Opinion of the European Economic and Social Committee on the Proposal for a Directive of the European Parliament and of the Council on road infrastructure safety management COM(2006) 569 final — 2006/0182 (COD)
Date: 2007-04-26
Institutions: European Economic and Social Committee
Subjects: ESC opinion, road network, road safety, transport infrastructure, transport network

20.7.2007

EN

Official Journal of the European Union

C 168/71

Opinion of the European Economic and Social Committee on the Proposal for a Directive of the
European Parliament and of the Council on road infrastructure safety management

COM(2006) 569 final — 2006/0182 (COD)

(2007/C 168/15)

On 10 November 2006 the Council decided to consult the European Economic and Social Committee,
under Article 71(1)(c) of
the Treaty establishing the European Community, on the above-mentioned
proposal.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 22 March. The rapporteur was
Mr Simons.

At its 435 plenary session, held on 25 and 26 April 2007 (meeting of 26 April), the European Economic
and Social Committee adopted unanimously the following opinion.

1. Conclusions

1.1
The Committee welcomes the Commission's initiative to
flesh out the third pillar of road safety policy: road infrastruc-
ture safety management. As an adjunct to driver-related action
and measures to improve vehicle safety, the directive now on
the table seeks to integrate safety into all phases of the planning,
design and operation of road infrastructure in the Trans-Euro-
pean Network (TEN-T). In road safety policy, all these factors are
equally important.

Although the Committee is aware that, in places where
1.2
infrastructure is already well developed,
road infrastructure
measures will, generally speaking, have less of an impact than
action on the driver or the vehicle, it is convinced that every
available means must be used in this field too to improve road
safety and bring down victim numbers.

1.3
The Committee feels that the proposed measures for the
third pillar of road safety policy should not be restricted to the
TEN-T alone, but should be extended to include all roads in the
Member States outside urban areas on which many accidents
clearly occur. Given that the aim is to minimise the number of
road traffic victims and that most gains on this front —
1 300 fewer fatalities instead of 600 — are to be made on non-
TEN-T infrastructure, this is one aspect to which the Commis-
sion might be expected to give much more attention. The
Committee feels that EC Treaty Article 71(1)(c) provides a
sound basis for this.

1.4
The Committee would therefore ask the Member States
to agree to extend the scope of the proposed measures to all
roads outside urban areas.

Commission must come up with a more binding legal instru-
ment than a directive, the provisions of which will have to be
complied with by all government players and private stake-
holders concerned.

that

The fact

the subsidiarity principle has

1.6
to be
complied with under the legal basis mentioned in point 1.3
above is no hindrance. On the contrary, a European approach is
vital to be sure of the uniform application that is so necessary
in this field.

1.7
The Committee also notes the importance of analysing
the causes of road traffic accidents. This is the only way to iden-
tify the precise extent to which such accidents are caused by
road infrastructure design and, on that basis, to put effective
measures in place.

2. Introduction

Until the 1990s, road traffic accidents were seen as a

2.1
phenomenon inherent to mobility in our economy and society.

2.2
The European Community's role was also limited. With
no explicit responsibilities in this area, it had little scope to act.
It was, however, possible to adopt directives, particularly in the
field of technical standards designed to improve vehicle safety
(obligatory use of seatbelts, speed limiters for lorries, etc.)

Since the turn of the millennium, however, there has
2.3
been a sea change in thinking in this field. Studies have shown
that road safety is one of
the European public's principal
concerns. This applies particularly to road transport — the
mode in which most fatalities occur.

The Commission is proposing action on the basis of a
1.5
directive. With an eye to the effectiveness of
the proposed
measures, the Committee does not feel that a directive will have
the desired impact as it gives Member States too much discre-
tion, thus ruling out any uniform application. The Committee
feels that, to achieve its objective of halving the number of road
fatalities by the year 2010 compared with the 2000 figures, the

2.4
In 2000, more than 40 000 people were killed and
more than 1.7 million injured in road accidents in the then
fifteen-Member-State European Union. The direct measurable
cost of road traffic accidents is put at EUR 45 billion, while the
indirect cost,
including physical and psychological damage to
victims and their families, comes to EUR 160 billion per year.

