EPTO Position on the Urban Mobility Package consultation.
23 September 2021
Evaluation of the 2013 Urban Mobility Package (UMP) shows that, despite some progress, congestion, poor air quality, CO2 emissions and road accidents persist.
Europe is facing additional challenges, such as poor connectivity of suburban and rural areas, the acceleration of the climate crisis, increasing congestion, the emergence of new mobility services enabled by technology and digitalisation, and the ongoing impact of Covid 19 with its anticipated changes in work, lifestyle and personal travel patterns.
EPTO strongly believes that the changes brought about by EU policy on urban mobility to date are insufficient (as demonstrated by the evaluation of the UMP and the recent Court of Auditors’ report[1] on Sustainable Urban Mobility in the EU). In addition, the acceleration of the climate crisis and the need to decarbonise the transport sector require a greater focus on public transport and active mobility to achieve the maximum efficiency of investment. Tackling the environmental challenge must be strongly linked with delivering important societal goals of affordability, accessibility, and availability of mobility. Therefore, public transport and active mobility must have a greater prominence in the revised UMP.
The proposed revision of several pieces of EU legislation in 2021 will have an impact on urban mobility, including the replacement of Directive 2014/94/EU by the Alternative Fuels Infrastructure Regulation, Directive 2010/40/EU on intelligent transport systems, and the Regulation on guidelines for the development of the trans-European transport network (TEN-T). It is critical that these revisions facilitate and deliver modal shift through strengthened public transport and active mobility. We make reference to these in our comments on the UMP below as they are intrinsically linked and cannot be considered in isolation.
The revised UMP must support these pieces of legislation and set bold standards. Strong recommendations and guidance need to be provided, outlining best practice for improved sustainable urban mobility and providing a mechanism to learn from and share experience between member states and communities.
To contribute to these objectives, the revised Urban Mobility Package should:
1. Ensure that all large and medium-sized cities put in place Sustainable Urban Mobility Plans (SUMPs) by 2025
The Commission’s Sustainable and Smart Mobility Strategy refers to “100 climate neutral cities by 2030”, each of which should be required to prepare a Sustainable Urban Mobility Plan (SUMP). Indeed several hundred major urban areas across Europe have already prepared such plans. Our concern is that many of these plans are either unambitious, not being followed up by implementation, or both. Linking delivery of actions and outcomes defined in SUMPs to access to additional sources of funding to support additional public transport improvement would be a major step forward in ensuring their efficacy. Having prepared a SUMP, a town or city must also be required to report on its effectiveness, acting as a showcase to demonstrate their transformation towards climate neutrality. By 2025 we would expect every urban area with a population over 100,000 to have prepared a SUMP for implementation.
2. Ensure that SUMPs make public transport the backbone of urban mobility strategies
Without shifting people from car-centric mobility to shared, sustainable and mass transport, Europe will not achieve its environmental targets. Public transport networks have a key role to play in decarbonising urban transport overall, in improving air quality, and in connecting rural areas to cities, but their effectiveness and attractiveness is often adversely affected by congestion.
Furthermore, this congestion requires the use of more vehicles and staff to deliver a punctual service than would otherwise be needed. This increases operating costs significantly, leading to public transport services becoming more expensive for users, for transport authorities and ultimately the passenger or the taxpayer. It also results in longer and more variable journey times making it less attractive to passengers, and makes the case for investment in new, cleaner vehicles much harder to develop.
SUMPs should ensure that public transport is at the core of their plan and create transport networks which allow public transport to realise its full benefits and be an attractive alternative to the private car.
3. Strengthen public transport and active mobility by supporting the redesign of transport networks and reallocation of road space through dedicated EU funding
Public transport and active mobility modes, such as walking and cycling, should be strengthened by redesigning transport networks and reallocating road space, moving away from car-centric urban environments. This can be done by facilitating the creation of pedestrianised areas, cycle lanes, bus rapid transit lanes, bus lanes, bus only streets, intelligent signalling and transport systems etc. EU funding should support such initiatives and be available to local authorities who develop and implement SUMPs.
4. Encourage member states, regions and cities to build multimodal mobility hubs to improve connectivity and facilitate multi-modal passenger journeys
Multimodal mobility hubs should become a priority to facilitate easier connectivity between modes, linking active mobility with multi-modal public transport services and connecting citizens with suburban and regional public transport networks. These must be located where people want to travel – centres of retail, business and leisure, and at strategic locations where longer distance car users can leave their cars and continue by public transport (park & ride). Alternative fuel facilities for public transport should be provided at these locations and this requirement should be set out in the forthcoming Alternative Fuels Infrastructure Regulation. The Commission should instigate the development of guidance and recommendations, and shared best practice, on the design and location of these hubs, and develop a framework for regions to share their experience and learn from each other.
