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Response to the EC’s Proposal for a Directive Relating to the Protection of Pedestrians and Other Vulnerable Road Users

Publication date: 14 August 2003

The AIT and the FIA are pleased to have this opportunity to respond to the Commission’s proposed Directive on Pedestrian Protection.  On behalf of Europe’s Touring and Automobile Clubs, representing some 40 million motorists, the AIT and the FIA welcome these proposals as a necessary and long overdue contribution to the goal of reducing the casualty rates of vulnerable road users in the European Union. 


Previously the AIT and the FIA supported the voluntary agreement between the Commission and the automobile industry, believing that this would be the fastest way to bring about improvements to the vehicle fleet.  However, we also argued at the time that a legislative requirement would probably also be necessary.  The AIT and the FIA, therefore, welcome both the two stage proposal of the Commission and the undertaking of Vehicle Manufacturers to introduce passive and active safety measurers, in addition to the requirements of the Directive. 


In Stage One of the proposals it is envisaged that, starting in 2005, new types of vehicles must comply with two tests concerning protection against head and leg injuries.  In Stage Two, starting in 2010, four new tests of increased severity will be introduced, two for leg and two for head injuries.  It is envisaged that by 2015 all new vehicles will comply with these requirements. 


The Stage Two standards are based on the proposals of Working Group 17 of the European Enhanced Vehicle-Safety Committee (EEVC).  These standards are, of course, already being used in the pioneering work of Euro NCAP; a programme strongly supported by motoring organisations through the participation of the FIA Foundation. 


Our experiences in Euro NCAP suggest, however, that the Stage Two standards are extremely stringent and close to the limits of design feasibility.  To date only a single Manufacturer has managed to achieve a three star rating for pedestrian protection.  Research by the International Harmonised Research Agenda (a body that brings together governments and test laboratories worldwide) also suggest that the issue of feasibility needs to be addressed.  We welcome, therefore, the Commission’s proposal to conduct a feasibility study looking at the suggested technical requirements and others measure which might contribute to the protection of vulnerable road users. 


Given the serious consequences of any pedestrian impact with a motor vehicle, it is important to recognise that passive safety engineering of the kind envisaged by the draft Directive needs to be supplemented by active safety systems which can help to avoid accidents involving vulnerable road users.  We believe, therefore, that the Parliamentary Rapporteur’s insistence on the study only considering passive measures to be mistaken and wrong in principle. 
Surely, it is better to introduce measures to avoid accidents in the first place, rather than trying to mitigate against the results of an accident.  Therefore, it is our view that a review of potential life saving active safety systems should feature prominently in the proposed feasibility study. 


The AIT and the FIA also believes that the feasibility study should examine carefully the developments at a global level in pedestrian protection.  At present a working group of the United Nations ECE World Forum for Harmonisation of Vehicle Regulations (WP29) is starting work on a draft Global Technical Regulation (GTR) for Pedestrian Protection.  (For further information on the GTR see the website:


The proposed GTR offers the prospect of enhancing pedestrian protection for the vehicle fleet worldwide, especially in emerging and rapidly motorising nations.  This raises the question of whether it would not be better in terms of the total number of lives saved and injuries avoided to use the proposed GTR as the Stage Two standard in 2010.  Since the content of the proposed GTR is not yet known, it would seem sensible to include this possibility as part of the future feasibility study.

Finally the AIT and FIA notes that the Directive is only applicable to passenger cars and car-derived vans up to 2.5 tonnes, yet we suggest that the scope of the Directive should be expanded to cover these classes of vehicle up to 3.5 tonnes.  This is necessary as an increasing number of vehicles classed as car-derived vans have a weight of over 2.5 tonnes and thus, would be excluded in the current proposal.  


In conclusion, the AIT and the FIA welcomes the Commission’s proposed Directive as a necessary and timely step forward.  Through a combination of passive and active safety systems it will be possible to reduce the unacceptably high level of pedestrian deaths and injuries.  The Directive’s twin stage approach, and the future feasibility study, are the best ways forward to ensure that the EU can progressively strengthen pedestrian protection at both European and world levels.


For More Information Contact:

AIT&FIA European Bureau
Rue d’Arlon 50
1000 Brussels

Tel: +32 (0)2 282 0825
Fax: +32 (0)2 280 0744


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