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Fighting Transport Poverty

with the Social Climate Fund

Recommendations

to Member States

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A unique opportunity – now Karen Vancluysen1

POLIS is the leading network of European cities and regions advancing transport innovation. We’re

committed, specifically, to innovations that can make urban, suburban, and rural mobility more

sustainable, safe, and equitable.

Our network brings together more than 120 local and regional governments and transport

authorities from across the European Union, with a simple but essential mission: finding and

implementing real solutions, for real problems, affecting real people, to build a real future.

That’s what local government is about. That is also what the European Union is about. And that’s

why our members are stepping forward with mobility policies and measures that deliver on

ambitious EU goals for sustainability, safety, competitiveness, and cohesion.

This is not an easy undertaking. We’re addressing very complex challenges, of a systemic nature,

created and sustained by land use, transport, and industrial policies. Real progress requires setting

new priorities, adopting new approaches, crafting new tools, and (re)building organisational

capacity2.

On top of that, this transition must be implemented in a very challenging context, where financial

resources are limited, speed is of the essence, and political polarisation can undermine dialogue,

foster misunderstandings, and quickly flame revolt.

The Social Climate Fund (SCF) can become a precious step in the right direction, but only if that

direction is taken decisively, and if the following steps are well aligned. Otherwise, we will stumble.

To support the development of Social Climate Plans, the European Commission has published a

lengthy report on Transport Poverty3, and a set of good practices4, including recommendations

formulated by the Expert Group on Urban Mobility (EGUM)5.

POLIS contributed to the EGUM’s recommendations, and strongly supports these efforts made by

the European Commission to help Member States make the most of this opportunity. In addition,

I believe it must be said that our active participation, over the years, in several European projects

and actions for transport research and innovation, has endowed our network with a unique

capacity to contribute on this matter. And with that capacity, I also believe, comes responsibility.

1 POLIS Secretary General. 2 To address the wider set of issues raised by the transition, POLIS established a “Just Transition Agenda”, which maps the

path to making transport inclusive (available here: https://www.polisnetwork.eu/wp-content/uploads/2021/11/Just-

Transition-Agenda-AGA.pdf). 3 European Commission (2024), “Transport poverty: definitions, indicators, determinants, and mitigation strategies - Final

Report” (available here: https://employment-social-affairs.ec.europa.eu/transport-poverty-definitions-indicators-

determinants-and-mitigation-strategies-final-report_en) 4 Available here: https://climate.ec.europa.eu/eu-action/eu-emissions-trading-system-eu-ets/social-climate-fund/good-

practices-social-climate-plans_en 5 Expert Group on Urban Mobility (2024), “Social Climate Fund” (available here:

https://transport.ec.europa.eu/document/download/f7e54ea5-23aa-4f8d-a24c-

9d902fc9652c_en?filename=EGUM_Recommendations_Social-Climate-Fund.pdf)

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We therefore take this opportunity for further contribution, with this set of strategic

recommendations, based on sound research and solid experience.

These recommendations are addressed to the Member States, who have a leading role to play in

the development of the (national) Social Climate Plans. They are also meant to support the work

of local and regional authorities, who will always have ‘the’ critical role to play in the successful

implementation of these plans.

We hope this document will also encourage the active involvement and positive contribution of

many stakeholders, from transport providers to advocates for sustainable mobility, road safety,

regional development, and social cohesion.

We at POLIS remain committed to working with all levels of European governance – local, regional,

national, and international – to address the key challenges of our time. Because the future starts

today, not tomorrow.6

6 Pope John Paul II (1920-2005).

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Table of Contents

A unique opportunity – now ...................................................................................................................... 2

Introduction ............................................................................................................................................... 5

1. The (real) Challenge .................................................................................................................... 7

1.1 Transport poverty is a structural problem requiring structural action .................................. 7

1.2 The key challenge is access, not movement .............................................................................. 8

1.3 Transport poverty is a regional problem .................................................................................... 8

1.4 For many households, owning a car will never be a “solution” ............................................... 9

1.5 Car dependency means lack of choice, not “freedom of movement” .................................... 9

1.6 We must (really) address vulnerability to fuel price increases .............................................. 10

1.7 Only alleviating the symptom perpetuates the problem ....................................................... 11

1.8 Transport poverty feeds injustice, and injustice fuels revolt ................................................. 12

2. Strategic Recommendations .................................................................................................. 14

2.1 Transport and Energy Poverty require different approaches ............................................... 14

2.2 Prioritise a multimodal approach .............................................................................................. 15

2.3 Build on a solid foundation: Public Transport ......................................................................... 16

2.4 Boost offer and demand for Shared Mobility .......................................................................... 18

2.5 Make the infrastructure protect freedom of choice ............................................................... 19

2.6 Mobilise the community’s social capital ................................................................................... 20

2.7 If users can’t reach the services, help services reach the users ............................................ 21

2.8 Mainstream service to vulnerable users .................................................................................. 23

2.9 If a car is “indispensable”, limit support to the indispensable .............................................. 26

2.10 Follow a focused approach to micro-enterprises ................................................................... 27

3. Empower Cities & Regions as Key Actors ............................................................................. 28

3.1 Consult & Cooperate for Effective Action ................................................................................. 28

3.2 Fund Sustainable Urban Mobility Planning (SUMP) ................................................................ 30

3.3 Set proportional targets for application of the Fund .............................................................. 31

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Introduction

The weight of road transport in the EU’s greenhouse gas emissions is well-known. For the EU to

become climate-neutral in 2050, road transport must undergo major transformations.

The European Union (EU) has taken key steps to decarbonise road transport. One of the most

important is the Emissions Trading System 2 (ETS-2), which will have a deep impact on the

everyday lives of European households and businesses.

Since Nicolas-Joseph Cugnot's 1769 steam tricycle7 started rolling, the use of fossil fuels in

transport has grown exponentially, fuelling the expansion of urbanised areas, transport

infrastructure and services, industrial capacity for car manufacturing, and personal mobility, all of

this in a mutually reinforcing manner.8

Structural factors drive recurrent choices, repeated choices become habits, and habits grow roots.

While freedom of movement and individual choice cannot be discarded in democratic societies,

we must not ignore that most mobility choices are driven and sustained by structural factors. We

must not ignore, either, that the current mobility system generates important negative

externalities, which pose collective threats.

Our current transport system is based on the massive consumption of fossil fuels, and the

consequent emission of massive amounts of carbon dioxide (CO2). By putting a cap on CO2

emissions, the ETS-2 will raise the price of fossil fuels.9

That rise will pose a serious challenge to households and enterprises whose everyday

mobility patterns require the consumption of large amounts of fossil fuels. They need

proper transport alternatives to be ready and rolling when that happens.

The absence of those alternatives will have serious economic, social, and political impacts.

To avoid those negative impacts, the ETS-2 provides the time, and the Social Climate Fund

provides the funds, to put in place adequate solutions.

These solutions will be particularly important for populations in low-density suburban, peri-urban,

and rural areas. For reasons explained below, they are among the most vulnerable to the rise of

fossil fuel prices in transport, with the inevitable threat this carries in terms of regional cohesion,

social peace, an urban-rural divide, and the political viability of climate policies. But they are also

among the ones who most stand to benefit from a shift towards a more sustainable, safe, and

affordable transport system.

Creating efficient, affordable, and reliable transport solutions for households and micro-

enterprises requires scale, speed, hands-on support, mobilisation of financial, political, and social

capital, integration of different sectors, concrete outcomes, and lasting impacts.

7 The first self-propelled land vehicle, a three-wheeled machine with a top speed of around 3 km/h originally designed for

carrying artillery. 8 The expansion of one factor pushes the expansion of the others. 9 The cap will be lowered on an annual basis, further raising prices if demand does not decrease.

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The SCF provides a way to prepare and act – but it will only be effective if it funds change in the

right direction. This requires clear choices, coherent measures, and cooperation. “Sprinkling”

subsidies at the national level with no local changes to match will just reinforce the status quo and

open no new path towards overcoming our structural problems.

It is of the utmost importance that these national plans are steered towards effective, timely, and

lasting results at the local and regional level. After all, it’s the lack of local and regional solutions

for everyday life that sparks revolt.

Local and regional governments and transport authorities must play a key role in the development

and implementation of the national level Social Climate Plans. This is simply logical, as they

(A) have jurisdiction over the vast majority of the EU’s total road network, (B) fund, and often also

operate, public transport, (C) are best placed to steer new mobility services towards serving public

needs, (D) have the duty of reducing road risk for walking and cycling, (E) have the duty of

eliminating barriers that discriminate based on disability, age, gender and income, and (F) are best

placed to engage with a vast number of communities, households and micro-enterprises, to shape

and support mass behaviour change.

Planning and implementing the SCF is a joint challenge, which requires a cooperative and coherent

approach across levels of government. For that reason, this document provides a way to

understand and frame the (real) challenge, strategic recommendations for an effective approach,

and some basic principles to best empower European cities and regions as key actors in this

process.

These recommendations have been prepared to support EU Member States, which have the role

of preparing the national level Social Climate Plans. The recommendations are also shared to

support and encourage the active contribution of local and regional authorities, and of many

relevant stakeholders, to these national plans.

Charles Darwin found that “the species that survives is the one that is able best to adapt and adjust to

the changing environment in which it finds itself”. 10 The Social Climate Fund provides a unique

opportunity to adapt our mobility systems. How can we best use it? This is a question we must

answer together.

10 Charles Darwin (1809-1882), English naturalist, geologist, and biologist.

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1. The (real) Challenge

Regulation (EU) 2023/955 (Social Climate Fund) defines transport poverty as the “inability or

difficulty” of individuals and households “to meet the costs of private or public transport, or their lack

of or limited access to transport needed for their access to essential socioeconomic services and

activities, taking into account the national and spatial context”. 11

A problem well-defined is a problem half-solved.12 Solving the ‘other half’ requires understanding

the root causes and key characteristics of the problem, acknowledging its complexity, and avoiding

simplistic explanations and approaches that may temporarily alleviate some symptoms but won’t

lead to effective solutions with lasting effects.

We recommend that the Member States consider the following key points, regarding the

understanding and framing of the challenges posed by Transport Poverty:

1.1 Transport poverty is a structural problem requiring structural action

Transport poverty is a result of (A) how people and activities have been distributed in space,

(B) how the transport system has been shaped and managed to connect them, and (C) how public

and private resources have been allocated to cover the capital and operational costs of that

system, as well as its externalities.

The insufficiencies we face today in suburban, peri-urban13, and rural areas derive in good part

from how land use and transportation policies pursued over the past century enabled and

fostered individual car ownership and use, relegating other modes to a secondary role.

The convergence of other changes accelerated and reinforced those effects. The rural exodus

towards urban areas, for example, depleted rural areas from population and services, and

expanded urban areas with vast low-density suburbs that do not favour mass public transport nor

active mobility. Also here, individual car ownership and use was often seen as the default solution.

This has created a situation of car dependency.

The question is not whether this situation can be undone in a fast and ‘painless’ way, because it

clearly cannot. What we must understand is that Transport Poverty results from, and is sustained

by, underlying structural factors. This makes it a structural problem.

Overcoming structural problems requires structural action, namely (A) setting a sound and smart

strategy, pointing at a clear direction for improvement, (B) removing obstacles that are impeding

change in that direction, (C) prioritising investments that help advance in that direction, and

(D) avoiding any measures that undermine the effort (particularly measures that, under the guise

of temporary relief, end up prolonging the problem).

11 Cf. Article 2, number 2. 12 John Dewey (1859-1952), American philosopher, psychologist, and educational reformer. 13 For the purposes of this document we can briefly designate as “suburban” areas with some open land, and as “peri-

urban” areas with very sparse development.

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While the afflictions caused by transport poverty must be addressed, the key question we

face with the Social Climate Fund and its national-level implementation is whether it will

be invested on the permanent removal of the problem, or wasted on the temporary relief

of its symptoms (while the problem keeps growing).

1.2 The key challenge is access, not movement

The core problem of transport poverty is that it harms access to essential socio-economic services

and activities such as health, education, jobs, leisure, political participation, etc.

Access implies movement, but increased movement does not, necessarily, improve access. Often,

quite the contrary – displacing a public service away from those who need it will force its users to

travel longer distances, thus increasing mobility (i.e., amount of kilometers travelled) while

reducing access.

The purpose of transport is not ‘movement’, but access. Naturally, movement enables access, but

efficiency is key for equity. The more movement is required from the household to conduct its

everyday life, the more energy it has to consume, the higher the energy costs it must bear, the

more vulnerable it becomes to an increase in the cost of energy, and, therefore, the more

vulnerable it becomes to transport poverty.

That’s why suburban, peri-urban and rural areas are particularly vulnerable, and why shared

transport solutions (e.g., public transport, demand-responsive transport, carpooling) are among

the most equitable – by aggregating trips they reduce the total amount and cost of km/passenger.

The core challenge for the Social Climate Fund is not to help sustain the inevitable ‘pains’ of

inefficient and inequitable mobility, but to improve access. This shift in perspective is crucial

to understand the problem, prioritise effective solutions, and unlocking innovative

approaches – we must help people reach basic services, but we can also, for example, invest

on helping the services reach them.

1.3 Transport poverty is a regional problem

Transport poverty is a local and regional issue. It is not about sporadic access to the whole country,

but about everyday access to local places for work, public and private services, and other

components and opportunities of social, civic and economic life. It requires local and regional

assessment, action, and responsibility.

Transport poverty is driven by an insufficient level of availability, accessibility, and affordability.

Addressing these insufficiencies requires (A) consulting with the community to understand the

specific needs and the specific resources available in a specific context, to (B) establish what is to

be considered a sufficient level14 of availability, accessibility, and affordability, in order to (C) define

context-specific strategies and priorities, and to (D) mobilise available resources towards ensuring

those sufficient levels for all, and finally (E) evaluating the efficacy of the measures, (F) assuming

responsibility for those results, and (G) correcting the course where and when necessary.

14 Cf. for example Karel Martens, keynote at the 2021 POLIS Conference keynote (available here:

https://www.youtube.com/live/58e_i2Vlrkk)

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All the steps above will have to factor in local context, local needs, and local resources. And

they will require political decisions with political responsibility at the local level.

Local and regional authorities are the level of government which has the legitimacy to lead on the

local and regional scale, the duty of finding practical solutions, and the responsibility of answering

politically for the efficacy of those solutions. That’s why it is indispensable to actively involve them

in the development and implementation of national plans for the SCF.

1.4 For many households, owning a car will never be a “solution”

Transport poverty is a multidimensional problem, which affects different types of individuals and

households, in different ways, in different spatial contexts. We must guard against generic

characterisations and simplistic solutions.

For example, saying that “many people really need a car” can be very misleading, because (A) it

obscures the plight of a large part of the population who cannot afford or cannot drive a car, e.g.,

the elderly and the young, persons with some types of disabilities, households with lower incomes;

(B) in car-owning households, it treats as irrelevant and subordinate the needs of household

members who cannot access that resource, e.g., women, youth, children; (C) it misses the fact that

the costs of a car impact very differently households with different levels of income; (D) it assumes

as equally inevitable a problem that can be addressed very differently, whether in rural or in

suburban areas; (E) it assumes there are individuals for whom the car is the only and best solution

for all trips, at all times of the day, on all days of the year, and for all purposes, which is a very rare

exception; (F) it assumes that the need of a car necessarily implies individual ownership, obscuring

the economic benefits that carpooling and car sharing can provide to households and individuals,

while satisfying their needs.

It may be true that those who do own and drive a car will feel a strong ‘sting’ with the rise of fuel

prices that will derive from the application of ETS-2 to road transport, and the Social Climate Fund

must address these groups.

But we must bear in mind, first, a constitutional imperative to pursue equity (and also support

those who do not own cars), and, second, a functional imperative: in most cases, improving

transport for those who do not own a private car is the best way to build an alternative for

those who do. “You’re never wrong for doing the right thing”.15

1.5 Car dependency means lack of choice, not “freedom of movement”

Freedom of choice requires the availability of comparable options. The existence and persistence

of severe differences between transport options makes them less comparable, and sometimes

not comparable at all.

Structural factors turn differences into disadvantages, and can heavily distort choice, pushing

individuals and households away from transport modes perceived as slower or unsafe. This

distortion is aggravated by the fact that car owners tend to not be aware of the full cost of

15 Samuel Langhorne Clemens (1835-1910), writer known as Mark Twain.

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individual car ownership and use,16 thus ignoring the full weight it has on the households finances,

and the potential savings they could make with other choices.

Distortion of choice reduces freedom of choice. In suburban, peri-urban and rural areas. This

severely constrains freedom of movement, as households are forced to choose between allocating

a significant portion of their income to individual car ownership, or a significant portion of their

time (and safety) to public transport or active mobility.

For the households who can (barely) afford it, forced car ownership17 is not a measure of ‘freedom’,

as it further aggravates financial vulnerability – research shows that forced car owners have

difficulty paying for heating and other basic expenses.18

In a way, these are mobility costs imposed by the lack of mobility choice, both for (A) those who

move to lower-priced suburban areas as a residential strategy to deal with rising housing costs,

and (B) those who remain in rural areas, as the distance to public services (education, health, social

care, postal, etc.) forces them to travel farther.

The solution lies not in keeping households locked in this ‘economic servitude’, nor in making their

lack of choice ‘palatable’. Forced car ownership is a structural problem to be overcome, not the

result of “free popular choice” in a “level-playing field” to which one must subordinate mobility

policies.

