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Response to the consultation on the Green Paper “Towards a new culture for urban mobility”

Publication date: 16 March 2008

Through its members the FIA represents over 34 million people in Europe who need mobility in their daily lives whether it be by car, motorcycle, public transport, cycling or walking. As the leading European mobility organisation, the FIA has unbiased consumer orientated expertise in a variety of transport issues, including road safety, traffic information and incident management. The FIA’s key priority is the representation of mobile consumers.


As some of the issues are dealt with by several questions, we would first like to outline a series of issues that we think should be considered by the European Commission when addressing the issue of mobility in urban areas. In the second section, we address the 25 questions asked in the European Commission’s Green Paper “Towards a new culture for urban mobility” while using cross references between the questions where appropriate.


The FIA member motoring and touring clubs’ long experience means that they have the knowledge of how to best address mobility challenges in our cities. The traditional focus of the clubs is on road safety. A more recent field of activity covers traffic management, with road patrols helping to speed up the process of incident clearance, and traffic information services giving congestion warnings to help motorists find an alternative route in time. Since the motoring and touring clubs are involved in technical development projects and participate in a variety of expert groups, they operate at the cutting edge and promote innovative solutions by taking part in pilot projects. With respect to traffic in cities, the clubs focus on their role in consumer protection, testing for example “green wave” traffic light coordination, public transport systems or cyclingfriendly infrastructure. It is the close contact to road users and municipal authorities that ensures practical, financially viable and user-oriented solutions.


For decades now, Europe’s cities have grown to become the centres of social and economic activity they are today. Increasing mobility has played an important role in this development, and is a key element in our cities’ future. Increasing mobility also has downsides. Congestion, air pollution, traffic accidents and noise are significant problems in many cities affecting the quality of life of their inhabitants. This requires collective efforts to find and implement well-balanced solutions, ensuring the mobility of persons and goods without impairing the residents’ quality of life.


Therefore, the FIA seeks to actively promote improvements to the urban mobility framework through policy that creates the right balance between all parties involved in urban mobility.


The FIA favours measures that prove to have benefits for the urban environment and lifestyle and ensure the mobility of citizens. Some cities have already introduced measures such as the congestion toll schemes, temporary closures of city centres or permanent access restrictions for certain types of vehicles or the limitation of maximum speeds. Although the effects of these measures have not yet been fully evaluated, preliminary results show that they have, in most cases, not produced the expected benefits for congestion, the environment, safety and noise. Some of these measures proved to be not only ineffective, but they also present missed opportunities to tackle these important issues. In a nutshell, the FIA favours solutions which give consumers choice when travelling rather than solutions which rely on the creation of physical or monetary barriers.


The FIA would like to make a more general comment about any actions that the European Commission will propose in its Action Plan on urban mobility to be proposed next autumn. The research on urban mobility problems and solutions, for instance with regard to traffic congestion, is still lacking trustworthy facts and figures and thorough analysis. This was confirmed by the European Commission at different occasions. The FIA would therefore like to stress that the European Commission should be very careful in defining European guidelines or even  recommendations. The FIA would therefore as well, in a first instance, rather see a role for the European Union (EU) in promoting the exchange of information at European level and another role in carrying out further factual research on urban mobility. This research on facts and figures is essential before drawing any conclusions with regard to guidelines or recommendations. A premature issuing of guidelines or recommendations would risk leading local authorities to wrong policies at local level with a high cost to society. The role seen by the FIA in the following answer to the public consultation in issuing guidelines or recommendations is therefore subject to a thorough research of the facts surrounding mobility problems and solutions as well as a thorough impact assessment of any proposed measures.


The FIA believes that flourishing cities of the future will be the ones that will have put in place best in class mobility solutions. Helping cities to find and implement these will continue to be a key priority of the FIA and its member associations for the years to come.

Answers to the questions posed by the Green Paper

1. Should a “labelling” scheme be envisaged to recognise the efforts of pioneering cities to combat congestion and improve living conditions?

A labelling scheme could be envisaged to recognise the efforts of pioneering cities to combat congestion and improve living conditions. However, before thinking about developing a labelling a good, thorough and well balanced analysis needs to be carried out as to define what is meant by “pioneering cities”. The exercise of establishing criteria for pioneering cities (London, Stockholm, Milan, Berlin) would be difficult considering the diversity of European cities, their structures and their problems.


In this respect, the Green Paper refers to different initiatives presented as examples of pioneering cities while no conclusive evidence exists currently to prove their success. One of the measures available to block access to inner cities and to combat congestion is urban charging. Two well-known examples of urban charging are London (congestion charging) and Stockholm (congestion tax). Both of these are mentioned in the Green Paper at various places and presented as examples of good practice. However, in the view of numerous external observers, the efficiency of urban charging is still questionable today.


During the 22nd of August 2005 and the 31st of July 2006, Stockholm did a trial implementation of a congestion tax in Stockholm2. According to a study carried out by Rémy Prud’homme and Pierre Kopp3 the congestion tax in Stockholm caused, as predicted by theory, a reduction in traffic, leading to increased speeds, and to time gains for remaining car-users. These time gains are modest as congestion was moderate. Reducing it to its optimal level, which is what, the congestion tax intended, does not represent massive time gains.


