Throw It Out?

caravan1smallIn May this year, the Irish Houses of the Oireachtas (Dáil Éireann (House of Representatives) and Seanad Éireann (the Senate) Joint Committee on Transport and Communications sent its opinion to the General Secretariat of the Council of the European Union regarding the Road Worthiness Testing (RWT) proposal.

In reference to motorcycling the opinion, “Is of the view that the merits of testing motorbikes needs to be further explored and proven before introducing roadworthiness testing of motorbikes in Ireland.”

The opinion was submitted before the July vote in the European Parliament, however the opinion aligned itself with the TRAN (Transport & Tourism) committee’s amendment to the European Commission’s proposal which was to remove motorcycles from the proposal with the caveat that:

“No later than [three years from the date of publication of this Regulation], the Commission shall submit a report to the European Parliament and the Council on the inclusion of two- or three-wheel vehicles into the scope of this Regulation. The report shall assess the road safety situation for that category of vehicles in the European Union. In particular, the Commission shall compare road safety results for that category of vehicles in Member States carrying out roadworthiness testing of that category of vehicles with those in Member States which do not test that category of vehicles in order to assess whether roadworthiness testing of the two- or three-wheel vehicles is proportionate to the set road safety objectives. The report shall be accompanied, if appropriate, by legislative proposals.”

MAG Ireland, the Irish riders’ organisation had previously stated, “Let’s see the evidence. Let’s quantify just what “safer” means. Let’s do a proper cost/benefit analysis and let’s have a discussion where all sides can be heard in a balanced rational and fair manner. MAG Ireland will work to make sure that any future test is proportionate to the problems it seeks to address and based on evidence of need using publicly available data.”

Therefore there should have been a proper study that would have set out the inclusion of motorcycle categories that would have been proportionate to the set of road safety objectives set out by the European Commission and not the reliance on flawed figures continually being quoted by the same European Commission.

MEPs Against An Objective Study

trailer2smallHowever, the majority of MEPs voted against undertaking this objective study and voted for amendments that put motorcycles back into the proposal, but agreed on a report to be submitted by the Commission in respect to vehicle categories – including motorcycles i.e. two- or three-wheel vehicles – vehicle categories L1e, L2e and L6e – light two-wheel powered vehicle – moped – quadricycles – in January 2018 unless the Commission demonstrates that such a measure would be ineffective.

Although this is not an issue for UK riders as we already have RWT in the form of our MoT, the Irish opinion and those UK MEPs who were briefed, looked at the whole issue surrounding the RWT proposal.

Although amendments and the proposal were agreed on, the Parliament’s position was referred back to the TRAN (Transport and Tourism) committee, which subsequently voted in favour of a mandate to enter into negotiations with the Council and the Commission to try and agree a common position before a further vote in Parliament.

Those further issues include extending the MoT frequency, in the UK we have 3-1-1 (after third year beginning of fourth year and then every year), “Increasing the frequency of periodic roadworthiness tests for certain categories of vehicles. Currently, cars and vans (up to 3.5 tons) older than six years are checked minimum once every 2 years. It is proposed to have them checked at least annually after the six years. This means a change to 4-2-1 instead of the current 4-2-2. The 4-2-1 formula is also proposed for scooters and motorbikes. Moreover, it is proposed to increase the frequency of tests for cars and vans with high mileage (160.000 km).

These vehicles would be inspected annually after the first test (4-1-1 instead of the existing 4-2-2) if they reach at the date of the first inspection (after 4 years) a mileage of more than 160 000 km. This would bring their tests in line with other high mileage vehicles such as taxis, ambulances etc.”

So unless there is a derogation to allow a stricter testing regime, for the UK to retain is testing frequency, then there might be less testing in the UK as regards cars and motorcycles.

A Lot More Than Motorcycles

caravan2smallIrish Opinion: Expresses reservations in relation to the proposed Introduction of annual road worthiness testing of cars after six years on the basis that Ireland is proactive in this area and Introduced in 2011 annual testing of cars after ten years; Recommends that the frequency of testing of cars annually after ten years in Ireland Is appropriate at this time, based on strong road safety evidence; Is of the opinion that increasing the frequency of testing to annually after six years would place an additional financial burden on vehicle owners without a significant safety dividend.