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2.5
Since the Maastricht Treaty, the European Community
has also had more effective regulatory tools at its disposal to
take action in the field of road safety, although application of
the subsidiarity principle continues to hinder any genuine
common policy in this area.

Member State concerned, will have less of an impact on cutting
the number of road accident victims. That said, the Committee
does feel that every available means must be used to bring
down victim numbers, for instance by introducing standards for
road infrastructure design and signposting in the EU Member
States.

The 2001 White Paper European transport policy for 2010:
2.6
time to decide and the June 2003 Communication on a European
Road Safety Action Programme devote a great deal of attention
to measures designed to improve road safety. The third key
component — alongside driver- and vehicle-related measures —
is action relating to the physical infrastructure.

No European-level

2.7
initiatives are yet in place for road
safety infrastructure. Some roads equipped with traffic manage-
ment and control systems based on information and communi-
cation technologies (ICT) have indeed become safer, but there is
a long way to go before all roads are fitted with ITC systems.

the

conducted in 2003 by

3.4
The Committee's view as to the effects of the measures
on the table is confirmed by the impact analysis of the proposed
directive
thematic network
ROSEBUD. This study found that implementation of the direc-
tive on TEN roads would — at a realistic estimate — lead to
more than 600 fewer fatalities and more than 7 000 fewer
injury accidents per year. If, however, the directive were also to
be applied to all roads outside urban areas, the number of
victims would be cut by some 1 300 per year, equating to an
annual saving of EUR 5 billion.

2.8 Much remains to be done, therefore, to improve the
safety of the physical infrastructure. The trend, however, is for
national governments to provide less funding for road infra-
structure — despite the increasing importance attached by road
users to road standards and road safety.

The Committee feels that EC Treaty Article 71(1)(c)
3.5
provides a sound basis for this. The Committee would therefore
ask the Member States to agree to extend the scope of the
proposed measures to all roads outside urban areas.

The Commission's aim,

2.9
in submitting this
directive is to integrate safety into all phases of road infrastruc-
ture in the Trans-European Network (TEN-T). Its intention is to
introduce road safety impact assessments alongside economic
and environmental analyses.

therefore,

3. General comments

3.1
In a point already made in its opinion of 10 December
2003 on the Communication from the Commission: European Road
Safety Action Programme: Halving the number of
road accident
victims in the European Union by 2010: A shared responsibility, the
Committee considers the Commission's objective of halving the
number of road fatalities by the year 2010 compared with the
2000 figures (from 40 000 in 2000 to 25 000 in 2010) to be
somewhat ambitious.

3.2
That is clearly the case, given that, in 2005, road accident
victim figures in the European Union were still running at
41 500 — despite the raft of driver- and vehicle-related road
safety measures now in place at EU level. The Committee thinks
that each and every road traffic victim is one victim too many,
and thus expects the Commission to be much more forceful in
its efforts to achieve the desired objective,
for instance by
launching a major European road safety campaign and giving
Member States recommendations on the use of tougher instru-
ments to cut the number of road traffic victims.

3.6
The draft directive sets out a minimum set of elements
that the Commission feels are necessary to have an impact on
safety and to spread procedures that have shown to be effective.
In that connection, the Commission cites the following four
procedures that are central to any system of road infrastructure
safety management: road safety impact assessments; road safety
audits;
identification of black spots; and safety inspections as
part of regular road maintenance. The Committee has serious
doubts about the effectiveness of any such measures in the form
of a directive as these four procedures will most definitely not
be applied in a uniform way in all the EU Member States.

