Response by the Eurocouncil of the Fédération Internationale de l’Automobile to the European Commission Recommendation on Enforcement in the Field of Road Safety (C(2003) 3861 final)
Publication date: 15 March 2005
The Eurocouncil of the FIA welcomes the opportunity to comment on the Commission’s Recommendation. As the FIA’s representative in Brussels, of Touring and Automobile Clubs, the Eurocouncil’s role is to champion the motorist’s concerns in EU matters. In the European Union we represent some 43 million motoring consumers. Road safety is a priority of the first order for all FIA members. We have consistently supported the Commission in its efforts to achieve a 50% reduction in road deaths by 2010. Indeed, for a number of years now our ‘vision zero’ strategy has been a key driver in our battle for safer roads. This vision postulates that all of our efforts should be based on the belief that any road death is one death too many and we should strive to reduce risk of death on the road to zero. Moreover, following the impressive results achieved in France and Italy we recognise that effective traffic law enforcement has a role to play in improving road safety.
The FIA along with its Member Organisations have actively campaigned for road safety at both the European and National level. We were founder members of the Euro NCAP crash testing programme. Our Members Clubs are now also leading the Euro RAP, Euro TEST, Euro TAP, and Euro NPACS; pan-European road safety programmes all of which aim at improving the safety of motorists in areas such as road tunnels, the design of the roads themselves and child restraint systems. At the national level, the touring and automobile clubs run road safety education programmes and campaign for better roads, vehicles, and drivers. This commitment to road safety was consolidated at the signing of the European Road Safety Charter in Dublin last year. At this event motoring organisations were the single largest group of signatories, and more of our Members are about to sign the Charter. We are committed to motivating all EU clubs to sign the Charter, the support and promotion of national road safety campaigns by our members and working with our member organisations in the new Member states to achieve road safety improvements.
As the representative of law abiding motorists, the FIA Eurocouncil has taken a serious look at this draft Recommendation. Our specific comments draw on our expertise in this field and are intended to strengthen the Recommendation and increase public acceptance of its aims and methods.
1) The FIA believes that the key to improving road safety lies in the use of the ‘systems’ approach to safety. The key to this approach is to recognise that road safety is a responsibility of all stakeholders including users, manufacturers, road infrastructure owners and governments. The ‘systems’ approach to safety is based on the premise that the vast majority of road crashes are preventable: significant numbers of road deaths and injuries are not a fundamental law of nature or an inevitable result of motorisation. Research shows that all accidents can be attributed to one or a combination of three causes: the road users, the vehicle, or the infrastructure. Thus, adequate and increased investment in producing better drivers, improved vehicles, and improved roads designs and maintenance standards can, and will, prevent accidents. A coordinated strategy taking these three problems areas into account forms the basis of the ‘systems’ approach. We are pleased to note that this approach is given credence in the Recommendation even if it focuses exclusively on the motorist.
In parallel, we would like to see the road safety challenge being taken on in other areas also. Whilst the car industry, together with the Commission, is making positive strides, infrastructure providers seem to have escaped responsibility. The long awaited proposals for a Directive on Infrastructure Safety have still to emerge. EuroRAP (European Road Assessment Programme) continues to demonstrate that there are other efficient means of achieving the sought after safety gains. Their research clearly shows that when a road is “self explanatory” and “forgiving” the potential for reducing death and serious injury is great. The motorist adopts an appropriate driving attitude and an adequate speed based on clearly identifiable road conditions and usage criteria. A “forgiving” road is constructed such that it will minimise the consequences of an accident once it is set in motion. We believe that EU support for initiatives such as EuroRAP (European Road Assessment Programme) will result in substantial safety gains. By taking responsibility for providing safe infrastructures Member states will give a clear indication that they are not simply interested in blaming motorists for their own failings.
2) One of the keys to producing better and safer drivers is education, an area where our Member Clubs lead the way. The training of drivers, throughout their life is one the simplest and most efficient way to produce better drivers. In this context, it is important that the proposals for enforcement are backed up by information and education campaigns. Simple enforcement will only have short-term effects and produce public resistance. Even in France, where amazing results have been achieved through traffic law enforcement, death and serious injuries continue to remain high within the young males’ category. The road safety message needs to be spread not just through law enforcement.
3) The European Commission’s approach in defining the objectives of reduction of road deaths and serious injuries and providing EU support for various road safety initiatives, while leaving the task of enforcement to each nation state is in our view correct. The Recommendation calls for monitoring and enforcement of traffic regulations based on national plans. Given that these activities are organised so differently in all 25 member states, the evaluation period provided in the Recommendation (seven month -see recommendation 12), for the analyses of the first national reports, the criteria by which these will be assessed and the progression to the preparation of a proposal for a Directive is both rapid and intransparent. Given that the situation in all 25 member states is so different, preparation of a standardised prescription from Brussels on how best to resolve the related road safety problems specific to each member state should surely warrant more time and reflection of the national reports submitted.
4) We agree with the Commission that more research and information is needed in the growing problem of drugs and driving and the proposals in the recommendation are fully supported. Once again we stress the view that education has a major role to play in combating this problem, a task already undertaken by many clubs. Other behaviours are also targeted such as mobile phone use, aggressive driving, and helmet wearing.
