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Document 52012SC0206
COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT Accompanying document to the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC and REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the technical roadside inspections of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC and DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Council Directive 1999/37/EC on the registration documents for vehicles
COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT Accompanying document to the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC and REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the technical roadside inspections of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC and DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Council Directive 1999/37/EC on the registration documents for vehicles
COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT Accompanying document to the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC and REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the technical roadside inspections of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC and DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Council Directive 1999/37/EC on the registration documents for vehicles
52012SC0206
COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT Accompanying document to the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC and REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the technical roadside inspections of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC and DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Council Directive 1999/37/EC on the registration documents for vehicles
COMMISSION STAFF WORKING DOCUMENT Accompanying the document REGULATION OF THE EUROPEAN
PARLIAMENT AND OF THE COUNCIL on periodic roadworthiness tests for motor
vehicles and their trailers and repealing Directive 2009/40/EC
and
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the technical
roadside inspections of the roadworthiness of commercial vehicles circulating
in the Union and repealing Directive 2000/30/EC
and
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
amending Council Directive 1999/37/EC on the registration documents for
vehicles || IMPACT ASSESSMENT || || Final Report of Contributions to Impact Assessment of Policy Options to Improve the EU Systems of PTI and of Roadside Vehicle Testing || Europe Economics Chancery House 53-64 Chancery Lane London WC2A 1QU Tel: (+44) (0) 20 7831 4717 Fax: (+44) (0) 20 7831 4515 www.europe-economics.com 02 February 2011 Executive Summary........................................................................................................................ i 1........... Introduction.................................................................................................................... 1 Political context............................................................................................................................. 1 Economic context......................................................................................................................... 2 Legal framework........................................................................................................................... 2 General comment on legal framework............................................................................................ 6 2........... Procedure...................................................................................................................... 7 3........... Problem Definition.......................................................................................................... 7 What is the problem that may require action?................................................................................. 7 What are the underlying causes of the
problem?............................................................................. 8 Who is affected and in what ways?.............................................................................................. 19 How would the problem evolve if present
policies are maintained?............................................... 20 Does the EU have the right to act and is
there evidence of EU added value?................................. 25 4........... Objectives.................................................................................................................... 26 What are the general policy objectives?....................................................................................... 26 What are the more specific/operational
objectives?...................................................................... 26 5........... Policy Options.............................................................................................................. 27 Definition of policy options.......................................................................................................... 27 Information exchange.................................................................................................................. 35 Possible combinations of policies................................................................................................. 35 6........... Analysis of Impacts....................................................................................................... 36 Scope of analysis........................................................................................................................ 36 Initial overview of options in relation to
objectives........................................................................ 36 Option 1: No new policy action................................................................................................... 37 Option 1a: No new EU legislation, but better
implementation........................................................ 47 Option 2: Encourage bilateral agreements.................................................................................... 56 Option 3: Mandatory mutual recognition
throughout the EU.......................................................... 60 Option 4: Impose a mandatory EU-wide system
for PTIs and roadside testing.............................. 68 Estimated costs to lift all MS to HIGH level................................................................................. 74 Summary.................................................................................................................................... 74 Option 5: Deregulation at EU level............................................................................................... 89 Information exchange.................................................................................................................. 90 7........... Comparison of Options................................................................................................. 93 PTI........ 93 Roadside testing.......................................................................................................................... 94 Data...... 94 Option summary......................................................................................................................... 95 Appendix 1: Expert Workshop.................................................................................................... 96 Attendance List........................................................................................................................... 96 Morning Session......................................................................................................................... 97 The Policy Context and DG MOVE Objectives........................................................................... 97 Social and Economic Benefits of Road Safety.............................................................................. 97 Single Market Aspects................................................................................................................ 98 Discussion.................................................................................................................................. 99 Afternoon Session..................................................................................................................... 100 Group Discussion – Data systems.............................................................................................. 100 Summary from Group Discussion on Potential
Impacts of Changes to PTIs................................ 101 Costs of Standardisation – the Case of RDW in
the Netherlands................................................ 102 Costs of Standardisation – Presentation by
Applus, Spain.......................................................... 103 Group Discussion - Mutual Recognition..................................................................................... 104 Summary from Group Discussion on Potential
Cost Impacts of PTI............................................ 105 Appendix 2: Stakeholders’ Meeting........................................................................................... 106 Attendance List......................................................................................................................... 106 Morning Session....................................................................................................................... 107 Discussion................................................................................................................................ 108 Afternoon Session..................................................................................................................... 111 Improved Flows of Information................................................................................................. 111 Interim Analysis of the Internet Consultation............................................................................... 112 First Analysis of the Options...................................................................................................... 112 Comments and Discussion......................................................................................................... 113 Concluding Remarks................................................................................................................. 113 Appendix 3: Public On-line Consultation.................................................................................... 114 Respondent profile.................................................................................................................... 122 Experience of PTIs................................................................................................................... 126 Impression of the overall efficiency and value
for money of the test............................................. 127 Experience of Roadside Inspections.......................................................................................... 135 Standardisation across Europe.................................................................................................. 135 Access to Test Results.............................................................................................................. 139 Level of Complexity of the System............................................................................................ 139 Exchange of Data...................................................................................................................... 140 Testing in other Member States................................................................................................. 141 Policy Options.......................................................................................................................... 142 Appendix 4: Improved Information Availability.......................................................................... 146 Suggested Aims of a Harmonised Data Exchange...................................................................... 148 Cost Benefit Analysis................................................................................................................ 163 Appendix 5: Potential Levels for Roadside
Inspections............................................................... 169 Appendix 6: European Approaches to Monetising
the Value of Road Safety.............................. 171 ‘The million Euros rule’............................................................................................................. 171 HEATCO Recommendation..................................................................................................... 171 Country-level Official Estimates................................................................................................. 172 Other Estimates........................................................................................................................ 173 Appendix 7: Calculating the Total Cost of
PTIs in Europe.......................................................... 174 IMPACT ASSESSMENT Executive Summary 1
This report presents the conclusions of a
project carried out by Europe Economics, advised on certain issues by DEKRA and
CENTIQ, to assist DG MOVE in preparing an impact assessment of policy options
to improve the EU systems of periodic technical inspection of vehicles (PTI) and
of roadside testing. The conclusions drawn are the sole responsibility of
Europe Economics.
1.1.1.
Context
2
The EU is committed to improving the level of
safety of road transport, and sees the system of vehicle testing as playing an
important part in achieving this. 3
EU legislation in this field has recently been
revised, and reflects a policy of increasingly detailed regulation. The
legislation takes the form of Directives, binding on Member States, rather than
Regulations, directly binding on individuals and businesses. 4
The economic context is such that it is even
more important than in more prosperous times that no new regulations should be
imposed unless there is a clear benefit to the consumer.
1.1.2.
Consultations
5
An experts’ workshop and a stakeholders’ meeting
were held in Brussels in August and September, respectively; and a public
on-line consultation was conducted between 30 July and 24 September, attracting
almost 10,000 replies. Half of the respondents felt that PTIs were excellent
value for money, and only 5 per cent found them insufficient. 6
A number of written contributions were also
received from stakeholders. These consultations provided information which is
taken into account in this impact assessment.
1.1.3.
