EPTO position on multimodal digital mobility services
22 February 2022
EPTO welcomes the Commission’s initiative to understand how stakeholders are using multimodal digital mobility services (MDMS) and what challenges and barriers they identify.
EPTO supports EU action in the field of MDMS to guide the development of digital mobility services in Europe. In line with the EU’s climate ambitions, it is essential that these new services contribute to the decarbonisation of transport as well as fight against urban pollution and congestion, helping to make public transport and active mobility the best choice for citizens.
EPTO strongly believes that MDMS must promote alternatives to individual car use by targeting everyday (local) mobility demand, which accounts for 95% of all journeys across Europe, and those who live on the outskirts of conurbations and are most dependent on private cars. However, these challenges cannot be met without public transport authorities (PTAs) which are responsible for coordinating public policies at local level and for commissioning public transport services within the legal framework of the PSO Regulation. The MDMS measures must be proportionately targeted by sector – local, regional, national or international travel, ensuring that any costs will be overcome by additional trips generating extra revenue, rather than having to pass these costs to existing passengers through fares.
EPTO therefore calls on the Commission to:
1. Respect the differences between long-distance and/or cross-border transport services and regional, suburban and urban public transport services
2. Recognise that MDMS must be developed in line with local, regional and national sustainable mobility goals
3. Create a regulatory framework that is flexible and allows for adaptation as MDMS is developed and deployed further
Creating a framework to support the development of MDMS across Europe
Generally, EPTO believes that opening up and making appropriate data available for re-use can be beneficial in leading to the development of (sustainable) mobility solutions. It can further support traditional public transport companies and PTAs in improving existing mobility service offers and transport networks. It also benefits the passenger by making it easy to plan, and pay for, routes using different modes.
However, any MDSM regulation must introduce a balanced framework for the development of MDMS across Europe, following some principles:
1. Respecting local mobility priorities: the Commission must recognise that MDSM must be developed in line with sustainable mobility goals (local, regional or national) and ensure that the development of MDMS does not hamper a PTA’s ability to set its own mobility priorities.
2. Ensuring fair and equal access to data: the Commission should ensure that transport data is collected and managed by a neutral, third party, such as a regulator, local, regional or national government body. This body should ensure that comprehensive datasets for a given territory with all mobility services are available and accessible to all interested parties.
3. Enabling complete mobility offers: any forthcoming regulation must ensure that MDMS platforms integrate all mobility services provided within their chosen category of mobility services and make them visible to users in a fair and non-discriminatory way. Consumers of MDMS data must be required to apply appropriate diligence to ensure that the information they make available to the public is non-discriminatory, accurate and up to date at all times.
4. Non-discriminatory ranking of travel solutions: selection criteria for a preferred option must be applied in a non-discriminatory manner to all services offered for sale by the MDMS. Services should take into account the characteristics of the travel solution, such as the price, journey time, and an indicator of environmental impact, and not any other element linked to any commercial agreement between the MDMS and the mobility service provider.
5. Ensuring appropriate liability measures: where the MDMS regulation applies to local and regional transport, the Commission must ensure that liability towards the passenger (e.g. in case of disruption) is appropriate. Mobility service operators must not be held liable for disruption on an urban/suburban journey to the same extent as an operator of long-distance rail or bus services would be, for example under any Passenger Rights legislation. The MDMS provider must also reflect the liabilities of the operator of any part of such a journey. Frameworks should make it clear that those operating shorter local legs are not statutorily responsible for compensating passengers in such manner.
6. Protecting business sensitive data: the Commission must ensure that appropriate mobility data is collected and avoid any requirement for the supply of commercially sensitive information. Clarity on which datasets may and may not be requested must be ensured. The Commission should consult with stakeholders across the sector (Private operators, public operators, PTAs, new mobility providers, etc.) to define datasets to be included and excluded from the scope of any forthcoming regulation. Datasets could include static data (e.g. timetable and fares data) and real time data, where possible (e.g. approximate position/time of arrival of vehicle). There are already established examples of good practice for mandating the supply of “open data” from transport operators, such as those in England pertaining to operators of local bus services.
7. Facilitating multimodal ticketing: to create multimodal mobility service offers, ticketing systems must not artificially or discriminatorily prevent interested parties from selling combined transport services other than their own. Doing so would hamper multimodal journeys. The Commission must ensure that there is a fair and non-discriminatory approach to multimodal ticketing, on the basis of commercial agreements. EPTO welcomes measures that would facilitate multimodal ticketing as it would lead to easier journeys for passengers, making door-to-door journeys using sustainable modes of transport, such as public transport, a reality and easier to plan. However, it’s important to consider that there are costs associated with implementing new (digital) ticketing systems and their maintenance. The benefits they will yield may vary on the type of service (e.g. rural public transport services vs urban public transport services). EPTO would therefore welcome the introduction of appropriate funding mechanisms to support public transport operators in implementing new ticketing system, with the aim of making journeys easier for the passenger.
8. Fair and transparent access to data: data held by any MDMS provider should be available to all mobility players (including PTAs), provided that this does not adversely affect the legitimate commercial interests or confidentiality of any operator. Making such datasets available to both, (traditional) public transport operators and PTAs can help further improve and strengthen public transport network and develop truly sustainable transport options that reduce CO2 emissions per passenger-km, congestion and air and noise pollution in urban environments, supporting the delivery of modal shift away from private car use.
A flexible framework, respecting the specificities of urban, suburban and regional public transport
EPTO looks forward to seeing the outcome of the Commission’s impact assessment. EPTO would welcome EU action in the field of MDMS to make seamless, door-to-door journeys a reality for European citizens, something which is at the core of EPTO’s members values.
However, EPTO calls on the Commission to keep in mind that while MDMS would most certainly be useful for long distance trips, 95% of trips are made locally, with urban or inter-urban journeys. Any future requirements should therefore reflect the realities of local, suburban and regional transport and acknowledge the role local public transport operators and PTAs play. Any future measures must be appropriate and bear the specificities of local transport in mind and not attempt to introduce “one-size-fits-all” measures. Proportionality of the costs of implementation and maintenance need to be weighed against the likely delivery of benefits, in particular according to the scale and nature of the market (local regional, national, international). Appropriate funding opportunities should therefore be made available at EU, national and regional level to facilitate the creation of digital multimodal ticketing systems.
As the Commission progresses with the development of an MDMS framework, it should consider that any future regulatory framework must not be static but instead allow for adaptation as MDMS is developed further to reflect changes in a maturing market.
EPTO welcomes the opportunity to discuss its members’ views on the challenges and opportunities linked to MDMS and future regulation from the perspective of private public transport companies, operating both commercial services and public service obligations.