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FIA answer to consultation on type-approval of two-and three wheelers

Publication date: 26 February 2009

FIA answers to the public consultation on a proposal for a Framework Regulation of the European Parliament and of the Council on type-approval of two- and three wheel motor vehicles and quadricycles

1.    What do you think of the use of one basic EU Regulation and the split level approach for the revision of the legislation on two- and three-wheelers? Why?
The use of one basic EU regulation and the split level approach is seen as a simplification. Therefore, the FIA is in favour of this approach. Simplifications are essential, especially for the smaller manufacturers of two- and three wheelers.

2.    Do you agree with the approach to increase the use of references to UNECE Regulations? Why?
Yes. To increase the use of references to UNECE Regulations is advantageous due to the fact that they are worldwide regulations. This sort of standardisation is a simplification and avoids unnecessary costs. 

3.    Which administrative measures introduced for motor vehicles (Directive 2007/46/EC) should not be included in the legislation on two- and three-wheelers? Why?
No answer.

4.    Do you support the introduction of new emission limits for motorcycles equivalent to Euro 5 limits for petrol cars? Why?
In principle yes. This could be an objective for 2015. An earlier introduction could particularly overcharge the smaller manufacturers.

5.    Do you think that additional emission measures should be introduced in the legislation? Why? What is your opinion on the introduction of additional measures such as CO2 measurement, fuel consumption, etc.?
Yes, due to the importance of consumption and of CO2 emissions reduction in respect to economics and to global warming, it is also essential to provide these measures.

6.    What is your view on the mandatory fitting of ABS on all motorcycles? Why?
ABS for motorcycles is a significant improvement of active safety. So it is desirable that in future all motorcycles are equipped with ABS. Firstly, it should be proved if a voluntary agreement is affordable. In case of a negative outcome, the mandatory fitting should be considered.

7.    In your opinion, are there other/supplementary solutions better suited for certain categories (i.e. coupled braking, stability control systems, etc.) that would produce the same/better effect at better costs?
No. ABS seems to be the most efficient system. Additional systems are desirable, e.g. coupled braking, traction control and antirobbing clutch (the two latter for powerful motorbikes), but they should not become mandatory fittings.
8.    Do you think that the additional measures proposed by the TüV study and the one proposed in the Motorcycle working group mentioned above? Why?
The FIA is in favour of improved anti-tempering measures. Additional measures in the area of electronics seem to be beneficial.

9.    Do you think other solutions should be preferred? Which one?
According to the passenger car type-approval, the interface and function of the OBD should be specified.

10.    Do you think that the option given to Member States to limit the maximum power of motorcycles to 74 kW should be maintained? Why?
The relationship between power and accident frequency is not proved. So the limitation to 74 kW would not have an impact on accident figures.

11.    Do you think that alternative criteria could be used (i.e. Power-to mass ratio, acceleration potential) to limit the accident occurrence of motorcycles?
Due to the fact that the relationship between power and accident frequency is not proved, there does not seem any need for alternative limitation criteria.

12.    Given their localized markets, do you think that EU legislation on these vehicles is justified? Why?
Due to their localised markets, an EU regulation does not seem justified.

13.    Do you think that these vehicles should have a stricter mass/passenger limitation to justify that they do not have to meet the safety requirements applying to cars or do you think that such vehicles should comply as much as possible with car requirements? Why?
Some reasonable crash safety requirements, especially for mini passenger cars (L6), should be taken into account, in order to guarantee a sufficient crash performance standard. The requirements could be less stringent than for passenger cars.

14.    Should these vehicles be in the scope of type-approval whereas they are not designed to be used on the road?
Yes, independently of their use, a type-approval seems reasonable.

15.    Do you think that at present the category in which these vehicles are type-approved is adapted to the design of such vehicles? Why?
There should be a higher orientation towards road traffic specific demands, e. g. regarding skid stability.

16.    Should new specific requirements be added to improve the safety of such vehicles? Why?
Provisions to reduce tilt tendency and to mitigate injury risk during tilting (rollover bar) should be taken into account.

17.    Do you think that EU legislation on hydrogen vehicles is needed? Why?
This depends on industry demands. If industry is developing hydrogen vehicles, they need some legislation for their planning security.

18.    What do you think will be the impact of the range of measures that are outlined above on the competitiveness of the EU industry, and in particular SME's?
In principle, the new regulations would improve the products and so would strengthen the competitiveness of the EU industry.

19.    What will be the impact of the measures on employment in the EU?
In the area of two- and three wheelers there are, beside some big manufacturers, several smaller companies. With the view to avoid negative impacts on the employment, for each new regulation, it must be ascertained that it can also be shouldered by the small companies.

20.    Do you think that the measures proposed could have a significant impact on the final price of the vehicles? If yes, which ones?

There could be a certain impact on the final price of the vehicle. But, there are several rationalisation measures conceivable to overcome this issue, such as modular construction systems across manufacturers or recourse to passenger car modules.


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