Overcoming forced car ownership requires creating the conditions for true freedom of

choice, by, at least, (A) diversifying options in terms of available modes of transport (public

transport, demand responsive transport, cycling, etc.), and (B) diversifying options in terms

of ownership (e.g., car sharing and carpooling, which have substantially lower costs).

1.6 We must (really) address vulnerability to fuel price increases

For individuals and households in a situation of forced car ownership, the vulnerability to fuel price

increases has three key parameters19: (A) exposure, i.e., how much the car is used and how much

fuel is consumed, (B) sensitivity, i.e., the resulting impact of the cost increase in relation to the

household’s available income, and (C) adaptive capacity, i.e., the ability to resort to less onerous

transport solutions, which depends, of course, on their availability and reliability.

16 Cf. for example Stefan Gössling, Jessica Kees, Todd Litman (2022), “The lifetime cost of driving a car”, Ecological

Ergonomics, Volume 194, April: “Motorists underestimate the full private costs of car ownership, while policy makers and

planners underestimate social costs.” 17 “Forced car ownership’ (FCO) applies to households who own cars despite limited economic resources (…) [it] results in

households cutting expenditure on other necessities and/or reducing travel activity to the bare minimum, both of which

may result in social exclusion. (…) The FCO phenomenon suggests that, among households with limited resources,

the enforced possession and use of a durable good can be the cause of material deprivation, economic stress and

vulnerability to fuel price increases”, in Giulio Mattioli (2017), “‘Forced Car Ownership’ in the UK and Germany: Socio-

Spatial Patterns and Potential Economic Stress Impacts”, Social Inclusion, Vol 5, No 4. 18 Cf. for example the presentation made by Mathias De Meyer, from Brussels Mobilité, at the 7th October 2024 meeting of

the POLIS Working Group for Governance & Integration (which can be made available upon request to POLIS or said

researcher). 19 See for example Giulio Mattioli, Ian Philips, Jillian Anable, Tim Chatterton (2019), “Vulnerability to motor fuel price

increases: Socio-spatial patterns in England”, Journal of Transport Geography, Volume 78, June.

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The Social Climate Fund includes, among its eligible measures, temporary direct income support.

We must highlight that, without a multimodal offer, that measure can only influence one of these

parameters (sensitivity), and in a very limited manner.

Another eligible measure is funding the purchase of zero- or low-emission cars, either through

first- or second-hand markets. This measure has limited benefits in terms of sensitivity20, and

essentially converts vulnerability to fossil fuel prices into vulnerability to electricity prices.

Investing in the growth of public transport and in the diversification of complementary

transport solutions such as shared mobility, walking, and cycling, is the most effective,

efficient, and reliable way of reducing vulnerability to fuel price increases.

First, because it increases adaptive capacity, by providing less onerous alternatives. Second,

because it reduces exposure: in the case of public transport, demand responsive transport and

carpooling, by dividing the number of km of the vehicle by its several passengers; in the case of

walking and cycling, by resorting to the energy of the traveller himself (i.e., not having to pay for

externally sourced fuel). Finally, because it reduces sensitivity, as transport services buffer the

impact of energy price fluctuations.

1.7 Only alleviating the symptom perpetuates the problem

The general objective of the Social Climate Fund (SCF) is to contribute to a socially fair

transition towards climate neutrality. Making this transition fair requires using the SCF to

increase the offer of sustainable mobility options for the groups targeted by the Fund.

Making this transition effective requires avoiding the dispersion of the SCF in options that

are inequitable and unsustainable.

While decarbonisation remains a core challenge, the SCF must be applied in a way that (A) is

coherent with other social and environmental policy goals, (B) helps as much as possible the

advancement of those goals, and (C) does not undermine nor delay policies that serve those goals.

On this point, one must bear in mind that electrification, while helpful for decarbonisation, will

not, by itself, eliminate the wide range of negative social and environmental externalities linked to

individual car ownership and use, namely road danger, traffic congestion, toxic microplastic

emissions from road and tyre wear, and the disproportionate use (and impermeabilization) of

public space.

It is critically important that Member States do not use the Social Climate Fund to

perpetuate car dependency. Regulation (EU) 2023/955 (Social Climate Fund) does include, among

its eligible measures, direct income support to reduce the impact of fuel prices, and funding for

the purchase of zero- or low-emission cars – but it’s critical to ensure that these measures do no

significant harm to the transition we need.

Support to those measures must be restricted to situations where more efficient and equitable

transport solutions are not available (and cannot, within a reasonable time frame, be made

available with the SCF). Otherwise, those measures will have the perverse effect of sustaining

20 Electric cars consume less energy and have lower running costs than cars with Internal Combustion Engines.

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behaviour that must change, thus delaying the transition and, what is worse, reinforcing the

obstacles to its achievement.

The best way to advance decarbonisation in a fair, fast, and lasting way, is to accelerate the

shift to public transport, shared mobility (including carpooling and car sharing) and active

mobility (including cycling and walking). The time and resources available are limited for a

shift of such a scale and speed, and we must not dissipate them. A key question must always

be: how can we maximise the SCF’s impact?

We know for sure what to avoid, as experience clearly shows that financial measures of a general

nature that support individual car ownership and use will disperse the available resources and

end up disproportionately benefiting those who are not the most in need. It’s essential to ensure

that measures are targeted to low-income households, and not to everyone equally (which is what

happens with the fuel tax cuts).

The SCF must avoid perpetuating and aggravating inequalities: the existing purchase

subsidies for electric cars are mainly supporting the already affluent households.

According to the latest EAFO Consumer Monitor and Survey 202321, the EU Battery Electric Vehicle

(BEV) driver is represented by a 35 to 55-year-old man living in a detached house with a middle to

high income and a high education level.

This has a proven adverse effect, in the sense that it offers benefits to people who can actually

afford to buy an EV without help, but for those in need it doesn’t make a sufficient difference, or

the compensation is not enough. If subsidies for EVs go disproportionately to high-income

households, we will be reducing exposure among the least sensitive households, while the most

sensitive will remain exposed.22

1.8 Transport poverty feeds injustice, and injustice fuels revolt

The “Gilets Jaunes” movement was triggered by a programmed rise in carbon taxes which

coincided with an increase in car fuel prices. Research conducted since the 2018 start of the

protests has highlighted deeper driving factors.

One must look beyond the ‘spark’ and understand the accumulation of ‘flammable material’: a

persistent sense of (A) disadvantage in the access to services and opportunities,

(B) marginalisation in the allocation of public resources, (C) difficulty in creating and retaining

businesses and jobs in the local economy, (D) vulnerability and degradation of community ties and

identity, (E) helplessness in the face of the effects of globalisation. People felt cornered.

Measures subsequent to the Gilets Jaunes outburst (cancellation of the fuel tax increase, freezing

of planned increases in gas and electricity tariffs, and subsidies to the consumption of fossil fuel

and purchase of electric cars) may have deflated the immediate cause of the protests, but did not

eliminate these driving factors.

21 https://alternative-fuels-observatory.ec.europa.eu/consumer-portal/consumer-monitor 22 Mattioli, Giulio, Dugato, Marco, Philips, Ian (2023) “Vulnerability to Motor Fuel Price Increases: Socio-Spatial Patterns in

Italy”, https://link.springer.com/chapter/10.1007/978-3-031-35684-1_5

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Individual car ownership and use is the most expensive form of land transport for the user and

for the State23 but also the least inclusive and the least efficient, in terms of improving access to

services, allocating public resources, creating local jobs and improving community ties and

identity. One can argue that, with some extreme exceptions, on all these issues it isn’t even

‘neutral’, but rather pushes in the wrong direction, i.e., making the transport system less inclusive

and more inefficient.

The Social Climate Fund must help EU regions move to a transport system that can (A)

improve access for all, leaving no one behind, (B) lead to a more equitable and efficient

allocation of public resources, (C) build on local resources, increase social capital and

support the creation of local jobs, and (D) provide communities with a sense of agency,

which is the only way to overcome helplessness, revolt, and resistance to climate-friendly

policies and measures.24

Road transport plays a central role in the economy – in the cost structure of various businesses

and in the price formation of their goods and services. The increase in fossil fuel prices expected

from the application of the ETS-2 to road transport will be felt across several domains, and will

have various social repercussions.

It would be shortsighted and dangerously naïve to assume that, when fossil fuel price increases

become an unavoidable reality, measures to keep households locked in forced car ownership will,

in any way, be perceived and appreciated as helpful by those most affected.

What households and businesses need is not temporary alleviation of the symptoms, but

committed and serious work on the root causes, through reliable and structural solutions,

as fast as possible.

23 Even more so if externalities are considered. 24 Algan, Yann & Beasley, Elizabeth & Cohen, Daniel & Foucault, Martial (2019), "Les Origines du populisme: Enquête sur un

schisme politique et social", Seuil, La République des idées.

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2. Strategic Recommendations

We cannot solve the problems we face with the same thinking that created them in the first place.25

In other words, the Social Climate Fund cannot solve transport poverty by doubling down on

the car-centric policies that created and sustain it. A new strategic approach is required, to

achieve efficient, fast, reliable, and lasting solutions.

We recommend to Member States the following key points, for a strategic approach:

2.1 Transport and Energy Poverty require different approaches

The ways in which Energy Poverty and Transport Poverty can be addressed in practice differ

substantively. Energy Poverty mainly involves the performance of a fixed asset (the home) with a

fairly stable use pattern. Transport Poverty, quite differently, involves the performance of a

dynamic system, in which different elements (infrastructure, vehicles, services running those

vehicles, businesses launching and managing those services) interact and influence each other.

This creates barriers but also leverage points. Use patterns also change, just as the activities that

individuals and households wish to pursue can vary substantially, and, thus, also their mobility

needs.

And there are more differences to consider. The assets (vehicles) involved in transportation

systems are diverse (bikes, buses, vans, cars, etc.), they can have different types of ownership(e.g.,

belong to the household, or to a public transport or shared mobility operator, or to a carpooling

partner that offers a ride), they can be chosen according to the purpose (e.g., for long or short

trips, for the full trip or just for the first and last mile, for commuting to work or for recreation,

etc.), and they may end up being dispensed with (e.g., by people who cannot drive anymore

because of age-related limitations, or because they can no longer afford it).

Furthermore, in such a dynamic system, individual and collective behaviours can strongly

influence each other, and transport policy-makers must carefully consider whether their decisions

will create virtuous or vicious cycles26, and to what extent support to individuals will result (or not)

in collective benefits27. These are critical questions to bear in mind for the application of the

Social Climate Fund.

In short, while investment in an individual home or building is a necessary way to reduce

energy poverty, the same does not apply to transport poverty, where the problem has

resided, precisely, in supporting the ownership and use of an individual four-wheeled

asset28.

25 Albert Einstein (1879-1955), att. and adapted. 26 I.e., whether they will lead the system to yield progressively positive or negative outcomes. 27 ITF (2021), “Reversing Car Dependency: Summary and Conclusions”, ITF Roundtable Reports, No. 181, OECD Publishing,

Paris. 28 I.e., cars.

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Experience in transport shows that subsidising the individual purchase and use of a car has several

practical limitations and perverse effects: (A) it involves administrative procedures which tend to

put at a disadvantage those who have lower income and social capital, and disproportionately

benefits those who least need the subsidy, (B) it does not enable nor encourage the beneficiaries

to pool their resources together to create more efficient solutions for the wider community (i.e., it

does not generate collective benefits), (C) it does not support the creation nor encourage the

upgrading of services (public or private) that could benefit a wider part of the community (another

way it does not generate collective benefits), (D) it does not attract additional funding from

entrepreneurs into the development and deployment of new mobility solutions, (E) it cannot

benefit from critical mass nor revenues generated by higher-income customers, unlike a mobility

service, (F) its resilience fully depends on the individual’s ability to pay for the use of its individual

asset, and not on the wider community, (G) it doesn’t encourage beneficiaries to change behaviour

and decrease their vulnerability to transport poverty where that is possible.

The definition of eligibility criteria for the Social Climate Fund must bear in mind these differences

between energy and transport poverty, in order to be effective and generate systemic benefits.

2.2 Prioritise a multimodal approach

Different people have different transportation needs – at different times of the day, days of the

week, and weeks of the year, to access different destinations, for different purposes, alone or with

others.

The most efficient and equitable solution for each of these transportation needs varies, and that

is why lack of choice is a key driver of transport poverty, because it forces people to use

inefficient and unsustainable transport options.

A fundamental step to address transport poverty, therefore, is to enable choice. The Social

Climate Fund must be used to foster the emergence of a multimodal ‘menu’ of transport

options. The more diversified this ‘menu’ becomes, the more versatile it will be. The more versatile

Recommendations for the national level Social Climate Plans:

(1) Privilege the support to transport solutions that do not limit their benefits to the

receiving household, i.e., to solutions that can generate direct and indirect collective benefits

(including, e.g., creating jobs and retaining funds in the local economy;

(2) Channel support to transport authorities and operators, which can support individuals

and their communities with solutions that best understand the local context, best address its

needs, and best build on its resources;

(3) For support to shared and sustainable mobility, focus eligibility criteria on geographical

areas (rural, suburban and peri-urban), types of users (elderly, low-income groups,

households with children) and purposes of trips (essential socio-economic services and

activities, including employment, education, health, etc.);

(4) Privilege financial support in ways that reduce administrative barriers, benefit the users

and support the services (e.g., vouchers, micro-subsidies, well-established eligibility criteria

using reduced-fare criteria and processes for public transport, etc.).

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it becomes, the more capable it will be, as a whole, of providing convenient solutions for different

transport needs. This will make this ‘mobility menu’ reliable, resilient, affordable, and equitable.

Real multimodal freedom of choice will have deeper effects as well, as it will allow vulnerable

households to forego individual car ownership and use, contributing directly to an improvement

in their social and material well-being. In other words, it will reduce vulnerability by improving

adaptive capacity.

Experience shows that the budget invested in individual car ownership and use (potentially several

hundred euros per month) can be devoted to other dimensions of household well-being, which

will in turn have beneficial effects on the local economy, as this will free financial resources that

now may flow to local economic activities (payment of food, rent, etc.).

Passengers cars can (and should) remain a part of this multimodal portfolio – for the reasons

discussed above, the challenge is not to eliminate options, but to diversify them.

What must be clear is that (A) individual car use is highly inefficient, and a source of environmental

and social problems, (B) car use does not require individual car ownership, with carpooling and

car sharing being very efficient solutions, and (C) monopoly of the transport system by individual

car-ownership and use is pushing out (and keeping out) of the mobility menu options that are

more efficient and much need to fight transport poverty.

2.3 Build on a solid foundation: Public Transport

As the backbone of urban mobility, mass public transport (by bus, tram, subway, train) provides

the most efficient and equitable solution to connect urban centres to their peri-urban and

suburban areas. Its great potential lies in the aggregation of trips, and the resulting efficiencies in

terms of space, energy and operating costs.

Public transport is a key tool to overcome the transport poverty that afflicts many peri-urban and

suburban areas. The characteristics of such areas, however, are challenging for mass public

transport: (A) lower densities (which make aggregation of trips difficult), (B) longer distances to

Recommendations for the national level Social Climate Plans:

(1) Prioritise measures that will, directly or indirectly, support and grow multimodality, either

through support to operators (to deploy or scale up, including benefits for drivers adhering

to carpooling systems) and users (to support or generate demand). More people in a situation

of transport poverty will be reached and supported in this way, and with more lasting effects.

(2) Support the use of (2.1) public transport, (2.2) various types of shared mobility (e.g., car

sharing, carpooling, demand responsive transport, shared micromobility), (2.3) cycling and

walking, (2.4) park and ride.

(3) Direct funding for these purposes to public services, but also to local labour-intensive

businesses, to launch and operate transport of people (e.g., car sharing, demand-responsive

transport, etc.) and transport of goods (e.g., cooperatives to enable local shops to offer local

deliveries).

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reach the network (which require a first- and last-mile connection) and (C) high variations between

peak and off-peak demands (which either overload or underutilise capacity).

The best way to deal with these challenges is to build on public transport as a solid foundation, by

simultaneously (A) facilitating the use of cycling and shared mobility (e.g., shared electric bikes, car

sharing) for first- and last-mile connections to mass public transport corridors (train, tram, subway

networks), (B) contracting with shared mobility services (e.g., carpooling, demand responsive

transport, taxi, etc.) when and where these are more efficient than a bus, and (C) when possible,

reallocating the buses ‘freed’ by these gains of efficiency to increase capacity (growing fleets and

frequencies) where trips are aggregated.

We must bear in mind that, while advancing sustainable mobility and fighting transport poverty,

public transport authorities and operators are having to address, at the same time, other key

challenges, namely (A) decarbonising bus fleets, (B) making infrastructure more resilient for the

now inevitable extreme climate events, (C) adjusting to an evolving demand, particularly after the

COVID-19 lockdown and the growth of teleworking, (D) recruiting, training, and retaining new

workers, and (E) in some Member States, dealing with a reduction of public funding. All these

challenges have serious CAPEX and OPEX implications.

In this context, one must exercise extreme care when considering “free public transport” schemes.

Public transport is never “free” – the question is who pays for it. However popular it may sound,

the fact is “free public transport” schemes (A) grow usage at the cost of growing capacity, (B) divest

transport authorities from the capacity to grow and improve the service, (C) loose revenues from

users for whom the current cost is not an obstacle and don’t need the support, and (D) don’t

necessarily achieve modal shift in key target groups.