Irish MoT (National Car Test) cars four years and older must undergo an NCT, with tests due every two years for cars younger than 10 years – older than ten years tested annually.

Measures being proposed include banning some repair garages from operating testing services. This would potentially affect the work of up to 50,000 inspectors, and 20,000 SMEs (Small Medium Enterprises) in the UK, threatening some with closure.

The Caravan Club alone has one million members, the Camping and Caravan Club has 500,000 members. The industry is worth more than £6 billion a year, UK citizens who are caravan enthusiasts and the caravan industry itself, have been quoted as being extremely fearful of the proposal.

The UK government last year estimated that it would cost £239m to introduce a caravan and trailer registration scheme for the UK.

The Caravan Club says that it, “actively supports and encourages measures designed to improve road safety, but we have not seen any EU evidence that MOT-style testing on caravans will do so. The huge majority of accidents involving caravans are caused by factors such as poor loading (causing instability) and driver behaviour, and not by factors that would have been mitigated by the testing of caravans.” Adding to this, the Camping and Caravanning Club say, “According to the Club and industry research, the primary causes for accidents involving caravans in the UK are driving too fast for the conditions, overloading, poor weight distribution, a poor car-caravan match, and tyre condition.” They added, ““We would rather see taxpayers’ money spent on education and training to prevent potential problems.”

This all sounds familiar in the argument against mandatory European wide testing for motorcycles. The more we hear from other road user groups the more it becomes clearer that the three proposals in the Road Worthiness Testing package just needs thrown out, no amendments, no compromises, no more opinions just thrown out and withdrawn!

There is also the threat to ordinary householders who occasionally use small trailers for jobs like taking garden waste to the tip. In order to deliver and enforce this, according to the House of Commons European Scrutiny Committee, “there would have to be a national registration system for trailers — a study in 2009 estimated a cost of £237 million.”

There are also concerns on the addition of testing for tractors.

While an agreement has been found by MEPs for trailers, caravans and tractors; trailers with a weight of up to 2000 kg and tractors with a speed up to 50km/h and which do not drive on public roads do not need to be checked. Only those tractors used ‘mainly’ on public roads for haulage with a maximum speed of more than 40kph should be required to undergo testing, while caravans need to undergo regular technical controls, there still needs to be agreement by the European Commission and the Council.

The NFU (National Farmers Union) said the proposals were “over the top” and has since worked hard with MEPs to make improvements. “We are pleased to see the European Parliament has made some good amendments to the original proposal, but more must be done before we are satisfied,” said NFU regulatory affairs adviser Ben Ellis.

John Allan, national chairman of the Federation of Small Businesses (FSB), said: “There is no evidence that introducing an MOT for light trailers and agricultural vehicles would improve road safety. “Evidence shows that accidents involving large trailers are largely caused by inappropriate driving behaviour or how the trailer has been connected, neither of which a test could check.”

Irish Opinion: Notes that The Health and Safety Authority (Ireland) have stated that there is no compelling evidence to indicate that compulsory testing of agricultural vehicles would have a significant Impact on fatalities.

As our own Northern Ireland Assembly Committee for the Environment has commented “The Northern Ireland Assembly rejects the proposal because of the cost implications and counter proposes a Directive rather than regulations”. The reason is that “This would allow for flexibility for Member States and their devolved regions to tailor their road safety actions according to need rather than incurring costs for negligible returns”. “Until it can be shown that these proposals will bring about significant benefits and improvements to Northern Ireland, the Committee will fight against them.”

Irish Opinion: Supports the view of the Road Safety Authority {Ireland), that the cost of increasing the frequency of testing would be approximately €19million annually on users and would increase the volume of testing by 27%. It would also require the provision of additional test centres and expansion of existing centres and therefore would like to see a strong road safety case for increased frequency of testing of cars.

