 
their country of origin.  Within the overall constraints emanating from EU legislation, 
each country should be free  to implement its own choice of options for  the treatment of 
non-equipped  users,  according  to  its  particular  circumstances, including  the  road 
network and traffic characteristics. 

The basis for fee  charging should be the same for  all users, although discounts can be 
given for  options that reduce operators ' costs. 

Information on the payment  options available  to non equipped users must be  readily 
available, e.g. via standardised signs before entering the tolling area, and also by way 
of telephone enquiry services. 

The time required for  arranging the use of a non-equipped option for payment should 
not be excessive in comparison with the journey time. 

4.2 

Classification  issues 

52. 

53. 

EFC  systems  need  to classify  vehicles  in  order  to  apply  the  appropriate  tariff  for  the 
use of the tolled road.  Most current road tolling systems use automatic equipment  for 
classifying  vehicles.  Current  classification  systems  installed  in  mono-lane  EFC 
systems  are  accurate  and  reliable.  They  measure  the  physical  characteristics  of 
vehicles, such as the number of axles and height and length of the vehicle, from which 
the  operator  determines  the  class  and  thus  the  tariff.  Classification  systems  being 
developed  for  the  measurement  of  characteristics  for  multi-lane  operation  perform 
poorly so far. 

Classification  systems  based  on  measured  characteristics  can  provide  only  a  limited 
range  of parameters,  such  as  length, height  and  width, which  do not  fully  satisfy  the 
emerging  needs  for  defining  classes.  To  resolve  this  issue,  the  use  of  declared 
characteristics,  which  would  be  stored  within  the  on-board  equipment,  is  being 
investigated.  In addition to physical characteristics, it would be possible to store other 
parameters  like  emission,  suspension  or  load  characteristics  which  are  much  more 
difficult  or even impossible  to measure directly, but which may  assume much  greater 
importance in the future. 

54. 

At present, the classes to be used for tariffing  are the sole concern of each operator and 
are  not  required  to  be  interoperable.  Agreements  on  interoperability  will  need  to 
include  a  common  set  of  declared  characteristics  to  be  stored  in  the  on-board 
equipment. 

Agreement is currently being reached through the standardisation process on the set of 
characteristics  that  may  be  required  for  interoperable  systems,  as  part  of  the  CEN 
proposal for a standard Application Interface  Definition. 

55. 

Recommended approach. 

Classification  systems  based purely  on  vehicle  length,  width  and  height might not 
adequately satisfy the requirements of all countries, nor the likely future requirements 
of  an  EU  efficient charging policy.  As  a  consequence, a  common set  of  declared 
classification  parameters  needs  to  be  agreed  during  the  negotiation  between 
operators.  This should be included in the MoU between them. 

EFC systems for  interoperable use in multi-lane environments  need to be capable  of 
storing  and processing  claimed  characteristics  without affecting the functionality  of 
systems using measured characteristics. 

10 

56. 

57. 

58. 

59. 

60. 

CEN  should  draw  up  a  standard  on  classification  parameters  able  to  fulfil  the 
requirements of the operators. 

4.3 

Enforcement  issues 

Enforcement  forms an integral part of any tolling system.  Failure to enforce payment 
results  in  loss  of  credibility  of  the  systems  and non-attainment  of  the  objectives  of 
revenue collection or traffic management.  There are two main issues here: 

Firstly, the technical performance  of enforcement  in DSRC  systems  that offer mono-
lane  operation  is  generally  acceptable  whereas  multi-lane  operation  is  still  not 
adequate.  These  systems  are  required  to  produce  proof  of  passage  and  of  the  fee 
payable  under  all  traffic  and  environmental  conditions.  The  task  of  detecting, 
classifying  and  registering  vehicles  travelling  in  free  traffic  conditions  present"  a 
complex  technical  challenge.  Enforcement  may  be  separated  from  charging, 
depending  on  privacy  requirements  and  overall  system  architecture.  Possible 
enforcement procedures include the use of data bases.  In the event of failure of the toll 
transaction,  it must be possible to identify  a vehicle  as  a result  of photographing  the 
physical number plate or electronically by reading an electronic number plate. 

A related issue is that roadside systems will register the passage of any vehicle that has 
been identified  as not paying.  Many users will not be obliged to pay and these users 
must  not  be  enforced.  EFC  systems  must  therefore  have  the  ability  to  distinguish 
between  non-obliged  users  and  obliged  users  who  have  not  paid,  in  order' to  avoid 
unjustified enforcement.  Any of these users may be either equipped or non-equipped. 

The  second  major  issue  is  that  cross  border  prosecution  of  offenders  will  only  be 
possible  through  international  (general  or  bilateral)  agreements  that  are  not  yet  in 
place.  An example for a bilateral agreement is arrangements between the Netherlands, 
Belgium  and Germany  on exchanges  of  data on  drivers  involved  in  traffic  offences. 
Agreements are needed on mutual recognition of proof of payment and fee payable, on 
the exchange of information and on the administrative processes.  The balance of costs 
incurred in carrying out these administrative processes  in relation to the revenue that 
may  be  recovered  is  also  likely  to  be  an  issue.  If  random  checks  are  used,  the 
probability of being checked must be the same for all users and must be high enough 
to act as a sufficient  deterrent to non-payers. 

Systems  that  use  satellite  location  and  mobile  telephone  technology  to  collect  tolls 
have  special  enforcement  requirements.  Whereas  in  DSRC  systems  the  technical 
process  of  detection  of  non-payment  occurs  at  the  same  time  as  the  toll  collection 
process and is an integral part of the transaction, this is not possible when the vehicle 
position  is  determined by its own on-board equipment  and payment  involves  mobile 
In  systems  of  this  type  a  separate  enforcement  system  is 
telephone  technology. 
needed. 

11 

61. 

Recommended approach. 

A  general  framework  at  EU  level  for  the facilitation  of  the prosecution  of  EFC 
the  Commission, 
violations  across  national  borders  should  be  explored  by 
complementary to or as a basis for  bilateral agreements. 

National  authorities should be  encouraged to  establish further  links between  tolling 
enforcement agencies  and  national  registration data  bases  to facilitate  enforcement 
across borders and of violators from other Member States. 

Toll  operators  and  enforcement agencies  should  be  encouraged to  adopt  common 
procedures  for  the  exchange  of  evidence  of  violations  and  of  data  relating  to 
enforcement.  Evidence  exchanged  should  comply  with  the  regulations  and  the 
requirements on privacy  (see §4.5). 

The electronic legibility  of licence plates  should be improved.  Research on this could 
be part  of the 5tn  Framework RTD Programme. 

Toll system purchasers, and prospective purchasers, should be encouraged to  promote 
further  research, development and testing of tolling systems, with particular  attention 
to  the  enforcement subsystems for  multi-lane tolling.  This should draw  on  relevant 
work within the EU RTD programmes. 

4.4 

Issues concerning data protection and system security 

62. 

63. 

As  users  are  offered  the  possibility  of  travelling  across  Europe  using  interoperable 
payment  methods  and  on-board  equipment,  the  risk  of  fraud  inevitably  increases. 
Users will  enjoy  the benefits  of unhindered  travel on longer journeys through  various 
concession  areas but  this, in itself, provides  greater opportunities  for  organised  fraud. 
The security mechanisms designed to protect operators and regular car users in a local 
area may not be appropriate for Trans-European  traffic. 

Fundamental  work  within  MOVE-it13,  CARDME  and  Working  Group  1  of  CEN 
Technical  Committee  27814  has  been  developing  the  security  framework  required  to 
support  these interoperable  systems.  Issues such as the acceptability  of  arrangements 
on  protection  of  data  from  other  Member  States, liability  in  case  of  failure,  disputes 
and burden  of proof, and the certification  of equipment, need to be taken into  account 
in  framing  contractual  agreements.  It  is  important  that  effort  is  focused  on  defining 
and reaching  agreement  on approaches to the common data protection  domain  and  on 
migration paths.  Those paths could lead to general agreement on the need to mimmise 
the  risk  of  non  interoperability  from  different  security  requirements  of  individual 
operators.  Any  decisions  on  the  privacy  and  security  aspects  of  interoperable  EFC 
systems will need to be in line with general principles of IT (Information  Technology) 

13 EU RTD project, acronym stands for Motorway Operators Validate EFC for interoperable transport 
14 Technical Committee on Road Transport and Traffic Telematics 

12 

data security and personal privacy as well  as national legislation and the EU Directive 
on Data Protection15. 

64. 

Recommended approach. 

The presumption should be that the general rules on data security and protection  will 
apply, and will be sufficient unless there is a convincing case otherwise. 

National  authorities and toll  operators  should however be encouraged to  consider if 
any  additional  measures  are  needed.  Provisions for  liability,  insurance and  risk 
acceptance  resulting from  failure  in  data  protection  should  be  integrated  in  the 
contracts between parties. 

In-depth studies must be encouraged about the legal and practical  implications for  the 
protection  of privacy,  and  about  data  which  may  arise from  the  use  of Telematics 
applications in EFC systems. 

4.5 

Privacy issues 

65. 

66. 

67. 

There  is  a  general  presumption  that  the  privacy  of  users  will  be  preserved  by  toll 
systems.  General privacy requirements are included in existing national and European 
legislation but the particular requirements of users in relation to ËFC systems  are not 
yet  subject to specific  legislation and are still  open to debate.  It may be very  costly, 
even if it is possible, to meet all the privacy requirements of all the Member States. 

For example, deferred payment has been suggested as a way of handling non-equipped 
users  in multi-lane  tolling  systems.  Users  would be  permitted to pay  tolls  within  a 
limited time such as 24 hours before  or after using  the motorway.  This would mean 
that the  operator would  need to  store the identity  of users who have not paid by the 
time of leaving the motorway for this period of time before either confirming payment 
or triggering the enforcement process.  The legality of such a scheme has not yet been 
tested in the courts, but there is  evidence from other applications  and other  locations 
that the principle of such a procedure is feasible. 

Some users may desire an anonymous method of payment.  This means that, not only 
is  the  user  identity  not  revealed  to  a third party,  but  also  the  operator  is  unable  to 
identify  the  user  except  as part  of  the  process  of  enforcement  of  non-paying  users. 
Cash  payment  currently  ensures  anonymity.  Electronic  money  will  soon  become 
available  and  could  offer  similar  anonymity  if  accepted  by  operators  as  a  payment 
means.  The  issuers  of  general  purpose  electronic  money  would  have  to  be  the 
financial institutions  but  many  operators  are  reluctant  to  accept  the  involvement  of 
financial institutions,  as  the  issuer  handles  very  large  amounts  of  money  which  are 
critical to the business of the operator.  A possible compromise acceptable to operators 
but  less  convenient  for  users  would  be  the  use  of  sector  specific  electronic  money 
which could only be used to pay for services provided by toll operators and for which 

15 EU Directive on the protection of individuals in regard to the processing  of personal data of 23.11.1995 OJ L 

281 

13 

they themselves could be the issuers.  Participation of consumer interest groups could 
help in the search for an appropriate solution and ensure its general acceptance. 

68. 

Recommended approach. 

The  Commission will  examine the  EC  Directive16  on privacy  to  check  whether  it 
adequately  covers the privacy  aspects  ofEFC  systems or whether specific legislation 
is required.  In depth studies of the legal and practical  implications for  the protection 
of privacy,  which may arise from  the use ofEFC, should also be encouraged. 

5. 

PREREQUISITES FOR CONVERGENCE 

69.  Given the present differences  in systems technologies, levels of deployment  and pilot 
to  pan-European 
schemes  throughout  the  EU,  a  strategy  for  convergence 
interoperability must envisage  several  stages of migration from the present position : 
EFC  systems  are deployed  on  a  large  or  a  small  scale  in  some  countries,  while  no 
systems  are  deployed  in  other  countries  and  several  countries  have  experimental 
systems  or  actively  plan  systems.  The  existence  of  these  different  stages  of 
development  means  that  migration  options  must  enable  an  appropriate  level  of 
interoperability.  This level will be reached through successive changes to equipment 
and  to  procedural  and  contractual  agreements  leading  to  interoperability  with 
increasing  functionality  and covering  a widening  geographical  area at minimum  cost 
to operators and users.  A first step will be the completion of work  within EU-funded 
projects, which should enable the existing  CEN pre-standard on the DSRC link to be 
converted into a full standard.. 