The Commission feels that this directive strikes a good
3.7
balance between improving safety,
limiting administrative
burdens and respecting the different traditions, values and stan-
dards in the Member States. The Committee disputes this, for
the reasons set out in points 3.4 and 3.5 above.

thus

too much discretion,

A directive will not have the desired impact as it gives
3.8
Member States
ruling out any
uniform application. The Committee feels that, to achieve its
objective of halving the number of road fatalities by the year
2010 compared with the 2000 figures, the Commission must
come up with a more binding legal instrument than a directive,
the provisions of which will have to be complied with by all
government players and private stakeholders concerned.

3.3
The Committee believes that Community action on
drivers and vehicles is most effective in improving road safety.
Measures to improve the road infrastructure — the third pillar
of road safety policy — are, in the Committee's view, less effec-
tive and, depending on the circumstances prevailing in the

3.9
The Commission thinks that cost increases as a result of
the proposals contained in the draft directive will be no more
than marginal and will be offset within a short time through
savings made as a result of the reduced number of accidents.
The Committee wonders on what basis the Commission makes
this assertion.

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4. Specific comments

The Committee thinks that, like action relating to vehi-
4.1
the proposed
cles and drivers under
measures on the third pillar of road safety policy — road infra-
structure — should cover not just the TEN-T, but should be
extended to include all roads outside urban areas on which
many accidents clearly occur.

two pillars,

the first

4.2
This is also one of the findings of the internet public
consultation held from 12 April to 19 May 2006. A significant
number of respondents suggested extending the provisions of
the directive to roads not part of
the trans-European road
network, since it is precisely on those roads that most lives
could be saved.

4.3
The proposed directive lays down procedures for road
safety assessments, audits and inspections. Member States are
expected to use the elements listed in the annexes to provide the
requested information in a uniform way. In the Committee's
view, however, the fact that the provisions are laid down in a
directive gives Member States too much leeway for any sound
comparison to be made of
the measures
contained therein.

the impact of

4.4
Annex I, for instance, sets out a number of components
and elements to be used by Member States in road safety impact
assessments. This list gives Member States so much discretion in
is highly doubtful
it
the conduct of such assessments that
whether they will produce comparable data.

4.5
The same can also be said of the list of elements for road
safety audits set out in Annex II. Here too Member States have
broad scope for their own interpretation.

The same shortcoming also applies to the safety inspec-
4.6
tions, with the additional difficulty that,
in Annex III of the
directive, one of the elements for reporting by the inspection
reports’. The
team is given as

the accident

‘analysis of

Brussels, 26 April 2007.

Committee feels that the focus should not be so much on
analysing the accident reports as on identifying what actually
causes the accidents in the first place. This consideration is,
regrettably, also missing from Article 7 of the draft directive
and from Annex IV, which deals in greater detail with the acci-
dent data to be included in accident reports.

4.7
As the Committee already pointed out in its opinion of
10 December 2003 on the Communication from the Commission:
European Road Safety Action Programme: Halving the number of
road accident victims in the European Union by 2010: A shared
responsibility, a great deal of information may be obtained by
giving closer consideration to black spots, with an analysis of
the causes of accidents for each one. In the same opinion, the
Committee also notes the work of the ‘Euro-RAP’ organisation
which publishes a road map of various European countries indi-
cating the level of danger on different roads, based on accidents
that have actually occurred.

that

The Committee

4.8
the Commission
recommends
include in its proposal a provision enjoining the Member States
to increase the number of parking areas for all users, including
those with disabilities, along major infrastructure routes. Such
parking areas should be secure as otherwise drivers will simply
carry on with their journey, resulting, among other things, in
non-compliance with the rules on driving time and rest periods
and thus compromising road safety.

The Committee feels that not enough attention has been
4.9
paid to the issue of road lighting. With a view to improving
road safety, it is recommended that Member States coordinate
their policy in this area.

A final point

the Committee would draw to the
4.10
Commission's attention is that a visual presentation of black
spots by Member States — i.e. infrastructure on which accidents
frequently occur — is an important tool in raising road users'
awareness.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS