UITP - International Association of Public Transport

UITP

UITP represents over 450 public transport operators and authorities across the EU, advocating for sustainable urban mobility and public transport interests.

Lobbying Activity

Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

26 Jan 2026 · Performance Regulation

Meeting with Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto)

3 Dec 2025 · Role and needs of public transport

Response to EU’s next long-term budget (MFF) – EU funding for competitiveness

4 Nov 2025

UITP welcomes the Horizon Europe proposal and calls for stronger support for public transport as a driver of climate, social, and economic progress. UITP urges full integration of public transport into collaborative research, innovation, and industrial deployment, especially for clean transition and multimodality. The paper advocates for inclusive public-private partnerships, easier funding access for local actors, and continued support for urban rail and autonomous mobility. Simplifying funding procedures and expanding lump-sum mechanisms are key. Public transport is vital for decarbonisation, job creation, and competitiveness. UITP calls for it to be central in FP10.
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Public transport group urges simpler EU budget reporting rules

28 Oct 2025
Message — UITP wants flexible reporting indicators and a two-year advance schedule for funding opportunities to improve planning. They also suggest that the European Commission pay project partners directly to reduce the workload for project coordinators.123
Why — Public transport operators would face lower compliance costs and better long-term financial predictability.45
Impact — Large industrial firms currently dominating research partnerships might lose their exclusive access to funding.6

UITP demands public transport focus in EU competitiveness budget

28 Oct 2025
Message — UITP requests that public transport becomes a central pillar of the new competitiveness fund. They call for simplified funding rules and direct payments to reduce administrative hurdles. The group also seeks investment in autonomous driving and green vehicle infrastructure.123
Why — This would provide public transport operators with essential capital to modernize and compete globally.45
Impact — Private car manufacturers and users would see funding diverted toward public transit alternatives.6

UITP demands dedicated EU urban mobility funding

28 Oct 2025
Message — UITP calls for a dedicated “urban and local mobility envelope” and mandated spending targets. They recommend ringfencing allocations for public transport and involving local authorities directly.12
Why — Dedicated funding envelopes provide certainty for long-term transport infrastructure projects and modernization.3
Impact — National governments would lose the flexibility to prioritize other sectors over urban transit.4

UITP Urges Dedicated EU Funding for Urban Public Transport

28 Oct 2025
Message — UITP calls for the explicit recognition of urban nodes as projects of common European interest. They request safeguarded funding for civilian public transport and easier access to grants for local authorities.123
Why — Direct access to EU grants would help operators modernize infrastructure and fleets.4
Impact — Military mobility projects might receive less funding if civilian transport is prioritized.5

UITP demands mobility be central to EU anti-poverty strategy

22 Oct 2025
Message — UITP urges the EU to recognize mobility as a core component of the anti-poverty strategy. They call for improved public transport links across rural and urban areas while reducing car dependency. They also advocate for dedicated funding from the Social Climate Fund to support these services.123
Why — Operators would secure long-term financial support and investment priority for expanding transport infrastructure.45
Impact — The car industry and motorized vehicle sectors lose dominance as policy targets car dependency.67

UITP Says Rail Through-Tickets Require Voluntary Commercial Agreements

19 Sept 2025
Message — UITP insists that through-tickets must be based on voluntary commercial agreements between operators. They advocate for excluding local and regional services from the framework and require vendors to follow operator-set connection times.123
Why — This avoids liability for uncoordinated connections and protects small operators from high costs.45
Impact — Online ticket platforms lose the flexibility to design their own multimodal journey offers.6

Meeting with François Kalfon (Member of the European Parliament)

16 Sept 2025 · Transports publics

Meeting with Herald Ruijters (Deputy Director-General Defence Industry and Space)

9 Sept 2025 · Civil Preparedness

Public transport group UITP demands exemptions from fleet rules

8 Sept 2025
Message — UITP insists that public transport remains a distinct category to avoid duplicating existing procurement laws. They call for special-purpose vehicle exemptions and targeted EU funding to support infrastructure.12
Why — Operators would avoid excessive compliance costs and administrative burdens that threaten public services.3
Impact — Local commuters lose as high technology costs could lead to reduced public transport services.4

Meeting with François Kalfon (Member of the European Parliament)

29 Aug 2025 · Transports publics

UITP Demands Dedicated EU Funding for Urban Public Transport

28 Aug 2025
Message — UITP calls for a dedicated funding mechanism for urban mobility to support land-based transport. They request expanded financial support for electric buses and rail infrastructure through the AFIF.12
Why — This would secure major EU funding for modernization and maintenance of public transport systems.34
Impact — Private vehicle users lose dominance as the strategy shifts focus toward reducing car dependency.56

Meeting with François Kalfon (Member of the European Parliament)

30 Jun 2025 · Transports publics

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

16 Jun 2025 · Participants briefly shared their perspective by answering the question: “What do you expect from the European Commission before the end of the current mandate?”