5. Introduce a blueprint for open data protocols and portals, facilitating innovation in mobility
Information on the availability of, and access to, public transport should be mandated as part of SUMPs. European frameworks should be developed to facilitate the provision and exchange of data on multimodal and shared transport (e.g. bike sharing), using existing data standards and protocols such as TransXChange, supported by the implementation of open data portals managed by transport authorities. This will make public transport easier to use, and will enable the emergence of third-party data platforms and services, including Mobility as a Service, thereby facilitating modal shift on the basis of better public information. Financial instruments should be focussed to support the development of digitalisation of the urban mobility sector and foster innovation, including MaaS applications and improved accurate and comprehensive journey planning information which can better connect active travel to public transport for “first and last mile” access.
6. Create opportunities for EU member states, regions, cities and transport operators to access EU funding to decarbonise and foster innovation
Public transport operators and authorities are facing significant cost pressures in the emergence from Covid 19 which are making investment in fleet replacement more challenging. The impacts of traffic congestion, reduced patronage, potential need for larger fleets to deal with the reduced range of electric vehicles and the cost premia associated with “green” power are making the economic case for decarbonisation much harder. EU funding should support cities in their delivery of their SUMPs through opening up access to new sources of funding. Deployment of alternative fuels infrastructure for public transport should be included in the new Alternative Fuels Infrastructure Regulation. Support will also be required for operators in their efforts to decarbonise their fleets, with capital grants for vehicles and to support operating costs where any duty reductions for fossil fuels are foregone through decarbonisation. Combining these measures will accelerate the decarbonisation of public transport fleets, and enable larger fleets to be deployed, facilitating the expansion of networks and services to further increase public transport usage.
In the development of SUMPs, authorities should be encouraged to identify future opportunities to review and reform fuel taxation to help address the decarbonisation issues and maximise the benefits of investment in public transport as the most efficient mover of people, rather than vehicles.
7. Recommend the adoption of mode-differentiated road pricing strategies by local, regional and national governments
Member states should develop road pricing strategies to encourage citizens to switch to sustainable modes of transport, taking account of the external and true internal costs of their journeys. They should be encouraged to apply the “user and polluter pays principle”, using the behaviour change principles “educate, inform, incentivise” to encouraging widespread acceptance and adoption. Revenue generated should be reinvested in the expansion and accelerated decarbonisation of transport networks, leading to more and improved mobility services for citizens.
8. Introduce a mandatory reporting requirement where cities develop SUMPs to ensure they are implemented and to provide a library of best practice examples for others to follow
Whilst SUMPs must not become a rigid definition of the urban planning paradigm, they cannot simply become unrealised ambitions. Not only must they be implemented by authorities that adopt them, but a requirement to report on progress, outcomes and challenges is also needed. Collating these reports will create an overview of best practice and provide useful examples for other cities to follow, encouraging more cities to develop their own SUMPs. The Commission should seek to establish a central repository of best practice on SUMPs for other authorities to access guidance and inspiration.
SUMPs should be required to include ongoing reporting of key indicators including modal shares of travel and journey times by mode to facilitate the identification of areas to be improved. Additional EU funding should be made available to cities introducing SUMPs, creating direct accountability and facilitating a successful implementation, stimulating a virtuous cycle of improvement.
9. Require development control to have public transport access as its focus, and recommend that land value is captured by local authorities to strengthen public transport networks
The move from a car centric “predict and provide” development framework to one which adopts a principle of “decide and provide” should be a key element of SUMPs in order to ensure the long term economic and environmental sustainability of urban areas. Looking to a longer impact horizon in the assessment of the transport requirements and implications of new development will help ensure that public transport is not only a means of access to new developments, but that it is the mode of choice, helping to reduce the demand for car use on urban networks. Developments should be required to incorporate appropriate public transport and active travel information and infrastructure as a pre-requisite for their approval.
Whilst well-developed and reliable public transport networks attract users and contribute to reducing emissions and congestion in urban environments, developing and modernising transport networks is costly. The Urban Mobility Package should therefore encourage public authorities to capture the land value following public transport infrastructure developments. This income can then be re-invested in the further development of public transport networks and repay part of the cost of the transport infrastructure.
Land Value Capture (LVC) is more than just a funding method. It can also offer a framework to integrate transport and land use, with a need to rethink how we plan and deliver transport infrastructure and services in relation to our cities. The UMP should therefore provide guidance and share best practice seen across Europe.
10. Recommend the use of innovative technology for public transport to harness its benefits
Technological advances in traffic management including traffic signalling, variable route/message signing and display of modal journey times to key destinations should all be used to improve the efficiency and attractiveness of public transport. Modern ticketing technology including contactless payment, capping and mobile ticketing will both make the journey experience easier for the passenger and reduce stop dwell times, improving operational efficiency and delivering quicker journeys.
[1] Court of Auditors, Special report: Sustainable Urban Mobility in the EU, June 2020