5) In examining the main causes of accidents the following should also be recognised as having an impact:
- inappropriate speed in given the road conditions
- right-of-way infringements
- Driver’s loss of attention
- Driver fatigue
- and drivers’ failure to maintain safe distances between vehicles.
Furthermore, we would ask the Commission to make the distinction between those drivers who through foolishness commit road traffic errors and those who do so deliberately and criminally. They should be treated differently in terms of enforcement.
Against this background we would strongly urge the Commission to give greater priority to emphasising to the Member States that the measures to be enacted are for the purposes of improving road safety. Use of credible measures based on sound guidelines with well publicised road safety objectives over and above targets are needed to demonstrate that the underlying objectives are not revenue raising and targeting foreign motorists.
We now turn to comment on some more specific measures in the Commission’s proposals.
We believe that the use of appropriate speed is a key element in any safe road system. These are limits established on the basis of the risk of an accident occurring. To be effective speed cameras should be highly visible and located in places known to be dangerous with a certain threshold of death and serious injury. The priority must be placed squarely on prevention of further accidents and not revenue.
We are concerned that the Commission is advocating an over reliance on technology and speed cameras. Of course cameras are useful tool when used in conjunction with education campaigns and human policing.
The FIA believe there is no excuse for drink-driving. We would like to see far greater emphasis placed on tackling this problem than “drugs and driving” The proposed measures for combating drinking & driving are approved of. The drinking & driving issue also requires a combination of overlapping measures. Among young motorists in particular drinking & driving is often a social problem, which has to be tackled first and foremost through information and motivation campaigns. Besides regular road-side breathalyser checks based on grid-square approach a suitable system of sanctions structured according to the severity of the transgression must also be communicated to the general public if it is to have a deterrent effect. Finally one might also consider designing technological devices that would make it impossible for a motorist under the influence to start up his or her vehicle, e.g. with alco-locks. Particularly motorists who have been sentenced repeatedly for driving under the influence should be obliged to use these immobilising systems.
Use of Restraints
We are keenly aware of the role wearing a seatbelt and child restraints can play in reducing death and injury. Indeed, we have conducted a number of campaigns to encourage seatbelt wearing. If higher quotas are to be achieved for seatbelt use throughout Europe, the European Automobile and Touring Clubs believe that a combination of measures aimed at influencing motorist behaviour and of vehicle-specific measures is essential: People who do not use safety belts give a number of reasons why they refuse to do so. An appropriate information and education campaign that uses media aimed specifically at the target group in question is in any case far better suited to increasing the quota of seatbelt users than any police sanctions.
Appealing to motorists’ sense of responsibility
We cannot over stress the importance of education in the battle to improve road safety. Educational measures such as awareness raising, motivation, and promoting motorists’ sense of responsibility as part of wide-scale road safety campaigns all have their role to play. Moreover, European motorists should be encouraged through a sense of personal responsibility to choose the speed best adapted to the prevailing traffic conditions, even if that speed should be considerably lower than the maximum speed permitted in each case. As a positive example we would mention the United Kingdom, which, unlike central European states in particular, makes do with an absolute minimum of individually signposted speed restrictions, yet for many years has had the lowest accident figures in the European accident statistics.
Motorist information systems/telematics
Another key aspect entirely overlooked in the Commission’s proposal is the vast array of technical aids available to inform motorists. Every effort should be made to broaden the use of motorist information systems and make them compatible with series manufacture. The emphasis should not be on making it easier to record and prosecute traffic offences (e.g. using automatic surveillance equipment) but on preventing transgressions. Simple visual and acoustic warnings aimed at motorists and transmitted for example by electronic roadside equipment could contribute significantly. Since May 2004, the Roncalli satellite based driver assistance system has been examining the use of ISA – intelligent speed adaptation. The system informs the motorist of the speed limits in operation and warns him if he exceeds a limit. In addition the system provides rights of way information at complex junctions as well as information concerning accident black boxes, schools, road grips.
Technical warning systems
With regard to seatbelt use we would also advocate the use of vehicle-integrated visual and acoustic warning systems. The Clubs called for the installation of seatbelt reminder systems already years ago as part of the guidelines for EuroNCAP. Seatbelt reminders are now standard in many new car models; however, on many models, they apply only to the driver’s seat. The Commission should therefore focus its attention on making seatbelt warning systems compulsory within two years at the latest for all vehicle seats; indeed, the proportion of rear-seat passengers who use seatbelts is still considerably lower than that of front-seat passengers.
Penalties and Cross Boarder Enforcement
The AIT and the FIA are concerned to ensure that the penalties following conviction are appropriate and in proportion to the offence committed. Thus, we call on the Commission to monitor the activities of the Member States in this area closely. This issue is even more acute due to the cross-boarder enforcement provisions in the Recommendation. In parallel to safeguard the rights of motorists we also support the efforts of the Commission in the field of Procedural Safeguards for Criminal Cases as a fair counter balance to the increasing harmonisation of enforcement and sanctions.
■ ■ ■
In summary, as the representatives of law abiding motorists we welcome the recommendations of the Commission. Road safety is our priority and that of our members. As can be seen from our comments, we have a number of issues where we feel more is needed if the enforcement initiatives envisaged are to the optimum desire effect. In this respect we would call on the Commission to develop an ongoing dialogue with us, the legitimate representatives of more than 43 million European motorists so that effective measures as part of the proposals outlined above can be drawn up jointly in order to improve European road safety