With reference to the EU Commission’s open consultation on the roadmap for a New Urban Mobility Framework (2021), the two northernmost counties of Norway; Nordland County and Troms og Finnmark County; would like to provide input as follows. 

1. It will be important to restructure our cities to meet the Green Deal goals. That is the goal behind the initiative in the city of Bodø called “New City, New Airport”, where a new district will be developed as a low-mission society. However, as a peripheral region, North Norway has some structural and geographical challenges that need to be taken into consideration. Our region is sparsely populated in a European context, with an aging population, and with long distances from one city to another. In addition, our regional economy remains vulnerable, and there is a tremendous lack of external and private investment capital in the region, which can make it difficult to incentivise the needed urban restructuration. Societies such as ours, needs external and private investment capital, especially for connectivity and accessibility.       
2. In regions with longer distances between cities, train commuting is an efficient and climate friendly way to facilitate access for commuters. It can also contribute to reduce greenhouse gas emissions, NOx emissions and traffic congestion. However, it is important that we see a change in train using fossil fuels over to alternative fuels.

3. We support public transport as the backbone for sustainable urban mobility. Bodø is the first city in Norway where all public city busses are electrical, and we have already started to work with projects where the goal is to establish car-free city centres in some of our regions. However, it will not be a practical solution that can be provided for all cities in regions like ours. First, we have long and harsh winters that needs to be taken into consideration. Second, there is a long distance between our cities. Third, our cities are quite small in a European context, where we are working on a 5-minute concept instead of the 15-minute concept as suggested in the Framework. Plus, a lot of the population in North Norway that works inside the cities, lives outside of the city border, dispersed around a larger area. This makes it (economically and practically) difficult to provide public transport for all, and there will still be a part of the population that needs to use the car as it is their only means of commuting. We ask that the EU takes this into account when making a new Framework: to find a balance that is fair and that includes everyone.   
4. We support efforts to facilitate incentives and funding opportunities that support the phasing-in of low- and zero-emission solutions, in order to reduce co2 emissions in the cities. Due to challenges in the north as highlighted above, we would also like to point out the need for a longer transition period including adaptation of requirements and solutions to be able to phase-in low- and zero-emission solutions.  

5. We welcome that the initiative will contribute to the goal of the strategy for sustainable and smart mobility to have 100 European cities climate-neutral by 2030. In our region, the city of / the Arctic Capital Tromsø, together with UiT – the Arctic University of Norway, and many other actors, are collaborating in writing an application to become one of the 100 cities. As a region where we see and feel the climate change well, we believe that we must achieve climate neutrality in a way that suits our conditions. That is why this collaboration is looking at practical solutions that will not only improve the climate, but also serve the people that lives here, and make it a more attractive place to live, work and study.   

6. We support strengthening of transport nodes including multi-modal terminals and their network integration, to facilitate both first and last mile connections. As freight transhipment creates noise and demands a lot of area, it will be important to create regulations, especially in urban areas. We hope that the EU can facilitate additional European development project within this field.   

We support ensured continuous coverage of alternative fuel infrastructure for both the core and comprehensive networks and for all transport modes within the whole of the EU, especially taking into account the challenges faced in regions with long distances to the larger markets.