Meeting with Kadri Uustal (Head of Unit Regional and Urban Policy)

12 Jun 2025 · Exchange of views on how public transportation will be covered in the upcoming agenda for cities and the wider policy landscape

Meeting with Elisabeth Kotthaus (Head of Unit Mobility and Transport)

29 Apr 2025 · Social Climate Fund and future of MFF (and possible funds for public transport), passenger rights, social issues, including staff shortage and women employment and social dialogue

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Meeting with Nikolina Brnjac (Member of the European Parliament, Shadow rapporteur for opinion)

27 Mar 2025 · Package Travel Directive

Meeting with Daniel Attard (Member of the European Parliament)

18 Feb 2025 · Public Transport

Meeting with Lena Schilling (Member of the European Parliament)

13 Jan 2025 · EU Public Transport Policies, Single Ticketing

Meeting with Isabella Tovaglieri (Member of the European Parliament)

9 Dec 2024 · Situazione dei trasporti in Italia ed Europa

Meeting with Gaetano Pedulla' (Member of the European Parliament)

19 Nov 2024 · Priorità settore trasporto pubblico locale

Response to Working Programme of the ITS Directive for the period 2024-2028

23 Aug 2024

The International Association of Public Transport (UITP) welcomes the European Commissions efforts to further harmonise ITS systems. We have a few remarks on the draft work programme 2024-2029. Point 3.2.1 C-ITS: C-ITS aims to provide communication and cooperation between vehicles and infrastructure. In public transport, such communication exists already today, e.g. when public transport vehicles influence traffic lights. The Commissions mapping exercise to further clarify its scope e.g. identify services, should include public transport use cases. When considering any further measures, the Commission should take into account the responsibilities of competent public transport authorities as per Regulation (EC) 1370/2007, and the question how the migration from todays technologies to future C-ITS systems could be achieved. A specific issue ist that of cybersecurity. Point 3.2.2 eCall: The Commission examines a possible extension to other vehicle categories, including buses. UITP wishes to point out that, currently, in case of accidents or emergencies buses communicate to the dispatching and monitoring center, who takes care of organising external help if needed. From our perspective, it is not enough to look at this possible extension only from a technological point of view, but the operational changes and change of responsibilities must also be considered without prejudice to the responsibilities of competent public transport authorities under Regulation (EC) 1370/2007. Point 3.2.3 Multimodal access nodes identifiers: Currently, the digital access nodes identifiers vary across countries, modes, and operators. (Some access nodes might not have any digital ID.) A mapping exercise will be useful to find out which systems exist where (and in parallel), and to develop some initial ideas how to achieve more harmonisation in order to clearly identify access nodes across the EU. However, any transition from a current legacy system to a new system would be complicated and costly for the operators. This must be born in mind. There are a few issues with the wording: The definition of access mode in delegated regulation 2024/490 (referring to del. Regl. 2017/1926) is very broad. The Commission should note that not all public transport operates with a schedule, but some services are run based on frequency. Furthermore, the exercise refers only to multimodal access nodes identifiers, which requires clarification re. the question in which case nodes are considered multimodal. UITP is eager to support this exercise with the input of its members all across the European Union. Point 3.2.4 Enhanced traffic and incident management: the scope includes standardised sharing of information on cycling (e.g. volumes, patterns, parking and infrastructure). Regarding cycling data and cycling infrastructure, we would like to point out that bikes are used in multiple different ways, e.g. as private bikes; for bike-sharing, which requires specific organisation of services and fare/ticketing (with sub-categories of e-bikes); or as bikes transported on collective public transport modes (in which case they are a specific category of luggage on-board a bus, tram, metro, mainline rail, etc). It might also be useful to look at e-scooters, as they may require some harmonization re. the vehicles performances and characteristics, conditions of use, condition of parking, etc.
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Shadow rapporteur) and Community of European Railway and Infrastructure Companies and

2 Apr 2024 · Stakeholder Meetings on Passenger Mobility Package

Meeting with Maroš Šefčovič (Executive Vice-President) and

15 Mar 2024 · Clean Transition Dialogue for Cities

Meeting with Jakop G. Dalunde (Member of the European Parliament)

7 Nov 2023 · EU Institutional dinnerkey urban mobility matters

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

4 Oct 2023 · Introductory meeting

Response to Evaluation of the European Union Agency for Cybersecurity (ENISA) and the European Cybersecurity Certification Framework

15 Sept 2023

UITP, the International Association of Public Transport, represents more than 450 urban, suburban and regional public transport operators and authorities from all EU Member States. We provide the perspective of short distance passenger transport services by all sustainable modes: bus, regional and suburban rail, metro, light rail, tram and waterborne. UITP recognises ENISA as a center of expertise for the overall cybersecurity community and ENISA reports such as the Annual Threat Landscape and the 2022 ENISA Transport Threat Landscape as a valuable reference in building up cybersecurity awareness and helping motivate management decisions related to cybersecurity. However, engagement with the local public transport sector has been extremely limited so far, with ENISAs work and interactions since 2016 focusing on mainline railways, road transport and aviation. We consider that the specificities of the public transport sector are currently not understood and taken into consideration in the ENISA work stream dedicated to transport. Similarly, ENISAs role, responsibility and resources remains largely unknown to the public transport community, as demonstrated by a lack of awareness and knowledge among the sector professionals of the European Cybersecurity Certification Framework and its potential impact on the public transport sector. We consider it essential that future ENISA activities in transport involve (local/regional) public transport stakeholders, so that a specifically adapted approach can be developed cooperatively. Please consider our more detailed feedback to the consultation in the annex.
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Response to Revision of the specifications for EU-wide Multimodal Travel Information Services (Delegated Regulation 2017/1926)

28 Jun 2023

The International Association of Public Transport (UITP) provides the sector's feedback on the draft MMTIS regulation in the attached paper. The paper addresses the following points: - Sharing only data that is already digitalised - Vehicle occupancy data - Parking - Voluntary use of APIs - Standards and commonly agreed specifications - Improving some terminology and references - Environmental impact of data storage / duration of data storage - Accelerating the digitalisation of the public transport sector
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Meeting with Karima Delli (Member of the European Parliament, Rapporteur) and European Transport Workers' Federation and

16 May 2023 · Driving Licence Directive

Response to Common form for reimbursement and compensation requests of rail passengers

