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28-08-2024 19:49
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Att: TRU | EUU | EU Passenger Rights Directive on long-distance bus providers are inefficient
Dear European Commissioner for Transport
and Danish Transport Authority, et al.
The current regulation 181/2011 Concerning the rights of passengers in bus and coach transport, sets out a
distance limitation of 250 km to be eligible for compensation if a "long-distance" bus carrier is delayed.
Above 250 km bus passengers have almost the same rights as airline passengers: Rights to compensation,
full refunds, access to amenities, overnight stays, etc.
However, when a bus drive is below 250 km passengers have barely any useful rights. I experienced it this
weekend when the bus was delayed several hours, and I opted to take another mode of transport (train), as
I would have otherwise been home in Copenhagen after midnight. I have a job, so this was not an option.
Afterwards, Kombardo Ekspressen refused to refund me for the 3 hour long delay with reference to the EU
Directive mentioned above, which sets the 250 km limit.
The Danish "long-distance" bus provider, Kombardo-Ekspressen, abuses this 250 km to its fullest extent. The
normal distance between the two major Danish cities of Aarhus and Copenhagen is minimum 307 km when
driving direct and usually takes a bus 4-5 hours. - by car 3 hours, but buses drive slower and need to make
more stops on the way, etc.
However, Kombardo-Ekspressen is a part-bus and part-ferry provider. They drive the bus onto a ferry,
reducing the distance to 192 km, but the bus ride still takes 4-5 hours.
In essence this means that although Kombardo Ekspressens markets itself as a long-distance provider, by
the definition of the EU Directive, they are actually not. None of the passenger rights apply to Kombardo
Ekspressen, and they are not actually long-distance, because that per definition is 250 km. This is also
despite that Kombardo Ekspressen competes in the long-distance segment with other similar providers,
such as Flixbus.
I see the following issues with the current directive on passenger rights:
a) The current regulation does not cover mixed-mode transport. When a long-distance bus uses a ferry on
legs of the journey, which passenger rights apply, when do they apply, and how do they apply in different
situations?
b) Bus passengers have barely any rights compared to ferry passengers. A ferry only has to be delayed by 90
minutes before passengers are eligible for full refunds of their tickets, irrespective of the physical distance
of the ferry ride. A bus ride, on the contrary, needs to be minimum 2-3 hours delayed, be scheduled for a
longer than 250 km drive, and much more, to earn even basic, fundamental human rights to be provided
with water by the bus carrier, right to a refund, etc. There are passenger right discrepancies across the
different modes of transport, which make no sense.