SUMP and PUMS: Building a Sustainable Urban Mobility Plan That Actually Works

If your city has more than 100,000 inhabitants, you’re required to have a PUMS — a Piano Urbano della Mobilità Sostenibile, or Sustainable Urban Mobility Plan. Since January 2023, having an adopted PUMS is mandatory to access national transport funding in Italy.

At the EU level, the bar is rising further. The revised TEN-T Regulation (in force since July 2024) designates 431 European cities as “urban nodes” that must have a SUMP (the EU term for the same thing) in place by the end of 2027 — with specific targets for emissions, accessibility, and modal integration.

These aren’t optional guidelines. They’re requirements with funding attached. And they share a common demand: objectives must be measurable by indicators.

The question facing Italian city officials isn’t whether to produce a PUMS — it’s whether that plan will be a compliance exercise that sits on a shelf, or a genuine planning tool that drives better infrastructure decisions. The difference is data.

What a PUMS Requires

The Legal Framework

Italy’s PUMS requirements are established by Decreto Ministeriale n. 396 of August 4, 2019 (Ministry of Infrastructure and Transport), building on the earlier DM 397/2017. The decree requires:

• A comprehensive analysis of current mobility patterns across all modes
• Measurable objectives with defined indicators
• Strategies covering public transport, cycling, walking, and private vehicle use
• Integration with urban planning, land use, and environmental strategies
• Public consultation and stakeholder engagement
• Monitoring and evaluation frameworks

What the EU Adds

The EU’s Sustainable Urban Mobility Planning framework — coordinated through the European Commission’s DG MOVE and supported by the EU Urban Mobility Observatory — adds further expectations:

• Modal shift targets — measurable commitments to increase the share of sustainable transport
• Safety targets — aligned with Vision Zero principles
• Accessibility requirements — ensuring mobility for all residents regardless of age, ability, or income
• Climate alignment — demonstrating how the plan contributes to EU emissions reduction targets
• Cross-boundary coordination — metropolitan and regional integration

The Common Thread: Measurable Indicators

Both the Italian decree and the EU framework insist on measurable indicators. This is where most PUMS documents fall short. It’s easy to write aspirational goals — “increase cycling modal share,” “improve safety for vulnerable road users,” “reduce car dependency.” It’s much harder to attach credible numbers to those goals without comprehensive baseline data.

Where Most Plans Fall Short

The Baseline Problem

A PUMS needs to describe the current state of mobility in your city. For cycling, this typically means:

• How many people cycle? Most cities can provide rough estimates from census data or periodic counts at a handful of locations. Network-wide cycling data? Rarely available.
• Where do they ride? Fixed counters show volume at specific points. Route data showing origin-to-destination journeys across the full network? Almost never.
• Who cycles? Age, gender, trip purpose, experience level? This data simply doesn’t exist in most Italian cities.
• What are the barriers? Dangerous intersections, network gaps, surface quality issues? Typically based on anecdotal reports rather than systematic measurement.

Without a robust baseline, targets become arbitrary and progress becomes unmeasurable. A PUMS that says “increase cycling modal share by 5% over 10 years” means nothing if you can’t accurately measure the starting point.

The Monitoring Gap

A PUMS isn’t a one-time document — it requires ongoing monitoring to track progress against targets. This is where the gap between aspiration and reality becomes widest.

Most cities establish their PUMS targets, build some infrastructure, and then have no systematic way to measure whether those targets are being met. Annual or biennial manual counts at a handful of locations don’t provide the granularity needed to evaluate specific investments or adjust strategies in response to real-world outcomes.

The Integration Challenge

A PUMS should integrate cycling with public transport, walking, and private vehicle strategies. But when cycling data is limited to basic counts, integration analysis is impossible. You can’t plan effective bike-transit connections if you don’t know where cyclists are coming from, how they reach transit stations, or what would make them more likely to combine cycling with public transport.

How Better Data Transforms Your PUMS

Robust Baselines

Crowdsourced cycling data provides what traditional methods can’t:

Credible Targets

With comprehensive baseline data, your PUMS targets become specific, measurable, and defensible:

• Instead of “increase cycling”: “increase cycling modal share from 4.2% to 8% by 2032, based on current growth trends of 12% annually on corridors with protected infrastructure”
• Instead of “improve safety”: “reduce rider-reported safety incidents by 30% at the 15 highest-risk intersections identified through crowdsourced data analysis”
• Instead of “expand the network”: “close the 12 critical network gaps identified through desire line analysis, connecting 85% of residential areas to the cycling network within 500m”

Continuous Monitoring

Crowdsourced data doesn’t stop when the PUMS is published. It provides continuous monitoring that allows your city to:

• Track progress against targets in real time, not just at annual review points
• Identify which investments are delivering results and which need adjustment
• Respond to unexpected changes — new development, road works, public transport disruptions — that affect cycling patterns
• Produce evidence-based progress reports for council, for constituents, and for EU compliance

Before/After Measurement

Every infrastructure investment in your PUMS should have a measurable impact. Crowdsourced data enables before/after analysis for every project:

• Establish baseline ridership, demographics, and route patterns before construction
• Measure changes in the weeks and months after completion
• Compare actual outcomes against projected outcomes
• Use the results to refine future investment priorities

This creates a feedback loop that makes your PUMS a living document rather than a static compliance exercise.

The Funding Connection

National Funding

Since January 2023, having an adopted PUMS is a prerequisite for accessing national transport funding in Italy. The quality of your PUMS — including the robustness of its data, the specificity of its targets, and the credibility of its monitoring framework — directly affects your city’s ability to compete for limited funding pools.

Italy’s PNRR allocates EUR 600 million for cycling infrastructure alone. The General Plan of Cycling Mobility adds EUR 943 million in loans. Cities with data-driven PUMS documents are better positioned to access these funds because they can:

• Identify the highest-impact projects with evidence
• Demonstrate that previous investments delivered measurable results
• Show they have monitoring systems in place to track outcomes

EU Funding

The EU’s Sustainable Urban Mobility funding streams — including Horizon Europe, LIFE, and Structural Funds — increasingly require evidence of data-driven planning. A PUMS built on comprehensive cycling data positions your city as a credible partner for EU-funded projects and pilots.

Getting Started

If your city is developing or updating its PUMS, here’s how to integrate better cycling data:

1. Audit your current cycling data — identify what you have, what you’re missing, and where the critical gaps are
2. Establish baseline measurements — deploy a crowdsourced data platform to capture network-wide cycling patterns before major infrastructure investments
3. Define measurable indicators — use the baseline data to set specific, credible targets that meet Italian and EU requirements
4. Build monitoring into the plan — commit to continuous data collection, not just periodic snapshots
5. Create feedback loops — use before/after measurement to evaluate investments and refine future priorities

The PUMS requirement isn’t going away — it’s getting more demanding. Cities that invest in data infrastructure now will produce better plans, access more funding, and build better cycling infrastructure. Cities that treat the PUMS as a paperwork exercise will find themselves falling behind.

Sources:

• Italy — EU Urban Mobility Observatory (European Commission)
• Italy — Eltis (European Local Transport Information Service)
• Piani urbani della mobilità sostenibile — Italian Ministry of Infrastructure and Transport
• SUMP: what it is and how it works in Italy — Safe Join
• Sustainable Urban Mobility Planning and Monitoring — European Commission (DG MOVE)
• Introduction to SUMPs — EU Urban Mobility Observatory
• 600 million euros for cycle paths in the Italian Recovery and Resilience Plan — SmartGreen Post
• The importance of National Cycling Strategies: Italy implements new General Plan of Cycling Mobility — European Cyclists’ Federation