The EC is exploring a new initiative dealing with “multimodal digital mobility services”. Delegated Regulation (EC) 2017/1926 already covers multimodal travel information services; payment and booking will be covered by this new initiative. EPF’s feedback to the Inception Impact Assessment roadmap (submitted on 2. November) is available here. EPF welcomes the EC’s proposal for a Regulation on Multimodal Digital Mobility Services. Without EU action we expect further delay in the provision of multimodal information and ticketing which is crucial to enable a modal shift.

Today, planning, booking and executing multimodal journeys is risky, difficult and time-consuming. Some advanced multimodal door-to-door journey planning applications exist, but are mostly limited in scope (in terms of geographic coverage, modes and operators) and/or do not offer any booking & ticketing facilities. Passengers need a neutral, comprehensive and reliable overview of available travel options to make an informed choice. Buying multimodal tickets should be easy, affordable and offer protection in case something goes wrong.

Access to data is an essential enabler. The MMTIS Regulation currently foresees mandatory sharing of static data by TSPs. Passengers also need real-time information about disruptions and the effect this will have on the rest of their trip: either by the operator they are travelling with and/or by the ticket vendor. TSPs make use of public infrastructure and (directly or indirectly) receive public funding; hence, real-time data on their services should be publicly available. Also, information on fares (including advantageous tariffs) is required to enable multimodal booking and ticketing.

In the air sector, the CRS Code of Conduct has played a vital role in ensuring consumer access to unbiased information on available flights and fares, so as to enable passengers to make meaningful comparisons between the offers of competing providers. The CoC was introduced to ensure that airlines did not promote their own services over those of competitors. Similar concerns need to be addressed for land (and water) based travel. The principles underlying the CoC – transparency, fair competition, neutral display – are also relevant for other distribution channels and modes. The CoC can serve as a model for Multimodal Digital Mobility Services.

New business models are needed that strike a balance between the interests of passengers, transport service operators and distributors / aggregators and, from the consumer side, guarantee data portability. Ownership and governance of data is a crucial topic to be addressed for all involved parties (including operators, ticket vendors, infrastructure managers, authorities, … and end-users). We need an open, multi-player distribution market, based on interoperability, non-exclusive partnerships between transport service providers and aggregators / MaaS providers. Competition both between TSPs and between distributors would eventually lead to a better offer to end-users.

Liability vis-à-vis end-users is an important issue. EU passenger rights do not address disruptions in a multimodal context and don’t cover urban and local transport. In the absence of through tickets, there is no guaranteed arrival at the final destination. A missed connection may leave passengers stranded and forced to buy new tickets. Adequate protection is needed for passengers using combinations of different transport modes.

Information on environmental impact should be provided as one of the (default) criteria for ranking travel options. To note that, without a level playing field between modes in terms of end-user cost, it will be very difficult to realise effectively a modal shift. Taxation and subsidies are policy tools that can make sustainable modes (and multimodal travel) more attractive. Market regulations could be considered as to the complementarity of travel services and modes at various territorial levels (with a hierarchy of modes depending on their capacity and economic, social and environmental efficiency, especially in cities).

EPF is ready to participate in the planned MDMS stakeholder consultation activities to give further input from the passengers’ perspective.