Problem definition
7
Two related issues are under consideration,
linked by the fact that improvements to the system of vehicle inspections might
contribute to their solutions. 8
These issues are: (a)
Significant numbers of accidents still occur on the
roads of EU Member States, costing lives and injury, and causing other social,
economic and environmental damage. (b)
The full potential of the EU single market is
not being achieved, since different Member States require different systems of
testing and there is no mutual recognition of the validity of tests. 9
It is recognised that there may be trade-offs
between these objectives, and that they may be seen as opportunities for
improvement rather than as problems demanding immediate solution.
1.1.4.
Causes of the problems
10
The causes of road accidents are primarily
mistakes by drivers, but vehicle faults also contribute. A significant
proportion of vehicles subjected to roadside tests in several Member States
were found to have some faults. 11
The reasons why there are different system of
testing in use is partly that circumstances differ and partly that expert
opinions on what is the most efficient method also differ. 12
There is no underlying reason why Member States
should seek different outcomes than those that would be optimal for the EU as a
whole.
1.1.5.
Who is affected?
13
A wide constituency of road users; businesses
making vehicles, testing equipment and carrying out tests; and regulatory
authorities are affected by road safety issues and may be affected by
differences between Member States.
1.1.6.
How would the problem be likely to evolve on
unchanged policies?
14
There has been good progress in reducing the
number of road accidents, and this would continue. Initiatives taken by some
Member States toward bilateral mutual recognition, and recent European Court of
Justice (ECJ) decisions, would help to alleviate some of the disadvantages of
differences in testing systems. 15
It is not possible to forecast with confidence
whether or not the EU political objective of halving the numbers of fatalities
by 2020 will be achieved on present policies.
1.1.7.
Does the EU have the right to act and is there
evidence of EU added value?
16
The EU has recently passed legislation
controlling both PTI and roadside testing, so the legal precedent for action in
this area has been established. 17
PTI is not an area in which it is immediately
obvious that the EU is a more efficient level of government than Member States,
and we assume that consensus would be needed before significant changes are
brought into effect, particularly if changes were to require any major
additional costs. This is taken into account in analysis of policy options. 18
With regard to roadside testing, it is hard to
see any requirement for action at EU level. The damage done by inadequate
roadside tests falls on the road users in the Member State concerned; there is
hardly any implication for other parts of the EU.[1] Nor is it necessary for similar approaches to be taken in
different Member States; apart from facilitating statistical comparisons, harmonisation
in itself would not deliver concrete advantages.
1.1.8.
Policy objectives
19
The general policy objectives are to: (a)
improve the systems of PTI and roadside testing in
order to reduce the number and severity of road accidents; (b)
reduce the costs and administrative burden for
people and businesses wishing to have their vehicles tested in different
countries, and facilitate other improvements in the operation of the EU single
market. 20
More specific objectives are to: (a)
reduce the proportion of vehicles which are not
compliant; (b)
make it easier for vehicles to be tested
wherever is most convenient; (c)
increase recognition of tests undertaken in
other Member States; (d)
increase the scope for vehicle-testing stations
to offer services to vehicles registered in other Member States; (e)
make it easier for those carrying out PTIs and
roadside tests to have reliable information on the vehicle; and to (f)
support consumer protection in the second-hand
vehicle market including milometer readings.
1.1.9.
Policy Options
1.1.9.1. Option 1: Continuation of
present policies 21
Option 1 provides the counterfactual case
against which the effects of other policy options are to be compared. The case
for a new policy intervention needs to be established. 1.1.9.2. Option 1a: No new
legislation, but enhanced implementation and enforcement 22
There would be increased effort by the
Commission to improve the standards of testing and to increase the advantages
for citizens and EU businesses of the single market. This would involve
increased use of some or all of the following: (a)
peer reviews and screening (European Commission
(EC)); (b)
exploration of optimal levels of investment in
PTI and roadside testing (EC, Member States (MS)); (c)
exploration of the scope for risk-based testing
regimes (EC, MS); (d)
PR campaigns focusing on the actions that
vehicle owners should be taking (EC, MS); (e)
enhancement of roadside inspections and testing
supervision (MS); (f)
voluntary action by vehicle manufacturers
(manufacturers); (g)
the Commission services could prepare to
institute infractions proceedings if required (EC). 1.1.9.3. Option 2: Encourage
bilateral agreements and better implementation 23
Under this option, in addition to better
implementation of the present law as in Option 1a, Member States would be
encouraged to seek bilateral or multilateral agreements for the mutual
recognition of tests done in either country. 24
As with Option 1a, no new legislation would be
needed to pursue Option 2. 1.1.9.4. Option 3: Mandatory mutual
recognition throughout the EU 25
This option would introduce new legislation to
require each Member State to recognise the validity of vehicle testing carried
out in any other Member State. This would mean that: (a)
any vehicle could be inspected in any Member
State; (b)
Member States would be obliged to recognise the
certificates issued by other Member States as equivalent to theirs (with no
additional requirements or conditions). 26
However, the frequency of the PTI in the Member
State of registration would have to be respected. 27
There would be a need to define the information
exchange standards required for mandatory mutual recognition and minimum data
visibility, and perhaps to provide infrastructure to facilitate data
exchange. 1.1.9.5. Option 4: Impose a mandatory
standard EU-wide system for PTI and roadside testing 28
Under Option 4, in addition to requiring mutual
recognition new legislation would prescribe the minimum standard of testing to
be required. Thus PTI and roadside testing requirements would include details
of: (a)
items to be inspected and inspection method; (b)
definition of defects and assessment of result
of test; (c)
equipment to be used; (d)
skills or training of staff; (e)
vehicle classes to be inspected; (f)
frequencies of PTI;[2] (g)
the system for supervision and enforcement; and (h)
the system for information exchange. 29
Member States would be permitted to apply tests
that were above the minimum standards, but could not require the same from
other Member States whose certificates they would be obliged to recognise.
Thus Option 4 would include mutual recognition as in Option 3, but also require
more standardisation of testing methods. 30
Three different possible levels of PTI testing were
outlined by DEKRA for the purposes of this impact assessment: –
Option 4a: Least rigorous –
Option 4b: Medium level –
Option 4c: High level.
1.1.10.
Analysis and comparison of impacts
1.1.10.1. PTI 31
Under Option 1 the system would continue to improve,
and more Member States may decide to implement bilateral agreements for mutual
recognition. However, the full potential single market benefits could not be
achieved, and scope for faster progress in reducing road accidents might be
missed. By definition, costs and benefits of Option 1 are zero. 32
Option 1a offers potentially very cost-effective
improvements. Improving road safety in a cost-effective manner is supported by
all concerned, and the scope for system improvements facilitated by the Commission
seems substantial; at little cost. However, there is no guarantee that single
market issues would be solved in this way. 33
Option 2 addresses the single market issues
directly, but on a partial basis. It is likely to be inexpensive; and to
reduce the scale of the single market issues while not offering a complete
solution. We see no reason not to pursue Option 2 as an increment to Option
1. 34
Option 3 is more problematic at this stage,
since although it would solve all single market issues it carries some risk of
lower road safety standards. However, the assessment of this option suggests
that it may be beneficial. 35
Option 4 would take the EU into new regulatory
territory, as the present legislation does not address all of the eight
“pillars” by which an ideal PTI system might be defined. Research suggests
that there is a case for increasing some of these standards, but in current
economic circumstances it would be important to be quite sure that the
additional costs would be justified for lower-income Member States in
particular. We have found no adequate research into the costs and benefits of most
of the “pillars” of an ideal testing system. 36
The options form a natural progression, in the
sense that by pursuing Options 1a and 2 more information would become
available, that might inform a decision on Options 3 (mutual recognition) and possibly
ultimately of 4 (imposition of more detailed technical standards at EU level). 1.1.10.2. Roadside testing 37
It is not necessary for the EU to specify
details of roadside testing systems, since these can safely be left for
decision by Member States. 1.1.10.3. Data 38
Under any option, it would be advantageous to
facilitate exchange of data between Member States (although not all of those
replying to the on-line consultation thought that this should be done).