6 Apr 2023

General comments: According to articles 18(6) and 19(5) of the rail passenger rights regulation (EU) 2021/782, the Commission shall adopt an implementing act establishing a common form respectively for reimbursement requests and for compensation requests by 7 June 2023. Generally, to avoid the confusion between the eligibility criteria for reimbursement and for compensation, it might have been clearer to split the point 3 Nature of your request into two parts, one for reimbursement request as requested by article 18(6) and one for compensation requests as defined by article 19(5) as suggested in the second part of this document. Regarding the services for which passengers may use this form, articles 18(6) and 19(5) of mandatory application for international and domestic services provided by one or more railway undertakings licensed in accordance with Directive 2012/34/EU. As for regional, suburban and urban services provided by one or more railway undertakings licensed in accordance with Directive 2012/34/EU, Member States may decide to exempt those services from the use of a European common form for compensation and request. Regarding the compensation policies applied by railway undertakings for national, long-distance services, they may start below the 60min threshold defined by the EU regulation. Therefore, though using this form should always be possible for the passengers, the scope of it should be somehow made clear to them in order to avoid confusion and wrong expectations. Also, the language which the passenger can use when using this form should be clarified. More comments and suggested amendments are in the attached document.
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Meeting with Ismail Ertug (Member of the European Parliament)

10 Jan 2023 · Sustainable and Smart Mobility Strategy

Response to European Disability Card

6 Jan 2023

The mutual recognition of a European disability card for mobility should ultimately make it easier for the staff dealing with passengers to welcome and assist passengers from different Member States. For this to happen, some pre-conditions need to be fulfilled. In growing and increasingly fast-paced cities, access to public transport is a key factor of mobility and social inclusion. In this regard, the public transport sector has an important role to play, to ensure that all citizens can move as smoothly as possible in their environment. Accessibility is not new for public transport, as illustrated by a number of examples in UITP brochure Travel for all. Making urban transport accessible through the adaptation of infrastructure and rolling stock as well as the provision of assistance and dedicated alternative transport solutions should benefit to all users who need it. A European disability card would, in principle, help, provided it is defined and implemented in strong coordination with all concerned stakeholders, and knowing that the sector will anyway always do its best to guarantee the appropriate level of service to all users. In the case of public transport, where most services run under public service contracts between public transport authorities (PTAs) and public transport operators (PTOs), the PTAs define the pricing policy and the beneficiaries of reduction cards. In practice, this means that there are currently different national / local mobility disability schemes in place. This includes different definitions of disability (and disability degrees) granting different the PRM status. In that sense, it will be necessary to clarify the compatibility between different ways of granting the PMR status across Member States. It will be up to the European Commission and Member States to raise awareness about the card and about the limitations of its use, i.e. the rights granted by a European disability card for mobility should be conditional to the local/national scheme in place. A European card should not call into question the existence of different national cards. A specific attention should be paid to the way in which the card is issued. On a more practical note, out of a survey carried out in the summer 2021 among their EU members, both public transport authorities and operators, UITP has identified a number of practical challenges related to the implementation of such EU card for the public transport sector: - The awareness of the initiative is very small so far, incl. in countries where a pilot project ran in 2016-2019. Care should be taken to make sure it is communicated about the card not only to the users but also to the economic actors concerned. - The definition of the format and conditions to use the card should be defined with all economic actors concerned, e.g. need for a picture and mention of the degree of disability and special needs (assistance dog or accompanying person). - The pricing policy is defined locally. Any policy granting new rights to passengers should be reflected in the contractual arrangements between PTOs and PTAs. - Digitalisation is a key point for the use of the EU disability card in different countries; it is important for securing exchange/verification of health information. - A single-format verification mechanism for checking purchase rights should be established, e.g. by setting up an interoperable number to verify that the passenger has an active status. As a conclusion, UITP advises to follow the 3 Ds rule in order to define a workable scheme with the involvement of all concerned actors: - Do not disappoint the beneficiaries - Do not discourage PT authorities and PT operators - Do discuss with all stakeholders involved. In Europe, UITP brings together more than 450 urban, suburban and regional public transport operators and authorities from all member states. UITP represents the perspective of local passenger transport services by road, rail and waterborne modes.
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Elena Kountoura (Member of the European Parliament, Shadow rapporteur)

27 Sept 2022 · TEN-T

Meeting with Isabel García Muñoz (Member of the European Parliament, Shadow rapporteur) and COMITE POUR LA LIAISON EUROPEENNE TRANSALPINE LYON-TURIN

5 Sept 2022 · TEN-T Revision

Meeting with Ismail Ertug (Member of the European Parliament)

