# C_2008211EN.01000901.xml

| 19.8.2008 | EN | Official Journal of the European Union | C 211/9 |
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19.8.2008

EN

Official Journal of the European Union

C 211/9

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Opinion of the European Economic and Social Committee on the ‘Proposal for a Regulation of the European Parliament and of the Council on the protection of pedestrians and other vulnerable road users’

COM(2007) 560 final — 2007/0201 (COD)

(2008/C 211/02)

On 23 October 2007 the Council decided to consult the European Economic and Social Committee, under Article 95 of the Treaty establishing the European Community, on the

Proposal for a Regulation of the European Parliament and of the Council on the protection of pedestrians and other vulnerable road users.

Proposal for a Regulation of the European Parliament and of the Council on the protection of pedestrians and other vulnerable road users.

The Section for the Single Market, Production and Consumption, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 3 April 2008. The rapporteur was Mr Ranocchiari.

At its 444th plenary session, held on 22-23 April 2008 (meeting of 22 April), the European Economic and Social Committee adopted the following opinion by 155 votes, nem con with three abstentions.

1.   Summary and conclusions

| 1.1 | Every year, more than 44 000 people are killed and a further 1,7 million injured in road accidents in the 27 Member States. Of these, more than 8 000 of those killed and 300 000 of those injured belong to the most vulnerable category of road users — pedestrians and cyclists (1). |
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1.1

Every year, more than 44 000 people are killed and a further 1,7 million injured in road accidents in the 27 Member States. Of these, more than 8 000 of those killed and 300 000 of those injured belong to the most vulnerable category of road users — pedestrians and cyclists (1).

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| 1.2 | A framework directive was adopted in 2003 in order to ensure better protection for vulnerable users. It entailed a thorough review of the construction of the front part of vehicles, to be implemented in two phases: the first was applied to vehicles type-approved from 1 October 2005, while the second was to take effect in September 2010, following a feasibility assessment to be carried out before the end of 2004. |
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1.2

A framework directive was adopted in 2003 in order to ensure better protection for vulnerable users. It entailed a thorough review of the construction of the front part of vehicles, to be implemented in two phases: the first was applied to vehicles type-approved from 1 October 2005, while the second was to take effect in September 2010, following a feasibility assessment to be carried out before the end of 2004.

| 1.3 | As confirmed in studies from numerous independent experts, the second phase has proved not to be feasible, at least under the conditions laid down: the Commission is therefore now proposing to revise it, including new alternative measures which will however guarantee, or even improve upon, the level of safety contained in the provisions of the existing directive. |
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1.3

As confirmed in studies from numerous independent experts, the second phase has proved not to be feasible, at least under the conditions laid down: the Commission is therefore now proposing to revise it, including new alternative measures which will however guarantee, or even improve upon, the level of safety contained in the provisions of the existing directive.

| 1.4 | More specifically, the study carried out by the expert engaged by the Commission (2) suggested a number of solutions, which have been taken up in the present proposal, combining active and passive safety measures, in line with the recommendations put forward by CARS 21 (3) and with the proposal for a global technical regulation (GTR) for the protection of pedestrians drawn up by the United Nations' Economic Commission for Europe, Geneva (UN-ECE). |
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1.4

More specifically, the study carried out by the expert engaged by the Commission (2) suggested a number of solutions, which have been taken up in the present proposal, combining active and passive safety measures, in line with the recommendations put forward by CARS 21 (3) and with the proposal for a global technical regulation (GTR) for the protection of pedestrians drawn up by the United Nations' Economic Commission for Europe, Geneva (UN-ECE).

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| 1.5 | The EESC also considers that the proposal does not hinder free competition between manufacturers, in that it does not restrict the market offer of vehicle models, but seeks to channel demand towards models with higher safety requirements. |
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1.5

The EESC also considers that the proposal does not hinder free competition between manufacturers, in that it does not restrict the market offer of vehicle models, but seeks to channel demand towards models with higher safety requirements.

| 1.6 | In the light of the above, the EESC unreservedly supports the Commission's proposal. However, it regrets the almost three-year delay in reviewing the measures that have proved not to be feasible and in drafting new ones, although the delay is probably due in part to the appearance of data and technical solutions that were not available when the current directive was adopted. |
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1.6