1.1.11.
Annex: Data exchange system
39
The study specifically requested that the
current and potential use of data be reviewed, whilst the impact of setting up
both national and international databases and the interchange and sharing
potential of the data stored be investigated. The highlighted areas of
interest were: registration and roadworthiness testing-systems
and type-approval and chain of custody (COC) documentation systems. Most
focus was placed on the roadworthiness testing-systems as these were seen as
more relevant to the overall study. 40
Responses from the Member States were limited,
yet the evidence from the responses received was that roadworthiness testing
results are being stored within national databases - yet the type, method and
level of information held varies from state to state. 41
Many Member States are also introducing COC
document stores at the national level and are considering type-approval
registration systems. The best design for such a system is open to debate.
The value of moving to an international system (as opposed to a national system
of data-exchange) needs to be challenged as the majority of vehicles - and
therefore use for type approval and COC documentation - remain in the country
of first registration. There is also the variance of vehicle models across
Member States to consider. For those limited occasions where access to
out-of-country COC and type-approval information is required the use of a
data-exchange system is expected to be more effective (the costs of
setting up such a system and also data-exchange system costs are covered from
Appendix A4.62 onwards). 42
The study looked at the usage of data by various
stakeholders to confirm the most effective manner of data exchange, and whether
the focus on COC and type-approval systems is correct. However, input from
stakeholders and Member States was limited and showed that whilst the idea of
data sharing is sound there is little quantitative evidence supporting its use,
neither are there expectations for data volumes or timeframes for data
availability to meet user demand. 43
Finally this study shows that a differentiation
between strategic planning and operational support systems needs to be made in
order to provide a cost-effective design. A full explanation of these systems
is in Appendix 4: . 1 Introduction 1.2
This is the final report of Europe Economics’
input to the impact assessment which DG MOVE is to prepare, to consider policy
options to improve the working of systems of periodic testing of vehicles and
of roadside tests in the EU. 1.3
An impact assessment does not pre-judge the
final decision to be taken by the European Commission. 1.2. Political context 1.2.1.1. Road safety 1.4
The Commission has recently adopted a major
policy orientation towards transport policy and road safety in particular.[3] This states: In view of achieving the objective of
creating a common road safety area, the Commission proposes to continue with
the target of halving the overall number of road deaths in the European
Union by 2020 starting from 2010. Such a common target represents a
significant increase of the level of ambition compared to the unmet target of
the current RSAP [Road Safety Action Programme], considering the progress already achieved by several Member States
during the past decade, which will give a clear signal of Europe's commitment
towards road safety. 1.5
The Commission has adopted a Communication on
better use of communications technology. A key action
to promote interoperability between public administrations will be the
Commission's adoption of an ambitious European Interoperability Strategy and
the European Interoperability Framework to be drawn up under the ISA programme
(Interoperability Solutions for European Public Administrations). 1.2.1.2. Single Market 1.6
At the end of 2009, Former Commissioner Monti
was invited to write a report encouraging a renewed political determination
around the concepts of the EU’s single market and providing a fresh impetus for
policies to achieve it. It is hoped that his report will help to re-launch the
Single Market as a key strategic objective of Europe. 1.7
Continued development of the EU single market
has indeed always been one of the Commission’s most important long-term goals. 1.3. Economic context 1.8
The economic context in which DG MOVE is
formulating its policies is one in which many or even all of the EU Member
State Governments are seeking substantial reductions in public expenditure,
while also seeking to avoid any unnecessary burdens of cost on businesses and on
the personal sector. This situation is likely to continue for a long time, and
to require a significant reduction in the role of the state in many parts of
the economy. It is even more important than in more prosperous times that any
new regulations should bring benefits that clearly outweigh any additional
costs they would impose. 1.4. Legal framework 1.9
Before outlining the policy options to be
considered, we first summarise the present legal framework and describe the
aspects of Periodic Technical Inspections (PTI) and roadside testing to which
the policy options will relate. 1.10
The current legislation on roadworthiness and on
roadside testing is laid out in the following Directives: (a)
Directive 2000/30/EC – Roadside technical
checks; (b)
Directive 2009/40/EC – Roadworthiness directive; (c)
Directive 2010/47/EU – amending Directive
2000/30/EC; (d)
Directive 2010/48/EU – amending Directive
2009/40/EC. 1.11
In addition, the Commission has issued two
recommendations: (a)
Recommendation 2010/378/EU – Assessment of
defects during roadworthiness testing; (b)
Recommendation 2010/379/EU – Risk assessment of
deficiencies detected during technical roadside inspections (of commercial
vehicles).
1.1.12.
Directive 2000/30/EC (Roadside checks)
1.12
Directive 2000/30/EC was adopted in June 2000.
It required all Member States to introduce technical roadside inspections[4] designed to improve road safety
and the environment by ensuring that vehicles comply with certain technical
conditions. 1.13
These roadside inspections were required to
comprise at least a visual assessment of the maintenance condition of the
commercial vehicle (whilst stationary) or else a check on a recent document
attesting to the vehicle’s technical roadworthiness. The inspection may also
include a check for irregularities in one or more of the vehicle parts. 1.14
In addition to this, it was recommended that the
inspection should include an examination of the braking systems and exhaust
emissions of the vehicles. Specific conditions concerning the required testing
process for brakes and exhaust emissions are laid out in the Directive. 1.15
The Directive also includes a provision
requiring each Member State to collect data, communicated to the Commission
every two years, on the number of commercial vehicles checked, classified by
category and country of registration, and the items checked and defects noted.
1.1.13.
Directive 2009/40/EC (Periodic inspections of
vehicles)
1.16
Directive 2009/40/EC was adopted in May 2009,
recasting previous legislation (96/96/EC). It: (a)
requires that vehicles registered in each Member
State undergo periodic roadworthiness tests; (b)
defines in detailed Annexes the minimum
categories of vehicles to be tested, how frequently the tests must take place
(e.g. annually for lorries; once every two years for cars after four years in
service) and the items to be tested; (c)
requires that proof of having passed a test be
available; (d)
allows some exemptions (e.g. classic cars;
military vehicles); (e)
permits Member States the freedom to implement a
more stringent roadworthiness periodic testing regime than detailed in the
Directive; (f)
requires or allows the Commission to adopt
further Directives to lay down more specific rules regarding the minimum
standards to be used in tests.
1.1.14.
Directive 2010/47/EU (Roadside checks)
1.17
This new Directive amends the technical annexes
of Directive 2000/30/EC, aiming to improve technical roadside inspections in
the EU by adapting standards and methods in accordance with technological
progress. It re-affirms the importance of commercial vehicle maintenance and
inspection to ensure road safety, environmental protection and fair competition
when circulating within the EU. 1.18
The requirements for roadside inspections are focused
primarily on brakes and emissions. No selection criteria are given for
vehicles or targets for numbers of vehicles to be tested. 1.19
To enable correlations to be drawn between test
results, defects and the specific characteristics of each vehicle inspected, a
more detailed standardised inspection report is required by this new
legislation. 1.20
The inspection must also cover identification of
the vehicle in order to ensure that the correct inspections and standards are
applied, to enable the results of the inspection to be recorded and to assist
in the enforcement of other legal requirements.
1.1.15.
Directive 2010/48/EU (Periodic inspections of
vehicles)
1.21
Directive 2010/48/EU amends Directive 2009/40/EC
and seeks to achieve further harmonisation of road-worthiness testing by
introducing specified testing methods for each of the test items. 1.22
To facilitate further harmonisation and to help
to achieve greater consistency of standards, a non-exhaustive list of the main
reasons for failure (as already included for braking systems) was added for all
test items. 1.23
Specific requirements for particular vehicle
categories were added to move towards having roadworthiness tests cover all
items relevant to the specific design, construction and equipment of the tested
vehicle. 1.24
Member States have extended the periodic test
requirement pursuant to Article 5(e) of Directive 2009/40/EC to other
categories of vehicles. For the purpose of further harmonised testing, this
amendment also outlined testing methods and standards for these categories of
vehicles. 1.25
In addition to the items related to safety,
security and environmental protection, the requirements for the test cover
identification of the vehicle in order to ensure that the correct tests and
standards are applied, to enable the results of the test to be recorded and to
enable enforcement of other legal requirements. 1.26
The Directive requires that in order to facilitate
the functioning of the internal market, and to improve methods of
roadworthiness testing, the results of a test should be set out in a
roadworthiness certificate covering certain core elements.
1.1.16.
Recommendation 2010/379/EU (Roadside checks)
1.27
Commission Recommendation of 5 July 2010 deals
with certain issues, regarding the risk assessment of deficiencies detected
during technical roadside inspections (of commercial vehicles) in accordance
with Directive 2000/30/EC. 1.28
The Recommendation provides a guideline on
standards and testing methods for the assessment of deficiencies listed in
Annex II of Directive 2000/30/EC for inspectors conducting technical roadside
inspections, in order to achieve a more harmonised roadside testing system and
to avoid unequal treatment at technical roadside inspections.
1.1.17.
Recommendation 2010/378/EU (Periodic inspections
of vehicles)
1.29
Commission Recommendation of 5 July 2010
addresses certain issues regarding the assessment of defects during
roadworthiness testing in accordance with Directive 2009/40/EC. 1.30
The Recommendation provides a guideline on
standards and testing methods referred to in 2009/40/EC for inspectors
conducting vehicle tests in order to ensure a harmonised assessment of the
failures listed in Annex II of the Directive. The Recommendation is seen as a
step towards a uniform assessment of the deficiencies identified during
roadworthiness testing within the EU. 1.31
Three categories of failure are introduced, to
reflect the seriousness of the defect, with the consequences for the use of the
vehicle in that condition given as shown in the following table. Table Error! No text of specified style in
document..1: Categorisation of failures found during
periodic testing of vehicles Type of defect || Definition || Action Minor || Technical defects that have no significant effect on the safety of the vehicle and other minor non-compliances. || The vehicle does not necessarily have to be re-examined as it can reasonably be expected that the detected defects will be rectified without delay. Major || Defects that may prejudice the safety of the vehicle or put other road users at risk and other more significant non-compliances. || Further use of the vehicle on the road without repair of the detected defects is subject to conditions. The competent authorities in the Member States must adopt a procedure for setting the conditions under which the vehicle may be used before passing another roadworthiness test. Dangerous || Defects that constitute a direct and immediate risk to road safety. || The vehicle should not be used on the road under any circumstances. Note: A
vehicle having defects falling into more than one defect group is classified
according to the most serious defect. A vehicle showing several defects of the
same group can be classified in the next more serious group if their combined
effect makes the vehicle more dangerous. 1.5. General comment on legal framework 1.32
The EU legislation governing both roadside tests
and periodic testing of vehicles is very recent, and represents increasingly
detailed regulation. The legislation takes the form of Directives, binding on
Member States, rather than Regulations, directly binding on individuals and
businesses. 1.33
In some Member States, further law makes it an
offence for an individual or business to put a vehicle onto the roads in an
unsafe condition; and an offender would be liable both to punishment and to
find that his vehicle’s insurance policy was invalid. 1.34
Regarding commercial vehicle operations, in
order to be engaged in the occupation of road transport operator Regulation EC
No 1071/2009[5] requires that the operator be standing in good repute. A condition
of maintaining good repute is that (Chapter II, Article 6:1): (b) the transport manager or the transport
undertaking have not in one or more Member States been convicted of a serious
criminal offence or incurred a penalty for a serious infringement of Community
rules related in particular to: […] (iv) the
roadworthiness of commercial vehicles, including the compulsory technical
inspection of motor vehicles; 1.35
If a transport manager comes to lose their good
repute, their authorisation to engage in the occupation of road transport
operator is suspended or withdrawn. 2 Procedure 1.36
Research to formulate this impact assessment was
carried out by Europe Economics with the support of DEKRA and CENTIQ. Europe
Economics is responsible for the main analysis and conclusions drawn, which do
not commit either DEKRA or CENTIQ. Where evidence or judgements are provided
by the sub-contractors this is made clear in the text. 1.37
An experts’ workshop was held in Brussels on 31
August 2010, attended by 32 experts. Participants are listed in Appendix 1: ,
with a note of the discussion. 1.38
A stakeholders’ meeting was held in Brussels on
8 September 2010, attended by 30 stakeholders. Participants are listed in Appendix
2: , again with a note of the discussion. 1.39
A public on-line consultation was conducted
between 30 July and 24 September 2010, attracting 9,653 replies. A copy of the
questionnaire and of the tabulated main results is in Appendix 3. 1.40
In addition to the questionnaire responses, a
number of written contributions were also received from stakeholders. These
were submitted as attachments to on-line questionnaire responses or sent by
email to DG MOVE. 1.41
These consultations provided useful information
which is taken into account in this IA. The consultation processes are in line
with EC recommended practice (e.g. for the period during which the on-line
questionnaire was open). 3 Problem Definition 1.6. What is the problem that may require action? 1.42
It is normally regarded as good practice in
policy formation to clearly define a single problem, and then to analyse which
options might be best to help to solve it. However, in this case two related
issues are under consideration, linked by the fact that improvements to the
system of vehicle inspections might contribute to their solutions. 1.43
These issues are: (a)
Large numbers of accidents still occur on roads
of EU Member States, costing lives and injury, and causing other social,
economic and environmental damage. This remains the case despite significant
improvements in the design and standards of vehicles and vehicle testing and in
road management that have contributed to improvements in road safety. (b)
The full potential of the EU single market is
not being achieved, since: –
individuals wishing to use the right to move and
reside freely within the EU[6]
may face inconvenience and costs arising from differences in the systems of
vehicle registration and PTI testing; –
transport firms wishing to use the right to
freedom of trade within the EU may face inconvenience and costs arising from
differences in the systems of vehicle registration and PTI testing; and –
testing services are limited in the extent to
which they can compete for business from other Member States. This second issue might be regarded as an opportunity for
improvement rather than as a problem demanding a solution. 1.44
It is useful to note at this point that there
may be trade-offs between these objectives, so that under some scenarios
progress towards mutual recognition might imply some reduction in safety.
