Position of the Fédération Internationale de l'Automobile (FIA) to the European Commission’s consultation paper regarding "Road Infrastructure Safety Management on the Trans-European Networks" (Consultation Paper TREN E3, 12 April 2006)
Publication date: 19 May 2006
The EuroCouncil of the Fédération Internationale de l’Automobile (FIA) represents through its affiliated members, national motoring and touring organisations in Europe, more than 40 million motorists in the European Union. Motoring organisations have as one of their highest priorities the improvement of road safety. The clubs carry out vehicle and safety equipment consumer tests, offer driver training, run seat belt campaigns and assess the safety of mobility infrastructure.
Consumer testing and benchmarking programmes such as the EuroTest, the European Tunnel Assessment Programme EuroTAP, the European Road Assessment Programme EuroRAP, the European New Car Assessment Programme Euro NCAP and the New Programme for the Assessment of Child restraint Systems NPACS provide an efficient means of raising consumers awareness to the quality and safety of Europe’s mobility infrastructure and related products and services. In particular the Euro NCAP has very clearly shown that consumer testing and benchmarking can stimulate road safety improvements more efficiently and rapidly than stringent legislation.
While it is well known that road safety improvements can most efficiently be achieved by combining measures directed at the driver, the vehicle and the road environment, traditionally the emphasis has been placed on drivers and their cars. As a result the car industry has been making positive strides in improving vehicle passenger safety and drivers have to demonstrate higher levels of competence to obtain their licence. The road environment has too often been neglected despite that research clearly shows that when a road is “self explanatory” and “forgiving” the potential for efficiently reducing death and serious injury is tremendous.
Road users have the right to see their road taxes invested in safe road infrastructure. EU funding of the TERN should therefore be conditioned to guarantee the delivery of safe roads. The statistics show that whereas Western Europe has seen a decrease in road deaths of 7.3% Eastern Europe has experienced an increase of 1.9%. Essentially traffic growth has not been matched by a corresponding expansion of the road network nor upgrading of the quality of the infrastructure. Road networks must be extended, upgraded and made safer, in particular in Central and Eastern Europe, if the result is not to be a growth in deaths and serious injuries as traffic increases.
With regard to the 42000 road users who die each year on European roads and the European objective to reduce this number to 25000 by 2010, the FIA, as the voice of European motoring consumers, is of the opinion that the improvement of road infrastructure safety will be an important milestone on the way to reduce the death toll on Europe’s roads. The human and economic cost of road accidents is very significant (2 % of GDP). Its reduction needs to remain a high priority for the European Union.
Consistent benchmarking EU wide coupled with quantitative and qualitative assessment can provide consumers and decision makers with a realistic overview of the current road infrastructure safety situation in terms of what has already been achieved and what still needs to be done. The EuroTAP is a model that could be applied to the open roads. Following the adoption of the directive on minimum safety standards in tunnels the EuroTAP is benchmarking the quality and safety of major road tunnels in Europe and providing road users with information about them and also how to behave correctly in any given tunnel under various circumstances. Co-funded by the European Commission the EuroTAP is a good model of the legislature working with citizens to improve road safety. The FIA believes a similar partnership could be forged with the EuroRAP.
The European automobile clubs, through their cooperation in the EuroRAP, plan to assess the safety performance of the Trans-European Road Network TERN, including risk mapping and physical inspection of the crash protection standards. They will propose measurable benchmarks of safety performance that the TERN should achieve and report on sections of the network that fall below these levels for which there can be no safety, economic or other justification as a focus for upgrading. These processes are aimed to provide a model demonstration for lower tiers of the network. These activities pave the way for a new culture on road safety assessment in Europe.
The FIA welcomes the Commission’s initiative to introduce a directive on road infrastructure safety management and is pleased to respond to this consultation.
1. Do you agree with the definition and assessment of the problem?
The general terms stating the opportunity of road traffic casualty reduction on European roads is well defined, though more level of detail could be given by means of the current available data on road accidents. It would be useful to state explicitly the percentage of deaths or severe injuries on the TERN to highlight the problem of severe accidents on other road networks. Although the focus of the EU legislation is on the TERN it should be noted that a large number of high risk sections is on other roads. Depending on national legislation, obtaining complete accident data in a geo-referenced format from these roads is sometimes impossible, time-consuming or not centrally available. It is therefore recommendable to address this issue.
2. Do you agree with the policy options defined, and assessed?
The FIA believes that
- option 1 will not contribute to sustainable and fast reduction of road deaths and should not be considered,
- option 2 does not guarantee a result in terms of road safety and
- option 3 may seem difficult to achieve at this stage.
The FIA agrees that European guidelines would be a reasonable way to ensure that safety criteria are applied to the building of new roads. However it is to be stressed that option 3 would be much more effective to support the road safety objectives of the European Union. Finding a political agreement on option 3 would involve a long discussion with an uncertain outcome regarding an important directive that the EU urgently needs. However, option 2 does not ensure that best practices will be extended across the EU and that minimum safety requirements will be attained.
Several member states have already a road infrastructure safety auditing system in place that offers good results. A new methodology would oblige them to change their procedures without bringing decisive road safety improvements. We believe therefore that the European Union should rather focus on raising the minimum safety standard requirements for existing roads and get member states to draw up action plans to eradicate all risky road sections from the TERN in line with the action ministers of transport committed themselves to in the 2003 Verona declaration. This first step must be followed on the longer term by a gradual increase of safety requirements. Road authorities, builders and operators need to take up the responsibility of offering a safe road infrastructure with similar standards of care as the ones that are required in other fields of transport and general health and safety.