The Social Climate Fund must be targeted, and must point at the right targets. We must

avoid repeating mistakes, aggravating problems, or increasing limitations. Public transport

is and must remain a solid foundation – we must build on its strengths, and complement it

with transport solutions that will increase its efficiency and convenience.

Recommendations for the national level Social Climate Plans:

(1) Provide funding for Public Transport, prioritising measures that build on its strengths and

help overcome its limitations in low-density areas;

(2) Fund the orchestration, by transport authorities, of schemes that combine public transport

and shared mobility, namely to (2.1) increase the catchment areas of mass transit corridors

and hubs, and to (2.2) increase the efficiency (e.g., cost per passenger per km) of means

allocated to low-density areas, off-peak hours, and specific groups of users or trip purposes;

(3) Support the implementation of physical and traffic management measures to improve

bus and tram service, including (3.1) reserved BUS lanes, (3.2) Intelligent Transportation

Systems (ITS) to protect and prioritise bus and tram flow, (3.3) upgrading of bus stops, to

facilitate docking, accelerate boarding and alighting, and protect and facilitate re-entry in

traffic flow, (3.4) improvement of lighting, seating, and waiting areas in bus and tram stops,

(3.5) upgrading of systems for ticket sales and validation.

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2.4 Boost offer and demand for Shared Mobility

We can broadly define shared mobility as transportation services and resources that are shared

among users, either concurrently or one after another – this includes, respectively, sharing rides

(carpooling, demand responsive transport, etc.), or sharing vehicles (bike, scooter, car, van, etc.).

Shared mobility has grown substantially over the past decade, and today offers a wide array of

solutions and a solid foundation of practical experience.

Shared mobility has several key advantages, as it (A) can provide choice, and various ways to

deploy, diversify and upscale mobility options to match local needs, (B) can be quickly started by

private initiative (both for-profit or non-profit), and build on local resources already available,

(C) can be steered to serve public needs in an affordable and efficient manner (e.g., to complement

public transport), (D) is more labour-intensive than individual car ownership and use, and creates

and retains local jobs, (E) retains in the local economy a higher percentage of the money spent on

transport, and can even reward some users for their service to others (e.g., in carpooling), (F) can

work in such a way that the more affluent users create critical mass and generate revenues that

make these services available and affordable for lower income users, (G) enables public support

to effectively target specific types of users, geographical areas, and trip purposes (e.g., through

micro-incentives, mobility credits, etc.), and (H) provides communities with a diverse catalogue of

practical solutions that can be used to create context-sensitive and tailor-made transport

solutions.

Shared mobility is an extremely useful tool to fight transport poverty in suburban, peri-

urban, and rural areas, while at the same time promoting (A) decarbonisation, (B) energy

efficiency, (C) resiliency, (D) local economies and (E) local jobs.

Shared mobility services are currently more concentrated in denser urban areas – these offer an

easier case for a go-alone business model (public incentives are mostly absent, contrary to what

happens, e.g., with individual car ownership and use, which benefits from fossil fuel subsidies and

much more).

But while the business case may appear more challenging in suburban, peri-urban and rural

settings, there is in fact massive untapped potential waiting for the right strategic approach

and support from the public sector. To fully achieve its potential benefits, shared mobility needs

public governance, and the Social Climate Fund can be instrumental, by simultaneously helping its

operators deploy in these areas, and laying the foundations for effective public steering.29

29 Docherty, Iain & Marsden, Greg & Anable, Jillian (2018), “The governance of smart mobility”, Transportation Research Part

A: Policy and Practice, Volume 115, September 2018, Pages 114-125

Recommendations for the national level Social Climate Plans:

(1) Finance the growth of both offer and demand of shared mobility (to avoid a ‘chicken-

and-egg’ problem, where demand doesn’t grow because of low offer, and vice-versa);

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2.5 Make the infrastructure protect freedom of choice

For several decades, the road network was planned, designed and managed to support individual

car ownership and use. This has led to an unequal distribution of space, speed, and risk.

This inequality systematically harms the performance and safety of other transport modes,

discouraging the adoption of more efficient and affordable solutions. It has also become an

obstacle to the deployment and consolidation of new mobility services. In short, it harms freedom

of choice, blocks innovation, and sustains transport poverty.

Experience at the local level clearly shows that sustainability, safety and equity must advance

together, or none of them will advance effectively – (A) lack of safety discourages the use of

sustainable modes like cycling and public transport, (B) sustainable modes are the most

affordable, and as such provide critical benefits to economically vulnerable groups, and (C) road

danger disproportionately affects economically vulnerable groups.

Local experience also shows that, contrary to highways and motorways, local roads and streets

can be improved at the network level, through simple traffic calming interventions which, in

comparison to large infrastructural interventions, require much lower budgets, enable faster and

simpler procurement procedures, and apply easier construction methods.

These traffic calming interventions have ripple effects over wider areas30, and allow for phased and

integrated approaches. Reducing speed limits can be a first and fast step to mitigate safety

insufficiencies detected in the framework of the RISM Directive31.

30 For example, raising an intersection for traffic calming can have an effect in a radius of 50 meters in all directions

(covering somewhere between 7,000 to 10,000 square meters of land). 31 Directive (EU) 2019/1936 of 23 October 2019, amending Directive 2008/96/EC on Road Infrastructure Safety

Management.

(2) Support funding that ensures a level of stable and reliable demand (e.g., for the full

duration of the SCF), to reduce risk and increase bankability;

(3) Privilege regional or local transport authorities as a funding channel, to encourage

combination with public transport and steer for-profit shared mobility operators towards

public needs;

(4) Enable different forms of targeting beneficiaries, supporting specific types of users,

geographical areas, and purposes of trips through (4.1) credits or vouchers, and (4.2) micro-

incentives;

(5) Support the integration (in the appropriate services) of stable travel demands, e.g.,

commuting to school, jobs, health and social services;

(6) Avoid restricting the services to low-income transport-poor, and enable use by higher-income

full-paying customers, to enable a wider and more resilient customer base and an inclusive

branding of the services, and to create critical mass and generate revenues that make these

services available and affordable for lower income users;

(7) Give preference to transport services based on socially responsible labour practices.

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Quality and accessibility to and from public transport stops and stations are also central

determinants when one chooses to or not to travel by public transport. Thus, ensuring that the

public space leading to and around public transport stops and stations is safe, comfortable and

accessible is essential, making public space also part of Public Transport infrastructure. Last, but

not least, we must bear in mind that the quality of public space is the quality of walking and cycling

infrastructure.

In short, these targeted interventions, easy to control in time and budget, can reduce traffic

speed but accelerate change, and unlock the full potential of streets as places for social and

economic life, and for transport innovation.

2.6 Mobilise the community’s social capital

Advancing decarbonisation and at the same time fighting transport poverty is a massive strategic

and political challenge. It requires the full mobilisation of the creative, social, and political capital

of the whole community. Many stakeholders have an important part to play: public and private,

for-profit and non-profit, elected officials and their constituencies. “Everyone can be great,

because everyone can serve”.32

Local and regional governments are the best placed to (A) tap community ties and trust (i.e., social

capital) as an economic resource, (B) mobilise and focus endogenous resources, and (C) to find

and foster creative and integrated measures that provide practical, viable and fast solutions. This

approach poses its own practical challenges, of course, but it can deliver in a more efficient, fast,

reliable, and economic way than centralisation and top-down measures, and have deeper and

longer-lasting impacts.

32 Martin Luther King, Jr. (1929-1968)

Recommendations for the national level Social Climate Plans:

(1) Promote speed reduction, including Zone 30 areas, Low Traffic Neighbourhoods, school

streets, shared spaces and woonerven1, and physical traffic calming measures, e.g., raised

intersections and crosswalks, bottlenecks and pedestrian islands;

(2) Make streets safely cyclable, through speed reduction, shared streets with bike priority

(fietsstraat1), and where necessary segregated cycling lanes;

(3) Grow bicycle parking, both on-street, including bicycle hangars, and off-street, including

bicycle parking in office, residential and public buildings, and in mass transit hubs;

(4) Implement shared mobility hubs, combining parking for shared bicycles, cargo bikes,

standing scooters, scooters, cars and vans, and respective charging infrastructure;

(5) Promote installation of charging infrastructure for light electric vehicles, including fire-

safe charging lockers in residential, public, and office buildings;

(6) Support targeted improvements to the pedestrian infrastructure, namely (6.1) safe and

accessible crosswalks, (6.2) missing links in pedestrian paths, (6.3) increase accessibility,

safety and comfort in pedestrian paths to and from mobility hubs, public transport stops and

stations.

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Furthermore, there is a critical need to interact directly with target beneficiaries. Experience

shows that those who most need this kind of support usually have less access to information about

it, and less availability to reach out and follow through all administrative procedures (usually

conducted during office hours or via digital channels, which increases the difficulty).

In addition, overcoming transport poverty will in most cases require some degree of behaviour

change for the household. Shaping and encouraging this change requires analysis, development

of tailor-made combinations and trial of new mobility options. All of this implies more than a

simple ‘administrative step’. It requires one-on-one dialogue, multiplied by many households.

Active cooperation of local organisations is indispensable for effective outreach, awareness-

raising, and dialogue.

2.7 If users can’t reach the services, help services reach the users

Physical access to essential socioeconomic services (education, health, social support, etc.) can be

achieved in two ways – either the user moves to reach the service, or the service moves to reach

the user33. The key question is to know, for different types of service and user, which way is the

most efficient, reliable, and affordable, for both the user and the service provider.

The default approach has been to put the “burden of moving” on the individual.34 When there are

public service obligations involved, and the user isn’t able to reach the services autonomously (e.g.,

because of disability or cost), the public sector provides (or at least pays for) specific and separate

transportation to the users for whom that burden is too much.

These specific services are, often, (A) a marginal part of the service (i.e., not designed as an integral

part of the process), (B) inefficient (commonly having to serve a small number of users over a wide

area), (C) inevitably limited in their capacity and quality (because of budget constraints, which can

then further aggravate those limitations), and (D) at risk, particularly in the case of services to the

33 Digital technologies may provide additional options for some procedures, but those options pose additional challenges

of their own, and, in any case, human contact is to a good degree indispensable. 34 This ‘burden’ must often taken up by the household or close support system, if the individual has one.

Recommendations for the national level Social Climate Plans:

(1) Privilege the creation of local one-stop “shops” that can reach out to target beneficiaries and

provide tailored guidance and support to households, individuals and micro-enterprises

(these “shops” can be added to already-established channels and programmes);

(2) Foster the involvement of regional business actors in the development of local shared

mobility services, and support the ongoing evolution of automobile clubs into mobility

clubs offering shared mobility solutions;

(3) Actively support the creation or growth of cooperatives in the transport sector, including

for direct operations (e.g., local deliveries) and associated services (e.g., bike maintenance

shops), covering (3.1) preparatory studies, (3.2) capacity building and (3.3) operating funds;

(4) Support community-led creation of services and schemes (e.g., car sharing, carpooling,

cargo bike sharing, etc.), e.g., by local development associations, mobility clubs, local charities,

resident associations, etc.

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elderly, because the ageing of the population will increase demand, and the rise of fossil fuel prices

will aggravate financial strains.

This is a bad dilemma – things are either bad for the user, or bad for the provider, and they’re

often bad for both. This issue is, fundamentally, about transport poverty, and there are two ways

in which the Social Climate Fund can help – by (A) supporting new solutions that help the service

reach the user, particularly in lower-density areas, and by (B) supporting more efficient options for

helping the user reach the service.

We can bring the service to the user by creating small decentralised service points for the regular

provision of basic services. In the health sector, for example, (A) the “basic services” can include

basic nursing care in an outpatient setting (e.g., taking samples for analysis, vaccinations,

supervised taking of special medication, changing dressings and removing surgical stitches) or

medical consultations that do not require fixed instrumentation (e.g., general medicine,

psychiatry, etc.), (B) the “regular provision” can consist of one or two fixed days of the week (clear

expectations make for easy management), and (C) the small decentralised service points can

consist of adapted rooms located in already existing public facilities, or made available by local

community organisations.

These decentralised service points may not “solve everything”, but they will certainly help a lot. In

the health sector that’s literally “a lot”, as many trips are taken for ambulatory care and outpatient

visits that could be done closer to the place of residence.

On the other hand, when transportation of users to places of service is indispensable, how can we

improve the efficiency and financial viability of the necessary transportation services?

The aggregation of trips is a key step for increasing transport efficiency – shared trips reduce the

amount of km per passenger, and therefore the costs. Aggregating trips in lower-density suburban

and rural areas has always been a challenge, but digital technology today provides very useful

tools to deal with that, and shared mobility (particularly demand responsive transport and

carpooling) provides efficient alternatives for many cases.

This will certainly help users in a situation of transport poverty – and, most importantly, it will have

very important economic benefits for the service providers, because it will (A) increase service

performance and efficiency (e.g., reduce no-shows, increase punctuality), (B) free up key assets

(e.g., hospital beds), (C) dispense with heavy and space-consuming infrastructure investments

(e.g., parking in large facilities), (D) increase the efficiency and therefore reduce the costs of

transportation services (e.g., increasing the number of users allows for several economies of scale,

which can be further increased by the resort to mainstream shared mobility services), (E) increase

competitiveness and innovation in local businesses (e.g., supporting the creation and growth of

local delivery cooperatives will enable local shops to deal with the growing pull of e-commerce),

and (F) increase the well-being (and satisfaction) of the users and respective households (which

has social but also financial benefits for the service providers, the community in general, and the

State).

Urban and regional planning and land use also play a key role here in determining what and where

is being developed and how the different uses and services are being distributed geographically.

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The city of proximity and other similar approaches to urban planning offers some insights and

principles that might alleviate the burden of lengthy trips and service locations by balancing

housing, services, jobs, education and leisure distribution.

Increasingly connecting transport to urban and regional planning and land use will increase the

efficiency of mobility solutions as well as travel distances, being particularly relevant for new

neighbourhoods and developments. The SFC can support the implementation of strategic plans

that develop transport and land use together, offer different sustainable transport choices, and

consider housing availability. It can also provide support to institutional and organisational

improvement to allow for such approaches at the local and regional levels.

2.8 Mainstream service to vulnerable users

Through its shape and function, the transport environment (infrastructure, vehicles, operations

and user interfaces) imposes on potential users certain implicit “conditions to use”, e.g., the ability

to walk to bus stops or move through train stations, to understand the network and plan the

desired routes, to use payment interfaces, to board and alight trains, trams and buses (e.g.,

overcoming steps and horizontal gaps), to look for and correctly identify the desired vehicle to

board, or stop to alight.

Recommendations for the national level Social Climate Plans:

(1) Support the development, implementation and improvement, by public and non-profit

health and social care organisations, of services provided at home (e.g., ambulatory health

care, elderly home support);

(2) Support the creation of local-based businesses (e.g., cooperatives) that can provide these

and other services, or transport solutions for their provision;

(3) Support the acquisition of electric vehicles by specialised organisations and

professionals providing for access to essential socio-economic services through home

service (e.g., nursing, physiotherapy, delivery of cooked meals for dependent elderly persons,

etc.);

(4) Support the development and acquisition of services, platforms and fleets that can increase

the efficiency and level of service of specialised transport to key services (e.g., school,

scheduled medical appointments, social services, etc.), including their aggregation, and their

integration with shared mobility services (e.g., taxi, demand responsive transport,

carpooling);

(5) Support the creation and growth of local delivery services, by local transport cooperatives,

or by individual or associated local businesses (e.g., groceries and supermarkets, pharmacies,

etc.), including the technological means for conduct of e-commerce (e.g., webpages enabling

the placement of orders to be delivered);

(6) Support the creation, improvement and operation of decentralised facilities for the

provision of public services (e.g., fiscal and other administrative services, local health clinics

for ambulatory care on fixed days), through direct public provision or where necessary in

agreement with third parties.

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These “conditions to use” require motor, sensory and cognitive abilities. And in some important

cases they require more, namely the ability to travel accompanied by children, or to overcome

fear, particularly of road danger or sexual harassment, when walking, cycling, or using public

transport.35

Users who cannot “satisfy” one or more of these “conditions to use” are either impeded or

restricted in their ability to move, and forced to either forego their autonomy, or to pay a higher

price for it. In all Member States, this affects a very substantial part of the population, and for two

main reasons.

First, because these problems are faced by a large, diverse, and dynamic universe of individuals,

including, among others, (A) women (of different ages, in different social and cultural contexts,

with or without children), (B) an ageing population (including those who are driverless in rural

areas, where individual car ownership is wrongly touted as ‘indispensable’), (C) persons with

different types of disability (motor, sensory, cognitive, including many elderly people, as age

correlates strongly with disability), and (D) children and adolescents (when they’re forming their

attitudes and preferences towards transport modes and travel habits).

Second, because lack of autonomy generates dependency, and that dependency has costs (in time,

money and resources) for the individual, but also for the respective household, close relatives and

friends, the wider community and, inevitably, the State.

The source of the problem lies not in the users, but in (A) the “conditions to use” imposed by the

transport environment (where the threshold for safe and autonomous use is placed too high it

becomes a barrier), and (B) the lack of adequate alternatives to bypass barriers in the available

offer. These factors narrow choice, and thus generate and aggravate transport poverty.