“apolitical” MEPs Views

trailer1smallAt Right To Ride we are “apolitical” which means we are politically neutral, however UK MEPs who voted against the proposal in the main have been MEPs (Conservative Party) in the European Conservatives and Reformists Group (ECR) those who voted for the proposal were MEPs (Liberal Democrats Party) in the Group of the Alliance of Liberals and Democrats for Europe (ALDE) and MEPs (Labour Party) in the Group of the Progressive Alliance of Socialists and Democrats in the European Parliament (S&D).

Those that abstained included UKIP in the Europe of freedom and democracy Group (EFD) – Northern Ireland MEP Martina Anderson ( Sinn Féin) in the Confederal Group of the European United Left – Nordic Green Left ( GUE-NGL) also abstained.

All of the UK Independent MEPs voted against the proposal including Northern Ireland’s Diane Dodds Democratic Unionist Party (DUP) and of course Northern Ireland’s Jim Nicholson (Northern Ireland Conservative and Unionist) in the European Conservatives and Reformists Group (ECR).

Roger Helmer UKIP in the Europe of freedom and democracy Group voted against the proposal and therefore against his political group.

Philip Bradbourn Conservative in the European Conservatives and Reformists Group (ECR) has mentioned at the Parliamentary debate his Groups particular welcome of the report on the registration documents were an agreement was found and which should work for the United Kingdom. The concerns on a mandatory exchange of database information had been addressed, safeguarding national sovereignty over the data that Member States collect.

Finally, Jacqueline Foster Conservative MEP- North West England and Conservative Spokesman for Transport & Tourism has stated that it is her believe is there is limited road safety benefit from including motorcycles in the proposal and that she has been involved with meetings with Government colleagues and representatives from the Department for Transport and is ensuring the interests of the UK are safeguarded.

So at this stage in the proposal in the European Parliament, Conservative MEPs have been well briefed, they have listened to UK Citizens concerns and those of our European Counterparts (including motorcyclists) to get the best deal for us in the proceedings. Compared to other MEPs, their parties and groups, they are certainly more savvy about motorcycling.

The negotiations for the proposal are due to open in September on the resumption of the European Parliament. Whether an agreement can be reached by the end of the year remains to be seen.

However elections for the European Parliament are scheduled in the UK for the 22nd May 2014 and perhaps will be too close a call for MEPs to appear to be willing to accept blindly the European Commission’s proposal without looking at the bigger picture, which includes other issues that would affect the UK and its citizens.

We can argue that these MEPs (i.e. Lib Dems and Labour) are not getting the best deal for UK citizens who include motorcyclists, cars drivers, trailer and caravan owners, the haulage industry and those who work in the repair and testing industry. In this case these MEPs have to consider that all these people who will be affected, have a vote.

The Voting Riding Citizens View?

trailer3smallThe Federation of European Motorcyclists Federation (FEMA) has now stated that the proposal:

  1. fails to justify the harmonisation of testing frequencies;
  2. is based on biased evidence which is neither representative nor sufficient to justify the economic and regulatory burdens involved;
  3. is completely disproportionate to the size of the problem;
  4. goes against the principle of subsidiarity which enables Member States to design specific national measures for national road safety priorities.

At Right To Ride we tend to agree with the FEMA statement, “FEMA believes that the conditions under which PTW could be subject to periodical technical inspections (PTI) depend from national parameters, and should therefore be up to member states, and thus PTWs be deleted from the scope of the directive.”

However, we would like to point out that we actually consider road worthiness testing to be beneficial for motorcycles because it ensures a minimum standard of technical quality for motorcycles on the roads. However we are also of the opinion that this must always be a national decision based on the needs and requirements of each country and their citizens.

In other words, based on all the evidence, it is blindingly obvious that these are the wrong proposals at the wrong time.

These proposals demonstrate once again that the European Commission is out of touch with the Member States and has not considered the economic impact that these proposals would have on the various countries within the European Union.

Simply, our view is that the three proposals in the Road Worthiness Testing package need to be thrown out: no more amendments, no more compromises, no more opinions – just withdrawn!


Irish Houses of the Oireachtas opinion – pdf – Click Here
Source for MEPs Voting – VoteWatch Europe – Click Here
FEMA (Federation Of European Motorcyclists Associations) – Click Here
Leave Comments On Right To Ride EU – Click Here

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