In the light of the above, the EESC unreservedly supports the Commission's proposal. However, it regrets the almost three-year delay in reviewing the measures that have proved not to be feasible and in drafting new ones, although the delay is probably due in part to the appearance of data and technical solutions that were not available when the current directive was adopted.

| 1.7 | The EESC calls for the delay — which is all the more serious since it concerns the lives and health of Europe's citizens — to be made up through the rapid and full approval of the proposal by the European Parliament and the Council, enabling the second phase to commence within the planned timescale. |
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1.7

The EESC calls for the delay — which is all the more serious since it concerns the lives and health of Europe's citizens — to be made up through the rapid and full approval of the proposal by the European Parliament and the Council, enabling the second phase to commence within the planned timescale.

| 1.8 | While welcoming the increased efficacy of the technical measures adopted for vehicles, the EESC calls on the European institutions and the Member States to press ahead more decisively with initiatives regarding the other two aspects contributing to road safety: firstly, enhanced infrastructure quality and safety and secondly, training and awareness of all road users. This call must equally be addressed to regional and local authorities, who are increasingly shouldering decisive responsibilities in this sector. |
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1.8

While welcoming the increased efficacy of the technical measures adopted for vehicles, the EESC calls on the European institutions and the Member States to press ahead more decisively with initiatives regarding the other two aspects contributing to road safety: firstly, enhanced infrastructure quality and safety and secondly, training and awareness of all road users. This call must equally be addressed to regional and local authorities, who are increasingly shouldering decisive responsibilities in this sector.

2.   Introduction

| 2.1 | Every year, some 8 000 pedestrians and cyclists, the most vulnerable road users, are killed and 300 000 injured in road accidents in the 27 Member States. |
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2.1

Every year, some 8 000 pedestrians and cyclists, the most vulnerable road users, are killed and 300 000 injured in road accidents in the 27 Member States.

| 2.2 | As far back as 2001, the Commission obtained a commitment on the part of vehicle manufacturers to develop new means of enhancing the protection of pedestrians and cyclists, both actively (before a collision occurs) and passively (at the time of collision). |
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2.2

As far back as 2001, the Commission obtained a commitment on the part of vehicle manufacturers to develop new means of enhancing the protection of pedestrians and cyclists, both actively (before a collision occurs) and passively (at the time of collision).

| 2.3 | The range of measures suggested at that time by manufacturers included the equipping of all vehicles with antilock brake systems (ABS), a voluntary ban on the sale of rigid bull bars, the fitting of daytime running lights (DRL) — a measure subsequently withdrawn following opposition from some Member States — and lastly, the future introduction of advanced active safety new technology, which was still at the research stage. |
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2.3

The range of measures suggested at that time by manufacturers included the equipping of all vehicles with antilock brake systems (ABS), a voluntary ban on the sale of rigid bull bars, the fitting of daytime running lights (DRL) — a measure subsequently withdrawn following opposition from some Member States — and lastly, the future introduction of advanced active safety new technology, which was still at the research stage.

| 2.4 | The Council and the European Parliament welcomed the industry's commitment, at the same time calling for this field to be governed, not by a voluntary agreement or a recommendation, but by fully-fledged legislation on the protection of pedestrians in the form of a specific directive. |
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2.4

The Council and the European Parliament welcomed the industry's commitment, at the same time calling for this field to be governed, not by a voluntary agreement or a recommendation, but by fully-fledged legislation on the protection of pedestrians in the form of a specific directive.

| 2.5 | This gave rise to ‘framework’ Directive 2003/102/EC (4) relating to the protection of pedestrians and other vulnerable road users, followed by Directive 2005/66/EC (5) relating to the use of frontal protection systems on motor vehicles (elimination of rigid bumpers). |
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2.5

This gave rise to ‘framework’ Directive 2003/102/EC (4) relating to the protection of pedestrians and other vulnerable road users, followed by Directive 2005/66/EC (5) relating to the use of frontal protection systems on motor vehicles (elimination of rigid bumpers).