According to the results of the trial implementation, the congestion tax meant an overall reduction of 22% in traffic crossing the congestion tax cordon. Rémy Prud’homme and Pierre Kopp evaluate this reduction to be of 15%, which is relatively lower than the figure put forward by the results of trial implementation.


According to the result of the trial implementation, the 14% reduction in road use in the inner city suggests that emissions of airborne pollutants in the inner city will also have decreased. On environmental benefits there is no disagreement between the trial implementation results and Rémy Prud’homme and Pierre Kopp. But it has to be said that the environmental benefits of urban charging remain relatively low.


The results of the trial implementation showed an increase in public transportation by the introduction of new bus services and an increase in rail traffic. According to Rémy Prud’homme and Pierre Kopp, this only led to an increase in public transport congestion.

A major cost is of the congestion tax of Stockholm is the implementation cost of the system. It is high at about € 56 million per year. A recent study has revealed that the revenues generated by the congestion tax have been equalised by the inherent cost of the system.


It is important to remember that for urban charging to produce net benefits, three conditions are required: a relatively high degree of road congestion, a reasonably cheap implementation system, and an efficient system of public transport. Regarding at least the first two aspects this is not the case in Stockholm anyhow.


Another example of measures recently taking by a number of city authorities is the limitation of maximum speed on motorways around cities. In this respect, in order to improve living conditions and comply to the European air quality Directive4, on the 1st of January 2008, a speed limit of 80 km/h was introduced on the highways entering the city of Barcelona. This is one measure of the Catalan Regional Government Action Plan to improve air quality in the Barcelona Metropolitan Area. The plan comprises 70 measures, affecting industry, energy, housing and mobility.


A study carried out by the Spanish club RACC on the basis of measurements carried by the German club ADAC has shown that it is doubtful that a reduction of maximum speed limits will automatically lead to any improvement in the air quality. In order to illustrate this point, the study compared the exhaust emissions of nitrogen oxide at the speeds of 80 km/h and of 120 km/h for petrol and diesel cars. The result showed that on average nitrogen oxide emissions are lower at 120 km/h than at 80 km/h. The study concluded that introducing variable speed limits is more effective in reducing congestion and traffic emissions.


Further according to the Automobile Association Ltd (AA), cutting the speed limit from 30 mph (± 50 km/h), to 20 mph (± 30 km/h) on the wrong roads could actually increase CO2 emissions by more than 10 %.5

Experience shows that the car is often singled out as the principle cause of problems in cities. Rather than integrate the car, that has been shown to bring economic and social benefits to cities, many policy makers try to shut them out of cities. Blocking accessibility to inner cities gives rise to an increasing outflow of labour and resident population into the surrounding areas and reduces attractiveness of inner cities as a living and economic environment.


The FIA member clubs are already participating in different benchmarking programmes at European level, for example EuroTest6 and the European Tunnel Assessment Programme (EuroTAP)7. The aim of EuroTest is to test the quality and safety of mobility in Europe and the aim of EuroTAP is to test the quality and safety of European tunnels. In the framework of EuroTest a railway stations survey was conducted in 2002 and in 2008 a pedestrian crossing survey was performed.


2. What measures could be taken to promote walking and cycling as real alternatives to car?

Walking and cycling are realistically only real alternatives to car for short distances. Measures that could be introduced in order to promote walking and cycling as real alternatives to car for short distances include:

  • Barrier-less road environment for the mobility impaired people
  • Bicycle hire points
  • Anti-theft bicycle sheds
  • Safe road environment (for example separated bicycle lanes)
  • Dedicated sign systems 
  • Bike-and-ride systems
  • Space for bicycles on public transport

In order to further promote walking and cycling as real alternative to car for short distances, it is important that the necessary infrastructure is already taken into account in the initial planning of urban areas. It is rather difficult to introduce such infrastructure (for example bicycle lanes) at a later stage.


3. What could be done to promote a modal shift towards sustainable transport modes in cities?

First of all, what is meant by “sustainable transport modes in cities” need to be defined. The Green Paper does not define which transport modes are sustainable in cities and which transport modes are not sustainable. In the view of the FIA, sustainability should be a requirement for all transport modes.


It has to be remembered that sustainability has three dimensions: an economical, a social and an environmental. By economical dimension, it is meant that the transport mode should enhance the economic activity and help the society to pursue its welfare objectives. By social dimension, it is meant that the transport mode should be affordable and accessible to all and should help different population categories to participate in social life by reducing barriers due to distance to overcome. By  environmental dimension, it is meant that the transport activity should have a relatively low negative impact on the environment, in the case also the well-being of the city’s inhabitants.


It is important that these three dimensions are taken into consideration when assessing and considering if a transport mode is sustainable. In most cases, the challenge will rather consist of making transport more sustainable, i.e. cleaner, safer and more reliable while keeping them affordable.