Mainstreaming the response to transportation needs is, whenever and wherever possible, the

best approach. Removing barriers that create undue effort and separation enables everyone

to benefit equally and independently, making the transport system functional, safe, and

appealing for all.

Paratransit36 or ‘transport for the disabled’, provided as a way to compensate for existing barriers

through the provision of specific and separate (i.e., segregated) services, are often the least

inclusive, the least efficient, the most limited, and the most vulnerable to financial constraints and

operational complications.

The way forward is not to create segregated solutions as an alternative to the elimination of

barriers in the mainstream services. That approach will always be the least efficient and the least

beneficial for all users – the alternative will chronically underperform, and the mainstream services

will not improve.

35 This fear is not to be discounted – first, because most often it is a reaction to objective risk, and second because,

regardless of its subjectivity, it objectively affects transport behaviour and mode choices. 36 “Paratransit” means comparable transportation service required by individuals with disabilities who are unable to use

fixed route transportation systems.

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What must be done is, at the same time, (A) eliminating barriers in mainstream services, and (B)

creating complementary solutions to mainstream services. The emphasis is on complementary –

again, diversification is key.

In what regards, specifically, persons with disabilities, the best is to align this complementary

approach with the principles of Independent Living37, and provide financial support to persons

with disabilities that will enable them to tailor and manage solutions for themselves.

37 “Independent Living” means that individuals with disabilities are provided with the necessary means to exercise choice

and control over their lives. This includes access to (among other things) transport and personal assistance. It should not

be interpreted solely as the ability to carry out daily activities by oneself, but as the freedom to choose and control, with

dignity and individual autonomy, as enshrined in article 3 (a) of the United Nations Convention on the Rights of Persons

with Disabilities.

Recommendations for the national level Social Climate Plans:

(1) The elimination of barriers to accessibility (physical and communicational) in the public

transport network, including (1.1) vehicles, e.g., ramps, reserved seating, and onboard

communication devices, (1.2) stations and stops, e.g., circulation paths within stations, and

pedestrian paths connecting to and from stations and stops, fixed or mechanical means to

overcome gaps between platforms and vehicles and human support services, wayfinding,

ticketing and access gates;

(2) The inclusivity of taxi and shared mobility services, including (2.1) purchase of wheelchair

accessible vehicles, (2.2) implementation of inclusive service procedures and respective

training of staff;

(3) The integration of shared mobility services in paratransit systems, to increase their

efficiency, flexibility, and choice;

(4) The creation or improvement of independent mobility solutions by Independent Living

Centres, including, (4.1) the acquisition, leasing, or rental of accessible vehicles for car sharing,

(4.2) the provision of financial support for persons with disabilities to be able to recruit and

manage personal assistants for driving1;

(5) Where necessary, in complement to existing supports (tax benefits or subsidies), the

acquisition of electric vehicles (cars, vans, scooters and bicycles) by individuals with a

threshold level of disability (or their respective household), and funding for vehicle

adaptations to their respective needs;

(6) The reduction of road danger for people walking and cycling, particularly through traffic

calming in the vicinity of schools, health care and social care facilities, and higher-risk

locations;

(7) The implementation of physical and operational measures to reduce the risk of sexual

harassment and improve the feeling of security in public transport vehicles, stops and

stations (e.g., lighting, video surveillance, staff training, etc.);

(8) The development and implementation of targeted and efficient combined mobility

solutions, to serve the needs of people who commonly have to resort to trip-chaining or to

travel in lower-density areas in off-peak hours (e.g., women, youth, elderly).

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2.9 If a car is “indispensable”, limit support to the indispensable

While individual car ownership and use plays an important role in the everyday routines of many

households, it’s important to keep in mind that the “need of a car” is never an absolute and

objective indicator – it can be part context and part perception, part habit and part justification of

habit, part lack of convenient alternatives and part lack of awareness of their existence, part need

and part preference. In peripheral rural areas, each owner of an ‘indispensable’ car certainly has

neighbours who carry on with their lives without one.

The Social Climate Fund’s regulation38 includes, among its eligible measures, direct income

support to reduce the impact of fuel prices, and funding for the purchase of zero- and low-

emission cars. Clear limits must be set on both the eligibility of beneficiaries, and on the type and

amount of support provided to those eligible, to avoid dispersion of the available funding, and to

ensure the best return on investment.

In principle, the “need of a car” must be considered in relation to:

• the needs of the full household, and not just the driver;

• the alternatives available and their cost (in terms of time and money) to ensure autonomous

access, by all members of the household, to a set of essential socio-economic services and

activities, e.g., health and social care, education, employment, provision of food and other

basic goods, etc. ;

• the alternatives that could be created or supported for that purpose (e.g., carpooling, demand-

responsive transport, etc.);

• regular work shifts starting or ending at late night or early dawn, particularly essential workers

(e.g., nurses, teachers, social care workers, police and fire service).

Basing support on an individual assessment of these issues could become burdensome and

intrusive. Spatial targeting and, within specific areas, income-based targeting could help

implement some of these principles in a fair and respectful way.

38 Regulation (EU) 2023/955

Recommendations for the national level Social Climate Plans:

(1) As a key guiding principle, restrict funding to the indispensable and not beyond;

(2) Avoid funding, in any case, the purchase of first- or second-hand large and heavy electric cars,

namely SUVs (fund a vehicle that is fit for purpose, but not beyond);

(3) Restrict the direct income support to reduce the impact of fuel prices to a time period that

ends before the term of the SCF;

(4) In low-density rural and peri-urban areas, for households who already own, or will acquire an

electric car, support the installation of home charging solutions;

(5) In low-density rural and peri-urban areas, consider supporting a social leasing scheme for

small electric cars, that would enable beneficiaries (households, cooperatives or

associations, micro-enterprises) to use electric cars made in Europe for a monthly rent,

without upfront costs (this measure could be co-financed through the Recovery and

Resilience Facility, and then revenues from ETS-2 and the Social Climate Fund; its impact could

be further increased if conditional on adhesion to carpooling or car sharing schemes).

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2.10 Follow a focused approach to micro-enterprises

There is much diversity in the types of micro-enterprises, in the business they conduct, in where

they are located and where they operate, in their transport needs and in the means available to

satisfy those needs, in their types of employees and respective transport needs, and in the ability

and functional interest of the employer to support those needs. It is important to understand and

build on this diversity.

Generic indicators and one-size-fits-all measures for micro-enterprises should be avoided, as they

would dissipate the impact of the Fund and have perverse effects – for example, (A) defining

eligibility of the basis of fiscal performance can benefit disproportionately companies who are able

to reduce their fiscal footprint39, and (B) supporting company passenger car ownership can

encourage the use of cars as a perk for higher-earning qualified workers.

Corporate mobility is an important component of local transport, and the mobility

practices implemented for business purposes and employee commuting have a wider

influence on mobility behaviour. Corporate mobility can also be a relevant and reliable source of

demand for public transport, shared mobility, and cycling, and as such can make an invaluable

contribution towards the viability and bankability of these services, which evidently will benefit the

wider community.

39 For example, by being able to afford specialised legal advice.

Recommendations for the national level Social Climate Plans to support micro-enterprises:

(1) Restrict support to the purchase of zero- and low-emission passenger cars, light

commercial vehicles and vans, to businesses which require dedicated vehicles for the

performance of their activities, namely to (1.1) carry tools, equipment or materials, e.g.,

plumbers, electricians, cleaning, etc., (1.2) deliver goods as an essential part of their service,

e.g., delivery companies, or companies which must deliver their own goods as part of their

service, or (1.3) provide social or health care services at different locations, e.g., nurses and

physiotherapists;

(2) Expressly avoid covering the costs of company cars provided to employees for their

personal use (either for purchase, leasing, renting, or energy costs);

(3) In low-density rural and peri-urban areas, for microenterprises who already own, or will

acquire an electric car, support the installation of facilities-based charging solutions.

(4) Support the development of corporate mobility plans1, encouraging the association of local

businesses and other employers for that purpose (e.g., in suburban business parks);

(5) Privilege the implementation of sustainable corporate mobility solutions based on

mobility budgets for public transport, shared mobility, and cycling;

(6) Support the acquisition of light electric vehicles, e.g., electric cargo bikes, electric scooters,

etc. for the conduct of business activities.

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3. Empower Cities & Regions as Key Actors

3.1 Consult & Cooperate for Effective Action

The Social Climate Fund regulation establishes a clear requirement for Member States to

undertake a public consultation process with key stakeholders, and to demonstrate how this input

has been integrated prior to submitting their Social Climate Plans.

Meaningful engagement of local and regional governments is not just a procedural

requirement – it is a strategic necessity.

Local and regional governments and transport authorities (A) deal directly with the SCF’s target

groups, (B) have jurisdiction over most of the key elements that make up the regional mobility

systems that serve everyday life, from transport infrastructure to transport services, (C) are the

best positioned to mobilise endogenous resources to support the design and implementation of

climate, energy and mobility policies, and multiplying their positive impacts, (D) are a specific level

of EU territorial governance, with its own democratic legitimacy, and its political accountability is

a key factor in the roll-out of measures funded by the SCF.

Integrating cities and regions into the planning and implementation of Social Climate Plans

is indispensable for the Social Climate Fund to achieve its intended impact.

We must learn from experience. The implementation of the Recovery and Resilience Facility (RRF)

demonstrated the challenges of centralised decision-making, where local and regional authorities

were often excluded from consultation and meaningful involvement. While these plans have had

a positive impact, their overall impact could have been much better with a more systematic

involvement of local and regional authorities.

Sidelining local and regional authorities in key phases of planning, implementation, and

monitoring led to broad, top-down measures that often lacked the granularity to address local

needs or adequately target vulnerable populations. For the SCF, which aims to support vulnerable

households and small businesses in the green transition, such exclusion could result in missed

opportunities to achieve equitable and effective outcomes and poor execution rates of the

available funds.

The Social Climate Fund also has tight timelines for ambitious goals, both for conception

and implementation. There is no time to lose, and conducting consultation as a mere

procedural requirement for conception would be a loss of time. Consultation with local and

regional governments and transport authorities must be approached as the condition for a

practical conception, and the foundation for fast and effective implementation.

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Recommendations for the national level Social Climate Plans, regarding principles for

sound and effective consultation and cooperation with local and regional authorities:

(1) On Consultation:

(1.1) Adequate time – Rushed timelines undermine the capacity for thoughtful engagement

and exclude critical voices. Allow for adequate time to review and to formulate proposals.

Adjust the consultation methods to the available time.

(1.2) Multiple stages – Consulting only at the start and end of the planning process, when the

plan is either completely undefined or completely closed, misses many potential

contributions. Use processes that enable constructive participation in multiple stages of

the process, from brainstorming to idea refinement. It will save time.

(1.3) Open dialogue – Genuinely seek and value the contributions of local and regional

authorities towards local obstacles and opportunities, encourage creative problem-

solving, build alignments, make implementation practical. Use adequate methods, e.g.,

targeted workshops.

(1.4) Transparency – Provide clarity to stakeholders on how their input will be considered and

integrated into final plans.

(2) On Cooperation:

(2.1) Governance – The consultation of local and regional authorities must go beyond the

planning phase. They must have a clear role in the governance structure of the Social

Climate Plans, contributing to monitoring, adjustment, and implementation. This requires

formally ensuring their participation at key stages of the Fund's lifecycle, with clearly

defined roles and responsibilities, as well as regular coordination mechanisms, such as

joint committees or working groups. This will improve accountability and effectiveness.

(2.2) Monitoring – Local and regional authorities have access to fundamental quantitative and

qualitative granular data on the effectiveness of measures, the identification of emerging

challenges. Sharing of real-time feedback in a structured way will ensure that the Social

Climate Fund is transparent and responsive to evolving realities.

(2.3) Dynamic adaptability – Adjustments are an indispensable component in the

implementation phase of all plans and measures. Local and regional authorities are

uniquely positioned: their proximity to the communities most affected by transport

poverty provides them with the insights needed to refine strategies in ways that maintain

their relevance and effectiveness. If certain measures prove less impactful than

anticipated, local authorities can propose targeted modifications based on their ongoing

engagement with local stakeholders. Embedding them in the adjustment process ensures

that changes are grounded in practical realities rather than abstract assumptions.

(2.4) Active implementation – Empower local and regional authorities to actively participate

in the implementation of critical measures. They are the best placed to expand public

transport, facilitate and steer shared mobility services, implement local one-stop shops

for mobility advisory services to households and micro-enterprises, and much more.

Their active participation in the implementation of the SCF is crucial to ensure national-

level planning translates into tangible and actionable measures at the local level.

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3.2 Fund Sustainable Urban Mobility Planning (SUMP)

Local and regional governments and transport authorities know, from extensive practical

experience, that creating practical, timely, and lasting solutions for the everyday lives of those

most vulnerable to transport poverty requires strategy and cooperation.

Otherwise, one can get fast measures pushing in the wrong direction, or measures undermining

each other, or measures that are highly visible in the short term but not viable in the long term.

The development of a Sustainable Urban Mobility Plan (SUMP) is the best way of setting and

effective strategy and a solid foundation for cooperation. Thanks to the investment of the

European Commission, we now have standardised guidelines to develop SUMP40, which have been

tested and refined by the practical experience of many authorities and experts, as well as

standardised Urban Mobility Indicators that enable proper monitoring, evaluation and

comparison.

The revision of the TEN-T Regulations41 established 432 Urban Nodes. Each of these nodes is based

on a Functional Urban Area, which includes important suburban and peri-urban areas, where large

numbers of households live in transport poverty. The TEN-T regulations require each of these

nodes to have its own SUMP by the end of 2027.

As we’ve seen above, most of the factors driving Transport Poverty are linked to unsustainable

mobility – after all, it’s the use of (and forced dependence on) energy-inefficient transport modes

and mobility patterns that makes household and micro-enterprises vulnerable to the increase in

the prices of fossil fuels.

This means that SUMPs are a powerful tool to not only advance Net Zero goals, but also to address

Transport Poverty. Making funding available for the implementation of SUMP measures that

address Transport Poverty will help their timely implementation, and that will, in turn, also

accelerate the implementation of the Social Climate Plans, by providing them with a portfolio of

coherent measures ready to deploy.

Finally, because several EU cities and regions do not have a SUMP yet, it’s important to point out

that the Social Climate Fund can cover costs related to “technical assistance to cover expenses related

to training, programming, monitoring, control, audit and evaluation activities which are necessary for

the management of the Fund and the achievement of its objectives” 42.

40 European Commission (2019), “Guidelines for developing and implementing a Sustainable Urban Mobility Plan” 2nd

Edition (available here: https://urban-mobility-observatory.transport.ec.europa.eu/sustainable-urban-mobility-

plans/sump-guidelines-and-decision-makers-summary_en) 41 Regulation (EU) 2024/1679 of the European Parliament and of the Council of 13 June 2024 on Union guidelines for the

development of the trans-European transport network, amending Regulations (EU) 2021/1153 and (EU) No 913/2010 and

repealing Regulation (EU) No 1315/2013, available here:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R1679 42 Cf. Regulation (EU) 2023/955 (Social Climate Fund), article 8, number 3.

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3.3 Set proportional targets for application of the Fund

The implementation of the Social Climate Fund must be balanced, grounded, and coherent:

• it will be balanced if both challenges (energy poverty and transport poverty) are allocated an

adequate proportion of the available funds;

• it will be grounded if regional and local governments and transport authorities play an active

role in the planning and a leading role in the implementation of the measures, ensuring local

support to beneficiaries, mobilisation of the local social and business communities, and the

alignment of the measures with local strategies and plans;

• it will be coherent if it privileges measures that address the root causes of transport poverty,

and offers practical solutions with a lasting effect.

National plans for the Social Climate Fund should:

(1) Support the development of Sustainable Urban Mobility Plans (SUMPs);

(2) Privilege the funding of measures which are planned for by SUMPs;

(3) Support costs related to the monitoring and capacity-building necessary to the

implementation of SUMPs;

(4) Support the implementation and operation, by Member States, of their respective National

SUMP support programmes, aimed at SUMP development and implementation through

funding, capacity building, communication and evaluation.

For this effect, National plans for the Social Climate Fund should set proportional targets for

the allocation of SCF funds, in the following manner:

(1) Dedicate 50% of the total amount to address Transport Poverty;

(2) Of the amount for transport, dedicate 65% of the total to measures that are to be planned

and managed at the regional or local level;

(3) Of the amount for local measures, dedicate 75% to multimodal solutions, i.e., not individual

car ownership and use.

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About POLIS:

POLIS is the leading network of European cities and regions advancing transport innovation. We

are committed, specifically, to innovations that can make urban, suburban, and rural mobility

more sustainable, safe, and equitable.

POLIS draws its expertise from a valuable network of decision makers, field practitioners, and

researchers, who are working for local and regional governments and transport authorities, public

research organisations, and private non-profit and for-profit organisations, from advocacy to

mobility service providers.

We build on the results of EU-funded projects and on the input of thematic Working Groups that

address key transport challenges, to link innovation and public policy guidance on urban and

regional mobility with European policy development.

Secretary General

Karen Vancluysen

Director of Policy & Projects

Ivo Cré

AUTHORS/CONTRIBUTORS:

Pedro Homem de Gouveia,

Senior Policy Advisor

Jorge Manso García,

Project Officer

FOR FURTHER INQUIRIES REGARDING

THIS DOCUMENT:

[email protected]

CONTACT POLIS:

Rue du Trône 98, B-1050 Brussels, Belgium

Tel +32 (0)2 500 56 70

[email protected]

www.polisnetwork.eu

www.polisnetwork.eu

Fighting Transport Poverty

with the Social Climate Fund

Recommendations

to Member States

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A unique opportunity – now Karen Vancluysen1

POLIS is the leading network of European cities and regions advancing transport innovation. We’re

committed, specifically, to innovations that can make urban, suburban, and rural mobility more

sustainable, safe, and equitable.

Our network brings together more than 120 local and regional governments and transport

authorities from across the European Union, with a simple but essential mission: finding and

implementing real solutions, for real problems, affecting real people, to build a real future.

That’s what local government is about. That is also what the European Union is about. And that’s

why our members are stepping forward with mobility policies and measures that deliver on

ambitious EU goals for sustainability, safety, competitiveness, and cohesion.

This is not an easy undertaking. We’re addressing very complex challenges, of a systemic nature,

created and sustained by land use, transport, and industrial policies. Real progress requires setting

new priorities, adopting new approaches, crafting new tools, and (re)building organisational

capacity2.

On top of that, this transition must be implemented in a very challenging context, where financial

resources are limited, speed is of the essence, and political polarisation can undermine dialogue,

foster misunderstandings, and quickly flame revolt.

The Social Climate Fund (SCF) can become a precious step in the right direction, but only if that

direction is taken decisively, and if the following steps are well aligned. Otherwise, we will stumble.

To support the development of Social Climate Plans, the European Commission has published a

lengthy report on Transport Poverty3, and a set of good practices4, including recommendations

formulated by the Expert Group on Urban Mobility (EGUM)5.

POLIS contributed to the EGUM’s recommendations, and strongly supports these efforts made by

the European Commission to help Member States make the most of this opportunity. In addition,

I believe it must be said that our active participation, over the years, in several European projects

and actions for transport research and innovation, has endowed our network with a unique

capacity to contribute on this matter. And with that capacity, I also believe, comes responsibility.

1 POLIS Secretary General. 2 To address the wider set of issues raised by the transition, POLIS established a “Just Transition Agenda”, which maps the

path to making transport inclusive (available here: https://www.polisnetwork.eu/wp-content/uploads/2021/11/Just-

Transition-Agenda-AGA.pdf). 3 European Commission (2024), “Transport poverty: definitions, indicators, determinants, and mitigation strategies - Final

Report” (available here: https://employment-social-affairs.ec.europa.eu/transport-poverty-definitions-indicators-

determinants-and-mitigation-strategies-final-report_en) 4 Available here: https://climate.ec.europa.eu/eu-action/eu-emissions-trading-system-eu-ets/social-climate-fund/good-

practices-social-climate-plans_en 5 Expert Group on Urban Mobility (2024), “Social Climate Fund” (available here:

https://transport.ec.europa.eu/document/download/f7e54ea5-23aa-4f8d-a24c-

9d902fc9652c_en?filename=EGUM_Recommendations_Social-Climate-Fund.pdf)

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We therefore take this opportunity for further contribution, with this set of strategic

recommendations, based on sound research and solid experience.

These recommendations are addressed to the Member States, who have a leading role to play in

the development of the (national) Social Climate Plans. They are also meant to support the work

of local and regional authorities, who will always have ‘the’ critical role to play in the successful

implementation of these plans.

We hope this document will also encourage the active involvement and positive contribution of

many stakeholders, from transport providers to advocates for sustainable mobility, road safety,

regional development, and social cohesion.

We at POLIS remain committed to working with all levels of European governance – local, regional,

national, and international – to address the key challenges of our time. Because the future starts

today, not tomorrow.6

6 Pope John Paul II (1920-2005).

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Table of Contents

A unique opportunity – now ...................................................................................................................... 2

Introduction ............................................................................................................................................... 5

1. The (real) Challenge .................................................................................................................... 7

1.1 Transport poverty is a structural problem requiring structural action .................................. 7

1.2 The key challenge is access, not movement .............................................................................. 8

1.3 Transport poverty is a regional problem .................................................................................... 8

1.4 For many households, owning a car will never be a “solution” ............................................... 9

1.5 Car dependency means lack of choice, not “freedom of movement” .................................... 9

1.6 We must (really) address vulnerability to fuel price increases .............................................. 10

1.7 Only alleviating the symptom perpetuates the problem ....................................................... 11

1.8 Transport poverty feeds injustice, and injustice fuels revolt ................................................. 12

2. Strategic Recommendations .................................................................................................. 14

2.1 Transport and Energy Poverty require different approaches ............................................... 14

2.2 Prioritise a multimodal approach .............................................................................................. 15

2.3 Build on a solid foundation: Public Transport ......................................................................... 16

2.4 Boost offer and demand for Shared Mobility .......................................................................... 18

2.5 Make the infrastructure protect freedom of choice ............................................................... 19

2.6 Mobilise the community’s social capital ................................................................................... 20

2.7 If users can’t reach the services, help services reach the users ............................................ 21

2.8 Mainstream service to vulnerable users .................................................................................. 23

2.9 If a car is “indispensable”, limit support to the indispensable .............................................. 26

2.10 Follow a focused approach to micro-enterprises ................................................................... 27

3. Empower Cities & Regions as Key Actors ............................................................................. 28

3.1 Consult & Cooperate for Effective Action ................................................................................. 28

3.2 Fund Sustainable Urban Mobility Planning (SUMP) ................................................................ 30

3.3 Set proportional targets for application of the Fund .............................................................. 31

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Introduction

The weight of road transport in the EU’s greenhouse gas emissions is well-known. For the EU to

become climate-neutral in 2050, road transport must undergo major transformations.

The European Union (EU) has taken key steps to decarbonise road transport. One of the most

important is the Emissions Trading System 2 (ETS-2), which will have a deep impact on the

everyday lives of European households and businesses.

Since Nicolas-Joseph Cugnot's 1769 steam tricycle7 started rolling, the use of fossil fuels in

transport has grown exponentially, fuelling the expansion of urbanised areas, transport

infrastructure and services, industrial capacity for car manufacturing, and personal mobility, all of

this in a mutually reinforcing manner.8

Structural factors drive recurrent choices, repeated choices become habits, and habits grow roots.

While freedom of movement and individual choice cannot be discarded in democratic societies,

we must not ignore that most mobility choices are driven and sustained by structural factors. We

must not ignore, either, that the current mobility system generates important negative

externalities, which pose collective threats.

Our current transport system is based on the massive consumption of fossil fuels, and the

consequent emission of massive amounts of carbon dioxide (CO2). By putting a cap on CO2

emissions, the ETS-2 will raise the price of fossil fuels.9

That rise will pose a serious challenge to households and enterprises whose everyday

mobility patterns require the consumption of large amounts of fossil fuels. They need

proper transport alternatives to be ready and rolling when that happens.

The absence of those alternatives will have serious economic, social, and political impacts.

To avoid those negative impacts, the ETS-2 provides the time, and the Social Climate Fund

provides the funds, to put in place adequate solutions.

These solutions will be particularly important for populations in low-density suburban, peri-urban,

and rural areas. For reasons explained below, they are among the most vulnerable to the rise of

fossil fuel prices in transport, with the inevitable threat this carries in terms of regional cohesion,

social peace, an urban-rural divide, and the political viability of climate policies. But they are also

among the ones who most stand to benefit from a shift towards a more sustainable, safe, and

affordable transport system.

Creating efficient, affordable, and reliable transport solutions for households and micro-

enterprises requires scale, speed, hands-on support, mobilisation of financial, political, and social

capital, integration of different sectors, concrete outcomes, and lasting impacts.

7 The first self-propelled land vehicle, a three-wheeled machine with a top speed of around 3 km/h originally designed for

carrying artillery. 8 The expansion of one factor pushes the expansion of the others. 9 The cap will be lowered on an annual basis, further raising prices if demand does not decrease.

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The SCF provides a way to prepare and act – but it will only be effective if it funds change in the

right direction. This requires clear choices, coherent measures, and cooperation. “Sprinkling”

subsidies at the national level with no local changes to match will just reinforce the status quo and

open no new path towards overcoming our structural problems.

It is of the utmost importance that these national plans are steered towards effective, timely, and

lasting results at the local and regional level. After all, it’s the lack of local and regional solutions

for everyday life that sparks revolt.

Local and regional governments and transport authorities must play a key role in the development

and implementation of the national level Social Climate Plans. This is simply logical, as they

(A) have jurisdiction over the vast majority of the EU’s total road network, (B) fund, and often also

operate, public transport, (C) are best placed to steer new mobility services towards serving public

needs, (D) have the duty of reducing road risk for walking and cycling, (E) have the duty of

eliminating barriers that discriminate based on disability, age, gender and income, and (F) are best

placed to engage with a vast number of communities, households and micro-enterprises, to shape

and support mass behaviour change.

Planning and implementing the SCF is a joint challenge, which requires a cooperative and coherent

approach across levels of government. For that reason, this document provides a way to

understand and frame the (real) challenge, strategic recommendations for an effective approach,

and some basic principles to best empower European cities and regions as key actors in this

process.

These recommendations have been prepared to support EU Member States, which have the role

of preparing the national level Social Climate Plans. The recommendations are also shared to

support and encourage the active contribution of local and regional authorities, and of many

relevant stakeholders, to these national plans.

Charles Darwin found that “the species that survives is the one that is able best to adapt and adjust to

the changing environment in which it finds itself”. 10 The Social Climate Fund provides a unique

opportunity to adapt our mobility systems. How can we best use it? This is a question we must

answer together.

10 Charles Darwin (1809-1882), English naturalist, geologist, and biologist.

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1. The (real) Challenge

Regulation (EU) 2023/955 (Social Climate Fund) defines transport poverty as the “inability or

difficulty” of individuals and households “to meet the costs of private or public transport, or their lack

of or limited access to transport needed for their access to essential socioeconomic services and

activities, taking into account the national and spatial context”. 11

A problem well-defined is a problem half-solved.12 Solving the ‘other half’ requires understanding

the root causes and key characteristics of the problem, acknowledging its complexity, and avoiding

simplistic explanations and approaches that may temporarily alleviate some symptoms but won’t

lead to effective solutions with lasting effects.

We recommend that the Member States consider the following key points, regarding the

understanding and framing of the challenges posed by Transport Poverty:

1.1 Transport poverty is a structural problem requiring structural action

Transport poverty is a result of (A) how people and activities have been distributed in space,

(B) how the transport system has been shaped and managed to connect them, and (C) how public

and private resources have been allocated to cover the capital and operational costs of that

system, as well as its externalities.

The insufficiencies we face today in suburban, peri-urban13, and rural areas derive in good part

from how land use and transportation policies pursued over the past century enabled and

fostered individual car ownership and use, relegating other modes to a secondary role.

The convergence of other changes accelerated and reinforced those effects. The rural exodus

towards urban areas, for example, depleted rural areas from population and services, and

expanded urban areas with vast low-density suburbs that do not favour mass public transport nor

active mobility. Also here, individual car ownership and use was often seen as the default solution.

This has created a situation of car dependency.

The question is not whether this situation can be undone in a fast and ‘painless’ way, because it

clearly cannot. What we must understand is that Transport Poverty results from, and is sustained

by, underlying structural factors. This makes it a structural problem.

Overcoming structural problems requires structural action, namely (A) setting a sound and smart

strategy, pointing at a clear direction for improvement, (B) removing obstacles that are impeding

change in that direction, (C) prioritising investments that help advance in that direction, and

(D) avoiding any measures that undermine the effort (particularly measures that, under the guise

of temporary relief, end up prolonging the problem).

11 Cf. Article 2, number 2. 12 John Dewey (1859-1952), American philosopher, psychologist, and educational reformer. 13 For the purposes of this document we can briefly designate as “suburban” areas with some open land, and as “peri-

urban” areas with very sparse development.

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While the afflictions caused by transport poverty must be addressed, the key question we

face with the Social Climate Fund and its national-level implementation is whether it will

be invested on the permanent removal of the problem, or wasted on the temporary relief

of its symptoms (while the problem keeps growing).

1.2 The key challenge is access, not movement

The core problem of transport poverty is that it harms access to essential socio-economic services

and activities such as health, education, jobs, leisure, political participation, etc.

Access implies movement, but increased movement does not, necessarily, improve access. Often,

quite the contrary – displacing a public service away from those who need it will force its users to

travel longer distances, thus increasing mobility (i.e., amount of kilometers travelled) while

reducing access.

The purpose of transport is not ‘movement’, but access. Naturally, movement enables access, but

efficiency is key for equity. The more movement is required from the household to conduct its

everyday life, the more energy it has to consume, the higher the energy costs it must bear, the

more vulnerable it becomes to an increase in the cost of energy, and, therefore, the more

vulnerable it becomes to transport poverty.

That’s why suburban, peri-urban and rural areas are particularly vulnerable, and why shared

transport solutions (e.g., public transport, demand-responsive transport, carpooling) are among

the most equitable – by aggregating trips they reduce the total amount and cost of km/passenger.

The core challenge for the Social Climate Fund is not to help sustain the inevitable ‘pains’ of

inefficient and inequitable mobility, but to improve access. This shift in perspective is crucial

to understand the problem, prioritise effective solutions, and unlocking innovative

approaches – we must help people reach basic services, but we can also, for example, invest

on helping the services reach them.

1.3 Transport poverty is a regional problem

Transport poverty is a local and regional issue. It is not about sporadic access to the whole country,

but about everyday access to local places for work, public and private services, and other

components and opportunities of social, civic and economic life. It requires local and regional

assessment, action, and responsibility.

Transport poverty is driven by an insufficient level of availability, accessibility, and affordability.

Addressing these insufficiencies requires (A) consulting with the community to understand the

specific needs and the specific resources available in a specific context, to (B) establish what is to

be considered a sufficient level14 of availability, accessibility, and affordability, in order to (C) define

context-specific strategies and priorities, and to (D) mobilise available resources towards ensuring

those sufficient levels for all, and finally (E) evaluating the efficacy of the measures, (F) assuming

responsibility for those results, and (G) correcting the course where and when necessary.

14 Cf. for example Karel Martens, keynote at the 2021 POLIS Conference keynote (available here:

https://www.youtube.com/live/58e_i2Vlrkk)

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All the steps above will have to factor in local context, local needs, and local resources. And

they will require political decisions with political responsibility at the local level.

Local and regional authorities are the level of government which has the legitimacy to lead on the

local and regional scale, the duty of finding practical solutions, and the responsibility of answering

politically for the efficacy of those solutions. That’s why it is indispensable to actively involve them

in the development and implementation of national plans for the SCF.

1.4 For many households, owning a car will never be a “solution”

Transport poverty is a multidimensional problem, which affects different types of individuals and

households, in different ways, in different spatial contexts. We must guard against generic

characterisations and simplistic solutions.

For example, saying that “many people really need a car” can be very misleading, because (A) it

obscures the plight of a large part of the population who cannot afford or cannot drive a car, e.g.,

the elderly and the young, persons with some types of disabilities, households with lower incomes;

(B) in car-owning households, it treats as irrelevant and subordinate the needs of household

members who cannot access that resource, e.g., women, youth, children; (C) it misses the fact that

the costs of a car impact very differently households with different levels of income; (D) it assumes

as equally inevitable a problem that can be addressed very differently, whether in rural or in

suburban areas; (E) it assumes there are individuals for whom the car is the only and best solution

for all trips, at all times of the day, on all days of the year, and for all purposes, which is a very rare

exception; (F) it assumes that the need of a car necessarily implies individual ownership, obscuring

the economic benefits that carpooling and car sharing can provide to households and individuals,

while satisfying their needs.

It may be true that those who do own and drive a car will feel a strong ‘sting’ with the rise of fuel

prices that will derive from the application of ETS-2 to road transport, and the Social Climate Fund

must address these groups.

But we must bear in mind, first, a constitutional imperative to pursue equity (and also support

those who do not own cars), and, second, a functional imperative: in most cases, improving

transport for those who do not own a private car is the best way to build an alternative for

those who do. “You’re never wrong for doing the right thing”.15

1.5 Car dependency means lack of choice, not “freedom of movement”

Freedom of choice requires the availability of comparable options. The existence and persistence

of severe differences between transport options makes them less comparable, and sometimes

not comparable at all.

Structural factors turn differences into disadvantages, and can heavily distort choice, pushing

individuals and households away from transport modes perceived as slower or unsafe. This

distortion is aggravated by the fact that car owners tend to not be aware of the full cost of

15 Samuel Langhorne Clemens (1835-1910), writer known as Mark Twain.

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individual car ownership and use,16 thus ignoring the full weight it has on the households finances,

and the potential savings they could make with other choices.

Distortion of choice reduces freedom of choice. In suburban, peri-urban and rural areas. This

severely constrains freedom of movement, as households are forced to choose between allocating

a significant portion of their income to individual car ownership, or a significant portion of their

time (and safety) to public transport or active mobility.

For the households who can (barely) afford it, forced car ownership17 is not a measure of ‘freedom’,

as it further aggravates financial vulnerability – research shows that forced car owners have

difficulty paying for heating and other basic expenses.18

In a way, these are mobility costs imposed by the lack of mobility choice, both for (A) those who

move to lower-priced suburban areas as a residential strategy to deal with rising housing costs,

and (B) those who remain in rural areas, as the distance to public services (education, health, social

care, postal, etc.) forces them to travel farther.

