FEMA Position Statement on Road Worthiness Tests (Motorcycle NCT)

F.E.M.A, The Federation of European Motorcyclists’ Assocations (of which MAG Ireland is a founder member) has published the following position statement in relation to Roadworthiness Testing. We reproduce it here for your information.


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FEMA Position Statement on Road Worthiness Tests

Statement on the European Commissions Proposal for a Regulation on periodic roadworthiness testing for motor vehicles and their trailers (2012/0184 (COD)) and repealing Directive 2009/40/EC

– The harmonisation of testing frequencies lacks any justification
– The proposal works against the principle of subsidiarity
– The evidence presented is neither representative not sufficient to justify the onerous economic and regulatory burdens of the proposal
– The proposal is disproportionate to the size of the problem

Until now only “motor vehicles having at least four wheels” (Directive 2009/40/EC) were covered by an EU Directive making provisions for periodic roadworthiness tests (RWT). Therein for cars the minimum testing frequency was set at four years and thereafter every two years.

The proposal of the European Commission, published on 13th July 2012, explicitly includes not only motorcycles but all powered two- or three wheelers, as well as trailers into periodical testing regimes. For new vehicles the Commission proposes the first inspection after 4 years, followed by a second inspection two years later and thereafter annually.
Nine member states of the European Union (EU), as well as EEA member Norway, will have to comply by introducing roadworthiness testing for motorcycles for the first time and almost all member states will have to newly integrate mopeds, scooters and light trailers into testing regimes.

Only a minority of member states have inspection schemes with annual test intervals. All other EU (and EEA) members will therefore have to increase the testing frequency for vehicles older than 6 years from biennial to annual. For the users of powered two wheelers in Europe the proposal causes additional annual costs of €1.2 billion , calculated with an average inspection cost of €50 and based on the assumption that 70% of the 35 million powered two wheelers in circulation in Europe are older than 6 years.

Since the proposal also aims at harmonising test standards most inspection bodies in Europe will have to purchase new equipment and to invest in training measures for testers. As a result vehicle inspections are likely to become significantly more expensive which increases the annual financial burden for the users of powered two wheelers up to 2 billion euros per year.

The European Commission declares that “solid investigation results show that 8% of the accidents involving motorcycles are caused or linked to technical defects” (see recital 7). The only study available in Europe that has delivered such a result is a study performed by the German testing organization DEKRA (DEKRA 2010: Motorcycle Road Safety Report). As the business model of DEKRA is based on testing as many vehicles as often as possible the Commission can be blamed for having relied on data which is not based on objective scientific principles.

A similar study, which was performed by the Swedish Transport Administration only found that 3% of fatal accidents involving motorcycles are caused or linked to technical defects. An in-depth study on motorcycle accidents (MAIDS 2004) which was co-funded by the European Commission, indicates that only about 1% of the accidents involving motorcycles are caused of linked to technical defects.

However, the impact assessment of the Commission fails to demonstrate a causal link between increased inspection intervals and a reduction of dangerous technical defects or road deaths.

Many countries without mandatory RWT for motorcycles are some of the best performing in Europe regarding motorcycle accidents statistics, especially Denmark, Finland, the Netherlands and Norway. Apparently, there must be other, more effective measures to prevent accidents than introducing RWT with increased test frequencies throughout Europe. Due to a lack of technical defects Sweden has even decided to skip annual RWT for motorcycles in 2004 and re-introduced biennial testing intervals. So far, this decision has not had negative effects on Swedish motorcycle accident statistics.

The integration of light powered two wheelers into RWT will cause problems especially in remote areas of the European Union. Some users of mopeds and scooters, which have a designed speed limitation of 45 km/h, will be forced to ride over 100 kilometres just to reach the nearest inspection centre. The decision about vehicle categories to be tested as well as on test frequencies should therefore be left to the Member State.

FEMA criticises the Commission for leaving aside the objective that vehicles registered in one Member State could be tested in another (see Article 4 (1)) while proposing to include powered two wheelers into RWT along with increased testing frequencies for older vehicles without providing convincing evidence that the proposed measures significantly improve road safety.