70. 

71. 

72. 

From  a theoretical point  of  view  there  is  something  to be  said  for  defining  a target 
system  for the  future  and then converging  as economically  as possible  to  this target 
system.  In the long term this may be possible, but, in the short term, the expectation is 
that  each  country  will  have  its  own  national  system  with  sufficient  common 
functionality  to enable drivers to pay tolls  electronically  in  at least  several  countries 
without needing to change equipment. 

Countries  that  have  existing  tolled  motorways,  whether  with  manual  or  automatic 
payment, have built toll plazas with many lanes.  Normally  only one or two  lanes at 
each plaza are equipped  for automatic  toll  collection.  Technical  interoperability  of a 
sort may be possible by installing another system in one of the existing lanes if the two 
systems are compatible and do not cause mutual interference. 

The situation in countries that do not have existing toll plazas is quite different.  The 
absence of toll plazas means that in most cases multi-lane operation will be  essential 
and  the  problem  becomes  one  of  ensuring  interoperability  with  the  single  lane  On-
Board  Equipment  in  use  in  other  countries.  The  technical  problems  may  not  be 
insuperable  but the operational  problems  of providing  anonymity when required and 
avoiding financial loss by fraud are at least as difficult as for the existing systems. 

16  EU Directive  on the protection  of individuals  with regard  to the processing  of personal data OJ L 281 of 

23.11.1995 

14 

73.  Anonymity is most easily achieved by cash payment as in existing systems and, if this 
solution  is  advocated  for  new  multi-lane  systems,  a  means  of  cash  payment  for 
motorways without toll plazas must be devised.  The distinction between anonymity 
when the movements of a vehicle are not known to anyone but the driver, and privacy 
when  the  vehicle  movements  are known  to  the  system  operator  but  can  be  legally 
protected, is important. 

74. 

75. 

The avoidance of fraud presents  escalating problems  as the number of users  and the 
number of interconnected operators offering  interoperability increases.  For this reason 
it could be efficient  to set up a step by step interoperable operation starting with some 
groups of operators and issuers in a limited area. 

In  developing  strategies  for  convergence  it  will  be  necessary  to  adopt  a  phased 
approach.  It is recommended that in the first phase, we concentrate on interoperability 
for heavy goods vehicles and long distance coaches, for which the equipment may be 
less  price  sensitive  than  for  private  users  and  for  which  issues  of  privacy  and 
enforcement  may  be  easier  to  solve.  Another  is  concerned  with  the  minimum 
functionality  concept  recognising  that  the  majority  of  private  vehicle  owners  will 
rarely travel outside their own country.  The project  CES ARE and the Euro-regional 
projects  like VIKING and CENTRICO will help to define  this strategy.  CARD-ME 
will be the forum for co-ordination between them on this issue. 

6. 

CONCLUSIONS 

76. 

EFC  systems  provide  a flexible  tool  to  implement  EU, national,  regional  and local 
policies for charging road vehicles for the use of infrastructure,  either for recovery of 
costs, or for traffic  management purposes. The Council has agreed that an appropriate 
level of interoperability between EFC systems must be achieved, and has called on the 
Commission  and Member States to accelerate work to identify  and remove obstacles 
to  interoperability  of  EFC  systems.  It  has  also  called  on  Member  States  when 
replacing,  upgrading  or  introducing  EFC  systems,  to  do  so  in  accordance  with  the 
strategy for convergence.17 This will require a phased approach. This Communication 
sets out the first phase of such a convergence strategy. 