3. What is your opinion on the measures/instruments described in point 4? What other measures could be taken?
The consultation paper leaves the issue of corrective actions to the member states. The Commission should foresee a review / revaluation tool or action to determine the success of the actions taken. It is positive to have different tools for each stage of road management, from design through construction, until maintenance. But even though the methodology is according to the state-of-the-art, there is a lack of targets / objectives in the application of the given measures. While it is well known which are the main accident types involving death on our roads the instruments should be applied focusing upon these causation types.
Another measure to be taken in order to ensure the correct application of such measures is to specify which contracted body is entitled to carry out specific actions (in particular audits and inspections). While Road Safety Impact Assessment and Road Safety Audits are to be addressed on a national level we believe that Network Safety Management, Safety Inspections should be supervised at a European level. Consumer organisations such as automobile clubs can play an important role supporting the European Union to carry out Network Safety Management and Safety Inspections.
While efficient local instruments are in place in some member states (such as local accident commissions, black spot management and road safety audits) they have very local and detail focus. In between the network safety and risk assessment is the missing element (such as accident rates or road protection scores). It is precisely this network assessment which will be most efficient if a common and understandable reporting (such as maps concerning risk and road protection) is achieved and enables comparisons between countries. This calls for a common instrument / method.
The network assessment should not only address issues of road administrations (such as safety potentials / accident cost densities), but also issues relevant to drivers (such as accident rates). Road Safety Impact Assessment (before political decisions are taken) and Road Safety Audits (design stage) could be left to national legislation defining only general objectives in the directive. Network Safety Management and Safety Inspections should be based on a common comparable method.
National authorities should be asked within the directive to provide access to relevant accident databases ("freedom of information"). Independent consumer organisations such as the automobile clubs should be able to conduct tests, processing data and informing the public about the safety performance. They should get access to the whole road infrastructure network, in particular tunnels, for testing purposes, independently from the fact that the infrastructure is in public or private hands. The Commission should collect on a regular basis the general reports as well as best practice and experiences with national legislation and methods. Results of this survey should be made available to all stakeholders and been discussed on regular forums. The road user should be at the heart of the policy. Transparency and citizen information need to be a main priority of the directive.
4. Do you have specific comments on the costs and benefits of the different instruments/measures?
The costs for Road Safety Impact Assessment and Road Safety Audits should be covered by national administrations. Costs for Network Safety Management, Safety Inspections and supervision should be co-financed by the EU.
5. Is there any other comment you would wish to make?
We take this opportunity to recall that the European Parliament proposed in its resolution of September 2005 the basic harmonisation of road signs and information as a first step towards a European system of road signs. This followed the findings of the EuroTest 2005 road signs survey, which revealed that 91% of motorists want greater harmonisation of road signs across Europe. The Parliament called upon the Commission
- to respond by taking effective measures to improve traffic signing systems and to insure the provision of information to drivers in this respect
- to ensure that the UN Convention on Road Signs and Signals is interpreted in the same way throughout the EU
- to investigate identified problems such as the over-abundance of road signs and the deficient understanding of signs
The Parliament suggested the provision of user-friendly and up-to-date information about the traffic signing systems used in the member states via an internet website available in all official EU languages. The FIA would very much welcome such an initiative as it would further facilitate cross-border traffic and improve road safety. One feature could for instance be to give the traveller a customised overview of foreign signs that are in use in the countries that the traveller will pass. The European automobile clubs have experience in this matter and offer their support to the Commission in order to implement such an internet website.
Another important safety issue linked to road infrastructure are road works. The automobile clubs have carried out in 2005 a EuroTest survey of major road work zones across Europe. Located on key European travel routes in 11 countries, all of the 50 road work zones tested had long-term road works lasting at least 14 days covering stretches of highway ranging from one to 21 km with traffic re-routed often via contra flow systems. The inspections focused on five areas: the quality of road signing and marking, the traffic routing, information to motorists, the road surface and night time orientation.
This initiative has been driven by the concern about the increased risk of accidents occurring in their vicinity as a result of inappropriate speed, congestion, motorists’ unfamiliarity with the zones, their design and organisation. The survey revealed that very often motorists approach major road works without any prior knowledge of the length, duration or even the reason for the road works. Foreign drivers’ unfamiliarity with the road works is exacerbated by the diversity of national rules and signing. This diversity coupled with the different ways in which accident data is gathered and recorded across Europe makes it difficult to assess conclusively the risk potential for accidents in proximity to road works. Existing studies show that the likelihood of an accident occurring can be anywhere between three and 450 times higher!
Another underestimated high risk zone is pedestrian crossings. The automobile clubs have therefore decided to analyse this issue in 2007 by carrying out a EuroTest leading to practical recommendations. It is a 3-year project with the aim to publish, in the first year, a state of the art on the pedestrian crossing situation in Europe and, in the second and third years, to assess major cities in Europe focusing on pedestrian crossing facilities. This overall project has got several goals, such as to highlight, in each country, the best and the worst pedestrian crossing design, to highlight the risk and safety potentials in each country, to make the users (drivers and pedestrian) aware of to their rights and obligations and to draw the national government offices’ attention to the measures to be taken to reduce accidents on pedestrian crossings.
The FIA would like the Commission to consider the results of these surveys and to take the necessary action giving the appropriate follow-up to the issued recommendations.
The FIA is pleased to have had the opportunity to participate to this consultation. We remain available for comment on all subsequent steps in this debate.
FIA European Bureau
19 May 2006