28 Jun 2022 · Public Transport

Response to Better protection for passengers and their rights

17 Jan 2022

UITP shares the Commission's ambition for better protection for passengers and their rights, especially in a multimodal perspective. Passengers are at the centre of public transport operations. The public transport sector therefore shares the following contribution to this initiative aiming at improving the passenger rights regulatory framework, addressing lessons from the COVID-19 pandemic. The current EU rail passenger rights framework covers urban, suburban and regional passenger transport services with a number of fundamental passenger rights, incl. information and assistance. As from June 2023, local rail passengers will benefit from enhanced rights with the new rail passenger rights regulation (EC) 2021/782 ; this initiative should not interfere with the investments and efforts currently made by local rail transport operators and authorities to implement these new rights. Care should also be taken that the “horizontal issues” raised by the Commission do not impact negatively existing regulatory framework for public transport modes. Besides, experience demonstrates that a legal text does not make it all; dialogue with passengers and their representatives at all levels remains essential to understand needs and enhance satisfaction. This appears even more important in a multimodal perspective. This initiative should not hinder, but rather promote and encourage dialogue between passengers and the transport sector. This initiative should also use and promote existing voluntary commitments. UITP members have agreed since 2006 to apply passengers’ rights defined together with the European Passenger Federation in a Passenger Charter. This Charter, was last updated in 2019 to take into account technological and societal evolutions (the text is available here https://cms.uitp.org/wp/wp-content/uploads/2020/08/PASSENGER-CHARTER-SIGNED-VERSION.pdf ) Finally, since the start of the current sanitary crisis, public transport operators and authorities have demonstrated worldwide their strong role as “Guardians of mobility”, ensuring services though passenger numbers have fallen sometimes dramatically. Looking ahead, this initiative should consider the “new normal” mobility patterns. The best passenger rights framework only makes sense when passengers use public transport. UITP has recently published a report assessing the effectiveness of a number of measures to win back passengers in public transport, and making suggestions for the “new normal” era (see https://www.uitp.org/publications/win-back-passengers-facts-figures-and-the-new-normal/ ). UITP is fully committed to play its role in the upcoming consultation process, to help shape a better regulatory framework serving passengers' interests. Note: In the European Union, UITP brings together more than 400 urban, suburban and regional public transport operators and authorities from all member states. It represents the perspectives of short and medium distance passenger transport services by all modes: bus, regional and suburban rail, metro, light rail and tram and waterborne.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

16 Nov 2021 · Public transport in Green and Efficient Mobility Package

Response to Multimodal Digital Mobility Services

2 Nov 2021

UITP, POLIS & EMTA welcome the publication of the roadmap on Multimodal Digital Mobility Services (MDMS). In anticipation of such an initiative, our three organisations published a joint opinion on EU-wide integrated ticketing (the former name of MDMS) in February this year. The joint paper proposes principles supported by recommendations regarding the role and the responsibility of the public transport sector in a multimodal digital mobility context. The paper (available at https://www.uitp.org/publications/uitp-polis-emta-joint-opinion-on-eu-wide-integrated-ticketing/) is relevant to the current roadmap and is therefore referenced in the attached opinion. Indeed, our joint opinion sets out the vision for a functioning market setting for digital mobility solutions that will (i) support, rather than undermine the key role of public transport as the backbone of urban mobility – and (ii) ensure the rights of all citizens to affordable and accessible transport services are not diluted. Regarding the roadmap itself, the European Commission will find our joint feedback attached hereafter. We look forward to the upcoming public consultation and stakeholder workshops which will allow us to further develop the sector’s vision for multimodal digital mobility services and continue to work closely with the Commission on this topic.
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Response to New EU urban mobility framework

25 May 2021

The Commission’s Sustainable and Smart Mobility Strategy recognises what mobility experts and mayors already know, namely that at the local level, modal shift to public transport and active mobility is a necessity to reach the objectives of the Green Deal and produce more liveable cities. UITP expects the Commission to provide a vision for urban mobility that is clearly centred around public transport, walking and cycling, as these modes have clearly demonstrated benefits over all other modes of transport. Other shared forms of mobility must complement this, and private motorized mobility must be managed in a smart way. The Urban Mobility Package should dedicate a specific section to the short- and mid-term development of public transport, focused on the benefits public transport systems bring to cities and on the triple challenge the sector is currently facing, namely decarbonisation, digitalisation, and growth. - As cities aim for more efficient mobility, public transport shall grow and serve more passengers than today. The first step is to re-gain the trust of passengers following the COVID-19 pandemic; the next step – and a huge challenge – is to enhance the offer and increase the capacity, i.e. the number of vehicles, frequency and lines served, as well as new multimodal services. - Decarbonisation requires our sector to replace our fleet with more expensive zero-emission buses and develop urban rail systems (metro, tram, etc.), set up the corresponding infrastructure and become climate-neutral at the latest by 2050. - Digitalisation requires public transport companies and authorities to invest into new skills, technology, platforms, as well as time to digitalise information, develop data strategies and enter new cooperation. Each of these three processes, which all need to happen at the same time, requires huge additional investments. It is therefore also vital to address the financial resilience of public transport funding and support cities in generating new revenues as resources for these investments, for example through applying the “user pays” and “polluter pays” principles. Further challenges the public transport sector needs to manage are: recruiting sufficient and gender-balanced staff; upskilling and retraining the workforce to adapt to changes (e.g. digitalisation); building new infrastructure; providing demand-responsive services; deploying automated and autonomous public transport; etc. Measures by the EU that can support the public transport sector are: - Possibilities of tax exemptions/reductions for public transport in the EU’s Energy Taxation Directive; - financial support from the EU and Member States for clean public transport vehicles and infrastructure as well as for the digitalisation of public transport; - stronger focus on public transport in urban nodes along the TEN-T network; - making investments into an improved local public transport eligible for cities’ GHG emissions offsetting payments; - a toolbox for cities including how to set targets, how to monitor them, and various measures that (alone or in combination) can promote active and collective mobility, such as road pricing, parking management, public transport priorisation/acceleration, partnership with companies for a better mobility management (promotion of job tickets), etc.; this should also include better monitoring of the environmental and social impacts of transport modes; - a fair level-playing field for data sharing; - a pan-European “re-discover public transport” campaign at the end of the COVID crisis; For more information on the benefits of public transport, a vision for the public transport sector of the future, and concrete measures how the EU can support the public transport sector, see also our input to the Sustainable and Smart Mobility Strategy: https://cms.uitp.org/wp/wp-content/uploads/2020/09/20200924_UITP_contribution_EUSSMS_final.pdf
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Response to Standards for recharging points for e-buses

20 Apr 2021

UITP, the International Association of Public Transport, welcomes the Delegated Regulation of the Commission which aims to establish standards for public electric bus charging points in the AFI Directive 2014/94/EU. This is an important step towards achieving interoperability in view of the quickly growing market for electric buses and the implementation of the Clean Vehicles Directive. The specifications must be aligned to ensure interoperability with respect to physical interconnection, communication, and electrical power transfer. We have the following remarks: 1. The choice of plugs (Type 2, Combo 2) and their respective mechanical standards (EN 62196-2; EN 62196-3), as well as the mechanical standard EN 50696 for opportunity charging are a good starting point and should be adopted but are not enough to have a functional interface. (See next point.) 2. The Delegated Regulation includes only the mechanical part of the charging processes (for plugs and opportunity charging) but misses other crucial aspects such as communication interfaces and the electrical power transfer (including electrical safety requirements). This omission results in a partial standard which can still lead to differences between charging points, hence missing the objective of full interoperability. UITP strongly recommends adding references - on top of these standards (point 1) - to the following standards if they are finalised, and in the future possibly to those standards that are now still in development: a. Electrical interfaces for all charging points: IEC 61851-1, IEC 61851-21-2, IEC 61851-23 and IEC 61851-23-Ed 2 (not yet read). b. Electrical interfaces for manual connection: ISO 17409 Ed1. c. Electrical interfaces for automated connection devices (ACD): IEC 61851-23-1 (not yet ready) and ISO 17409 Ed 2. d. Communication interfaces for manual connection: ISO 15118-2 Ed1 and ISO 15118-3. e. Communication interfaces for automated connection devices (ACD): ISO 15118-20 Ed 1 (not yet ready), ISO 15118-3 and ISO 15118-8. The standards that are still in development at ISO/IEC (see c and e) need to be finalised as soon as possible and CEN/CENELEC should push for a very fast publication as a European standard (EN). UITP asks the European Commission to renew its standardisation request and try to accelerate the process. 3. The standards are delivering interoperability in theory, but all bus and charger combinations should still be verified if they are truly compatible in practice. UITP recommends that the European Commission includes a reference to the ASSURED 1.0 Interoperability Reference which includes the necessary protocols and rules for such conformity checks. (https://assured-project.eu/storage/files/assured-10-interoperability-reference.pdf) Furthermore, results from the project ASSURED – especially those ensuring interoperability while some standards are still missing – could help bridge the missing gaps until such standards are fully developed. 4. The standards that are still in development and future versions of all of these standards should be backward compatible to ensure interoperability between existing infrastructure and buses and future ones. 5. The plugs developed for electric city buses should be compatible with the charging infrastructure for coaches and lorries along the TEN-T and the highway network. This would enable flexible e-bus movements across Europe e.g. when electric buses are driven from the manufacturing plant to their final destination. 6. UITP would like to emphasis for matter of clarity that these standards shall only apply to battery electric buses and not to trolleybuses.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

15 Apr 2021 · Boosting clean public transport

Response to Climate change mitigation and adaptation taxonomy

7 Dec 2020

The Delegated Act must build on the recommendations of the Technical Expert Group on Sustainable Finance (TEG) and retain the threshold of 50 gCO2e/pkm for urban public transport vehicles in the taxonomy. Public transport is a recognised climate mitigation solution in the transport sector. Emissions avoided from public transport are quantified into 3 major categories and is consistent with the objectives of Article 1 (6) of the draft Delegated Act: it contributes to avoid producing greenhouse gas emissions thanks to urban densification, modal shift to lower emissions modes and less overall congestion. Article 1 (21) states that the technical screening criteria for the transport sector should focus on reducing the main emission sources from that sector (private car use), while also considering the need to shift the transport of people and goods to lower emission modes (like public transport) and for the creation of an infrastructure that enables clean mobility. With this in mind, the technical screening criteria for the transport sector much enable this approach with more public transport rather than limiting investments in the sector. The TEG’s advice published in March 2020 (https://ec.europa.eu/info/sites/info/files/business_economy_euro/banking_and_finance/documents/200309-sustainable-finance-teg-final-report-taxonomy-annexes_en.pdf) for urban and suburban public transport states that other fleets should eligible (beyond just zero emissions vehicles for urban road passenger transport) as long as direct emissions are below 50 gCO2e/pkm until 2025 (non-eligible thereafter). The rationale being is that it ensures that the carbon intensity remains similar to criteria for other eligible road vehicles (e.g. vehicles of category M1 and N1). It also provides a clear policy direction for the sector and investors alike that is consistent with Article 1 of the Delegated Act, in that it will also ensure that investments are directed towards cleaner vehicles while simultaneously encouraging a modal shift through increased patronage so as to meet the threshold. Setting the threshold of 50 gCO2e/pkm until 2025 will ensure that it is sufficiently stringent while providing some flexibility to recognize highly efficient systems and advanced technologies to accommodate for some kind of transition period to enable the implementation of relevant EU Directives (e.g. Clean Vehicles Directive). This is essential as a lack of immediate investment in much needed low emission public transport fleet renewal can lead to behavioural changes, such as modal shift to private car that will be significantly more difficult to revert in the future. Retaining the threshold of 50 gCO2e/pkm for public transport vehicles is a workable solution in the fact that guidance to calculate this indicator is laid out in UITP’s SORT methodology which provides the representative value of the energy efficiency of the vehicle operation using a half load capacity. This methodology is the reference for the public transport sector and can be used as the underlying reference in the Delegated Act in order to allow for comparable decision making and consistency across the sector, thereby avoiding any ‘green washing’ claims. This approach would also be consistent with that used in other areas of the Act’s annex – for example, for sea and coastal freight water transport where the IMO’s Energy Efficiency Design Index is identified as the relevant calculation methodology for the emissions threshold. Using a similar approach for urban passenger transport - identifying UITP’s SORT methodology as the means to calculate the threshold - would provide a workable, consistent, transparent and evidence-based solution for both the public transport sector and investors. UITP therefore strongly recommends that the Delegated Act reverts back to the approach recommended by the TEG and retain the threshold of 50 gCO2e/pkm for urban passenger transport.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