It is in general difficult to transfer transport performance between modes. Each mode of transport is used for reasons best known to the user. Criteria include for instance the facility of use, the level of comfort, the speed of transport, the safety and security. In this respect, the car is in most cities the premier mode of transport. It is unmatched for independent mobility and convenience and its benefit to society will continue to grow as the balance between social costs and benefits becomes increasingly positive. However, in the city centres, the car has downsides for the inhabitants on one side and the driver (e.g. parking problems and low travel speed) on the other side. The integration of the car and public transport can combine the advantages of the car in suburban areas and the advantages of public transport in urban areas. Before trying to promote a modal shift from one mode to another, one needs to offer a partly equivalent and effective alternative. In concrete terms, if as suggested by the Green Paper public transport is due to be promoted, it needs to offer an equivalent service as does the individual transport that is favoured by most of Europe’s citizens for the reasons mentioned above. An important element in this strategy is the inter-modal integration that gives public transport a significant competitive advantage. In order to reach such a result individual and collective transport would need to be better connected (e.g. through park-and-ride or bike-and-ride). Carpooling or (company) mobility management can also help.


What could be the potential role of the EU?

The EU could have many potential roles and these will be discussed below.


The FIA understands that it is the principal duty of the EU to identify best practices, to set standards aiming at ensuring interoperability and to promote pilot projects and their evaluation. In this respect, the FIA believes that the urban environment is not an appropriate stage to establish legislation. The FIA emphasises the significance of the principle of subsidiarity; urban initiatives should be taken at city level. In view of the high level of diversification of traffic in European cities, standard “top down” solutions are not viable. Naturally, city regions need policy guidelines for a sustainable transport planning. They do not need legislative imposition on a broad front.


While local policy needs to be done on local level the FIA sees a role for the EU to promote the exchange of information about how local problems have been solved in different cities. The EU should as well promote further research in the field of urban mobility.

The EU could also put in place a benchmarking of European cities on urban mobility. Defining the testing and benchmarking will be a difficult task, but it can give the opportunity to see how European cities really perform and to see which cities are really “pioneering cities”. Here, FIA member clubs could help in the definition of the testing and benchmarking guidelines.


FIA member clubs have been testing and benchmarking city mobility infrastructure for several years (see answer to question 1). Based on the experience gained in past years the FIA member clubs will continue to carry out consumer testing of transport infrastructure in European cities. In this respect the FIA would welcome in the future further support from the EU. The EU supported the EuroTAP benchmarking programme from 2005 to 2007. The EuroTest has not been granted support by the EU.


4. How could the use of clean and energy efficient technologies in urban transport be further increased?

According to the Green Paper, over 60% of the population in the EU lives in urban areas (of over 10,000 inhabitants). These densely populated areas often suffer from nuisances coming from transport. It is therefore very important to further increase the use of clean and energy efficient technologies, both in private transport and in public transport. Only increase of clean and energy efficient technologies of one kind of  transport mode, for example private transport, will not be sufficient.


A targeted incentive policy should underpin the development of CO2 efficient technologies and fuels. To further increase the use of clean and energy efficient technologies in private transport, taxation of environmentally friendly vehicles should be lowered. Hence, the FIA supports the proposal for a Directive8 on car taxation based on CO2 as a vital part of the EU strategy to achieve sustainable mobility. Furthermore the FIA supports stricter emission limits to PM10 and NOx for new cars.


The FIA also believes that consumer information needs to play a major role. FIA studies provide evidence of the need and demand for better information. In this respect, a tool to increase the use of clean and energy efficient technologies in private transport is the information of the EcoTest programme9. The annual EcoTest, developed by the German club ADAC under the commission of the FIA Foundation10, supports consumers in choosing environmentally friendly vehicles, taking into consideration individual needs regarding vehicle size and class. The ADAC has been mesuring car exhaust emissions and informing the general public on emission values of almost 400 actual car models for the last five years. The Eco Test assesses the emissions of hydrocarbon (HC), carbon monoxide (CO), nitrogen oxide (NOx), particulate matter (PM) and the greenhouse gas carbon dioxide (CO2). The final star rating awarded to the different car models is based on toxic emissions and fuel consumption. The public interest in this important consumer information is shown by the numerous enquiries and requests for further measurements. The FIA believes that the Eco Test results should be used at the point of sale to allow consumers to make an informed purchasing choice. The EU should support this initiative and take the scheme into consideration when revising the fuel efficiency labelling directive11. On request of the European Commission the ADAC performed in 2005 a study about the availability of consumer information on fuel economy and CO2 emissions for new passenger cars. In order to be most effective, the study recommended an EU harmonised label at the point of sale. This recommendation needs to be implemented as soon as possible. The European Commission will adopt an amending proposal to improve the effectiveness of the directive, aiming inter alia at extending the scope of the labelling scheme to light-commercial vehicles (N1), harmonising the design of the label and at introducing energy efficiency classes in order to better raise consumer awareness at the time of car purchase. In this respect, the FIA is preparing a proposal for developing a harmonised label.


Eco-driving should as well be further promoted, both for private transport and for public transport. This is especially important in urban areas where a lot of stop and go occurs.


Vehicle on-board driver support systems, for example gear shift indicators and tyre pressure management systems, play as well a significant role in supporting the clean and energy efficient use of vehicles.

Real-Time Travel Information (RTTI) and routing guidance provided by GPS systems could as well be of importance in this context.


Further, the time needed by break-down services to intervene on accidents sites need to be reduced. When the traffic flow is disturbed for long periods of time, both pollution and congestion increase.

Improved traffic management is also an important part of the equation. Traffic lights need for instance to become more coordinated in order to provide a regular and smooth traffic flow. With a regular and smooth traffic flow pollution and congestion is reduced.


