DfT Response – Nightmare Scenario

Right To Ride responds to The Department for Transport’s Consultation on the EU Regulations

(The proposal for the approval and market surveillance of two or three wheel vehicles and quadricycles).

The aim of the consultation is to help refine the UK’s impact assessment on the Commission’s proposal and provide an opportunity to receive comments based on the progress of discussions to date.

The Department for Transport’s impact assessment highlights the complexity of the existing legal framework and identifies the recommendations from the CARS21 High Group report as the foundation for the simplification of the regulations for L category vehicles (including motorcycles).

The recognition of the recommendations from the CARS21 High Group is fundamental because these set out the criteria for the proposals – which, with the exception of the European Economic and Social Committee  the Commission and the EU parliament have since ignored.

We have disagreed on the positions taken by the EU Commission, European Parliament and the Department for Transport with regards to Advanced Braking Systems (ABS) and Automatic Headlights on (AHO), but also because the basis for their assumptions on the (lack of) reduction of motorcycle casualties in Europe was unsound, fundamentally flawed and outdated.

We have agreed with the DfT’s assessment with regards to emissions, durability requirements and RMI, but we disagreed with their assessment regarding On Board Diagnostics because as highlighted in the LAT report  (which was carried out on behalf of the Commission and then ignored)  there are difficulties in monitoring the probability of emission malfunctions because there aren’t solid experimental data on the behaviour of actual motorcycles as well as difficulties in the technical implementation of catalyst efficiency monitoring in motorcycles.

In this case and in response to the question regarding “In Service Conformity Checking”, we argued in favour of a more appropriate method of check conformity which should be carried out through regular road worthiness test or MoT.

Finally in response to the last question (other comments) we wrote that we have major concerns due to where the proposal sits at present within the legislative process. It is our understanding that the proposal is scheduled to be voted on before the regulations, delegated acts and the adoption of harmonised international  standards, have been agreed on.

Our recommendation:  the best way forward is to delay everything, because it is clear that the Commission and EU parliament have got themselves in a fine mess, even ACEM has suggested that the situation has now entered a “Nightmare Scenario”.

The DfT Consultation is open until 28 October 2011

Read the full article and view our response to the DfT on Right To Ride EU – Click Here

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