15 Oct 2020

- While action to reduce transport emissions alone cannot remove the causes of poor air quality in cities, it can play an important role in working towards the achievement of the EU goals and delivering health benefits. - Actions to reduce emissions from vehicles should be achieved through a combination of measures, notably from shifting to alternative sustainable modes like public transport and to cleaner fuels and improved vehicle technology. This should be complemented by better managing transport demand to increase the efficiency with which we use transport. - The EU should support and enable actions at the local level and earmark more resources (including through the EU Sustainable Finance Taxonomy) for the development of sustainable urban mobility based on high quality networks, low emissions fuels/public transport and the electrification of the transport sector. This will support the delivery of other relevant pieces of EU legislation, such as the Clean Vehicles Directive. - Public transport undertakings have already made considerable strides in addressing air pollutants from the sector. Placing additional disproportionate burdens on it that is already under substantial cuts to passenger numbers and funding could result, in these tight budgetary times, lead to reduced public transport services. Pushing public transport ridership away to single-occupancy cars will have adverse emissions implications. - Local authorities/public transport undertakings are committed to support the achievement of air quality values with the means at their disposal. However, in some cases these means are limited and for some measures public acceptance is rather low. Member States should remain responsible for paying respective fines and should not 'hand down' fines to local authorities/public transport undertakings. - The relationship between air pollution, climate change and Green Deal objectives needs particular attention. The Commission should support policies that encourage a shift to sustainable modes of public transport as this can greatly benefit wider sustainability objectives such as the reduction of carbon dioxide (CO2), oil dependence, the competitiveness of Europe's economy while at the same time improving air quality.
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Response to Implementing act on a list of High-Value Datasets

24 Aug 2020

Public transport (PT) companies as well as public transport authorities (PTA), are dedicated to improving their passengers’ experience and are keen on voluntarily sharing certain data they generate. Operators and authorities are uniquely suited to know which data will improve the service rendered to passengers and already make the data they hold accessible and reusable. As mentioned in the roadmap, the public transport sector is already subject to the Intelligent Transport Systems (ITS) Directive and the delegated regulation on MMTIS (2017) that regulate which data must be made accessible and determine standards and procedures (using national access points). Some Member States also have additional sector-specific legislation regarding access to transport data. The European Commissioners have previously clarified in a letter to UITP that datasets covered by the ITS delegated acts would not be covered by the list of HVDs. This ensures that the same datasets are not regulated by two different European legislative acts. As the delegated regulation is already in place and is sensitive to the specificities of the transport sector and competition issues, the High Value Data Sets (HVD) should include other aspects of mobility than those covered by existing regulations. Regardless of the nature of data included in the “mobility” HVDs, UITP has a number of remarks: The roadmap does not shed sufficient light on how the specifities of the “mobility” category will be dealt with and guaranteed. Will the arrangements for publication and re-use be the same for all 6 data categories or will they vary depending on the type of data category? UITP believes that the latter principle should apply and that the arrangements regarding the terms applicable to mobility datasets should be specific to that category. It is important to take into account the effect the HVDs will have on competition. For example, it would be difficult in the context of PT to differentiate between public sector bodies and public undertakings operating a public transport service. Indeed, across the EU Member States, PT services are sometimes operated directly by the PTA (often a public sector body according to the definition of the PSI Directive) and sometimes by a public undertaking or private undertaking. These are the exact same services, only the management mode differs. Today, public transport also faces competition from new (private) mobility services provided by large companies or IT platforms. While the roadmap states that mostly SMEs profit from the data, in the public transport sector, previous experience teaches that data flows mostly to large platforms. For these reasons, UITP approves the general understanding in current directives covering data that at least the direct costs related to the reproduction, provision and distribution of data can be charged by all undertakings. Investing in IT systems and providing access to data (through APIs for instance) has a cost. The volume of required data and the update frequency (“real time” or not) must also be taken into account. Data has value. Therefore such value should be safeguarded and recognised by allowing the body releasing it to cover the marginal costs of the data. This should especially be the case for “high-value” datasets, which should not have to be published for free. It should be kept in mind that in the PT sector, most small and medium authorities/operators do not have sufficient resources to develop complex server infrastructure and foster in-house IT skills. Considering this, the sharing process should require standards that all PTAs and operators can achieve and should not impose a disproportionate burden. Last but not least, UITP asks the Commission to clarify the timeline for the public consultation on the draft implementing act. The roadmap indicates that the consultation has already passed. However, the Commission’s Better regulation webpage indicates that an additional consultation is upcoming.
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