5. How could joint green procurement be promoted?

Stimulating environmentally friendly vehicles can help in the promotion of joint green procurement (see also answer to question 4).


Fleet managers need as well to be better informed on what joint green procurement means.


The introduction of environmental aspects in tendering should be further increased. In the future, environmental aspects should be an integral part of tendering.


6. Should criteria or guidance be set out for the definition of Green Zones and their restriction measures? What is the best way to ensure their compatibility with free circulation? Is there an issue of cross border enforcement of local rules governing Green Zones?

The EU, as the guardian of the treaties, needs to guarantee that traffic restrictions introduced at local level do not represent disproportionately barriers to the freedom of mobility of citizens and goods.


The FIA believes however that wherever possible, measures at local level which do not restrict mobility should be preferred in order to reach given objectives (for example air quality levels). Restriction measures, such as the ones put in place by the German local authorities in the framework of the Low Emission Zones (LEZs), should beforehand be thoroughly evaluated for their effectiveness and should be re-evaluated after having been put in place. A thorough impact assessment should be carried before any decision about an implementation should be taken. This has unfortunately not been the case up to now. In the few cases where restriction measures are necessary, they should be as limited as possible. In order to avoid unnecessary barriers to foreign travellers,
restriction measures such as Green Zones should make sure that the specific needs of foreign travellers are taken into account.


The FIA believes that, when low emission zones are implemented by local authorities, the zones should not form a barrier to free mobility in Europe. In the present day situation, countries and cities take different measures to implement low emission zones. The result of this is that motorists who travel through Europe don’t know what they are expected to do. They have to have a variety of vignettes and other instruments to be allowed to drive in a town. A next problem is that there is no unity at the time in which car is allowed in a city and which is not. This is different over cities and is much confusing for motorist. To improve free mobility throughout Europe, the EU should take the lead in harmonising information to be given to citizens about the low emission zones (European website in different languages, signposting, etc.). However, the decision to implement a low emission zone must be taken at a local level and there is in this respect no need for legislation at European level.


7. How could eco-driving be further promoted?

Initiatives to improve fuel efficient driving must play a key role in efficient CO2 abatement policies. In many countries eco-driving still receives little attention and plays known to the national audiences and policy-makers are not (well) aware of the potential of eco-driving. A communication strategy that focuses on the environmental and financial savings will give rise to the use of eco-driving in the EU.


Long-term analysis shows that the promotion of such driver information and education schemes increases overall fuel efficiency of passenger cars by five to ten percent, a nonnegligible contribution to reducing greenhouse gases. To further promote eco-driving, fuel efficient driving should be part of novice driver training while advanced driver training should help to sustain the long-term effect (see also answer to question 4). Member States should be encouraged to fund eco-driving courses.


In order to further promote eco-driving, the FIA will organise this year (in September 2008) the FIA EcoTour. The goal of the FIA EcoTour is to drive as fuel efficiently as possible, while still trying to be as fast as possible and respecting traffic rules.

What could be the potential role of the EU?


Concerning eco-driving, the EU will support the ECODRIVEN project until 2008. ECODRIVEN, the European Campaign On improving DRIVing behaviour, ENergyefficiency and traffic safety is a synchronised European-wide eco-driving campaign, iming at drivers of passenger cars, delivery vans, lorries and buses in 9 EU-countries, including Eastern-European countries. The campaign is based on a bottom-up approach through European-wide local and regional collaborations. The FIA believes that the ECODRIVEN project should get a follow-up. Another possible role of the EU concerning eco-driving, could be to give support to the FIA EcoTour.


Concerning joint green procurement, the European Commission adopted on the 19th of December 2007 a revised proposal for a Directive on the promotion of clean and energy efficient road transport vehicles12. Covered by the proposal are all road transport vehicles procured by public authorities and by operators providing transport services under contract, license, permit or authorisation by public authorities. It is important that this Directive is properly implemented. It will help to increase clean and energy efficient technologies in road transport.


For private transport, the EU should revise the European labelling scheme for new cars as this will help consumers to make informed choices. In this respect, the Eco Test programme and its labelling scheme should be taken into consideration (see also answer to question 4).


Concerning the taxation of environmentally friendly vehicles, it should be harmonised in the EU. The registration tax should be abolished in the EU. Further, the taxation 12 Directive COM(2007) 817 final should be linked to CO2 emissions and toxic pollutants. Linking taxation to CO2 emissions and toxic pollutants is not only the best choice for the consumer but it is also the best choice for the environment (see also answer to question 4).


The EU should as well continue to promote the EURO norms. This can include financial incentives to EURO 5 and EURO 6 vehicles.


8. Should better information services for travellers be developed and promoted?

The FIA believes that better information services for travellers should be developed and promoted. This could be done in several ways.


They could be developed both for private transport and for public transport and include a focus on multimodal integration.


For private transport, for example navigation systems with Traffic Message Channel (TMC) and or municipal parking guidance systems should be promoted. Such systems help to increase traffic fluidity, reduce congestion and avoid unnecessary detours. In the case of an accident or of road works, the system can calculate on the basis of Real-Time Traffic Information an alternative route.


Car-sharing and car-pooling information should be more easily available to the general public in urban areas, for example via the municipal website.


