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Response by the Fédération Internationale de l’Automobile to the European Commission’s public consultation regarding the mid-term review of the White Paper on the European transport policy

Publication date: 31 December 2005

As the voice of Europe’s motoring consumers, representing over forty million motorists in Europe, the Fédération Internationale de l’Automobile is pleased to have this opportunity to respond to the European Commission’s public consultation regarding the mid-term review of the White Paper on the European transport policy.


As some issues are dealt with by several questions we would first like to outline a series of policy issues that we think should be considered by the Commission when revising the White Paper on the transport policy. In the second section we address the 10 questions while referring where needed to the statement above.

1) General remarks

Role of road transport

The European Commission has failed to take account of the vital and central role of road transport in the European economy and society.

The car is the premier mode of transport for the vast majority of European citizens.

It is unmatched for independent mobility and convenience and its benefit to society will continue to grow as the balance between social costs and benefits becomes increasingly positive.


Modal shift and cross-subsidisation

With its focus on moving away from the car and road transport, the White Paper risks undermining socio-economic welfare.

The Commission policy fails to focus sufficient support (for instance the TEN investment) on road infrastructure maintenance and development, road and car safety, driver information and training, new technologies and efficient urban public transport but seeks to promote inefficient and costly alternatives.


This policy lacks a basis in economic or social reality. The use of a car is essential for economic and social activity for the majority of people. Car dependence is a social and economic reality.

The FIA therefore rejects a significant cross-subsidisation between modes and a forced shift from road and aviation towards rail, shipping and intermodal operations.


Enlargement & road infrastructure

More investment in road infrastructure is needed to remove bottlenecks and missing links, reduce congestion and absorb the effects of EU enlargement.

The enlargement has led to a high increase in road traffic in Europe. This increase is an additional burden on Europe’s road infrastructure which often reaches the point of saturation.

The ETMC pointed out that whereas Western Europe has seen a decrease of its road deaths of 7.3 %, Eastern Europe has even seen an increase in road deaths by 1.9 %. The growing traffic in Eastern Europe has not been accompanied by a corresponding quantitative and qualitative upgrade of the infrastructure.

2) Environment

Air pollution

Cars have ever become cleaner and more fuel efficient.

Atmospheric pollution from transport has decreased in recent years following the technological development of vehicles and fuels (CO, SO2, NOx, Pb). However further improvement is still necessary to increase the sustainability of road transport.

Particle matter emissions are still a problem which needs to be addressed by the generalisation of particle matter filters.



The CO2 emissions from cars have remained stable over the last 10 years, despite a significant growth in traffic. If the voluntary agreement between the EU and the ACEA takes effect, CO2 from cars should not increase. However there is an issue as to whether the agreement is working effectively as planned.


The consultation paper refers to the fact that 90% of CO2 in urban areas from the transport sector is from cars. This statement is misleading as CO2 is not a local pollutant.

However this high level has to be tackled by policies that encourage non-car modes, in particular, through the provision of quality and affordable local public transport services.

Cleaner vehicles introduction should be encouraged by effective incentives. Motoring tax policies that incentivise fuel efficiency (e.g. COM(2005) 0261) are more cost effective and progressive than increasing motoring costs.

An effective and Europe-wide harmonised CO2-labelling is a key policy element.


Fuel efficient driving

Fuel efficient driving can be promoted by specific driver information and training. Long-term analysis has shown that the promotion of such driver information and education schemes increases overall fuel efficiency of passenger cars by five to ten percent, a significant contribution to reducing greenhouse gas emissions.

3) Road safety

The ‘systems’ approach

In order to reach the objective of reducing the annual number of deaths on the roads by 50% by 2010 the European road safety efforts need to be significantly increased.

The FIA believes that the key to improving road safety lies in the use of the ‘systems’ approach. Road safety is a responsibility of all stakeholders including users, vehicle manufacturers, road infrastructure owners and governments.


Vehicle safety

A significant road safety effort has been to improve the vehicle occupant protection in car crashes. Industry has made substantial progress, encouraged by the EuroNCAP consumer testing. Further efforts are still needed with regard to vulnerable road users.

Active safety is the next significant step. The recommendations of the eSafety Forum of the Commission need to be implemented. Motorists have to be informed on the use of safety devices.

Tax incentives for specific safety devices would help to speed up their penetration (e.g. ESC).

Child restraint systems need to be further standardised and improved. Consumer testing as the NPACS informs the motorist and promotes the correct use (incl. rear-ward child restraints).


Driver behaviour

The following causes of accidents should be recognised: inappropriate speed, right-of-way infringements, loss of attention, fatigue and failure to maintain safe distances between vehicles.

Furthermore, a distinction needs to be made between those drivers who through foolishness commit road traffic errors and those who do so deliberately.

The awareness and responsibility of all road users need to be further promoted through education and information.