UITP appreciates the opportunity to comment on the roadmap and fully supports its aim of providing more affordable, accessible, healthier and cleaner transport alternatives. We urge the Commission to recognise public transport as the backbone of sustainable mobility and welcome its intention to promote modal shift. This should be clearly stated in the Strategy. As affirmed in the roadmap, the sector faces enormous challenges, exacerbated by the COVID-19 crisis. Public transport was heavily impacted and continues to feel the effects of citizens’ fear of using mass transport solutions. It is now vital for the sector that the EU prioritise political and financial support for clean, shared public mobility. As the economy recovers, it should be steered towards a Green Deal compatible growth. The ambitious objectives of the Green Deal cannot be attained without making urban and regional public transport a priority: • In European cities, public transport by rail and road replaces millions of car trips each day • Public transport empowers the economy e.g. through many direct jobs, infrastructure investments, cooperation with local SMEs, etc • Public transport is fully inclusive, offering services to all categories of European citizens • A modal shift towards public transport means reducing congestion and CO2 emissions, saving urban space, preventing climate change, safer mobility, more local jobs, economic well-being, clean air, social cohesion and healthier citizens We urge the Commission to support a level playing field between transport modes, taking into account their externalities. This could be achieved e.g. via the “polluter pays” principle, through the promotion of congestion charges (depending on the local context), taxation for CO2-emitting modes or reduced energy taxation for public transport services. The Commission should also encourage new ear-marked contributions in support of public transport. Considering the title of the strategy, we would like to point out that smart mobility solutions are most useful in conjunction with a focus on sustainable mobility. Any MaaS (Mobility as a Service) governance framework should contribute to modal shift and guarantee the transport authority’s ability to organise mobility on its territory on equal and inclusive terms. MaaS should have public transport as its backbone, follow the principle of reciprocity (of data exchange and liability), and ultimately enable life without having to own a car. Similarly, initiatives like Cooperative Intelligent Transport Systems and the development of automated vehicles can become true success stories for future sustainable mobility by putting public transport at their core. UITP is an advocate of the “avoid-shift-improve” principle – avoiding unnecessary traffic, shifting to the most sustainable modes of transport, and improving each mode of transport – to successfully transform the transport system. Sustainable Urban Mobility Plans, separate or dedicated infrastructure for public transport as well as prioritisation of public transport can help to significantly improve the speed and reliability of shared, collective transport. Substantial European financial support and an “urban shift” in the EU budget are required to improve public transport: to shift to clean vehicles (requiring the set-up of charging and refuelling infrastructure), foster digitalisation, modernize existing infrastructure and expand public transport networks. Any new legislation affecting the public transport sector should be accompanied by a comprehensive financing package to cover the additional financial burden. To support the expansion and improvement of the public transport network, the EU must strengthen future investment and research funding in sustainable mobility, for example through the Connecting Europe Facility (CEF) and the creation of new financing tools. Attachments: - Open letter with CEO signatures - UITP policy priorities for 2019-2024
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Meeting with Frans Timmermans (Executive Vice-President)

14 May 2020 · Recovery and Green Deal in Transport

Meeting with Adina-Ioana Vălean (Commissioner)

12 May 2020 · Public transport

Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

30 Apr 2020

Public transport, whether powered by conventional or alternative fuels, means sustainable mobility. By using little space and moving millions of passengers every day, it is a very energy-efficient mode of transport and the backbone of urban mobility. When tackling air pollution, bus transport is not part of the problem, but part of the solution. In European cities, public transport by rail and road is estimated to save 100 million car trips daily. It is vital that public transport continues to grow. Therefore, when considering the development of stricter emissions standards, the Commission should carefully consider the implications of a new Euro VII standard for the bus segment on public transport. The European emission standards, and Euro VI in particular, have been very useful in reducing local pollutant emissions. Euro VI diesel buses have extremely low pollutant emissions and a comparable level of CO2 and pollutant emissions to natural gas buses. In the bus segment, there were no irregularities with software. Unlike cars, buses are not tested on test benches, but on the street in so-called “SORT” cycles (SORT = Standardised On-Road Testing). Real driving tests by bus operators have demonstrated that diesel buses actually meet the emission limits set in the EURO standards. One of the quickest ways of reducing emissions from the bus sector is to replace the oldest parts of a bus fleet, for which modern Euro VI buses are the most cost-effective replacement. Overall, UITP and its members are satisfied with the Euro VI standard for buses. While UITP shares the Commission’s goal of making public transport even more sustainable, the recent revision of the Clean Vehicles Directive (2019/1161/EU) already established a clear and ambitious trajectory for the shift to alternatively fuelled buses of Classes I and A. The shift towards clean and zero-emission buses is ongoing and is expected to accelerate as of 2021, thus reducing the demand for conventional diesel buses in Europe. Hence, it is questionable to what extent a Euro VII standard would be useful and effective, considering that it would not be adopted before 2022. As became evident during the step from Euro V to Euro VI, a revision of the standards (EURO VII) would require significant investment from the bus manufacturing industry, expenses they would have to pass on to the customers. This would come at a time where the public transport sector is heavily investing in clean and zero-emission buses. Not only are the technologies prescribed by the Clean Vehicles Directive more expensive than conventional diesel buses, but costs for the system change, especially the charging or refuelling infrastructure, need to be taken into account as well. If the authorities’ budget for public transport remains the same while buses and their related infrastructure become more expensive, there is a risk that the number of buses or the overall service must be reduced, thus negatively impacting sustainable urban mobility. The focus of the Commission and relevant stakeholders should be on delivering on the Clean Vehicles Directive and supporting the uptake of its associated infrastructure (e.g. via the revision of the DAFI Directive ). The use of electric and other alternatively fuelled buses will contribute to reducing local air pollution. Instead of drawing much-needed resources away towards developing a Euro VII standard, the research and development capacities of manufacturers should be dedicated to alternatively fuelled vehicles (including hybrids), with the aim of ultimately making them a more affordable option for operators and authorities. Considering all these factors, the cost-benefit-ratio of developing a EURO VII standard appears to be negative. UITP therefore advises against working on such a standard for the bus segment.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