The solution lies not in keeping households locked in this ‘economic servitude’, nor in making their

lack of choice ‘palatable’. Forced car ownership is a structural problem to be overcome, not the

result of “free popular choice” in a “level-playing field” to which one must subordinate mobility

policies.

Overcoming forced car ownership requires creating the conditions for true freedom of

choice, by, at least, (A) diversifying options in terms of available modes of transport (public

transport, demand responsive transport, cycling, etc.), and (B) diversifying options in terms

of ownership (e.g., car sharing and carpooling, which have substantially lower costs).

1.6 We must (really) address vulnerability to fuel price increases

For individuals and households in a situation of forced car ownership, the vulnerability to fuel price

increases has three key parameters19: (A) exposure, i.e., how much the car is used and how much

fuel is consumed, (B) sensitivity, i.e., the resulting impact of the cost increase in relation to the

household’s available income, and (C) adaptive capacity, i.e., the ability to resort to less onerous

transport solutions, which depends, of course, on their availability and reliability.

16 Cf. for example Stefan Gössling, Jessica Kees, Todd Litman (2022), “The lifetime cost of driving a car”, Ecological

Ergonomics, Volume 194, April: “Motorists underestimate the full private costs of car ownership, while policy makers and

planners underestimate social costs.” 17 “Forced car ownership’ (FCO) applies to households who own cars despite limited economic resources (…) [it] results in

households cutting expenditure on other necessities and/or reducing travel activity to the bare minimum, both of which

may result in social exclusion. (…) The FCO phenomenon suggests that, among households with limited resources,

the enforced possession and use of a durable good can be the cause of material deprivation, economic stress and

vulnerability to fuel price increases”, in Giulio Mattioli (2017), “‘Forced Car Ownership’ in the UK and Germany: Socio-

Spatial Patterns and Potential Economic Stress Impacts”, Social Inclusion, Vol 5, No 4. 18 Cf. for example the presentation made by Mathias De Meyer, from Brussels Mobilité, at the 7th October 2024 meeting of

the POLIS Working Group for Governance & Integration (which can be made available upon request to POLIS or said

researcher). 19 See for example Giulio Mattioli, Ian Philips, Jillian Anable, Tim Chatterton (2019), “Vulnerability to motor fuel price

increases: Socio-spatial patterns in England”, Journal of Transport Geography, Volume 78, June.

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The Social Climate Fund includes, among its eligible measures, temporary direct income support.

We must highlight that, without a multimodal offer, that measure can only influence one of these

parameters (sensitivity), and in a very limited manner.

Another eligible measure is funding the purchase of zero- or low-emission cars, either through

first- or second-hand markets. This measure has limited benefits in terms of sensitivity20, and

essentially converts vulnerability to fossil fuel prices into vulnerability to electricity prices.

Investing in the growth of public transport and in the diversification of complementary

transport solutions such as shared mobility, walking, and cycling, is the most effective,

efficient, and reliable way of reducing vulnerability to fuel price increases.

First, because it increases adaptive capacity, by providing less onerous alternatives. Second,

because it reduces exposure: in the case of public transport, demand responsive transport and

carpooling, by dividing the number of km of the vehicle by its several passengers; in the case of

walking and cycling, by resorting to the energy of the traveller himself (i.e., not having to pay for

externally sourced fuel). Finally, because it reduces sensitivity, as transport services buffer the

impact of energy price fluctuations.

1.7 Only alleviating the symptom perpetuates the problem

The general objective of the Social Climate Fund (SCF) is to contribute to a socially fair

transition towards climate neutrality. Making this transition fair requires using the SCF to

increase the offer of sustainable mobility options for the groups targeted by the Fund.

Making this transition effective requires avoiding the dispersion of the SCF in options that

are inequitable and unsustainable.

While decarbonisation remains a core challenge, the SCF must be applied in a way that (A) is

coherent with other social and environmental policy goals, (B) helps as much as possible the

advancement of those goals, and (C) does not undermine nor delay policies that serve those goals.

On this point, one must bear in mind that electrification, while helpful for decarbonisation, will

not, by itself, eliminate the wide range of negative social and environmental externalities linked to

individual car ownership and use, namely road danger, traffic congestion, toxic microplastic

emissions from road and tyre wear, and the disproportionate use (and impermeabilization) of

public space.

It is critically important that Member States do not use the Social Climate Fund to

perpetuate car dependency. Regulation (EU) 2023/955 (Social Climate Fund) does include, among

its eligible measures, direct income support to reduce the impact of fuel prices, and funding for

the purchase of zero- or low-emission cars – but it’s critical to ensure that these measures do no

significant harm to the transition we need.

Support to those measures must be restricted to situations where more efficient and equitable

transport solutions are not available (and cannot, within a reasonable time frame, be made

available with the SCF). Otherwise, those measures will have the perverse effect of sustaining

20 Electric cars consume less energy and have lower running costs than cars with Internal Combustion Engines.

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behaviour that must change, thus delaying the transition and, what is worse, reinforcing the

obstacles to its achievement.

The best way to advance decarbonisation in a fair, fast, and lasting way, is to accelerate the

shift to public transport, shared mobility (including carpooling and car sharing) and active

mobility (including cycling and walking). The time and resources available are limited for a

shift of such a scale and speed, and we must not dissipate them. A key question must always

be: how can we maximise the SCF’s impact?

We know for sure what to avoid, as experience clearly shows that financial measures of a general

nature that support individual car ownership and use will disperse the available resources and

end up disproportionately benefiting those who are not the most in need. It’s essential to ensure

that measures are targeted to low-income households, and not to everyone equally (which is what

happens with the fuel tax cuts).

The SCF must avoid perpetuating and aggravating inequalities: the existing purchase

subsidies for electric cars are mainly supporting the already affluent households.

According to the latest EAFO Consumer Monitor and Survey 202321, the EU Battery Electric Vehicle

(BEV) driver is represented by a 35 to 55-year-old man living in a detached house with a middle to

high income and a high education level.

This has a proven adverse effect, in the sense that it offers benefits to people who can actually

afford to buy an EV without help, but for those in need it doesn’t make a sufficient difference, or

the compensation is not enough. If subsidies for EVs go disproportionately to high-income

households, we will be reducing exposure among the least sensitive households, while the most

sensitive will remain exposed.22

1.8 Transport poverty feeds injustice, and injustice fuels revolt

The “Gilets Jaunes” movement was triggered by a programmed rise in carbon taxes which

coincided with an increase in car fuel prices. Research conducted since the 2018 start of the

protests has highlighted deeper driving factors.

One must look beyond the ‘spark’ and understand the accumulation of ‘flammable material’: a

persistent sense of (A) disadvantage in the access to services and opportunities,

(B) marginalisation in the allocation of public resources, (C) difficulty in creating and retaining

businesses and jobs in the local economy, (D) vulnerability and degradation of community ties and

identity, (E) helplessness in the face of the effects of globalisation. People felt cornered.

Measures subsequent to the Gilets Jaunes outburst (cancellation of the fuel tax increase, freezing

of planned increases in gas and electricity tariffs, and subsidies to the consumption of fossil fuel

and purchase of electric cars) may have deflated the immediate cause of the protests, but did not

eliminate these driving factors.

21 https://alternative-fuels-observatory.ec.europa.eu/consumer-portal/consumer-monitor 22 Mattioli, Giulio, Dugato, Marco, Philips, Ian (2023) “Vulnerability to Motor Fuel Price Increases: Socio-Spatial Patterns in

Italy”, https://link.springer.com/chapter/10.1007/978-3-031-35684-1_5

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Individual car ownership and use is the most expensive form of land transport for the user and

for the State23 but also the least inclusive and the least efficient, in terms of improving access to

services, allocating public resources, creating local jobs and improving community ties and

identity. One can argue that, with some extreme exceptions, on all these issues it isn’t even

‘neutral’, but rather pushes in the wrong direction, i.e., making the transport system less inclusive

and more inefficient.

The Social Climate Fund must help EU regions move to a transport system that can (A)

improve access for all, leaving no one behind, (B) lead to a more equitable and efficient

allocation of public resources, (C) build on local resources, increase social capital and

support the creation of local jobs, and (D) provide communities with a sense of agency,

which is the only way to overcome helplessness, revolt, and resistance to climate-friendly

policies and measures.24

Road transport plays a central role in the economy – in the cost structure of various businesses

and in the price formation of their goods and services. The increase in fossil fuel prices expected

from the application of the ETS-2 to road transport will be felt across several domains, and will

have various social repercussions.

It would be shortsighted and dangerously naïve to assume that, when fossil fuel price increases

become an unavoidable reality, measures to keep households locked in forced car ownership will,

in any way, be perceived and appreciated as helpful by those most affected.

What households and businesses need is not temporary alleviation of the symptoms, but

committed and serious work on the root causes, through reliable and structural solutions,

as fast as possible.

23 Even more so if externalities are considered. 24 Algan, Yann & Beasley, Elizabeth & Cohen, Daniel & Foucault, Martial (2019), "Les Origines du populisme: Enquête sur un

schisme politique et social", Seuil, La République des idées.

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2. Strategic Recommendations

We cannot solve the problems we face with the same thinking that created them in the first place.25

In other words, the Social Climate Fund cannot solve transport poverty by doubling down on

the car-centric policies that created and sustain it. A new strategic approach is required, to

achieve efficient, fast, reliable, and lasting solutions.

We recommend to Member States the following key points, for a strategic approach:

2.1 Transport and Energy Poverty require different approaches

The ways in which Energy Poverty and Transport Poverty can be addressed in practice differ

substantively. Energy Poverty mainly involves the performance of a fixed asset (the home) with a

fairly stable use pattern. Transport Poverty, quite differently, involves the performance of a

dynamic system, in which different elements (infrastructure, vehicles, services running those

vehicles, businesses launching and managing those services) interact and influence each other.

This creates barriers but also leverage points. Use patterns also change, just as the activities that

individuals and households wish to pursue can vary substantially, and, thus, also their mobility

needs.

And there are more differences to consider. The assets (vehicles) involved in transportation

systems are diverse (bikes, buses, vans, cars, etc.), they can have different types of ownership(e.g.,

belong to the household, or to a public transport or shared mobility operator, or to a carpooling

partner that offers a ride), they can be chosen according to the purpose (e.g., for long or short

trips, for the full trip or just for the first and last mile, for commuting to work or for recreation,

etc.), and they may end up being dispensed with (e.g., by people who cannot drive anymore

because of age-related limitations, or because they can no longer afford it).

Furthermore, in such a dynamic system, individual and collective behaviours can strongly

influence each other, and transport policy-makers must carefully consider whether their decisions

will create virtuous or vicious cycles26, and to what extent support to individuals will result (or not)

in collective benefits27. These are critical questions to bear in mind for the application of the

Social Climate Fund.

In short, while investment in an individual home or building is a necessary way to reduce

energy poverty, the same does not apply to transport poverty, where the problem has

resided, precisely, in supporting the ownership and use of an individual four-wheeled

asset28.

25 Albert Einstein (1879-1955), att. and adapted. 26 I.e., whether they will lead the system to yield progressively positive or negative outcomes. 27 ITF (2021), “Reversing Car Dependency: Summary and Conclusions”, ITF Roundtable Reports, No. 181, OECD Publishing,

Paris. 28 I.e., cars.

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Experience in transport shows that subsidising the individual purchase and use of a car has several

practical limitations and perverse effects: (A) it involves administrative procedures which tend to

put at a disadvantage those who have lower income and social capital, and disproportionately

benefits those who least need the subsidy, (B) it does not enable nor encourage the beneficiaries

to pool their resources together to create more efficient solutions for the wider community (i.e., it

does not generate collective benefits), (C) it does not support the creation nor encourage the

upgrading of services (public or private) that could benefit a wider part of the community (another

way it does not generate collective benefits), (D) it does not attract additional funding from

entrepreneurs into the development and deployment of new mobility solutions, (E) it cannot

benefit from critical mass nor revenues generated by higher-income customers, unlike a mobility

service, (F) its resilience fully depends on the individual’s ability to pay for the use of its individual

asset, and not on the wider community, (G) it doesn’t encourage beneficiaries to change behaviour

and decrease their vulnerability to transport poverty where that is possible.

The definition of eligibility criteria for the Social Climate Fund must bear in mind these differences

between energy and transport poverty, in order to be effective and generate systemic benefits.

2.2 Prioritise a multimodal approach

Different people have different transportation needs – at different times of the day, days of the

week, and weeks of the year, to access different destinations, for different purposes, alone or with

others.

The most efficient and equitable solution for each of these transportation needs varies, and that

is why lack of choice is a key driver of transport poverty, because it forces people to use

inefficient and unsustainable transport options.

A fundamental step to address transport poverty, therefore, is to enable choice. The Social

Climate Fund must be used to foster the emergence of a multimodal ‘menu’ of transport

options. The more diversified this ‘menu’ becomes, the more versatile it will be. The more versatile

Recommendations for the national level Social Climate Plans:

(1) Privilege the support to transport solutions that do not limit their benefits to the

receiving household, i.e., to solutions that can generate direct and indirect collective benefits

(including, e.g., creating jobs and retaining funds in the local economy;

(2) Channel support to transport authorities and operators, which can support individuals

and their communities with solutions that best understand the local context, best address its

needs, and best build on its resources;

(3) For support to shared and sustainable mobility, focus eligibility criteria on geographical

areas (rural, suburban and peri-urban), types of users (elderly, low-income groups,

households with children) and purposes of trips (essential socio-economic services and

activities, including employment, education, health, etc.);

(4) Privilege financial support in ways that reduce administrative barriers, benefit the users

and support the services (e.g., vouchers, micro-subsidies, well-established eligibility criteria

using reduced-fare criteria and processes for public transport, etc.).

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it becomes, the more capable it will be, as a whole, of providing convenient solutions for different

transport needs. This will make this ‘mobility menu’ reliable, resilient, affordable, and equitable.

Real multimodal freedom of choice will have deeper effects as well, as it will allow vulnerable

households to forego individual car ownership and use, contributing directly to an improvement

in their social and material well-being. In other words, it will reduce vulnerability by improving

adaptive capacity.

Experience shows that the budget invested in individual car ownership and use (potentially several

hundred euros per month) can be devoted to other dimensions of household well-being, which

will in turn have beneficial effects on the local economy, as this will free financial resources that

now may flow to local economic activities (payment of food, rent, etc.).

Passengers cars can (and should) remain a part of this multimodal portfolio – for the reasons

discussed above, the challenge is not to eliminate options, but to diversify them.

What must be clear is that (A) individual car use is highly inefficient, and a source of environmental

and social problems, (B) car use does not require individual car ownership, with carpooling and

car sharing being very efficient solutions, and (C) monopoly of the transport system by individual

car-ownership and use is pushing out (and keeping out) of the mobility menu options that are

more efficient and much need to fight transport poverty.

2.3 Build on a solid foundation: Public Transport

As the backbone of urban mobility, mass public transport (by bus, tram, subway, train) provides

the most efficient and equitable solution to connect urban centres to their peri-urban and

suburban areas. Its great potential lies in the aggregation of trips, and the resulting efficiencies in

terms of space, energy and operating costs.

Public transport is a key tool to overcome the transport poverty that afflicts many peri-urban and

suburban areas. The characteristics of such areas, however, are challenging for mass public

transport: (A) lower densities (which make aggregation of trips difficult), (B) longer distances to

Recommendations for the national level Social Climate Plans:

(1) Prioritise measures that will, directly or indirectly, support and grow multimodality, either

through support to operators (to deploy or scale up, including benefits for drivers adhering

to carpooling systems) and users (to support or generate demand). More people in a situation

of transport poverty will be reached and supported in this way, and with more lasting effects.

(2) Support the use of (2.1) public transport, (2.2) various types of shared mobility (e.g., car

sharing, carpooling, demand responsive transport, shared micromobility), (2.3) cycling and

walking, (2.4) park and ride.

(3) Direct funding for these purposes to public services, but also to local labour-intensive

businesses, to launch and operate transport of people (e.g., car sharing, demand-responsive

transport, etc.) and transport of goods (e.g., cooperatives to enable local shops to offer local

deliveries).

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reach the network (which require a first- and last-mile connection) and (C) high variations between

peak and off-peak demands (which either overload or underutilise capacity).

The best way to deal with these challenges is to build on public transport as a solid foundation, by

simultaneously (A) facilitating the use of cycling and shared mobility (e.g., shared electric bikes, car

sharing) for first- and last-mile connections to mass public transport corridors (train, tram, subway

networks), (B) contracting with shared mobility services (e.g., carpooling, demand responsive

transport, taxi, etc.) when and where these are more efficient than a bus, and (C) when possible,

reallocating the buses ‘freed’ by these gains of efficiency to increase capacity (growing fleets and

frequencies) where trips are aggregated.

We must bear in mind that, while advancing sustainable mobility and fighting transport poverty,

public transport authorities and operators are having to address, at the same time, other key

challenges, namely (A) decarbonising bus fleets, (B) making infrastructure more resilient for the

now inevitable extreme climate events, (C) adjusting to an evolving demand, particularly after the

COVID-19 lockdown and the growth of teleworking, (D) recruiting, training, and retaining new

workers, and (E) in some Member States, dealing with a reduction of public funding. All these

challenges have serious CAPEX and OPEX implications.

In this context, one must exercise extreme care when considering “free public transport” schemes.

Public transport is never “free” – the question is who pays for it. However popular it may sound,

the fact is “free public transport” schemes (A) grow usage at the cost of growing capacity, (B) divest

transport authorities from the capacity to grow and improve the service, (C) loose revenues from

users for whom the current cost is not an obstacle and don’t need the support, and (D) don’t

necessarily achieve modal shift in key target groups.

The Social Climate Fund must be targeted, and must point at the right targets. We must

avoid repeating mistakes, aggravating problems, or increasing limitations. Public transport

is and must remain a solid foundation – we must build on its strengths, and complement it

with transport solutions that will increase its efficiency and convenience.

Recommendations for the national level Social Climate Plans:

(1) Provide funding for Public Transport, prioritising measures that build on its strengths and

help overcome its limitations in low-density areas;

(2) Fund the orchestration, by transport authorities, of schemes that combine public transport

and shared mobility, namely to (2.1) increase the catchment areas of mass transit corridors

and hubs, and to (2.2) increase the efficiency (e.g., cost per passenger per km) of means

allocated to low-density areas, off-peak hours, and specific groups of users or trip purposes;

(3) Support the implementation of physical and traffic management measures to improve

bus and tram service, including (3.1) reserved BUS lanes, (3.2) Intelligent Transportation

Systems (ITS) to protect and prioritise bus and tram flow, (3.3) upgrading of bus stops, to

facilitate docking, accelerate boarding and alighting, and protect and facilitate re-entry in

traffic flow, (3.4) improvement of lighting, seating, and waiting areas in bus and tram stops,

(3.5) upgrading of systems for ticket sales and validation.

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2.4 Boost offer and demand for Shared Mobility

We can broadly define shared mobility as transportation services and resources that are shared

among users, either concurrently or one after another – this includes, respectively, sharing rides

(carpooling, demand responsive transport, etc.), or sharing vehicles (bike, scooter, car, van, etc.).

Shared mobility has grown substantially over the past decade, and today offers a wide array of

solutions and a solid foundation of practical experience.

Shared mobility has several key advantages, as it (A) can provide choice, and various ways to

deploy, diversify and upscale mobility options to match local needs, (B) can be quickly started by

private initiative (both for-profit or non-profit), and build on local resources already available,

(C) can be steered to serve public needs in an affordable and efficient manner (e.g., to complement

public transport), (D) is more labour-intensive than individual car ownership and use, and creates

and retains local jobs, (E) retains in the local economy a higher percentage of the money spent on

transport, and can even reward some users for their service to others (e.g., in carpooling), (F) can

work in such a way that the more affluent users create critical mass and generate revenues that

make these services available and affordable for lower income users, (G) enables public support

to effectively target specific types of users, geographical areas, and trip purposes (e.g., through

micro-incentives, mobility credits, etc.), and (H) provides communities with a diverse catalogue of

practical solutions that can be used to create context-sensitive and tailor-made transport

solutions.

Shared mobility is an extremely useful tool to fight transport poverty in suburban, peri-

urban, and rural areas, while at the same time promoting (A) decarbonisation, (B) energy

efficiency, (C) resiliency, (D) local economies and (E) local jobs.

Shared mobility services are currently more concentrated in denser urban areas – these offer an

easier case for a go-alone business model (public incentives are mostly absent, contrary to what

happens, e.g., with individual car ownership and use, which benefits from fossil fuel subsidies and

much more).

But while the business case may appear more challenging in suburban, peri-urban and rural

settings, there is in fact massive untapped potential waiting for the right strategic approach

and support from the public sector. To fully achieve its potential benefits, shared mobility needs

public governance, and the Social Climate Fund can be instrumental, by simultaneously helping its

operators deploy in these areas, and laying the foundations for effective public steering.29

29 Docherty, Iain & Marsden, Greg & Anable, Jillian (2018), “The governance of smart mobility”, Transportation Research Part

A: Policy and Practice, Volume 115, September 2018, Pages 114-125

Recommendations for the national level Social Climate Plans:

(1) Finance the growth of both offer and demand of shared mobility (to avoid a ‘chicken-

and-egg’ problem, where demand doesn’t grow because of low offer, and vice-versa);

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2.5 Make the infrastructure protect freedom of choice

For several decades, the road network was planned, designed and managed to support individual

car ownership and use. This has led to an unequal distribution of space, speed, and risk.

This inequality systematically harms the performance and safety of other transport modes,

discouraging the adoption of more efficient and affordable solutions. It has also become an

obstacle to the deployment and consolidation of new mobility services. In short, it harms freedom

of choice, blocks innovation, and sustains transport poverty.

Experience at the local level clearly shows that sustainability, safety and equity must advance

together, or none of them will advance effectively – (A) lack of safety discourages the use of

sustainable modes like cycling and public transport, (B) sustainable modes are the most

affordable, and as such provide critical benefits to economically vulnerable groups, and (C) road

danger disproportionately affects economically vulnerable groups.

Local experience also shows that, contrary to highways and motorways, local roads and streets

can be improved at the network level, through simple traffic calming interventions which, in

comparison to large infrastructural interventions, require much lower budgets, enable faster and

simpler procurement procedures, and apply easier construction methods.

These traffic calming interventions have ripple effects over wider areas30, and allow for phased and

integrated approaches. Reducing speed limits can be a first and fast step to mitigate safety

insufficiencies detected in the framework of the RISM Directive31.

30 For example, raising an intersection for traffic calming can have an effect in a radius of 50 meters in all directions

(covering somewhere between 7,000 to 10,000 square meters of land). 31 Directive (EU) 2019/1936 of 23 October 2019, amending Directive 2008/96/EC on Road Infrastructure Safety

Management.

(2) Support funding that ensures a level of stable and reliable demand (e.g., for the full

duration of the SCF), to reduce risk and increase bankability;

(3) Privilege regional or local transport authorities as a funding channel, to encourage

combination with public transport and steer for-profit shared mobility operators towards

public needs;

(4) Enable different forms of targeting beneficiaries, supporting specific types of users,

geographical areas, and purposes of trips through (4.1) credits or vouchers, and (4.2) micro-

incentives;

(5) Support the integration (in the appropriate services) of stable travel demands, e.g.,

commuting to school, jobs, health and social services;

(6) Avoid restricting the services to low-income transport-poor, and enable use by higher-income

full-paying customers, to enable a wider and more resilient customer base and an inclusive

branding of the services, and to create critical mass and generate revenues that make these

services available and affordable for lower income users;

(7) Give preference to transport services based on socially responsible labour practices.

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Quality and accessibility to and from public transport stops and stations are also central

determinants when one chooses to or not to travel by public transport. Thus, ensuring that the

public space leading to and around public transport stops and stations is safe, comfortable and

accessible is essential, making public space also part of Public Transport infrastructure. Last, but

not least, we must bear in mind that the quality of public space is the quality of walking and cycling

infrastructure.

In short, these targeted interventions, easy to control in time and budget, can reduce traffic

speed but accelerate change, and unlock the full potential of streets as places for social and

economic life, and for transport innovation.

2.6 Mobilise the community’s social capital

Advancing decarbonisation and at the same time fighting transport poverty is a massive strategic

and political challenge. It requires the full mobilisation of the creative, social, and political capital

of the whole community. Many stakeholders have an important part to play: public and private,

for-profit and non-profit, elected officials and their constituencies. “Everyone can be great,

because everyone can serve”.32

Local and regional governments are the best placed to (A) tap community ties and trust (i.e., social

capital) as an economic resource, (B) mobilise and focus endogenous resources, and (C) to find

and foster creative and integrated measures that provide practical, viable and fast solutions. This

approach poses its own practical challenges, of course, but it can deliver in a more efficient, fast,

reliable, and economic way than centralisation and top-down measures, and have deeper and

longer-lasting impacts.

32 Martin Luther King, Jr. (1929-1968)

Recommendations for the national level Social Climate Plans:

(1) Promote speed reduction, including Zone 30 areas, Low Traffic Neighbourhoods, school

streets, shared spaces and woonerven1, and physical traffic calming measures, e.g., raised

intersections and crosswalks, bottlenecks and pedestrian islands;

(2) Make streets safely cyclable, through speed reduction, shared streets with bike priority

(fietsstraat1), and where necessary segregated cycling lanes;

(3) Grow bicycle parking, both on-street, including bicycle hangars, and off-street, including

bicycle parking in office, residential and public buildings, and in mass transit hubs;

(4) Implement shared mobility hubs, combining parking for shared bicycles, cargo bikes,

standing scooters, scooters, cars and vans, and respective charging infrastructure;

(5) Promote installation of charging infrastructure for light electric vehicles, including fire-

safe charging lockers in residential, public, and office buildings;

(6) Support targeted improvements to the pedestrian infrastructure, namely (6.1) safe and

accessible crosswalks, (6.2) missing links in pedestrian paths, (6.3) increase accessibility,

safety and comfort in pedestrian paths to and from mobility hubs, public transport stops and

stations.

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Furthermore, there is a critical need to interact directly with target beneficiaries. Experience

shows that those who most need this kind of support usually have less access to information about

it, and less availability to reach out and follow through all administrative procedures (usually

conducted during office hours or via digital channels, which increases the difficulty).

In addition, overcoming transport poverty will in most cases require some degree of behaviour

change for the household. Shaping and encouraging this change requires analysis, development

of tailor-made combinations and trial of new mobility options. All of this implies more than a

simple ‘administrative step’. It requires one-on-one dialogue, multiplied by many households.

Active cooperation of local organisations is indispensable for effective outreach, awareness-

raising, and dialogue.

2.7 If users can’t reach the services, help services reach the users

Physical access to essential socioeconomic services (education, health, social support, etc.) can be

achieved in two ways – either the user moves to reach the service, or the service moves to reach

the user33. The key question is to know, for different types of service and user, which way is the

most efficient, reliable, and affordable, for both the user and the service provider.

The default approach has been to put the “burden of moving” on the individual.34 When there are

public service obligations involved, and the user isn’t able to reach the services autonomously (e.g.,

because of disability or cost), the public sector provides (or at least pays for) specific and separate

transportation to the users for whom that burden is too much.

These specific services are, often, (A) a marginal part of the service (i.e., not designed as an integral

part of the process), (B) inefficient (commonly having to serve a small number of users over a wide

area), (C) inevitably limited in their capacity and quality (because of budget constraints, which can

then further aggravate those limitations), and (D) at risk, particularly in the case of services to the

33 Digital technologies may provide additional options for some procedures, but those options pose additional challenges

of their own, and, in any case, human contact is to a good degree indispensable. 34 This ‘burden’ must often taken up by the household or close support system, if the individual has one.

Recommendations for the national level Social Climate Plans:

(1) Privilege the creation of local one-stop “shops” that can reach out to target beneficiaries and

provide tailored guidance and support to households, individuals and micro-enterprises

(these “shops” can be added to already-established channels and programmes);

(2) Foster the involvement of regional business actors in the development of local shared

mobility services, and support the ongoing evolution of automobile clubs into mobility

clubs offering shared mobility solutions;

(3) Actively support the creation or growth of cooperatives in the transport sector, including

for direct operations (e.g., local deliveries) and associated services (e.g., bike maintenance

shops), covering (3.1) preparatory studies, (3.2) capacity building and (3.3) operating funds;

(4) Support community-led creation of services and schemes (e.g., car sharing, carpooling,

cargo bike sharing, etc.), e.g., by local development associations, mobility clubs, local charities,

resident associations, etc.

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elderly, because the ageing of the population will increase demand, and the rise of fossil fuel prices

will aggravate financial strains.

This is a bad dilemma – things are either bad for the user, or bad for the provider, and they’re

often bad for both. This issue is, fundamentally, about transport poverty, and there are two ways

in which the Social Climate Fund can help – by (A) supporting new solutions that help the service

reach the user, particularly in lower-density areas, and by (B) supporting more efficient options for

helping the user reach the service.

We can bring the service to the user by creating small decentralised service points for the regular

provision of basic services. In the health sector, for example, (A) the “basic services” can include

basic nursing care in an outpatient setting (e.g., taking samples for analysis, vaccinations,

supervised taking of special medication, changing dressings and removing surgical stitches) or

medical consultations that do not require fixed instrumentation (e.g., general medicine,

psychiatry, etc.), (B) the “regular provision” can consist of one or two fixed days of the week (clear

expectations make for easy management), and (C) the small decentralised service points can

consist of adapted rooms located in already existing public facilities, or made available by local

community organisations.

These decentralised service points may not “solve everything”, but they will certainly help a lot. In

the health sector that’s literally “a lot”, as many trips are taken for ambulatory care and outpatient

visits that could be done closer to the place of residence.

On the other hand, when transportation of users to places of service is indispensable, how can we

improve the efficiency and financial viability of the necessary transportation services?

The aggregation of trips is a key step for increasing transport efficiency – shared trips reduce the

amount of km per passenger, and therefore the costs. Aggregating trips in lower-density suburban

and rural areas has always been a challenge, but digital technology today provides very useful

tools to deal with that, and shared mobility (particularly demand responsive transport and

carpooling) provides efficient alternatives for many cases.

This will certainly help users in a situation of transport poverty – and, most importantly, it will have

very important economic benefits for the service providers, because it will (A) increase service

performance and efficiency (e.g., reduce no-shows, increase punctuality), (B) free up key assets

(e.g., hospital beds), (C) dispense with heavy and space-consuming infrastructure investments

(e.g., parking in large facilities), (D) increase the efficiency and therefore reduce the costs of

transportation services (e.g., increasing the number of users allows for several economies of scale,

which can be further increased by the resort to mainstream shared mobility services), (E) increase

competitiveness and innovation in local businesses (e.g., supporting the creation and growth of

local delivery cooperatives will enable local shops to deal with the growing pull of e-commerce),

and (F) increase the well-being (and satisfaction) of the users and respective households (which

has social but also financial benefits for the service providers, the community in general, and the

State).

Urban and regional planning and land use also play a key role here in determining what and where

is being developed and how the different uses and services are being distributed geographically.

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The city of proximity and other similar approaches to urban planning offers some insights and

principles that might alleviate the burden of lengthy trips and service locations by balancing

housing, services, jobs, education and leisure distribution.

Increasingly connecting transport to urban and regional planning and land use will increase the

efficiency of mobility solutions as well as travel distances, being particularly relevant for new

neighbourhoods and developments. The SFC can support the implementation of strategic plans

that develop transport and land use together, offer different sustainable transport choices, and

consider housing availability. It can also provide support to institutional and organisational

improvement to allow for such approaches at the local and regional levels.

2.8 Mainstream service to vulnerable users

Through its shape and function, the transport environment (infrastructure, vehicles, operations

and user interfaces) imposes on potential users certain implicit “conditions to use”, e.g., the ability

to walk to bus stops or move through train stations, to understand the network and plan the

desired routes, to use payment interfaces, to board and alight trains, trams and buses (e.g.,

overcoming steps and horizontal gaps), to look for and correctly identify the desired vehicle to

board, or stop to alight.

Recommendations for the national level Social Climate Plans:

(1) Support the development, implementation and improvement, by public and non-profit

health and social care organisations, of services provided at home (e.g., ambulatory health

care, elderly home support);

(2) Support the creation of local-based businesses (e.g., cooperatives) that can provide these

and other services, or transport solutions for their provision;

(3) Support the acquisition of electric vehicles by specialised organisations and

professionals providing for access to essential socio-economic services through home

service (e.g., nursing, physiotherapy, delivery of cooked meals for dependent elderly persons,

etc.);

(4) Support the development and acquisition of services, platforms and fleets that can increase

the efficiency and level of service of specialised transport to key services (e.g., school,

scheduled medical appointments, social services, etc.), including their aggregation, and their

integration with shared mobility services (e.g., taxi, demand responsive transport,

carpooling);

(5) Support the creation and growth of local delivery services, by local transport cooperatives,

or by individual or associated local businesses (e.g., groceries and supermarkets, pharmacies,

etc.), including the technological means for conduct of e-commerce (e.g., webpages enabling

the placement of orders to be delivered);

(6) Support the creation, improvement and operation of decentralised facilities for the

provision of public services (e.g., fiscal and other administrative services, local health clinics

for ambulatory care on fixed days), through direct public provision or where necessary in

agreement with third parties.

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These “conditions to use” require motor, sensory and cognitive abilities. And in some important

cases they require more, namely the ability to travel accompanied by children, or to overcome

fear, particularly of road danger or sexual harassment, when walking, cycling, or using public

transport.35

Users who cannot “satisfy” one or more of these “conditions to use” are either impeded or

restricted in their ability to move, and forced to either forego their autonomy, or to pay a higher

price for it. In all Member States, this affects a very substantial part of the population, and for two

main reasons.

First, because these problems are faced by a large, diverse, and dynamic universe of individuals,

including, among others, (A) women (of different ages, in different social and cultural contexts,

with or without children), (B) an ageing population (including those who are driverless in rural

areas, where individual car ownership is wrongly touted as ‘indispensable’), (C) persons with

different types of disability (motor, sensory, cognitive, including many elderly people, as age

correlates strongly with disability), and (D) children and adolescents (when they’re forming their

attitudes and preferences towards transport modes and travel habits).

Second, because lack of autonomy generates dependency, and that dependency has costs (in time,

money and resources) for the individual, but also for the respective household, close relatives and

friends, the wider community and, inevitably, the State.

The source of the problem lies not in the users, but in (A) the “conditions to use” imposed by the

transport environment (where the threshold for safe and autonomous use is placed too high it

becomes a barrier), and (B) the lack of adequate alternatives to bypass barriers in the available

offer. These factors narrow choice, and thus generate and aggravate transport poverty.

Mainstreaming the response to transportation needs is, whenever and wherever possible, the

best approach. Removing barriers that create undue effort and separation enables everyone

to benefit equally and independently, making the transport system functional, safe, and

appealing for all.

Paratransit36 or ‘transport for the disabled’, provided as a way to compensate for existing barriers

through the provision of specific and separate (i.e., segregated) services, are often the least

inclusive, the least efficient, the most limited, and the most vulnerable to financial constraints and

operational complications.

The way forward is not to create segregated solutions as an alternative to the elimination of

barriers in the mainstream services. That approach will always be the least efficient and the least

beneficial for all users – the alternative will chronically underperform, and the mainstream services

will not improve.

35 This fear is not to be discounted – first, because most often it is a reaction to objective risk, and second because,

regardless of its subjectivity, it objectively affects transport behaviour and mode choices. 36 “Paratransit” means comparable transportation service required by individuals with disabilities who are unable to use

fixed route transportation systems.

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What must be done is, at the same time, (A) eliminating barriers in mainstream services, and (B)

creating complementary solutions to mainstream services. The emphasis is on complementary –

again, diversification is key.

In what regards, specifically, persons with disabilities, the best is to align this complementary

approach with the principles of Independent Living37, and provide financial support to persons

with disabilities that will enable them to tailor and manage solutions for themselves.

37 “Independent Living” means that individuals with disabilities are provided with the necessary means to exercise choice

and control over their lives. This includes access to (among other things) transport and personal assistance. It should not

be interpreted solely as the ability to carry out daily activities by oneself, but as the freedom to choose and control, with

dignity and individual autonomy, as enshrined in article 3 (a) of the United Nations Convention on the Rights of Persons

with Disabilities.

Recommendations for the national level Social Climate Plans:

(1) The elimination of barriers to accessibility (physical and communicational) in the public

transport network, including (1.1) vehicles, e.g., ramps, reserved seating, and onboard

communication devices, (1.2) stations and stops, e.g., circulation paths within stations, and

pedestrian paths connecting to and from stations and stops, fixed or mechanical means to

overcome gaps between platforms and vehicles and human support services, wayfinding,

ticketing and access gates;

(2) The inclusivity of taxi and shared mobility services, including (2.1) purchase of wheelchair

accessible vehicles, (2.2) implementation of inclusive service procedures and respective

training of staff;

(3) The integration of shared mobility services in paratransit systems, to increase their

efficiency, flexibility, and choice;

(4) The creation or improvement of independent mobility solutions by Independent Living

Centres, including, (4.1) the acquisition, leasing, or rental of accessible vehicles for car sharing,

(4.2) the provision of financial support for persons with disabilities to be able to recruit and

manage personal assistants for driving1;

(5) Where necessary, in complement to existing supports (tax benefits or subsidies), the

acquisition of electric vehicles (cars, vans, scooters and bicycles) by individuals with a

threshold level of disability (or their respective household), and funding for vehicle

adaptations to their respective needs;

(6) The reduction of road danger for people walking and cycling, particularly through traffic

calming in the vicinity of schools, health care and social care facilities, and higher-risk

locations;

(7) The implementation of physical and operational measures to reduce the risk of sexual

harassment and improve the feeling of security in public transport vehicles, stops and

stations (e.g., lighting, video surveillance, staff training, etc.);

(8) The development and implementation of targeted and efficient combined mobility

solutions, to serve the needs of people who commonly have to resort to trip-chaining or to

travel in lower-density areas in off-peak hours (e.g., women, youth, elderly).

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2.9 If a car is “indispensable”, limit support to the indispensable

While individual car ownership and use plays an important role in the everyday routines of many

households, it’s important to keep in mind that the “need of a car” is never an absolute and

objective indicator – it can be part context and part perception, part habit and part justification of

habit, part lack of convenient alternatives and part lack of awareness of their existence, part need

and part preference. In peripheral rural areas, each owner of an ‘indispensable’ car certainly has

neighbours who carry on with their lives without one.

The Social Climate Fund’s regulation38 includes, among its eligible measures, direct income

support to reduce the impact of fuel prices, and funding for the purchase of zero- and low-

emission cars. Clear limits must be set on both the eligibility of beneficiaries, and on the type and

amount of support provided to those eligible, to avoid dispersion of the available funding, and to

ensure the best return on investment.

In principle, the “need of a car” must be considered in relation to:

• the needs of the full household, and not just the driver;

• the alternatives available and their cost (in terms of time and money) to ensure autonomous

access, by all members of the household, to a set of essential socio-economic services and

activities, e.g., health and social care, education, employment, provision of food and other

basic goods, etc. ;

• the alternatives that could be created or supported for that purpose (e.g., carpooling, demand-

responsive transport, etc.);

• regular work shifts starting or ending at late night or early dawn, particularly essential workers

(e.g., nurses, teachers, social care workers, police and fire service).

Basing support on an individual assessment of these issues could become burdensome and

intrusive. Spatial targeting and, within specific areas, income-based targeting could help

implement some of these principles in a fair and respectful way.

38 Regulation (EU) 2023/955

Recommendations for the national level Social Climate Plans:

(1) As a key guiding principle, restrict funding to the indispensable and not beyond;

(2) Avoid funding, in any case, the purchase of first- or second-hand large and heavy electric cars,

namely SUVs (fund a vehicle that is fit for purpose, but not beyond);

(3) Restrict the direct income support to reduce the impact of fuel prices to a time period that

ends before the term of the SCF;

(4) In low-density rural and peri-urban areas, for households who already own, or will acquire an

electric car, support the installation of home charging solutions;

(5) In low-density rural and peri-urban areas, consider supporting a social leasing scheme for

small electric cars, that would enable beneficiaries (households, cooperatives or

associations, micro-enterprises) to use electric cars made in Europe for a monthly rent,

without upfront costs (this measure could be co-financed through the Recovery and

Resilience Facility, and then revenues from ETS-2 and the Social Climate Fund; its impact could

be further increased if conditional on adhesion to carpooling or car sharing schemes).

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2.10 Follow a focused approach to micro-enterprises

There is much diversity in the types of micro-enterprises, in the business they conduct, in where

they are located and where they operate, in their transport needs and in the means available to

satisfy those needs, in their types of employees and respective transport needs, and in the ability

and functional interest of the employer to support those needs. It is important to understand and

build on this diversity.

Generic indicators and one-size-fits-all measures for micro-enterprises should be avoided, as they

would dissipate the impact of the Fund and have perverse effects – for example, (A) defining

eligibility of the basis of fiscal performance can benefit disproportionately companies who are able

to reduce their fiscal footprint39, and (B) supporting company passenger car ownership can

encourage the use of cars as a perk for higher-earning qualified workers.

Corporate mobility is an important component of local transport, and the mobility

practices implemented for business purposes and employee commuting have a wider

influence on mobility behaviour. Corporate mobility can also be a relevant and reliable source of

demand for public transport, shared mobility, and cycling, and as such can make an invaluable

contribution towards the viability and bankability of these services, which evidently will benefit the

wider community.

39 For example, by being able to afford specialised legal advice.

Recommendations for the national level Social Climate Plans to support micro-enterprises:

(1) Restrict support to the purchase of zero- and low-emission passenger cars, light

commercial vehicles and vans, to businesses which require dedicated vehicles for the

performance of their activities, namely to (1.1) carry tools, equipment or materials, e.g.,

plumbers, electricians, cleaning, etc., (1.2) deliver goods as an essential part of their service,

e.g., delivery companies, or companies which must deliver their own goods as part of their

service, or (1.3) provide social or health care services at different locations, e.g., nurses and

physiotherapists;

(2) Expressly avoid covering the costs of company cars provided to employees for their

personal use (either for purchase, leasing, renting, or energy costs);

(3) In low-density rural and peri-urban areas, for microenterprises who already own, or will

acquire an electric car, support the installation of facilities-based charging solutions.

(4) Support the development of corporate mobility plans1, encouraging the association of local

businesses and other employers for that purpose (e.g., in suburban business parks);

(5) Privilege the implementation of sustainable corporate mobility solutions based on

mobility budgets for public transport, shared mobility, and cycling;

(6) Support the acquisition of light electric vehicles, e.g., electric cargo bikes, electric scooters,

etc. for the conduct of business activities.

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3. Empower Cities & Regions as Key Actors

3.1 Consult & Cooperate for Effective Action

The Social Climate Fund regulation establishes a clear requirement for Member States to

undertake a public consultation process with key stakeholders, and to demonstrate how this input

has been integrated prior to submitting their Social Climate Plans.

Meaningful engagement of local and regional governments is not just a procedural

requirement – it is a strategic necessity.

Local and regional governments and transport authorities (A) deal directly with the SCF’s target

groups, (B) have jurisdiction over most of the key elements that make up the regional mobility

systems that serve everyday life, from transport infrastructure to transport services, (C) are the

best positioned to mobilise endogenous resources to support the design and implementation of

climate, energy and mobility policies, and multiplying their positive impacts, (D) are a specific level

of EU territorial governance, with its own democratic legitimacy, and its political accountability is

a key factor in the roll-out of measures funded by the SCF.

Integrating cities and regions into the planning and implementation of Social Climate Plans

is indispensable for the Social Climate Fund to achieve its intended impact.

We must learn from experience. The implementation of the Recovery and Resilience Facility (RRF)

demonstrated the challenges of centralised decision-making, where local and regional authorities

were often excluded from consultation and meaningful involvement. While these plans have had

a positive impact, their overall impact could have been much better with a more systematic

involvement of local and regional authorities.

Sidelining local and regional authorities in key phases of planning, implementation, and

monitoring led to broad, top-down measures that often lacked the granularity to address local

needs or adequately target vulnerable populations. For the SCF, which aims to support vulnerable

households and small businesses in the green transition, such exclusion could result in missed

opportunities to achieve equitable and effective outcomes and poor execution rates of the

available funds.

The Social Climate Fund also has tight timelines for ambitious goals, both for conception

and implementation. There is no time to lose, and conducting consultation as a mere

procedural requirement for conception would be a loss of time. Consultation with local and

regional governments and transport authorities must be approached as the condition for a

practical conception, and the foundation for fast and effective implementation.

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Recommendations for the national level Social Climate Plans, regarding principles for

sound and effective consultation and cooperation with local and regional authorities:

(1) On Consultation:

(1.1) Adequate time – Rushed timelines undermine the capacity for thoughtful engagement

and exclude critical voices. Allow for adequate time to review and to formulate proposals.

Adjust the consultation methods to the available time.

(1.2) Multiple stages – Consulting only at the start and end of the planning process, when the

plan is either completely undefined or completely closed, misses many potential

contributions. Use processes that enable constructive participation in multiple stages of

the process, from brainstorming to idea refinement. It will save time.

(1.3) Open dialogue – Genuinely seek and value the contributions of local and regional

authorities towards local obstacles and opportunities, encourage creative problem-

solving, build alignments, make implementation practical. Use adequate methods, e.g.,

targeted workshops.

(1.4) Transparency – Provide clarity to stakeholders on how their input will be considered and

integrated into final plans.

(2) On Cooperation:

(2.1) Governance – The consultation of local and regional authorities must go beyond the

planning phase. They must have a clear role in the governance structure of the Social

Climate Plans, contributing to monitoring, adjustment, and implementation. This requires

formally ensuring their participation at key stages of the Fund's lifecycle, with clearly

defined roles and responsibilities, as well as regular coordination mechanisms, such as

joint committees or working groups. This will improve accountability and effectiveness.

(2.2) Monitoring – Local and regional authorities have access to fundamental quantitative and

qualitative granular data on the effectiveness of measures, the identification of emerging

challenges. Sharing of real-time feedback in a structured way will ensure that the Social

Climate Fund is transparent and responsive to evolving realities.

(2.3) Dynamic adaptability – Adjustments are an indispensable component in the

implementation phase of all plans and measures. Local and regional authorities are

uniquely positioned: their proximity to the communities most affected by transport

poverty provides them with the insights needed to refine strategies in ways that maintain

their relevance and effectiveness. If certain measures prove less impactful than

anticipated, local authorities can propose targeted modifications based on their ongoing

engagement with local stakeholders. Embedding them in the adjustment process ensures

that changes are grounded in practical realities rather than abstract assumptions.

(2.4) Active implementation – Empower local and regional authorities to actively participate

in the implementation of critical measures. They are the best placed to expand public

transport, facilitate and steer shared mobility services, implement local one-stop shops

for mobility advisory services to households and micro-enterprises, and much more.

Their active participation in the implementation of the SCF is crucial to ensure national-

level planning translates into tangible and actionable measures at the local level.

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3.2 Fund Sustainable Urban Mobility Planning (SUMP)

Local and regional governments and transport authorities know, from extensive practical

experience, that creating practical, timely, and lasting solutions for the everyday lives of those

most vulnerable to transport poverty requires strategy and cooperation.

Otherwise, one can get fast measures pushing in the wrong direction, or measures undermining

each other, or measures that are highly visible in the short term but not viable in the long term.

The development of a Sustainable Urban Mobility Plan (SUMP) is the best way of setting and

effective strategy and a solid foundation for cooperation. Thanks to the investment of the

European Commission, we now have standardised guidelines to develop SUMP40, which have been

tested and refined by the practical experience of many authorities and experts, as well as

standardised Urban Mobility Indicators that enable proper monitoring, evaluation and

comparison.

The revision of the TEN-T Regulations41 established 432 Urban Nodes. Each of these nodes is based

on a Functional Urban Area, which includes important suburban and peri-urban areas, where large

numbers of households live in transport poverty. The TEN-T regulations require each of these

nodes to have its own SUMP by the end of 2027.

As we’ve seen above, most of the factors driving Transport Poverty are linked to unsustainable

mobility – after all, it’s the use of (and forced dependence on) energy-inefficient transport modes

and mobility patterns that makes household and micro-enterprises vulnerable to the increase in

the prices of fossil fuels.

This means that SUMPs are a powerful tool to not only advance Net Zero goals, but also to address

Transport Poverty. Making funding available for the implementation of SUMP measures that

address Transport Poverty will help their timely implementation, and that will, in turn, also

accelerate the implementation of the Social Climate Plans, by providing them with a portfolio of

coherent measures ready to deploy.

Finally, because several EU cities and regions do not have a SUMP yet, it’s important to point out

that the Social Climate Fund can cover costs related to “technical assistance to cover expenses related

to training, programming, monitoring, control, audit and evaluation activities which are necessary for

the management of the Fund and the achievement of its objectives” 42.

40 European Commission (2019), “Guidelines for developing and implementing a Sustainable Urban Mobility Plan” 2nd

Edition (available here: https://urban-mobility-observatory.transport.ec.europa.eu/sustainable-urban-mobility-

plans/sump-guidelines-and-decision-makers-summary_en) 41 Regulation (EU) 2024/1679 of the European Parliament and of the Council of 13 June 2024 on Union guidelines for the

development of the trans-European transport network, amending Regulations (EU) 2021/1153 and (EU) No 913/2010 and

repealing Regulation (EU) No 1315/2013, available here:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R1679 42 Cf. Regulation (EU) 2023/955 (Social Climate Fund), article 8, number 3.

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3.3 Set proportional targets for application of the Fund

The implementation of the Social Climate Fund must be balanced, grounded, and coherent:

• it will be balanced if both challenges (energy poverty and transport poverty) are allocated an

adequate proportion of the available funds;

• it will be grounded if regional and local governments and transport authorities play an active

role in the planning and a leading role in the implementation of the measures, ensuring local

support to beneficiaries, mobilisation of the local social and business communities, and the

alignment of the measures with local strategies and plans;

• it will be coherent if it privileges measures that address the root causes of transport poverty,

and offers practical solutions with a lasting effect.

National plans for the Social Climate Fund should:

(1) Support the development of Sustainable Urban Mobility Plans (SUMPs);

(2) Privilege the funding of measures which are planned for by SUMPs;

(3) Support costs related to the monitoring and capacity-building necessary to the

implementation of SUMPs;

(4) Support the implementation and operation, by Member States, of their respective National

SUMP support programmes, aimed at SUMP development and implementation through

funding, capacity building, communication and evaluation.

For this effect, National plans for the Social Climate Fund should set proportional targets for

the allocation of SCF funds, in the following manner:

(1) Dedicate 50% of the total amount to address Transport Poverty;

(2) Of the amount for transport, dedicate 65% of the total to measures that are to be planned

and managed at the regional or local level;

(3) Of the amount for local measures, dedicate 75% to multimodal solutions, i.e., not individual

car ownership and use.

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About POLIS:

POLIS is the leading network of European cities and regions advancing transport innovation. We

are committed, specifically, to innovations that can make urban, suburban, and rural mobility

more sustainable, safe, and equitable.

POLIS draws its expertise from a valuable network of decision makers, field practitioners, and

researchers, who are working for local and regional governments and transport authorities, public

research organisations, and private non-profit and for-profit organisations, from advocacy to

mobility service providers.

We build on the results of EU-funded projects and on the input of thematic Working Groups that

address key transport challenges, to link innovation and public policy guidance on urban and

regional mobility with European policy development.

Secretary General

Karen Vancluysen

Director of Policy & Projects

Ivo Cré

AUTHORS/CONTRIBUTORS:

Pedro Homem de Gouveia,

Senior Policy Advisor

Jorge Manso García,

Project Officer

FOR FURTHER INQUIRIES REGARDING

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[email protected]

www.polisnetwork.eu