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| 2.6 | The framework directive on protecting pedestrians is based on tests and threshold values suggested by the European Enhanced Vehicle-safety Committee, and entails implementation in two phases, both focusing on passive safety. The first phase, which introduced changes in construction and lighter bonnets and bumpers for M1 and N1
   (6) vehicles weighing not more than 2 500 kg, came into force for vehicles that were type-approved from 1 October 2005. The second phase, laying down stricter tests and threshold values, is to apply to vehicles that are type-approved from 1 September 2010. |
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2.6

The framework directive on protecting pedestrians is based on tests and threshold values suggested by the European Enhanced Vehicle-safety Committee, and entails implementation in two phases, both focusing on passive safety. The first phase, which introduced changes in construction and lighter bonnets and bumpers for M1 and N1
   (6) vehicles weighing not more than 2 500 kg, came into force for vehicles that were type-approved from 1 October 2005. The second phase, laying down stricter tests and threshold values, is to apply to vehicles that are type-approved from 1 September 2010.

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| 2.7 | Serious doubts concerning the feasibility of the tests planned for the second phase were already expressed when the proposal was discussed at the European Parliament: in the final version of the text, the directive stipulated that the Commission should carry out a feasibility assessment of the second phase by 1 July 2004. Specifically, the assessment was to identify ‘alternative measures — either passive or a combination of active and passive measures — which are at least equivalent in terms of actual effectiveness’ (7). |
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2.7

Serious doubts concerning the feasibility of the tests planned for the second phase were already expressed when the proposal was discussed at the European Parliament: in the final version of the text, the directive stipulated that the Commission should carry out a feasibility assessment of the second phase by 1 July 2004. Specifically, the assessment was to identify ‘alternative measures — either passive or a combination of active and passive measures — which are at least equivalent in terms of actual effectiveness’ (7).

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| 2.8 | A series of studies carried out by independent experts, including those engaged by the Commission, showed that it was technically impossible to fulfil the second-phase requirements within the deadline set and using the tests stipulated by the EEVC. In consequence, the new proposal lays down revised passive safety parameters, together with new active safety elements that have been developed by the industry in the meantime, which can meet and even exceed the requirements of Article 5, being ‘at least equivalent in terms of actual effectiveness’. |
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2.8

A series of studies carried out by independent experts, including those engaged by the Commission, showed that it was technically impossible to fulfil the second-phase requirements within the deadline set and using the tests stipulated by the EEVC. In consequence, the new proposal lays down revised passive safety parameters, together with new active safety elements that have been developed by the industry in the meantime, which can meet and even exceed the requirements of Article 5, being ‘at least equivalent in terms of actual effectiveness’.

| 2.9 | Furthermore, the tests now suggested are equal to those contained in the global technical regulation for the protection of pedestrians drawn up by the UN Economic Commission for Europe (UN-ECE). The ensuing possible harmonisation of European legislation with legislation outside Europe would also clearly boost the competitiveness of the European vehicle industry. |
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2.9

Furthermore, the tests now suggested are equal to those contained in the global technical regulation for the protection of pedestrians drawn up by the UN Economic Commission for Europe (UN-ECE). The ensuing possible harmonisation of European legislation with legislation outside Europe would also clearly boost the competitiveness of the European vehicle industry.

3.   The European Commission's proposal

| 3.1 | The new proposal, which is now for a regulation rather than a directive, sets out first and foremost to combine the provisions of the directive on frontal protection systems with those of the earlier directive on the protection of pedestrians, which will be amended as necessary in order to ensure that they can be applied. Consequently, if the proposed regulation is adopted, both of these directives will be repealed. |
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3.1

The new proposal, which is now for a regulation rather than a directive, sets out first and foremost to combine the provisions of the directive on frontal protection systems with those of the earlier directive on the protection of pedestrians, which will be amended as necessary in order to ensure that they can be applied. Consequently, if the proposed regulation is adopted, both of these directives will be repealed.

| 3.2 | The tests that vehicles will have to pass in order to be type-approved under the proposed regulation concern: |
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3.2

The tests that vehicles will have to pass in order to be type-approved under the proposed regulation concern:

| 3.2.1 | collision of child or small adult headform with the forward part of the bonnet; collision of adult headform with the rear part of the bonnet and collision of lower and upper legforms with the bumper, with partially revised parameters regarding phase II under the present directive. For the purposes of monitoring rather than type-approval, and with a view to future technological developments, collision tests for the pelvis with the bonnet leading edge and adult headform with the windscreen are also stipulated. |
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3.2.1

collision of child or small adult headform with the forward part of the bonnet; collision of adult headform with the rear part of the bonnet and collision of lower and upper legforms with the bumper, with partially revised parameters regarding phase II under the present directive. For the purposes of monitoring rather than type-approval, and with a view to future technological developments, collision tests for the pelvis with the bonnet leading edge and adult headform with the windscreen are also stipulated.