Other issues such as the desirability of reducing environmental pollution and
the administrative burden on businesses and individuals are also relevant. 1.7. What are the underlying causes of the problem? 1.7.1.1. Road safety 1.45
The causes of road accidents are primarily
mistakes by drivers, the consequences of which are exacerbated by road
conditions, bad weather and the like, but vehicle faults also contribute. For
example, 1.7 per cent of accidents in Germany in 2009 were attributed to faulty
brakes, and a significant proportion of vehicles subjected to roadside tests in
several Member States were found to have some faults. 1.46
Studies of crashed
vehicles have shown that defects contribute directly or substantially from
around 3 per cent to 19 per cent of accidents, with the more robust studies
indicating at least 6 per cent.[7]
Recent empirical evidence from Germany has shown that
technical defects are a contributory factor for around 10 per cent of accidents
as seen in the following figure. Figure Error! No text of specified style in
document..1: General causes of accidents involving
personal injury in Germany, 2009 Source: Federal Statistics Office,
Germany 1.47
Commercial vehicles cause disproportionately
high levels of accident deaths and injuries whilst breakdowns of commercial
vehicles are also a significant cause of traffic congestion.[8] 1.48
The age of a vehicle is
a significant factor. Twice as many vehicles which are eight years or older
are involved in accidents attributable to technical defects than newer
vehicles. Currently the average age of the vehicle fleet in the EU is 8.5
years.[9]
Analysis of results by the DEKRA Inspection Department
showed that, across all car age ranges, 24.9 per cent of cars involved in a
road accident were found to have serious faults, whereas only 11.3 per cent of
accident cars under three years old had any such faults.[10] Figure Error! No text of specified style in
document..2: Cars with faults discovered after road
accidents, relative incidence by vehicle age in years Source: DEKRA, Road Safety Report
2008: Strategies for preventing accidents on Europe’s roads 1.49
This chart takes the number of accidents
involving vehicles aged 0-3 years as 100, and shows accident rates for older
vehicles in relation to this. 1.50
Comparison of accident figures on the basis of
the distances travelled shows that older vehicles are involved in accidents
twice as often as newer vehicles. Older vehicles are responsible for more fatal
accidents than newer vehicles.[11] 1.51
In addition, although
the technical condition of a vehicle deteriorates with vehicle age in some cases
less money is spent on maintenance and repairs for older vehicles, and the
older the vehicle, the more often repairs are performed on a “do-it-yourself”
basis or with the assistance of private acquaintances; this applies equally to
accident repairs. 1.52
A comprehensive study
by the Monash University Accident Research Centre (Australia) under the title
“The effect of vehicle roadworthiness on crash incidence and severity” compares
the results of important studies.[12]
There was significant variation in the study findings regarding the role of
vehicle defects in accident causation, and the effectiveness of PTI programmes
in reducing defects and accidents related to vehicle age. Overall, the study
concludes that it would appear that vehicle defects are a contributing factor
in over six per cent of accidents. As evidence of the effects of PTI programmes
on vehicle defects and accidents in general, the prevalence of defects in the
vehicle fleet was found to be lower in jurisdictions with PTIs (by up to 16 per
cent). Comparisons of inspected cars and non-inspected cars in the same
jurisdictions suggested lower accident rates for the former. 1.53
Studies that have
compared accident rates before and after the introduction of PTIs have generally
shown decreases in injury accident rates. Rompe and Seul (1985)[13] noted that inspection programmes
may also influence and reduce accidents by increasing drivers’ understanding of
the need for regular maintenance, of safety issues and of the condition of
their own car. 1.54
Moreover, failure rates in PTI tests are high.
A study by the UK Government published in 2008 found that in the UK PTI test,
the ‘MOT’, about one third of vehicles tested failed, and that this proportion
had remained at about this level for some years. 1.55
The UK study mentioned above estimated that
about 10 per cent of cars on roads in Great Britain at any point in time have a
defect that would cause them to fail the MOT test.[14] It was concluded that if the
UK were to reduce the frequency with which vehicles are tested to the EU legal
requirement, the likely costs to the economy from additional accidents would
exceed the benefits to vehicle owners from not needing to have the tests done.
(The benefit to owners from not having to take the tests was measured as the
saving of the money spent on the tests and the value of time taken.) 1.56
Other countries also report high failure rates
in PTI tests. 1.57
Further evidence, if it is needed, that
significant numbers of unsafe vehicles are using roads in the EU comes from
roadside tests on commercial vehicles. These tests are carried out using
different techniques in different countries, so that one cannot draw
comparisons as to the absolute numbers of unsafe vehicles on a like-for-like
basis, but for our immediate purposes this is immaterial. Almost all of the
tests reported a significant number of vehicles failing the roadside tests. Table Error! No text of specified style in
document..2: Failure rates in roadside tests,
2007-2008 Reporting Member State || Vehicles checked || % Non-compliant vehicles^ Austria || 12,658 || 41.4 % Belgium || 18,732 || 13.3 % Bulgaria || 472,324 || 0.3 % Cyprus || 919 || 197.3 %^^ Czech Republic || 52,842 || n/a Germany || 2,679,907 || 2.3 % Denmark || 265 || 63.0 % Estonia || 2,236 || 19.2 % Finland || 9,267 || n/a France || 1,669,391 || 3.3 % Greece || 22,360 || 14.2 % Hungary || 351,690 || 6.5 % Ireland || 5,204 || n/a Italy || 13,577 || n/a Lithuania || n/a || n/a Luxembourg || 896 || 33.0 % Latvia || 9,294 || 0.5 % Malta || 3,579 || 55.2 % Netherlands || 4,147 || 2.8 % Poland || 1,254,706 || 0.6 % Portugal || 558 || 5.0 % Romania || 43,700 || 36.8 % Sweden || 165,263 || 20.0 % Slovenia || 3,179 || 3.8 % Slovakia || 4,631 || n/a United Kingdom || 165,927 || 48.9 % TOTAL || 6,967,252 ||
Source: EC, Report on the technical roadside inspection of the roadworthiness
of commercial vehicles ^ The percentage of non-compliant vehicles
can be more than 100 per cent due to the counting of vehicle combinations
"road train" and "articulated vehicles" as single vehicles
where both vehicles or the combination or only one of them could be counted as
a non-compliant vehicle. ^^ The figure of 197.3 per cent in
Cyprus is probably based on a different method of counting checks and
non-compliant vehicles. 1.58
Clearly, different countries took different
approaches in deciding how many vehicles to test. The lowest number of inspected
vehicles in a Member State was 265 in Denmark, followed by Portugal (558
vehicles) and (less surprisingly) Luxembourg (896 vehicles). In Germany,
France and Poland large numbers of vehicles were stopped (2,679,907, 1,669,391
and 1,254,706, respectively) but a relatively small percentage were found
defective. In the UK, Sweden, Luxembourg and Austria, smaller numbers were
stopped, presumably due to more stringently selecting those vehicles which
looked likely to have problems and a higher percentage was therefore found
defective. 1.59
Recital 10 of Directive 2000/30/EC requires that
roadside inspections in each Member State utilise a targeted approach in their
selection of vehicles. This is because the direct benefit to road safety of
undertaking roadside inspections is related to the number of vehicles inspected
which are detected as non-compliant, rather than the total volume of vehicles
inspected. Targeting helps to maximise the number of non-compliant vehicles
detected for a given budget, but also means that the statistics derived from
results of roadside tests are not representative of the vehicle fleet in each
Member State as a whole. It thereby reduces the comparability of roadside
testing results between Member States, decreasing the value of these data in
comparing the quality of PTIs in each country. 1.60
The share of non-compliant vehicles out of the
inspected vehicles in a Member State ranged from 0.3 per cent in Bulgaria to 63
per cent in Denmark. For 8 out of the 20 Member States where compliance rates
were reported, the rate of non-compliant commercial vehicles was less than 5
per cent, whereas for 7 countries the rate reported was higher than 30 per
cent. 1.61
In 11 Member States more than 90 per cent of all
inspected vehicles were registered in the Member State.[15] It is clear that in Cyprus or
Malta very few foreign commercial vehicles can be found, but this result is
perhaps surprising for countries like Poland or Denmark, where a significant
number of foreign commercial vehicles are expected to be using the roads. 1.62
Differences are found in the inspection results
of vehicles registered in the reporting Member State and the results of
vehicles from other EU Member States. For example, in the UK, 38 per cent of
locally registered vehicles were found non-compliant at roadside checks,
whereas 80 per cent of vehicles registered in another Member State were found
non-compliant. In contrast, Belgium found 19 per cent of vehicles locally
registered to be non-compliant and a lower percentage of only 10 percent of
vehicles registered elsewhere in the EU were found non-compliant. 1.63
The picture of the 2007-2008 roadside inspection
(RSI) results is very similar to that of the previous results from 2003-2004.
In most cases the failure rates fell between 2003 and 2007 (Denmark -9.1 per
cent, Sweden -26.9 per cent, Hungary -3.9 per cent etc.) but in some Member
States the rate increased in the newer results (UK +12 per cent, Luxembourg +23
per cent). 1.64
Bearing in mind the different approaches to
technical roadside inspections, the most commonly detected deficiencies in
roadside tests were lamps, lighting or signalling devices (30 per cent)
followed by braking system and components (21 per cent) and wheels / tyres (20
per cent). Deficiencies in other areas[16]
were discovered at a much smaller rate.[17] 1.65
We can take it as a firm finding that, despite
present EU and national legislation, and despite the natural wish of motorists
to be safe, significant numbers of vehicles on EU roads are defective by the
standards of the tests. 1.66
It is in theory possible that the standards of
the tests are too high and that a ‘failure’ might not be an important matter
(for example, hypothetically a Member State could increase the tread required
on tyres to a higher level than is really needed, so that a failure to meet the
standard would not be an immediately urgent matter; or there may be other minor
reasons for failing the test that could reasonably have been left to the
vehicle owner to deal with without a regulatory requirement to do so).
However, the consensus among those we have been able to consult (admittedly,
apart from the large number of individuals responding to the on-line
questionnaire, these have mainly been people and organisations professionally
involved in testing or in road haulage as a business) is that the tests are not
too rigorous, but if anything too undemanding. 1.67
What then are the underlying reasons why so many
vehicles are apparently unsafe to drive, and yet are on the roads? A
fundamental point is that part of the cost of accidents falls on people other
than the driver or owner, so that in the absence of regulation one would expect
a sub-optimal level of safety. For this reason, regulation to require
satisfactory safety standards is justified. This also explains why it is
appropriate that buses and taxis should be tested more frequently than
passenger cars; and why a lower rate of testing is used for motor cycles; and
none for pushbikes. 1.68
Vehicles are sometimes defective as a result of
faulty design or mistakes in the manufacturing process. Such errors occur occasionally,
and lead to vehicle recall programmes, but this cannot fully explain the
general phenomenon of unsafe vehicles. Defects can sometimes be explained
instead by vehicle owners not maintaining their vehicle properly. This is due
to the usual human failings of laziness, ignorance and so on, as well as a wish
or need to avoid expense where possible. 1.69
The PTI regulations and roadside inspections are
intended to improve standards compared with those that motorist and fleet
owners would maintain without regulation. This implies that another possible
cause of avoidable road accidents is inefficient PTI or roadside inspection. 1.70
PTI is a government requirement, rather than a
voluntary choice for individuals, and therefore some consumers of PTIs are
likely to aim just to pass the test, as inexpensively as possible. In
addition, repair shops can ignore mechanical defects in order to minimise
customer hassle or to pocket more inspection fees by increasing the number of
inspections performed. On the other hand, repair shops in Member States where
both PTIs and subsequent repairs can be performed at the same garage might like
to find more faults than there really are, to increase the amount of repair
work needed. Hemenway (1989)[18]
found evidence that some drivers actively seek out repair shops that perform
fraudulent inspections. This has implications for the design of policy, e.g.
towards methods of enforcement. 1.71
Governments will have attempted to take into
account this possible misalignment of incentives (between themselves, vehicle
owners and garages / workshops) in the design of their PTI systems and of their
enforcement. The design of an optimal system of testing is not an easy or
straightforward matter, but something on which experts may reasonably disagree;
however, there appears to be no reason why the public authorities - national
governments or regional administrations[19]
- responsible for the design, supervision and enforcement of such regulations
should not wish to do so effectively.[20] 1.72
As an example, the optimal level of technical
inspections is likely to depend on the income per head in the individual Member
State, as this will impact on the costs involved if an accident occurs. We see
that there is currently a clear correlation between the quality of PTIs in EU
Member States and the income per head, as one would expect. Figure Error! No text of specified style in
document..3: Differences in income per head in Member States
with differing PTI standards Source: Eurostat – Euro per inhabitant and
population, Europe Economics categorisation of countries into PTI quality
groups Trend line shows weighted average Euro per
inhabitant for each PTI quality group. All values are for 2009 except for
Bulgaria, Belgium, and the UK where 2008 values were used and Romania where
2007 values were used. 1.73
In general, the reported government expenditure
on national road safety strategies varies greatly in Europe. In all cases (since
no amount of expenditure could prevent all crashes) the expenditure by Member
States is considerably less than the costs incurred from road crashes. Table Error! No text of specified style in
document..3: Expenditure on implementing national
strategies on road safety versus the costs of road crashes, 2008 || Expenditure on national strategy per person (€) || Cost of road crashes per person (€) France || 38 || 194 Poland || 17 || 148 Estonia || 12 || 113 Latvia || 3 || 87 Source: WHO European status report on road
safety Note: These calculations are based on
the gross output method. The cost components can be divided into the costs of
resources consumed because of a crash (property damage costs, health care costs
and administrative costs) and costs resulting from a loss of future output
(absence from work, long-term disability or death). 1.7.1.2. Single Market 1.74
Turning from road safety to the Single Market
issues, the causes of the costs and inconvenience for EU businesses and citizens
resulting from absence of a standardised system throughout the EU are
historical. The EU is gradually reducing national differences; the present
situation can be described either as an improved access of MS citizens to the
services of other MS compared with the previous situation, or as a continuing
limitation on citizens’ access to the full services of MS other than his or her
own (the glass is half full or half empty). 1.75
Currently citizens are still sometimes reluctant
to purchase a motor vehicle from another Member State due to the fear that this
would require additional paperwork and extra costs. The transfer of motor
vehicles is still a source of complaints, in particular due to burdensome
type-approval registration procedures.[21] 1.76
The current registration requirements for cars
are the natural corollary of the exercise of the powers of taxation by Member
States in the area of motor vehicles. People with residence in a Member State
need to have any vehicle they are using on the roads in that Member State
registered there. When people move residency between two Member States, EU
legislation requires that any vehicle must be re-registered in the new Member
State after 185 days of residency there.[22]
Current national legislation of Member States provides for (a maximum of) three
different steps for registering a motor vehicle in the receiving Member State: –
the approval of the technical characteristics of
the motor vehicle; –
roadworthiness testing of used vehicles; and –
the registration of the motor vehicle. 1.77
Recent work by the European Commission has
helped to reduce the burden of applying for registration of a vehicle in a new
Member State. For instance, EC type approval regulations[23] have established mutually
recognised type approvals for most vehicles in the EU, making the approval of
the technical characteristics of the motor vehicle straightforward in the
majority of cases. In addition, recent ECJ judgments[24] have reduced the scope for
Member States to request an additional roadworthiness test for used vehicles
from another Member State before registration. However, it is thought that
some barriers to the registration of used vehicles in a different Member State
persist. 1.78
Temporary use of a vehicle in another Member
State is allowed without paying taxes in that country. Temporary use is
generally defined as less than 6 months in any 12 months in this case. The
group of people most likely to wish to store a vehicle in another Member State
and to be using it less than 6 months in any year are long-term tourists – e.g.
those with a holiday home in a foreign Member State, who therefore intend to
return to the same destination over a period of many years and may leave a car
there permanently. These people may choose to keep their vehicle registered in
their resident MS rather than the MS in which the vehicle is located if this
means they save money in insurance premiums, or to avoid any practical difficulties
involved in registering the vehicle in the holiday location.[25] In such cases, a demand is
created for the mutual recognition of PTIs or PTI results, as these vehicles
would most efficiently undertake their PTI in the location they are kept,
rather than the country in which they are registered. Without mutual
recognition of PTIs the vehicle owners are either required to drive the vehicle
back to their resident country in order to undertake a PTI, or incur the costs
of changing the vehicle’s registration (which might, however, not be an
unreasonable cost in these circumstances). 1.79
Commercial vehicles - and particularly trailers
- are more likely to experience costs from the lack of a single EU market for
PTIs, due to the higher frequency at which these vehicles will find themselves
away from their country of registration due to undertaking long distance
haulage.[26]
As noted above, there is no obvious reason why Member States should not seek
the PTI and roadside-testing systems that they believe are optimal for their
circumstances.[27]
The current differences may therefore be attributed to different historical
developments, differences in the affordability of alternative systems of
testing, and different views taken by Member State regulators on the
cost-effectiveness of different aspects of the tests. Whatever the reasons for
the differences, in the absence of mutual recognition of PTIs some additional
journeys may be required. 1.8. Who is affected and in what
ways? 1.80
Those affected include: (a)
all road users; (b)
vehicle owners, private and commercial; (c)
vehicle manufacturers, distributors, and repair
shops and garage equipment producers; (d)
vehicle testers; (e)
insurers; (f)
regulatory authorities, including the police; (g)
all concerned with environmental issues. 1.81
All are affected by the costs of accidents, and
all might benefit to some extent from a more effective EU internal market and
better use of modern communications technology. 1.9. How would the problem evolve
if present policies are maintained?
1.1.18.
Road safety
1.82
There is a significantly improving trend in road
safety, due to improvements in vehicle design and other factors,[28] and there is no reason to
doubt that a similar trend would continue. There would, however, still be
significant numbers of accidents, and the potential for more efficient
operation of the EU single market would continue to be under-exploited. Figure Error! No text of specified style in
document..4: EU road accident fatalities, 1991-2009 Source: CARE (EU road accidents
database) and national data. *2009 figure is a provisional estimate. 1.83
We see no reason to expect a significant
divergence from this trend if present policies (which include continued work by
the Commission through comitology to improve the system of testing, and other
initiatives foreshadowed in the Commission’s Policy Orientation) continue.
Substantial action has been undertaken in the last ten years under the EU’s
road safety action programme 2001-2010; and many new measures are currently
envisaged in the EC white paper for the period up to 2020, including improving
driver education and increasing enforcement of road rules as well as working
towards environmental targets. Vehicle designs are being continually improved,
and on-board diagnostic equipment is becoming cheaper and more widely used.
All of these effects will be part of the forecast on unchanged policies for PTI
and roadside testing. 1.84
An example of an initiative related to road
safety that is already proposed for the period 2010-2020 is the introduction of
mandatory fitting of tyre-pressure monitoring systems. The fitting of automatic
warning systems for tyre pressure in new cars has been mandatory in the United
States since 2008. While the fitment of tyre pressure monitoring systems is
currently included as a recommendation in EU legislation, this is expected to
change starting from 2012, when new EU Regulation requiring the mandatory
fitting of tyre pressure monitoring systems in all new models is planned to be
introduced, followed by the mandatory fitting of this equipment in all new
vehicles by 2014.[29] 1.85
Keeping tyres at the correct pressure has
positive impacts on the environment, fuel consumption and tyre wear, in
addition to the safety benefits of reducing road accidents through giving
vehicles a better grip on the road. In the US, the introduction of mandatory
automatic tyre-pressure warning systems was calculated to be expected to cause
a reduction in road deaths of 0.8 per cent. Based on the number of road deaths
in 2008 in the EU of 38,875,[30]
a 0.8 per cent reduction in deaths would amount to 311 fewer fatalities. 1.86
One estimate of the future evolution of road
fatalities and injuries in the period 2011-2010 has been constructed as part of
the European Road Safety Action Program (ERSAP).[31] A log linear future trend was
chosen (meaning a constant percentage change each year) on the grounds that the
higher the level of safety on the roads the more difficult to further decrease
the number of injuries and fatalities. Two scenarios were calculated based on
different assumptions about current and future road safety measures. The
optimistic scenario assumes that both current safety measures, introduced in
1995-2008, and new safety measures, introduced in 2008-2020, will have a
positive impact on road safety in the period 2010-2020. The pessimistic
scenario assumes that the effect of current measures fades away and so these
measures will not have any further impact on road safety in 2010-2020. Table Error! No text of specified style in
document..4: Log linear extrapolation of recent trends
in road safety || ERSAP Pessimistic scenario || ERSAP Optimistic scenario 2020 || % reduction from estimated 2010 level || 2020 || % reduction from estimated 2010 level Fatalities || 26,948 || -23% || 22,048 || -37% Injuries || 1,459,205 || -9% || 1,395,064 || -13% Source:
Summary of the ERSAP scenario as provided by DG MOVE 1.87
This suggests that, by 2020, if the log linear trend
in fatalities is assumed, total EU road deaths will have dropped by 23 to 37
per cent, down to between 22,000 and 27,000 a year. Injuries will also have
seen a decline, although on a smaller scale: down by around 10 per cent. 1.88
However, a log linear trend may not be the most
appropriate model in this instance. A number of Member States in the EU still
have low levels of road safety and therefore there are potentially significant
opportunities for fatalities to still decrease in certain regions. In
addition, analysis of the historic data on road fatalities, as available for
the years 1991-2008[32]
shows that a linear trend fits the data better than a log linear trend.[33] 1.89
Therefore, for robustness, we also estimated the
likely evolution of road accidents under the assumption of a linear trend. We
used a simple linear regression, without adjustments for the projected increase
in mobility or providing for the possibility that the effects of RSAP
(2003-2010) are not durable, as taken into account in the ERSAP scenarios.