Furthermore, in order to improve the information about specific traffic restrictions put in place at local level, such as the LEZs in certain German cities and London or the EcoPass in Milan, the EU could help consumers to travel cross-border by putting in place an information website about local traffic restrictions put in place in the EU, informing mobile consumers about them and enabling them to get the necessary passes if applicable.


In certain Member States cities, a website informing the general public about the availability of parking places has been set up (e.g. the ADAC “ParkInfo-Service”13). Such initiatives help to improve urban mobility, since people are able to better plan their journey. Such schemes and the related information websites should therefore be further promoted.


For public transport, passenger information systems (for example pre-/on-trip information and doorstep-to-doorstep information) and digital timetables should be developed and put in place. Such information gives a competitive advantage to public transport.


9. Are further actions needed to ensure standardisation of interfaces and interoperability of ITS applications in towns and cities? Which applications should take priority when action is taken?

Yes, further actions are needed to ensure standardisation of interfaces and interoperability of ITS applications in towns and cities. It is important that the used technology will provide an open access to different service providers (e.g. RTTI). ITS applications that could take priority when action is taken are:

  • Real-Time Traffic Information (RTTI)
  • SpeedAlert systems
  • Route guidance / parking availability information
  • Variable message signs and variable speed management
  • Multi Modal door-to-door trip planning

With regard to speed information voluntary arrangements to fit technology such as ISA (Intelligent Speed Adaption) are the most likely to gain support.


10. Regarding ITS, how could the exchange of information and best practices between all involved parties be improved?

The exchange of information and of best practices between all involved parties can be improved by discussing them in forums, such as the eSafety Forum14. The eSafety Forum was established in early 2003 by the European Commission in close co-operation with the industry, industrial associations and public sector stakeholders.


The eSafety Forum is a joint platform involving the main road safety stakeholders, including the FIA. Its general objective is to promote and monitor the implementation of the recommendations identified by the eSafety Working Group and to support the development, deployment and use of eSafety systems.


What could be the potential role of the EU?

The EU should continue to give its support to forums such as the eSafety Forum.


The EU could help consumers to travel cross-border by putting in place an information website about local traffic restrictions operating in the EU, informing mobile consumers about them and enabling them to get the necessary passes if applicable.


The EU should promote the technical standardisation of interfaces and interoperability of ITS applications in towns and cities. The EU should also make sure that the technology provides an open access to different service providers. ITS applications that could take priority when action is taken are Real-Time Traffic Information (RTTI), SpeedAlert systems and Parking availability information.


11. How can the quality of collective transport in European towns and cities be increased?

In order to fulfil the needs of mobile consumers in public transport the service quality and service integration need to be further improved and considered from the start in the urban planning. To modify existing infrastructure at a later stage in order to improve the quality of collective transport is more difficult; it requires more efforts and is more costly.


The quality and sustainability of collective transport could be improved by:

  • Increasing bus average speed on main routes of public transport
  • Introducing interchange control systems
  • Using environmentally friendly vehicles
  • Improving passenger information (for example pre-/on-trip information and doorstep-to-doorstep information)
  • Introducing multimodal cashless payment systems (for example e-ticketing)
  • Increasing passenger comfort in vehicles
  • Decreasing vehicle noise (on-board and ambient noise)
  • Barrier-less road environment for the mobility impaired people
  • User friendly charges for tickets
  • Creating more safety by video-surveillance and security-guards

Furthermore, the relation of the price to the quality is important for mobile consumers.


12. Should the development of dedicated lanes for collective transport be encouraged?

In some very specific cases, the development of dedicated lanes for collective transport should be encouraged. These dedicated lanes should not only be at ground level, they could as well be underground, for instance to improve the passage through important traffic crossings. If dedicated lanes for collective transport are developed, and if these are under-used, it could be used for car-pooling, car-sharing, taxi and cycling15. In order to increase the flexibility of lane dedication, traffic management systems can vary the use of lanes according to the time of day or to the traffic situation using variable message signs in order to minimise congestion.


13. Is there a need to introduce a European Charter on rights and obligations for passengers using collective transport?

Yes, there is a need to introduce a European Charter on rights and obligations for passengers using collective transport. Such a charter would be beneficial in instances where passengers are either strongly encouraged to increasingly use collective transport (to build trust in the systems) or where their freedom to choose individual private vehicles is increasingly restricted in urban areas (due to high congestion or parking charges for example).


A charter would be useful in defining passengers’ rights and also distinguishing between what constitute rights and what constitute expectations (e.g. with the air passengers charter, there is no compensation for a delay only cancelled trips are compensated).


Passengers have a right to safe, efficient and cost-effective transport. The FIA automobile clubs would argue that passengers also have a right to expect certain levels of quality from the collective services offered. Information provision and communication are key elements in this respect.

  • General service information (e.g. regarding timetables - date of publication/expiry/explanation of the different versions – during the week /weekends etc)
  • Information about how to contact the service provider / customer relations
  • definition of the service providers standard customer polices regarding refunds, how to make claims
  • Information about how to make a complaint with an indication of how they will be treated.
  • Information about how passengers / users can participate in monitoring groups consulted by the service provider regarding the quality of the services provided.