An important step in improving driver education should be taken by implementing the second stage of driver training. Some Member States have already successfully implemented it. The Commission should use the experience gained to implement it on the European level.

Campaigns should encourage safe driving practices and programmes should insure life-long learning, targeting especially high risk groups.

We realise that there is road safety role to be played by effective road traffic enforcement as witnessed in Italy and France. However on its own the impact is only short term. The FIA would welcome the opportunity to be consulted on this issue more than thus far.

Traffic regulations and restrictions should be harmonised Europe-wide in order that road users are in no doubt of what is required of them when travelling through Europe. For instance the EuroTest road signs survey revealed that 91% of motorists want greater harmonisation of road signs across Europe in order to improve road safety.


Road infrastructure safety

Whilst the car industry is making positive strides, road infrastructure providers seem to have escaped responsibility. The long awaited Directive on Infrastructure Safety has still to emerge.

EuroRAP research clearly shows that when a road is “self explanatory” and “forgiving” the potential for reducing death and serious injury is increased.

Road users have the right to see their tax money invested in safe road infrastructure. Therefore EU funding of the TEN should be conditioned to the guarantee to deliver safe infrastructure.

EuroRAP should be the platform for motorists, authorities and experts to work hand-in-hand. It provides the necessary tool to analyse safety on road networks, wich will be valuable for consumers and road authorities alike. It is the missing link between single-site auditing and road safety policy.

National authorities must be encouraged to inform the public about road related risk per road section according to the concept of the "freedom of information act". European funding should be linked to its application. An independent body such as EuroRAP should assess the application of the rules on national basis.

Methods on local level such as road safety audits, black spot management and regular on-site auditing should be standardised and regularly applied in the Member States.

Consumer testing programmes like EuroTest, EuroRAP and EuroTAP play an important role in informing consumers about the safety of mobility in Europe and so contributing to higher safety.



In addition to the policy issues outlined above we would like to respond to the 10 questions listed in the consultation paper whilst referring where needed to the statement above.

Shifting the balance between modes, traffic relief and safety improvements


1. Do you observe a halt in the decline of rail, in particular for freight? What role is played by rail policy?

Despite the considerable support allocated to rail, the targeted modal shift has not come anywhere close.

The White Paper outlined a series of measures targeted at shifting the balance between modes and halting the decline of rail. The measures included making rail systems inter-operable, integrating the modes and further improving urban transport.



Inter-operability is a prerequisite for international transport services. Despite the ever-increasing demand for international transport services and the European Commission call to create ”favourable technical conditions and modernise services”, we assert that rail transport services still continue to be managed within a national framework.



There is sufficient evidence showing that sticking to the “inter-modality approach” has not brought the EU any closer to having a solid, reality-tested, long-term transport policy that would successfully tackle the most important challenges facing the EU road transport sector, i.e. efficiency, safety, congestion, pollution and a sustainable financing for infrastructure.


Urban transport

There is an overall lack of investment in efficient urban public transport systems providing a competitive alternative to car transport.


2. How is road transport developing, in particular international transport and cabotage after the enlargement?

Road transport contributes to social integration by reducing the geographical handicap of peripheral countries and regions and bringing EU citizens closer together.

90% of passengers and 80% of inland freight transport in the EU is carried on roads.

The proper functioning of the EU’s transport system is essential to its competitiveness and the quality of life of its citizens. It enables the production process to run smoothly and is an indispensable condition for economic growth.

As stated above the enlargement has led to a high increase of road freight traffic in Europe. For instance foreign road freight transport has doubled in Germany since the East border opening in 1991.

As Europe embarks on transport infrastructure development projects in Central and Eastern Europe road infrastructure needs urgently to be upgraded, extended and made safer in order to match the requirements of a growing traffic.


3. What is the situation of intermodal/combined transport in your country? What is the position of inland waterways transport (if there is any in your country)?

Inter-modal integration is an important issue, especially in urban areas, where public transport plays an important role as an alternative to the private car.

Urban public transport needs to be more efficient in the way that different modes of transport are better integrated in order to offer a competitive transport service to the mobile consumer.


4. Are there any developments in congestion and pollution on the main axes, in air transport, in the cities, in particularly sensitive areas?

As stated above cars have ever become cleaner and more fuel efficient. Due to technological development CO, SO2 and Pb emissions from cars are no longer a threat to health. However further improvement remain necessary, in particular in the field of particle matter emissions.

CO2 emissions remain a problem.

A policy decreasing car dependency through better urban management and the provision of quality and affordable local public transport services should be promoted.

The introduction of cleaner vehicles should be encouraged by effective incentives promoting their acquisition and efficient driving should get a high priority.

Research shows that car owning families generate more CO2 from their homes and that a focus on the home as a strategy to reduce CO2 would be much more cost effective than increasing the cost of motoring.