77.  Main  actions  in the first phase (1998 to 2000) will be based  on the  following  key 

assumptions: 

i. priority will be given to interoperability of EFC systems for HGVs and long-distance 
coaches used on the Trans-European Road Network (TERN). This will need to provide 
the  means  to  implement  decisions  on  EU wide  charging  policies.  The  Commission's 
White  Paper  proposed  application  to  commercial  operators  of  greater  cost-related 
charging, differentiating by time, vehicle characteristics, route and so on, by 2004. 

ii.  interoperability  between urban  and  inter-urban  applications  also  needs to be given 
priority in the development  and implementation of EFC systems 

17 Present plans in some Member States for replacing, upgrading or introducing EFC systems already go in this 

direction 

15 

iii.  an  open-system  architecture  will  be  necessary,  capable  of  responding  to  policies 
developed at EU or national levels, of integrating further  operational and technological 
developments,  and  enabling  commercial  opportunities.  Such  an  architecture  would 
require consideration of dual or multi-mode equipment which would  permit the use not 
only of  DSRC technology but also of GNSS-based systems or other technology, where 
appropriate,  in response  to policy need  or  operational  convenience.  The  architecture 
should  also  allow  the  potential  exploitation  of  EFC-based  technologies  for  traffic 
management and value-added services. 

Achieving these objectives will require action by the Commission, the Member States, 
local and regional authorities, concessionaires and by the standards bodies. 

These actions will be : 

a) 

b) 

c) 

d) 

e) 

to define and agree a common minimum level of functionality  at the EU level 
(ie the basic features needed in order to achieve interoperability, e.g. capacity to 
distinguish types of vehicle, methods and arrangements to effect payments etc) , 
reflecting policy and operational requirements.  This will be based on work done 
within  EU-sponsored  projects  under  the  4th  Framework  R&D  Programme 
particularly  on  Transport  Telematics  Applications  and  of  the  Trans-European 
Network -  Transport Programme.  Any additional actions will be undertaken in 
the 5th Framework Programme. 

to enable these common functions to be performed,  CEN (Comité Européen de 
Normalisation)  should complete its work on EFC on the basis of Mandate 270 
from the European Commission, developing, validating and adopting  standards 
on  DSRC  and  other  areas, where  appropriate.  These  standards  should  enable 
multilane operation and the introduction of  traffic management arid other value-
added services,  using the same technology. 

The  Commission  will  help  all  interested  parties  to  complete  the  work  on 
contractual interoperability by promoting the signature of a Memorandum of 
Understanding between them, based on an EU framework agreement. 

The Commission will explore ways to facilitate cross-border enforcement  and to 
adequately cover privacy and data-protection issues. 

The Commission will co-operate with cross-national groups of urban or regional 
authorities  considering  the  introduction  of  road  pricing,  so  as  to  offer  a  co 
ordinated  approach  between  local  systems  and  between  them  and  inter-urban 
services. 

78. 

The  Commission  will  produce  detailed  proposals  based  on  this  approach  and  the 
results of the work currently underway at EU, national and regional levels.  It will then 
put  forward  proposals  for  actions  in  subsequent  phases  on  the  basis  of  the  results 
obtained in the first phase. 

79, 

In the meantime it recommends that decisions by national or local administrations or 
private concessionaires on EFC systems should be based on this Communication. 

16 

80 

Failure to achieve interoperable EFC systems will cause disbenefits  for the European 
citizens, especially long distance drivers who will be confronted with artificial borders 
between the different  Member States, obliging them to use different  cards or onboard 
units, or to stop and pay cash at toll booths. European industry will loose a competitive 
advantage on the world market, due to the proliferation of proprietary systems, and the 
resulting  absence  of  economies  of  scales.  Finally,  road  operators  will  also  suffer 
because of increased equipment costs and restriction on their freedom of choice. 

81 

The Commission  therefore,asks  the  Council  and the Parliament  to  endorse this first 
stage in  a convergence  strategy  for  EFC systems in Europe and the assumptions  on 
which it is based. 

17 

ISSN 0254-1475 

COM(98) 795  final 

DOCUMENTS 

EN 

10  09  02  06 

Catalogue  number  :  CB-CO-98-795-EN-C 

Office  for Official  Publications'of the European  Communities 

L-2985  Luxembourg 

it