There is also a need to guarantee the multimodal links between urban and suburban / interurban environments. In densely urban areas, passengers will generally always find a means to complete their journey hopping from one collective mode to another. In suburban / less dense interurban areas, providers of collective transport need to provide passengers with guarantees they also will be able complete their journeys by maintaining the necessary multimodal chains.


To further support a European Charter on rights and obligations for passengers using collective transport, on-going monitoring and benchmarking of the collective transport services provided in terms of safety, efficiency, cost effectiveness and quality would provide passengers with regular updates on the current situation and also highlight best practices and failings that operators should take heed of. As seen by FIA automobile clubs in their regular benchmarking assessments (carried out by EuroTest, EuroTAP, EuroRAP and individual club assessments of services such as buses and metros) of the mobility infrastructure across Europe, such measures can also help to create and strengthen the internal market in mobility. By instilling competition, such benchmarking exercises can stimulate competition sufficiently to lead to improvements at a faster pace than legislation alone.


14. What measures could be undertaken to better integrate passenger and freight transport in research and in urban mobility planning?

The FIA believes that any urban mobility solution needs to take into account the mobility of people and of goods. The following measures could be undertaken to better integrate passenger and freight transport in research and in urban mobility planning:

  • Close co-operation and co-ordination between the different actors and the authorities need to be established.
  • An inventory of best practices should be put in place and these should be disseminated.
  • Spatial planning should be improved.
  • The co-ordination between passenger and goods transport should be improved.
  • Technical investments (for example infrastructure improvements, traffic guidance systems, green waves and dedicated freight parking spaces) should be realised.
  • Incentives to promote new technologies to further develop clean and energyefficient vehicles for private and commercial usage as well as a transition period for supply traffic until the production of new truck propulsion technologies should be available.
  • Tailor-made solutions at local/regional level are needed
  • Access for freight transport within city centres – if necessary within specific but adequate delivery times (of minimum 4 continuous hours) needs to be guaranteed.
  • Public-private partnerships and co-ordination is needed.
  • Freight transport delivery times could take place during the night.

15. How can better coordination between urban and interurban transport and land use planning be achieved? What type of organisational structure could be appropriate?

Better coordination between urban and interurban transport and land use planning can be achieved through, for example appropriate park-and-ride structures and multimodal e-ticketing.


Park-and-ride structures will facilitate the switch between transport modes, for instance between private transport and public transport, both in urban and interurban areas. With multimodal e-ticketing, a person will be able to buy a ticket that will cover all of his/her travel (urban and interurban as well as change of transportation modes, for example from train to bus).


In order to improve the coordination between urban and interurban transport, a kind of regional mobility agency could be set up that can play a bridging role between interurban and urban transport and guarantee seamless mobility.


What could be the potential role of the EU?

The EU should introduce the European Charter on rights and obligations for passengers using collective transport Charter.

As written before, The EU should as well promote further research in the field of urban mobility.


16. What further actions should be undertaken to help cities and towns meet their road safety and personal security challenges in urban transport?

Measures in the fields of infrastructure, traffic management and traffic telematics can contribute to improving road safety in urban areas. As for infrastructural measures traffic calming measures in residential areas can be complemented with the enhancement of the main road network (e.g. ring roads, tunnels, roundabouts). With regard to traffic management it is important to optimise the organisation of the incidents and road work zones. Additionally better signposting should enhance mobility with a special care for foreign visitors. An increased use of traffic telematics in the vehicle (e.g. car-to-car communication, eCall) or on the road can also contribute to more road safety. The subjective security in collective transport can be significantly improved through the introduction of new vehicle with walkable articulations. Moreover the increased presence of service personnel or video surveillance in stations and vehicles can help to increase the subjective security in collective transport.


To set minimum requirements for road infrastructure safety and personal security should help cities and towns to meet their road safety and personal security challenges in urban transport.


An initiative, such as the Trans-European Transport Networks “TEN-T”, could be envisaged for the urban level. Such an initiative could help to improve interconnection and interoperability of urban transport and interurban as well as the access to them.

As mentioned before, FIA member clubs participate in different benchmarking programmes at the European level (for example EuroTAP16 and EuroTest17). These different benchmarking programmes could be of benefit to cities and towns in helping them to meet their road safety challenges.


Another relevant programme at European level in which FIA member clubs are involved is the European Road Assessment Programme (EuroRAP)18. The aim of EuroRAP is to show how European roads can be made safer, so that the car and road work together to protect life. The methodologies developed by EuroRAP for interurban roads could as well, if further developed with an urban focus, be of benefit to cities and towns in helping them to meet their road safety challenges.


17. How can operators and citizens be better informed on the potential of advanced infrastructure management and vehicle technologies for safety?

FIA member clubs could inform their members via their respective magazines on the potential of advanced infrastructure management and vehicle technologies for safety.


The EU could do the same at European level via public campaigns in for example newspapers, magazines and on Internet.


18. Should automatic radar devices adapted to the urban environment be developed and should their use be promoted?

Traffic controls have increased significantly over the past years. Europe’s traffic offenders provide Member States and cities every year with income of several billion Euro. The positioning of the stationary radar devices and of the mobile controls is however often to be criticised. The reason for the criticism is that the measurement is often carried out where the higher income can be made, as for example on main roads.


Speed controls are however according to the FIA only successful when the persons concerned do not feel cashed in, but recognise the sense of the control measure.