The Commission’s proposal does not affect people who can afford to buy a new vehicle every 3 or 5 years. But it strongly affects European citizens owning vehicles older than 6 years, which is especially the case for low income and middle class families as well as for motorcycle enthusiasts who tend to ride and maintain several older motorcycles.

In Brussels, Dublin, Helsinki and in many French cities on 22nd September 2012 tens of thousands of motorcyclists have protested against the proposal and expressed their disappointment with the European Commission, which in their views is trying to solve a non-existent problem and placing unnecessary additional financial burdens on them.

The European Union and especially the European Currency Union are facing threatening crisis and Europe’s citizens are losing faith in the European institutions. Thus it is intolerable that the Commission proposes a regulation which will cause billions of additional costs while lacking solid scientific evidence that effective improvements in road safety can be achieved.

FEMA therefore calls the European Parliament and the Council to reject the proposal of the European Commission.

Note: EEA countries without mandatory RWT for motorcycles are Belgium, Denmark, Finland, France, Greece, Ireland, Malta, Netherlands, Norway, and Portugal.

The Federation of European Motorcyclists’ Associations
The Federation of European Motorcyclists’ Associations (FEMA) is the representative federation of motorcycle (comprising all powered two-wheeled vehicles) users throughout Europe. FEMA represents the interests of citizens’ national organisations at the European Union and agencies of the United Nations. FEMA’s primary objective is to pursue, promote and protect the interests of motorcyclists. FEMA recognises that motorcycles have different characteristics from other vehicles and emphasises the need for motorcyclists’ specific requirements to be addressed.

 


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 A brief word from MAG Ireland

As noted above by FEMA, the EU Commission claim that 8% of motorcycle accidents are caused by mechanical failure flies in the face of findings by the Motorcycle Accident In Depth Study (MAIDS) which shows that just 3 of the 921 accidents in the sample (0.3%) cited technical failure as the primary cause1, while technical failure was a contributory factor in just 1.6% of all cases2.

Despite all the evidence to the contrary, the EU Commission chooses to use the unsubstantiated figure of 8%. The RSA believes that motorcycles account for about 2% of Irish road traffic, so even if this 8% figure were true, it would represent just 8% of 2% – in other words, just 0.16% of all road going vehicles in the country, and even that tiny figure is five times more than the true figure as revealed by the MAIDS study.

The Road Safety Authority (RSA) agree with MAG Ireland that mechanical defects in motorcycles are not a road safety issue here in Ireland saying:

“…it is accepted that there is little evidence that defective motorcycles are a major factor in causing collisions…”.3

Meanwhile, MAG Ireland has called for a cost benefit analysis to be carried out on the proposals in the context of the Irish testing regime, something which has been provided for as part of the National Motorcycle Safety Action Plan 2010-20144, because with 46 NCT centres, and about 51,000 registered motorcycles, the average test rate will be about three per centre per day. It cannot be economically viable to test motorcycles at these volumes given the specialist equipment and operative training necessary to implement such a scheme.

MAG Ireland will continue to work with our colleagues in FEMA at the EU level on this issue while providing the relevant Irish authorities with scientifically proven information to counter the unsubstantiated “8% claim” on which the EU Commission is basing this proposal.


References:

1. http://www.maids-study.eu/pdf/MAIDS2.pdf Table C.5, Page 151
2. http://www.maids-study.eu/pdf/MAIDS2.pdf Table 4.2, Page 31
3. http://www.rsa.ie/Documents/Road%20Safety/Motorcycles/National_Motorcycle_Action_Plan.pdf
(Page 13, Section 4.2.8)
4. http://www.rsa.ie/Documents/Road%20Safety/Motorcycles/National_Motorcycle_Action_Plan.pdf
(Page 13, Section 4.2.9)

The EU Roadworthiness Testing Proposal is published online at:

http://ec.europa.eu/transport/road_safety/pdf/road_worthiness_package/proposal_for_a_regulation_on_periodic_roadworthiness_tests_en.pdf
 
Find all MAG Ireland posts on this issue here:
http://www.magireland.org/category/campaigns/rwt/