EPF has discussed its expectations towards the EU and the new Commission in the coming legislature. Passengers want a public transport system that is

• affordable,
• reliable,
• sustainable and
• coordinated

with sufficient capacity to get people comfortably to where they want to go at the times they wish to travel, using whichever combination of modes is most efficient overall, in social and environmental as well as economic terms. The European Union can help delivering this vision.

Goal: A seamless European passenger transport system.

Passenger transport providers can learn from advances in freight logistics which is pioneering synchro-mobility. This involves integrating the different transport modes and their under-pinning IT systems. Its purpose is to deliver a flexible, synchronised and efficient inter-modal network. Switches between modes during end-to-end journeys can be achieved almost seamlessly, facilitated by an integrated data framework and collaborative data analytics. It is a system in which a passenger is enabled to use each mode to do that for which it is the most efficient in achieving an affordable, reliable and sustainable end-to-end journey.


  • Interfaces: Common standards and standardised interfaces are vital to synchro-mobility. They facilitate interoperability, minimising eliminating operational delays between networks, operators, systems and modes, and creating economies of scale. The European Union has a key role to play is establishing these standards. The European Commission’s work on connected and automated mobility in has familiarised it with its principal technical and regulatory implications for the road sector. Consideration should now be given to providing an enabling regulatory framework for synchro-mobility across all modes.

Goal: Passengers should be able to make informed choices, both when planning and making their journeys.

Intending passengers need access to unbiased journey information before deciding to travel. Informed consumers are essential to any truly competitive market. Passengers also need timely and practical information should things go wrong during their journey. (Lack of useful information at times of disruption is the major source of passenger dissatisfaction.)


  • Transparency & non-discrimination: There may need to be regulation of those who accrete and then effectively control the supply of information to consumers or to third-party intermediaries such as ticketing retailers.
  • Information provision should be transparent, non-discriminatory, accurate, up-to-date and non-exclusive. (See, for example, Council Regulation 2299/89, replaced by Regulation 80/2009 on a Code of Conduct for Computerised Reservation Systems.) Regulation may also be needed to address privacy principles as well as security concerns arising from individuals’ data use and provision.
  • Consistent and effective regulatory enforcement: There appears to be considerable variances between the competence and capacity of National Enforcement Bodies. The European Union should consider what legislative measures might be necessary to ensure greater coherence and effective and consistent enforcement. The European Commission should also ensure that there is provision for Alternative Dispute Resolution across all modes, capable of dealing with disputes involving more than one mode and that suitable arrangements are in place for the oversight passengers’ rights in the case of a journey involving more than one mode.

Goal: Administrative and political boundaries should not be a barrier to the efficiency of Europe’s passenger transport system.

The European transport network should reflect the needs of potential passengers and of its ability to act as an instrument of economic development, social cohesion and the promotion of greater sustainability across frontiers.


  • Actions to promote cross-frontier links: Active support for cross-border transport initiatives, such as that pioneered by Aachener Verkehrsverbund GmbH (AVV). This requires engagement of local stakeholders, needs to reflect the input of passengers, and may benefit from European seed-corn funding.
  • Consistent regulatory principles: Prospective operators of new international rail services, in particular, claim that their aspirations are inhibited by the lack of a common regulatory approach between neighbouring countries, particularly in relation to incompatible train service planning cycles, track access policies etc. In the
    telecommunications sector the EU has created the Body of European Regulators for Electronic Communications (BEREC) to improve consistency of EU telecoms rules and to contribute to the development of the Single Market. The Agency for the Cooperation of Energy Regulators (ACER) is the analogous EU Agency for the natural gas and electricity market. It fosters cooperation among European energy regulators, ensures market integration and the harmonisation of regulatory frameworks within the framework of the EU’s energy policy objective. In the rail sector some – but by no means all – of the rail regulators meet in the IRG-Rail. This has the general objective of promoting a more competitive internal rail market, but it is not an EU Agency, has limited standing and no formal role in relation to the European corridors and other major EU initiatives affecting the rail sector. An opportunity to ensure consistent regulatory practice and shape the evolution of the Single European Railway Area and the work of the ERA is being missed.

Goal: More-informed decision making

Understanding costs is important to the successful realisation of synchro-mobility. It is a foundation for the level playing-field upon which fair competition and the optimisation of resources depends.


  • Internalisation of External Costs: EPF was impressed by the preliminary results of the study conducted in the context of the Commission’s Year of Multimodality, 2018, Sustainable Transport Infrastructure Charging and Internalisation of Transport Externalities. This estimated that the annual cost of transport externalities is about 1€ billion (of which road accounts for 75%, maritime 15%, air 7% and rail 3%). Internalisation of transport externalities must form a pillar of future Commission transport initiatives.
  • Polluter-pays principle: The surge of popular concern about climate change and, more particularly, the growing recognition of the scale and effects of particulate pollution on mortality and public health means that more sustainable forms of transport, such as land-based public transport will gain increased political momentum. This requires that it should have a more prominent place in European Union’s priorities and that greater effort should be directed at establishing which policy and investment measures would make it more attractive for passengers.
  • User charging: As a corollary to its support for a level playing-field to enable fair competition between transport modes, EPF considers that each transport users should meet the external cost of their journey and that there should be consistency as to the basis of charging across all modes, including environmental impact costs in the case of maritime and air transport. Any rebate then granted in pursuit of government policy grounds – for example, to secure social inclusion – should be identified transparently.

Goal: A greater focus on end-users

Public transport provision is inevitably characterised by market failure. Adam Smith’s ‘invisible hand’ where the marginal cost of an additional customer is effectively zero. The cost of running a coach, ferry, aeroplane of train is much the same whether it is full or carrying just one passenger. Policymakers therefore need a set of tools which can help make up for the deficiency of market information.


  • Passenger satisfaction surveys: We welcome DG MOVE’s increasing use of the Special Eurobarometer surveys of passenger satisfaction. Successive surveys – as with rail – are beginning to build a useful lateral body of understanding. Satisfaction surveys, comparable across all modes, could be commissioned usefully on an annual basis and used to inform the assessment of policy delivery.
  • End-user engagement: European acquis acknowledges that passengers are the weaker party to the transport contract. The Commission needs to make greater effort to connect with users’ representatives and, where-ever possible, to ensure that end-users’ representatives are encouraged to participate in policy development processes, as is currently the case with the Administrative Board of the ERA, the Commission’s Rail Security Platform and the Rail Market Monitoring working group, amongst a number of similar engagements. It needs to accept that, as largely voluntary organisations seeking to represent diffuse publics, the costs of representation at European level is a heavy burden, yet without effective representation there is a democratic deficit that needs to be addressed. The European Commission should make financial provision for this.