The increased controls that are often called for have generally only a short term effect and do not change the behaviour of the drivers on the long term. The FIA calls upon the authorities concentrate traffic controls in the future on accident black spots and dangerous road sections as well as to apply appropriate tolerances when allowed speed limits are exceeded.


More research into the cost effectiveness of such devices and their deployment across the EU is needed to determine to what extent they are effective in preventing accidents and also facilitating smoother traffic flows at optimal speeds in the long-term.


The FIA would argue that in urban areas much more emphasis should be place on the design of the infrastructure (e.g. roads) coupled with complementary speed limits as a better means of controlling traffic flows. Over the next two years, FIA clubs will be looking at the design and use of pedestrian crossings in this context.


19. Is video surveillance a good tool for safety and security in urban transport?

The use of cameras to survey traffic can according to the FIA contribute to quicker detection of congestion and traffic incidents if this is their principle purpose. If the data is transmitted via the related information systems to the drivers they can appropriately approach the area of the congestion or the traffic incident and so minimise the danger of accidents. Video surveillance in the area of collective transport can represent an appropriate tool to reduce vandalism and physical violence in buses and trains. Apart from the deterrent factor, video surveillance is probably more useful in the investigation of offences and crimes committed rather than in their prevention.


What could be the potential role of the EU?

The EU should continue to promote the different benchmarking programmes at European level in which FIA member clubs are involved (EuroTest, EuroRAP and EuroTAP).


The EU should as well launch information campaigns at the European level in order to better inform local authorities, operators and citizens (e.g. eSafetyAware with ChooseESC to which the FIA member clubs have strongly contributed).


20. Should all stakeholders work together in developing a new mobility culture in Europe? Based on the model of the European Road Safety Observatory, could a European Observatory on Urban Mobility be a useful initiative to support this cooperation?

A European Observatory on Urban Mobility could be a useful initiative to help cities to exchange information. But it is very important that the future role(s) and duty/duties are initially well defined. The European Observatory on Urban Mobility should serve as a place where best practices can be exchanged. Moreover an Observatory could help the EU to gather facts and figures about urban mobility to help mainly local authorities to analyse mobility issues and to define appropriate transport policy.


As for reliable figures about urban mobility a lot of information is available. This statistical information is however difficult to compare since it relies on different definitions of the Member States. It is therefore unlikely that a European Observatory on Urban Mobility can contribute to better data


21. How could existing financial instruments such as structural and cohesion funds be better used in a coherent way to support integrated and sustainable urban transport?

The structural funds and the cohesion funds are funds allocated by the EU for two related purposes: (1) Support for the poorer regions of Europe and (2) Support for integrating European infrastructure especially in the transport sector. They have three objectives: Objective 1 –  Convergence, Objective 2 – Regional competitiveness and employment and Objective 3 – Territorial Cooperation.


The structural and cohesion funds could be better used in a coherent way to support for example further research on traffic management, ITS and joint green procurement since one of the funds purposes is to integrate European infrastructure, especially in the transport sector.


The EU should via its own website better inform about the existing funding possibilities as well as best practice examples.


22. How could economic instruments, in particular market-based instruments, support clean and energy efficient urban transport?

CO2 and toxic pollutant emissions linked taxation and joint green procurement are examples of market-based instruments that could support clean and energy efficient urban transport. But, all market-based instruments are not of interest. One market-based mechanism, even if it is theoretically a good method, that is not suitable for private transport, is the Emission Trading Scheme (ETS). In order for the ETS to be efficient, the potential number of participants needs to be kept low. In private transport, the potential number of participants is relatively high. Therefore, an eventual ETS for private transport would be inefficient.


23. How could targeted research activities help more in integrating urban constraints and urban traffic development?

Targeted research activities could address several particular objectives: promoting competition between open-source technologies as well as promoting technical harmonisation, promoting best practices all across the EU and give municipalities the tools they need to implement them.


In the case of urban mobility, targeted research activities could be structured along the following four research areas.

  • Area 1: Data collection / Demand analysis / Health impact research
  • Area 2: Sustainable strategies / Traffic planning & management / Land use
  • Area 3: Urban transport supply side / Integrated and harmonised systems and services
  • Area 4: User aspects: Safety, security, comfort, accessibility

Each of these areas could then be analysed with the purpose to:

  • Screen and comment on existing documents at the European level, such as Strategic Research Agendas and European Research Projects, so as to propose some European targets for a sustainable urban mobility, keeping in mind the major role of transport authorities at the national and local level in each Member State
  • Identify the research topics which can be regarded as essential for their consideration in the future draft of the Urban Mobility Strategic Research

Agenda to be set up at the European level.

The targeted research activities needs should be driven by the needs of urban mobility, i.e. decision makers as well as by urban transport users.


24. Should towns and cities be encouraged to use urban charging? Is there a need for a general framework and/or guidance for urban charging? Should the revenues be earmarked to improve collective urban transport? Should external costs be internalised?

Town and cities should not be encouraged to use urban charging. The case of the congestion tax in Stockholm, which was discussed above in question 1, shows that efficiency of urban charging still needs to be proven. The Green Paper refers to the congestion charging schemes of Stockholm and London while no thorough impact assessment has been carried-out, neither before the implementation, nor after.


