Transport & Environment tries to come up with a position on rail ticketing, but it's very imprecise

Transport & Environment (T&E), the lobby organisation that works to green Europe's transport sector, has today put online a new page about its position on the forthcoming EU reform of rail ticketing. They were pushing it on LinkedIn as well. You can find everything I have written about this topic here, and some of those pieces will be used to explain why I think T&E is not taking a clear enough position on some of the vital battles to come.

First, the title

"One ticket across Europe"

Do you really mean that? T&E, do you know the implications of that? Are you sure more than one ticket, but passenger rights, is not a better way?

The statistics that follow, about the problems passengers face when trying to book rail tickets are all very well, and will no doubt come in handy.

It is then in the yellow boxes we get to the policy demands.

"All major rail operator booking platforms with significant market power should be required to display and sell available tickets domestically and internationally. This includes selling and displaying willing competitors’ tickets under FRAND (Fair, Reasonable, and Non-Discriminatory) terms, to ensure passengers can access the best ticket for their journey."

But let's unpack this.

There is a known debate whether incumbent sales platforms - like Deutsche Bahn's website and Navigator app - should sell rivals tickets within Germany. This is a well known demand from European Sleeper - that DB should sell its tickets as its trains run in Germany. You could make the same argument for SNCF Connect within France, ÖBB's website within Austria etc.

But T&E demands "and internationally" - but to what extent? DB would have to sell everything to Germany's neighbouring countries, regardless of what company operates it? Or DB would also have to sell me tickets for everything internationally, everywhere in the EU? Even tickets for the CFR train between București and Ruse in Bulgaria, or LTG Link's service from Vilnius in Lithuania to Tallinn in Estonia?

If internationally is to mean everything, Europe wide, that is basically mandating that DB Navigator and SNCF Connect and NS's site would all have to become de facto sell everything platforms. I can hear the IT departments of state owned railways screaming from here.

But if internationally means only to neighbouring countries, that is less onerous, but is then not going to be what the Commission is supposed to want - true Europe-wide booking.

"Rail operators with significant market power should also be required to share journey data with other willing operators and third party platforms under FRAND. This includes special fares, disability seats, bike access and real time data so that passengers have access to all relevant information for their journey regardless of where they booked their tickets."

Rail operators with significant market power? So Deutsche Bahn for example would be obliged to share its data with third parties, but the likes of Italo or RegioJet would not? So - to take this to its most absurd extent - RegioJet could develop a ticket sales platform that could sell its tickets, and Deutsche Bahn's, but Deutsche Bahn (or, third party platforms like Trainline or Railfinder) could request RegioJet data but RegioJet could turn them down?

And not only is this incoherent, it is also weak. It is not as if operators of open access train services are incapable of sharing this data with third parties! ALL railway operators should share their ticketing data with third parties under FRAND.

"Third party booking platforms with significant market power should be mandated to display and sell tickets from all willing operators including all ticket discounts and offers, to ensure passengers can access the cheapest available tickets and current journey data"

Does such a platform even exist? EU wide it most definitely does not, in some markets (Trainline in Spain for example?) maybe it does? But I am not sure why this demand is even here - I am not aware of third parties deliberately not selling some tickets. The reasons generally they do not sell everything is that the data is not available, or data is available but on terms that are too bad so a re-sale would make a loss (i.e. non-FRAND). The inclusion of this one looks to me more tactical than anything, to face off the known state railway dislike of third party platforms.

Also by now have you noticed something?

Tickets.

Not ticket.

But the title of T&E's page is singular.

So how does T&E actually foresee, for example, Deutsche Bahn selling a passenger a Hannover - Barcelona? Three tickets (1x DB, 1x SNCF, 1x Renfe), bundled in one transaction? Or somehow some forced collaboration between those railways to make one ticket?

It's a very central issue, and T&E does not explain it.

There is also nothing about booking horizons (my view on that here), nor liability in the case of disruption (my take on that here), nor anything on whether a railway operator needs to know my entire journey chain (my view on that here).

Ultimately here T&E makes a solid case why the problems of rail booking need to be fixed, but falls down when it comes to how. Given Brussels policymakers need to know how, honestly I would have expected a bit more clarity of thought and more precision from T&E.