20 Feb 2020 · Discussion on clean public transport

Response to European Partnership for transforming Europe’s rail system

26 Aug 2019

UITP recognises the importance of the Shift2Rail initiative to strengthen European rail research and innovation as well as the desirability to pursue the efforts beyond 2021 in order to achieve critical results and added-value to boost sustainable urban mobility in Europe. However, UITP strongly insists that any follow-up initiative should recognise and better address the peculiarities of the multiple rail market segments. For what concern urban rail, it is not a “spin-off” of mainline railways. Therefore successful follow-up initiative should be designed in a more inclusive way, both in terms of programme and participation rules, taking the characteristics of various stakeholders, and especially of urban rail operators, due to their critical importance for mobility in and around cities. We would like to remind that ridership of tram and metros in Europe (~22 400 m passengers per annum – 2017) is more than twice as high as the total ridership of commuter, regional, long-distance and high speed railways in Europe. A better balanced R&I initiative would allow all rail markets maximise the potential of rail research and innovation. UITP is willing to support an extension of the Shift2Rail programme provided that a number of principles are met towards more inclusiveness: • A more flexible and open collaborative framework • Easier access to funded activities and lower administrative burden that would attract in particular local operators • R&I topics addressing also specific Urban Rail issues identified in UITP R&I priorities
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Response to Evaluation of the 2011 White Paper on Transport

7 Mar 2019

UITP would like to thank the European Commission for the publication of this roadmap. Please find enclosed UITP’s Mobility Manifesto which summarises our priorities for the next legislative period and constitutes at this stage an appropriate feedback for the roadmap for the evaluation of the White Paper on Transport. UITP will of course contribute in a more detailed fashion and closely follow the actual evaluation of the 2011 White Paper. http://mobilityontop.uitp.org/manifesto2019/home/
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Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

8 Feb 2019

UITP welcomes the publication of the draft delegated act on Cooperative Intelligent Transport Systems (C-ITS) and would like to take this opportunity to thank the European Commission for organising multiple workshops in 2018 and for consulting with a wide variety of stakeholders. UITP is in favour of the road safety-oriented approach taken by the Commission. UITP agrees with the Commission that one of the objectives should of course be a reduction in the number of accidents and strict safety requirements are a pre-condition. Establishing a list of authorised technologies that comply with these requirements therefore makes sense from a safety point of view. On the issue of technology neutrality and compatibility, we do, however, wonder if all the use-case scenarios of C-ITS technologies are efficiently covered by the Wi-Fi technology put forward by the Commission. Cities will decide on the most-suited technologies based on the use-cases they will have identified and based on the inevitable financial constraints they are subject to, as well as on safety requirements. Taking into account these, as well as countless other urban planning and environmental objectives, cities should be able to choose the right technology for them. This is why a technology neutral approach is so important. Moreover, if unquestionably C-ITS will play a central role in improving road safety in the future, it cannot be the only solution and must be combined with other advanced-driver assistance systems (ADAS). Regarding the issue of spectrum, the band currently allocated for safety-related (road) ITS applications goes up to 5905MHz (EC Decision 2008/671/EC). Regarding the possible extension of the band up to 5925MHz (addressed in ECC Decision ECC/CED/(08)01) the European Commission needs to take into account existing technologies already deployed, under development or planned by public transport services (Communication Based Train Control-Command - CBTC- urban and suburban rail applications segregated from road and pedestrian traffic). For this purpose, it is useful to look at the studies underway at ECC and CEPT level under the so-called ITS mandate (see CEPT report 71) which associate the UITP Spectrum User Group. Equally, UITP believes the Commission’s stated objective of reducing congestion is the right one and the list of priority services established in the Annex - Ares(2019)153204/1 is an important step towards achieving such an objective. Within that list, specifically in the Infrastructure-to-vehicle services list, UITP notes the inclusion of service profile – section 33: “Signalised intersections – Public transport prioritisation”. It has always been UITP’s position to state that priority must be granted to public transport services, and more broadly to shared transport services – be they publicly or privately-owned or organised. The inclusion of such a service profile is therefore a very positive element of the draft delegated act. Nevertheless, we believe more public transport and shared mobility-oriented services should be included in the list of priority services. For instance, within the vehicle-to-vehicle services list, in the “Special vehicle warning”, we believe priority should be given to buses around bus stops as is currently the case in many cities and Member States. Indeed, the risk otherwise, already identified by the Commission, is that optimising the traffic conditions and fluidity for private vehicles will only lead to an increase of the dynamic capacity of the road in terms of the number of vehicles for a relatively short amount of time. At a later stage however, the congestion will reappear. The urban environment is a limited space and a global approach is needed in order to organize the life and transport of the population. Let’s move people, not cars!
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Meeting with Silke Obst (Cabinet of Commissioner Violeta Bulc)

7 Feb 2019 · Sustainable and Digital Transport

Meeting with Silke Obst (Cabinet of Commissioner Violeta Bulc)

6 Dec 2017 · Meeting with Mr T. AVANZATA, Europe Director

Meeting with Henrik Hololei (Director-General Mobility and Transport)

4 Nov 2015 · 4th Railway Package

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and Community of European Railway and Infrastructure Companies and

29 Sept 2015 · Metal Theft

Meeting with Joao Aguiar Machado (Director-General Mobility and Transport)

9 Jun 2015 · Urban transport, Future of UITP

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

23 Apr 2015 · Meeting with UITP

Meeting with Matthias Ruete (Director-General Migration and Home Affairs)

6 Mar 2015 · Overview of the Security Concerns of the Public Transport Sector, Exchange on the Role of DG HOME in new Commission

Meeting with Violeta Bulc (Commissioner)

26 Feb 2015 · Meeting with UITP

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

22 Jan 2015 · Priorities of Transport Commissioner for Public Transport