The FIA believes that a prerequisite for sustainable mobility is ensuring smooth traffic flow - avoiding congestion -, limiting nuisances (noise, air pollution, etc.) - and giving a high level of safety - avoiding accidents – while keeping it affordable for all.


The FIA believes that there is no need for a general framework and/or guidance for urban charging. Congestion is a local problem that needs local solutions. The FIA does not see an added value of any European action in this field.


With regard to the costs that traffic congestion and related obstacles impose on European economies, the FIA would particularly like to draw attention to the issue of quantification. A vital tool to assess transport-related problems is sound statistics. Quantifying transport performance should be an important step when highlighting a problem, assessing its extent and defining the need for action. Quantified evidence of traffic congestion partially exists on a national or regional level following national or regional statistical methods. The FIA is however, not aware of any usable pan-European statistics. The main reason for this is that – like in many other areas – statistical methods have not been harmonised. Furthermore, there is no agreed definition of what congestion exactly is and how it is to be measured. The figures given in the documents published by the European Commission are therefore in our opinion not of any use. The cost of congestion was estimated in the Green Paper at approximately 1% of Community Gross Domestic Product (GDP). The European Commission for a long time (notably in its White Paper of 2001) announced a cost of 2% of GDP. The UNITE report (Unification of  accounts and marginal cost for transport efficiency) reported a figure for France of 3.5% of GDP.


According to estimations done by Pierre Kopp and Rémy Prud’homme19, the cost of congestion amounts to 0.1 % of GDP in the centre of London and to 0.14 % of GDP in the centre of Stockholm, both city centres being among the most congested places in Europe.

In discussions that the FIA had with statistical and economical experts of the European Commission and of EUROSTAT, it has become clear that usable statistics or even common definitions do not exist on an international, pan-European level. In this regard, developing policies to combat traffic congestion without usable definitions or numerical and statistical foundations is like developing economic policy without sound GDP figures, interest rates or price indices. The FIA underlines that under these circumstances the European Commission should be very careful in defining European guidelines or even recommendations with regard to solving local congestion problems.


As for congestion charging schemes that have already been introduced by local authorities, the FIA believes that the revenues should not only be earmarked to improve collective transport. A part of the revenues, if not the majority, could be as well be earmarked for infrastructure investment and maintenance.


As for nuisances coming from the transport activity, the FIA is of the opinion that these should be minimised and that the users of transport should pay for this reduction. External costs of private transport should however not be internalised by levying additional taxes or charges. Avoiding and reducing negative effects of traffic is much more adequate then charging for them. This includes measures to reduce environmental nuisances (for example tight emission standards, testing car emissions  via Eco Test, eco-labelling and intelligent schemes for annual circulation taxes) and improving road safety (via for example EuroTest, EuroRAP and EuroTAP).


Private transport already overall covers its internal and external costs by far. Traffic benefits should as well be studied in this context and be  considered in the Action Plan on urban mobility and future public consultations.


25. What added value could, in the longer term, targeted European support for financing clean and energy efficient urban transport, bring?

In the longer term, targeted European support for financing clean and energy efficient urban transport should help to bring up a competitive European market for clean and energy efficient urban transport solutions.


This market should in turn enable the EU to export these solutions to the rest of the world. The EU is already a leader in environmental matters (for example in fuel efficiency and combating climate change). In the urban environment, the EU could as well become in the longer term a leader in clean and energy efficient urban transport.


Targeted European support for financing clean and energy efficient urban transport should as well bring better and more efficient traffic  management systems and should further promote joint green procurement.


What could be the potential role of the EU?

The EU should not set a general framework and/or guidance for urban congestion charging or low emission zones. Congestion and air pollution are a local problem that needs local solutions. The FIA does not see an added value of a European action in this field.

The EU should support the creation a competitive European market for clean and energy efficient urban transport solutions and promote in the rest of the world the solutions put forward by this market.


The EU should promote end user awareness campaigns.


The FIA believes that, similar to the implementation of low emission zones, any form of congestion charging should not form a barrier to free mobility in Europe. The EU should take care of harmonisation of information to citizens (traffic signs, set of rights of mobile citizens), also in their own language.


The FIA remains at your disposal for any further discussion should you so wish.
Wil Botman
Fédération Internationale de l’Automobile (FIA) European Bureau


For more information please contact:
Olivier Lenz
Fédération Internationale de l’Automobile (FIA) European Bureau
Rue d'Arlon 53
1040 Bruxelles
Tel: +32 2 282 08 25
Fax: +32 2 280 07 44
March 2008


  1. COM (2007)551 final
  3. The Stockholm Toll: An Economic Evaluation (January 25, 2007, revised May 3
  4. Directive 1999/94/EC
  5. More information about research carried out by the Automobile Association (AA) canbe found on
  6. See also
  7. See also
  8. COM(2005) 261 final
  9. See also
  10. See also
  11. Directive 1999/94/EC
  12. More information about the scheme developed and implemented by the ADAC can be found on
  13. See also
  14. More information about research carried out by the Automobile Association (AA) can be found on
  15. For further information see also
  16. For further information see also
  17. For further information see also
  18. Pierre Kopp, Rémy Prud’homme (2007), The internalisation of external costs in the transportation system.


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