| 3.2.2 | Regarding frontal protection systems (former Directive 2005/66/EC), collision of legform and child or small adult headform with the system are confirmed as type-approval tests. Further tests are proposed for monitoring purposes, together with binding provisions on the construction and installation of these systems. |
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3.2.2

Regarding frontal protection systems (former Directive 2005/66/EC), collision of legform and child or small adult headform with the system are confirmed as type-approval tests. Further tests are proposed for monitoring purposes, together with binding provisions on the construction and installation of these systems.

| 3.3 | Passive safety measures are supplemented by the installation of an active safety system in order to ensure the level of safety laid down in the two previous directives. These are the brake assist system (BAS), which helps a driver attempting to brake rapidly in an emergency but not applying sufficient pressure. In combination with ABS it ensures maximum braking pressure and optimises the rate of deceleration, significantly reducing the impact velocity with pedestrians. |
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3.3

Passive safety measures are supplemented by the installation of an active safety system in order to ensure the level of safety laid down in the two previous directives. These are the brake assist system (BAS), which helps a driver attempting to brake rapidly in an emergency but not applying sufficient pressure. In combination with ABS it ensures maximum braking pressure and optimises the rate of deceleration, significantly reducing the impact velocity with pedestrians.

| 3.4 | Lastly, in view of the increasing number of heavier vehicles (especially SUVs) using the roads, it is now recommended that, following a transitional period, the provisions apply not only to M1 and N1 vehicles weighing up to 2 500 kg, as under the existing legislation, but also heavier ones weighing up to 3 500 kg, which is the upper limit for the two categories concerned. |
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3.4

Lastly, in view of the increasing number of heavier vehicles (especially SUVs) using the roads, it is now recommended that, following a transitional period, the provisions apply not only to M1 and N1 vehicles weighing up to 2 500 kg, as under the existing legislation, but also heavier ones weighing up to 3 500 kg, which is the upper limit for the two categories concerned.

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4.   The EESC's comments on the Commission's proposal

| 4.1 | Firstly, the EESC welcomes the Commission's decision to merge the two preceding directives in the proposed regulation. This option clarifies and simplifies the relevant legislation, as the EESC previously suggested in its opinion on the proposal for a directive on the use of frontal protection systems (8). |
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4.1

Firstly, the EESC welcomes the Commission's decision to merge the two preceding directives in the proposed regulation. This option clarifies and simplifies the relevant legislation, as the EESC previously suggested in its opinion on the proposal for a directive on the use of frontal protection systems (8).

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| 4.2 | Similarly, the EESC also endorses the choice of a regulation as the legal instrument, as this ensures specific implementation methods and deadlines in all the Member States — a particularly important aspect for such highly technical legislation. |
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4.2

Similarly, the EESC also endorses the choice of a regulation as the legal instrument, as this ensures specific implementation methods and deadlines in all the Member States — a particularly important aspect for such highly technical legislation.

| 4.3 | On the other hand, the EESC regrets that it has proved impossible to implement the tests put forward by the EEVC for phase II, as their feasibility was not tested within the stipulated deadline (1 July 2004), leading to a delay of more than three years. |
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4.3

On the other hand, the EESC regrets that it has proved impossible to implement the tests put forward by the EEVC for phase II, as their feasibility was not tested within the stipulated deadline (1 July 2004), leading to a delay of more than three years.

| 4.4 | The EESC, however, wishes to express its appreciation of the solution proposed following a lengthy but fruitful process, in which the recommendations put forward by CARS 21 on an integrated approach have been taken on board. This also enables European legislation to be brought into line with non-European laws. It is particularly satisfying that all this has been underpinned by a rigorous impact assessment, the first to have been examined and approved by the Impact Assessment Board recently set up by the European Commission. |
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4.4

The EESC, however, wishes to express its appreciation of the solution proposed following a lengthy but fruitful process, in which the recommendations put forward by CARS 21 on an integrated approach have been taken on board. This also enables European legislation to be brought into line with non-European laws. It is particularly satisfying that all this has been underpinned by a rigorous impact assessment, the first to have been examined and approved by the Impact Assessment Board recently set up by the European Commission.

