2. Roadworthiness testing

2.1 Context
In view of the European Commission's current work (January 1997) on drafting proposed European roadworthiness testing legislation for motorcycles the Irish Motorcyclists' Action Group (MAG Ireland) would like to submit the following policy.

2.2 Basics
Our fundamental view is that there needs to be a proven need for legislation before it is introduced. As this has not been given and does not appear to exist we oppose roadworthiness testing for motorcycles and believe the current proposal should be rejected or reduced to a recommendation where subsidiarity can be used.

2.3 Road Safety
In Irish accident statistics vehicle defects are only listed as a possible contributory factor in 1.4% of accidents. The defect type is not stated but it is highly likely that a significant number of these defects would not have been remedied by a vehicle check once a year. The statistics are also not given for vehicle defects by vehicle type.

Given the high cost to the taxpayer or to the motorcyclist of introducing compulsory annual testing for the relatively small number of Irish motorcycles any improvement in road safety would be very small and statistically insignificant compared to the expenditure. With driver/rider error listed as a possible contributory factor in 65% of accidents it is clear that the money and government effort could be much better spent on our scandalously underfunded motorcyclist training and safety schemes. Expenditure in these areas has proven road safety benefit.

Overall on-road vehicle quality can be improved with scrapping schemes and by the proper enforcement of existing legislation for roadworthiness. If vehicle defects were found to be a serious factor in accidents then stricter penalties and more comprehensive enforcement should be the solution.

2.4 Older machines
Existing motorcycles and older machines should not be forced to meet standards meant for newer machines. Noise and emission test criteria must be lower than those when the machine is new.

2.5 Environmental reasons
In some European countries an annual check on the environmental effects of the vehicle (primarily noise and emissions) is given to support roadworthiness testing.

2.5.1 Noise
Well maintained modern motorcycles are extremely quiet and do not cause a noise problem. The small amount of problem noise is exclusively caused by inconsiderate vehicle usage, vehicle deterioration or deliberate modification by owners. When these occur the resulting noise is very obvious and easy to identify and prevent using conventional means. In the case of deliberate tampering it is often the case in other countries that offenders temporarily return their vehicles to an acceptable noise level for the purposes of passing the annual test. This is a ludicrous situation. In the case of modified motorcycles annual tests are an ineffectual approach to enforcing sensible noise limits. It is much better to rely on enforcement of existing legislation.

2.5.2 Emissions 
Very few Irish motorcycles (possibly less than 100) are fitted with the catalytic converters which are checked in European emissions roadworthiness testing for cars. Motorcycle engines run exclusively on petrol, are generally of low capacity (90% are under 250cc) and do not have the lifespan of larger engined vehicles and hence do not have a fraction of the environmental impact of many problem vehicle sectors such as ill-maintained buses, lorries or older cars. The small number of Irish motorcycles make very little contribution to air pollution.

2.6 Economic reasons
In addition small motorcycles are often used as necessary transport for people who cannot afford to run a car. Any increase in annual running costs whether for environmental reasons or otherwise hits these users harder than the average motorist and encourages them to use the less environmentally friendly car instead.

2.7 Conclusion
Roadworthiness testing for motorcycles is simply a pandering to commercial interests and bureaucratic mentalities and is a complete distraction from the real issues of road safety and environmental awareness.