Noise exposure from transport is an increasing problem in urban areas threatening the citizens’ quality of life. This problem can also be tackled through improved urban and traffic management and the provision of good local public transport services.


5. What are the trends as regards road safety?

In order to reach the objective of reducing the annual number of deaths on the roads by 50% by 2010 the European road safety efforts need to be significantly increased.

The introductory statement above outlines policy recommendations in the fields of vehicle safety, driver behaviour and road infrastructure safety.

The financial and economic situation of the transport sectors

6. What is the financial situation of companies within the various modes, including infrastructure managers? How is the industrial structure evolving?


7. How are infrastructure investments developing, in particular on the corridors of the trans-European network? What are the financing perspectives of public budgets and charging? Will these perspectives allow the completion of the priority corridors by 2020?

The infrastructure investments to further develop the corridors of the TEN are mostly going into non-road modes. This policy prevents the urgently needed road infrastructure maintenance and development.

As stated above a good road infrastructure is a condition for sustainable mobility in ensuring smooth traffic flow – avoiding congestion and limiting air pollution – and giving a high level of safety – avoiding accidents.

Priorities for the future

8. What actions of the White Paper need to be reinforced? What are the new actions to be added, in which new fields?



The idea of decoupling transport from economic growth as stated in the White Paper has proved unrealistic. Any policy which seeks to decouple transport and economic growth is a policy which seeks to damage the European economy.

The European policy should focus its resources into efforts to decouple the negative aspects of transport (pollution, congestion, accidents) from economic growth.



As outlined above the European transport policy needs to promote eSafety technologies to become a part of everyday life of European motorists.


Road infrastructure safety

As outlined above the White Paper mid-term review needs to pave the ground for legislation leading to a safer road infrastructure.


Fuel efficiency

As outlined above the FIA welcomes the Commission’s proposal for directive on reforming car taxation and the publication of the Euro 5 norm for cars that will also promote higher fuel efficiency.

Also fuel efficient driving has a high potential and should be further promoted.

An efficient and harmonised CO2-labelling scheme is also an important policy tool.



Tourism is key generator of mobility demand for both business and leisure.

It’s significant economic contribution merits better attention. In particular the White Paper has not considered promoting the benefits of certain modes of transport used for recreational activities (inland waterways, sea cruises).

All discussions about transport and mobility issues impact tourism.

The tourism industry gives jobs to more than 8% of our citizens. And many areas depend on the development of the tourism sector.


Passenger rights

The FIA welcomes the work done by the Commission to improve passenger rights. Beside rail and aviation our own consumer testing programmes (bus test, ferry test) indicate that similar initiatives in other fields would be beneficial.


9. Which should be the priority actions between now and 2010 (congestion limitation, new technologies, trans-European network, charging, focus on the corridors, new actions on urban transport)?

The priority actions between now and 2010 should focus on reaching more efficiency in the allocation of resources, on further improving road safety and on reducing the negative environmental impact of road traffic. By doing so the European transport policy will achieve important steps in making mobility more sustainable: economically, socially and environmentally.

The FIA calls upon the Commission to allocate its resources on the basis of cost-benefit analysis.

Especially with regard to the objectives of the Lisbon agenda, European transport policy has to fully support the needs of Europe’s citizens in terms of mobility and should not be misused as an instrument to pursue ideological objectives. Every mode of transport has advantages and disadvantages. They need to be recognised and used to the benefit of European citizens.

A policy that does take into account the real needs is bound to fail, implying tremendous costs to society.


10. What new additional actions between now and 2010 on safety issues (maritime, aviation, road)?



The EU eSafety initiative has tremendous potential to avoid road casualties and to reduce the consequences of road accidents. After the technical development the time has come to make it available to the consumer.

The Commission should stimulate Member States to offer tax incentives for eSafety technologies with the priority to introduce ESC in all new cars.

The Commission should also stimulate insurance companies to give premium rebates for cars with eSafety technologies with the priority to introduce ESC in all new cars.


Consumer campaigns

The Commission should support and promote consumer campaigns to raise awareness on road safety issues, in particular in order to

  • support the deployment of eSafety technologies
  • improve the safety performance of road infrastructure
  • improve driver behaviour (e.g. belting, speeding, drunk driving)

Driver training

As stated above the FIA believes that implementing the second stage of driver training would represent an important step in improving driver education and improving road safety.



The Commission should propose legislation on the following subjects:

  • Road infrastructure safety
  • Harmonisation of the use of daytime running lights
  • Compulsory fitting on of ESC in the case that other measures than legislation show little effect
  • Harmonisation of the use of reflective jackets
  • Harmonisation of the highway code

For more information please contact:


FIA European Bureau

Rue d’Arlon 53

B-1040 Bruxelles

Tel: +32 2 282 08 25

Fax: +32 2 280 07 44


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