| 4.5 | The chosen solution, by implementing active safety measures as well, will — according to the forecasts from the Commission and its experts — cut the number of deaths and serious injuries by 80 % and 44 % respectively compared to the results that would have been achieved with the original phase II (9) (that has turned out to be unachievable), thereby helping to save more than 1 100 lives and reducing the number of people injured by 46 000. Moreover, the new measures entail very low costs and will therefore have a negligible impact on vehicle prices. |
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4.5

The chosen solution, by implementing active safety measures as well, will — according to the forecasts from the Commission and its experts — cut the number of deaths and serious injuries by 80 % and 44 % respectively compared to the results that would have been achieved with the original phase II (9) (that has turned out to be unachievable), thereby helping to save more than 1 100 lives and reducing the number of people injured by 46 000. Moreover, the new measures entail very low costs and will therefore have a negligible impact on vehicle prices.

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| 4.6 | In the light of the above, the EESC strongly recommends that the Commission's proposal should be rapidly and fully approved by the European Parliament and the Council, with no further delay, which would inevitably cause further slippage due to the vehicle industry's lead times (10). |
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4.6

In the light of the above, the EESC strongly recommends that the Commission's proposal should be rapidly and fully approved by the European Parliament and the Council, with no further delay, which would inevitably cause further slippage due to the vehicle industry's lead times (10).

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| 4.7 | The EESC hopes that the new provisions will also be rapidly applied to heavier vehicles, including SUVs, present in increasing numbers in urban traffic. To this end, the transitory period mentioned in the proposal should be fixed immediately. |
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4.7

The EESC hopes that the new provisions will also be rapidly applied to heavier vehicles, including SUVs, present in increasing numbers in urban traffic. To this end, the transitory period mentioned in the proposal should be fixed immediately.

| 4.8 | Lastly, it should be remembered that these protective measures do not, of course, apply to older vehicles which now constitute one of the greatest dangers for vulnerable users. It is also worth pointing out that although ABS — now combined with BAS to great effect — has been widely introduced on a voluntary basis since 2004, will only become compulsory with the new legislation. |
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4.8

Lastly, it should be remembered that these protective measures do not, of course, apply to older vehicles which now constitute one of the greatest dangers for vulnerable users. It is also worth pointing out that although ABS — now combined with BAS to great effect — has been widely introduced on a voluntary basis since 2004, will only become compulsory with the new legislation.

| 4.9 | The EESC would lastly point out that in the type of collision in question, injuries fall into two categories: those caused by the primary impact between the pedestrian or cyclist and the front part of the vehicle, and those caused by the secondary impact with the road surface onto which pedestrians are often thrown. It should in any case be pointed out that it is unrealistic to expect to protect pedestrians if the primary impact occurs at speeds above 40 kph. |
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4.9

The EESC would lastly point out that in the type of collision in question, injuries fall into two categories: those caused by the primary impact between the pedestrian or cyclist and the front part of the vehicle, and those caused by the secondary impact with the road surface onto which pedestrians are often thrown. It should in any case be pointed out that it is unrealistic to expect to protect pedestrians if the primary impact occurs at speeds above 40 kph.

| 4.10 | The purpose of the above comments is to emphasise once again that a solution to this problem, as in the case of many other road user safety issues, depends on an integrated approach that must include — in addition to technical improvements to vehicles — another two key aspects: road user behaviour and infrastructure. These are both aspects on which the European institutions and the Member States will need to shoulder decisive responsibilities. |
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4.10

The purpose of the above comments is to emphasise once again that a solution to this problem, as in the case of many other road user safety issues, depends on an integrated approach that must include — in addition to technical improvements to vehicles — another two key aspects: road user behaviour and infrastructure. These are both aspects on which the European institutions and the Member States will need to shoulder decisive responsibilities.

| 4.11 | The EESC considers that the European Commission has done, and continues to do, much in this regard, with proposals for legislative and policy initiatives, funds channelled through European framework research programmes, the programme for subsidising road safety and, last but not least, the launch of the European road safety charter. |
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4.11

The EESC considers that the European Commission has done, and continues to do, much in this regard, with proposals for legislative and policy initiatives, funds channelled through European framework research programmes, the programme for subsidising road safety and, last but not least, the launch of the European road safety charter.

| 4.12 | In contrast, the other institutions and the Member States, although addressing the problem, do not always give sufficient support to the Commission's initiatives. The Commission's proposal, intended to raise road infrastructure safety standards (11), is a recent example of this. The proposal, considered by the EESC to be necessary in order to reduce the number of road casualties, has been judged by the European Parliament to be over-prescriptive and as a result has, in the name of the subsidiarity principle, been emptied of its most vigorous, binding provisions. In this case too, unless changes are made during the plenary vote — which is unlikely — the Parliament will have handed over all decisions to the Member States. |
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4.12

In contrast, the other institutions and the Member States, although addressing the problem, do not always give sufficient support to the Commission's initiatives. The Commission's proposal, intended to raise road infrastructure safety standards (11), is a recent example of this. The proposal, considered by the EESC to be necessary in order to reduce the number of road casualties, has been judged by the European Parliament to be over-prescriptive and as a result has, in the name of the subsidiarity principle, been emptied of its most vigorous, binding provisions. In this case too, unless changes are made during the plenary vote — which is unlikely — the Parliament will have handed over all decisions to the Member States.

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| 4.13 | Concerning the first aspect mentioned above, i.e. road user behaviour, accidents are frequently caused by driver carelessness, but just as often pedestrians and cyclists act imprudently, in contravention of the basic rules of the road and sometimes of common sense. Education and information in this area should be provided from primary school onward by means of regular publicity campaigns aimed at encouraging proper behaviour by all users. It is equally important to introduce severe penalties for dangerous behaviour by all road users. |
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4.13

Concerning the first aspect mentioned above, i.e. road user behaviour, accidents are frequently caused by driver carelessness, but just as often pedestrians and cyclists act imprudently, in contravention of the basic rules of the road and sometimes of common sense. Education and information in this area should be provided from primary school onward by means of regular publicity campaigns aimed at encouraging proper behaviour by all users. It is equally important to introduce severe penalties for dangerous behaviour by all road users.

| 4.14 | The other essential aspect of road safety concerns infrastructure, first and foremost in cities, where 80 % of pedestrian and cyclist deaths occur. Physical separation of road users wherever possible represents the most effective way of preventing contact between vehicles, pedestrians and cyclists. From this point of view, work to build protected pedestrian crossings, footbridges, cycle lanes, proper lighting and surfaces, and clear signage, which should as far as possible be the same in the different Member States, would help to reduce the number of accidents, as well as creating a less hostile urban environment for people with disabilities. |
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4.14

The other essential aspect of road safety concerns infrastructure, first and foremost in cities, where 80 % of pedestrian and cyclist deaths occur. Physical separation of road users wherever possible represents the most effective way of preventing contact between vehicles, pedestrians and cyclists. From this point of view, work to build protected pedestrian crossings, footbridges, cycle lanes, proper lighting and surfaces, and clear signage, which should as far as possible be the same in the different Member States, would help to reduce the number of accidents, as well as creating a less hostile urban environment for people with disabilities.

| 4.15 | Initiatives of this kind increase safety and improve the quality of life in cities, and should therefore be recalled in all Commission proposals including those, such as the present one, that refer only to the technical aspects of motor vehicles. |
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4.15

Initiatives of this kind increase safety and improve the quality of life in cities, and should therefore be recalled in all Commission proposals including those, such as the present one, that refer only to the technical aspects of motor vehicles.

Brussels, 22 April 2008.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

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(1)  Source: CARE (Community Road Accident data base): a database that collects and compiles data provided by the Member States on road accidents.

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(2)  Transport Research Limited UK.

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(3)  COM(2007) 22 final of 7 February 2007, A Competitive Automotive Regulatory Framework for the 21st Century.

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A Competitive Automotive Regulatory Framework for the 21st Century

(4)  OJ L 321 of 6.12.2003 p. 15.

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(5)  OJ L 309 of 25.11.2005 p. 37.

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(6)

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| M1 | = | vehicles for eight passengers + driver, maximum mass not exceeding 3 500 kg. |
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| N1 | = | commercial vehicles deriving from M1, maximum mass not exceeding 3 500 kg. |

M1

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=

vehicles for eight passengers + driver, maximum mass not exceeding 3 500 kg.

N1

1

=

commercial vehicles deriving from M1, maximum mass not exceeding 3 500 kg.

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(7)  Article 5 of Directive 2003/102/EC on the protection of pedestrians.

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(8)  Opinion OJ C 118 of 30.4.2004.

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(9)  SEC(2007) 1244: impact assessment accompanying the proposal for a regulation.

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(10)  The time needed to implement any new requirement involving structural changes to vehicles.

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(11)  COM(2006) 569 final.

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