Pessimistic, middle and optimistic estimates of the predicted future accident
levels under a linear trend were constructed using the best estimate and the 95
per cent confidence interval for the gradient of the slope. Table Error! No text of specified style in
document..5: Linear extrapolation of recent trends in
road safety || Pessimistic scenario || Middle scenario || Optimistic scenario 2020 || % reduction from estimated 2010 level || 2020 || % reduction from estimated 2010 level || 2020 || % reduction from estimated 2010 level Fatalities || 18,641 || -47% || 16,628 || -53% || 14,615 || -58% Injuries || 1,597,368 || -2% || 1,501,130 || -7% || 1,404,891 || -12% Accidents || 1,186,843 || -3% || 1,126,724 || -7% || 1,066,605 || -11% 1.90
If this linear trend in fatalities is assumed we
would therefore expect to see road deaths fall by around 1,900 deaths a year,
road injuries by 11,000 a year, and road accidents by 9,000 a year. This
suggests that, by 2020, total EU road deaths will have dropped by 47 to 58 per
cent, down to between 15,000 and 19,000 a year. The decline in injuries and
accidents would be on a smaller scale, each down by around 7 per cent. 1.91
The choice of forecast used has a large impact
on the conclusion to be made regarding whether or not the Commission will need
to enact additional legislation in order to meet their aim of halving the
overall number of road deaths in the EU by 2020, starting from 2010. If the
log linear model of the trend is to be believed then the conclusion is that the
Commission’s target will not be easily met, even under the optimistic ERSAP
scenario. Conversely, if the linear model is believed to more accurately
reflect the likely future trend in fatal accidents then - if this trend rate of
decline of fatal accidents is able to be achieved purely through the
continuation of present policies - the Commission’s aim would be met without
the requirement for any additional legislation or other new policy initiatives. 1.92
Taking the two forecasts above into
consideration, we can provide a cautious estimate of the likely scale of the
reduction in road fatalities between 2010 and 2020 as lying between 23 and 58
per cent. 1.93
Recent incentives by different Member States to
encourage citizens to purchase new cars and scrap old cars will have
temporarily accelerated the improvement in the average safety of the EU vehicle
fleet, so a steep reduction in the number of accidents may be witnessed early
on in the period 2010-2020. This expected reduction is not reflected in either
of the forecasts as given above. 1.94
The fact that the forecast shows that the target
of halving the overall number of road deaths may be met without any new
legislation does not of course affect the need for the Commission to consider
whether new legislation would be beneficial; it simply affects the size of the
problem to be addressed, which is not meeting a particular target but of
improving the welfare of citizens. It should be added that the aim of
“halving” was probably chosen for political effect rather than as a result of
any close calculation of what would be feasible, or optimal. Furthermore, the
Commission should also consider that under the extrapolations as presented in
Table 3.3 and Table 3.4 above, there would still be between 900 and 1,600 deaths
and around 84,000 to 96,000 injuries in 2020 to which a technical fault in the
vehicle had contributed.[34] 1.95
Also, fatal accidents only consist of a small
percentage of the total number of accidents. Based on the estimates above the
number of accidents with injuries will only see a very small reduction in the
next ten years.[35]
In addition, although there has been an overall decline in the number of road
fatalities, the same trend has not been seen for all vehicle categories, in
particular for motorbikes. Figure Error! No text of specified style in
document..5: Change in number of road fatalities by
vehicle type (1997=100) Source: DEKRA (2010) “Verkehrssicherheitsreport Motorrad 2010: Strategien zur
Unfallvermeidung auf den Strassen Europas”
1.1.19.
Single market issues
1.96
As EU integration proceeds, more people may wish
to move from one country to another; or to have holiday homes in other Member
States, leaving their cars there; and it may also be assumed that road
transport undertakings will increasingly be operated on a pan-EU basis. 1.97
Several Member States or involved organisations
(with permission from the Member State government but with no direct involvement
of the relevant Member State department) have reached agreements with others
for the bilateral recognition of their PTI results. We would expect a larger
number of testing stations to start implementing similar agreements in the
future, for pairings where this is cost-effective. These agreements would
alleviate some of the single market issues outlined above. 1.98
Recent decisions by the ECJ (in 2007 and 2008)
will also help to alleviate the single market problems identified above and
reinforce the move towards a single market. The 2007 decision[36] held that the Netherlands had
failed to fulfil its obligations under Articles 28 EC (free movement of goods)
and 30 EC (proof that the national provision is proportionate to the objective
pursued) by requiring vehicles which are more than three years old and which
have previously been registered in other Member States to undergo testing as to
their general condition prior to registration in the Netherlands. The ECJ
noted that, although road safety and the protection of the environment do
constitute overriding reasons in the public interest capable of justifying a
hindrance to the free movement of goods, the requirement for cars to undergo
testing before registration was unnecessary as a similar result could be achieved
by less restrictive measures.[37]
Similarly, the 2008 decision[38]
held that Poland had failed to fulfil its obligations under Article 28 EC (free
movement of goods) by subjecting imported second-hand vehicles registered in
other Member States to a roadworthiness test prior to their registration in
Poland, whereas domestic vehicles with the same characteristics were not
subject to such a requirement. 1.10. Does the EU have the right to act and is there evidence
of EU added value? 1.99
Here we need to consider any fundamental rights
issues, the Treaty base, and the ‘necessity test’ (subsidiarity). 1.100
We see no fundamental rights issues in this
area. 1.101
The EU has recently passed legislation
controlling both PTI and roadside testing, so the legal precedent for action in
this area has been established. 1.102
The Treaty requires the Commission to seek the
right balance between legislation at EU and at national level (subsidiarity). 1.103
PTI is not an area in which it is immediately
obvious that the EU is a more efficient level of government than Member States,
and we assume that a significant measure of consensus would be needed before
significant changes are brought into effect, particularly if changes were to
require any major additional costs. This is taken into account in analysis of
policy options. This approach would also help to ensure that action is only
taken where “EU value added” is evident. 1.104
With regard to roadside testing as a method of
directly increasing road safety, it is hard to see any requirement for action
at the EU level action. The damage done by inadequate roadside tests falls on
the road users in the Member State concerned; there is hardly any implication
for other parts of the EU.[39]
Nor is it necessary for similar approaches to be taken in different Member States;
apart from making statistical comparisons more easily, therefore helping to
inform EU policy, harmonisation in itself would not deliver concrete
advantages. 4 Objectives 1.11. What are the general policy
objectives? 1.105
The general policy objectives are to: (a)
improve the systems of PTI and roadside testing
so as to contribute, with other policies, to a cost-effective reduction in the
number and severity of road accidents and adverse effects of road vehicles on
the environment; (b)
reduce the costs and administrative burden for
people and businesses wishing to have their vehicles tested in different
countries, and facilitate other improvements in the operation of the EU single
market. 1.106
These objectives would both be achieved if a
system of mutual recognition of PTIs was able to improve the efficiency of the
single market while also increasing road safety, reducing the environmental
disbenefits of road transport, increasing the provision of information wherever
necessary and reducing administrative burdens. However, it is recognised that
some of these objectives may conflict, in which case the guiding principle
should be to select the policies that would do most to enhance EU citizens’
welfare. 1.12. What are the more
specific/operational objectives? 1.107
The specific/operational objectives, in SMART
terms as recommended in the IA guidelines, include the following. The time
frame for each should be within the period to 2020, in line with the strategy
document targets mentioned earlier. All are Specific; Measurable; Achievable,
Relevant and Time-framed: (a)
to reduce the proportion of vehicles which are
not compliant and therefore present a risk to other road users and to the
environment, as measured by the number of vehicles which fail roadside tests; (b)
to make it easier for people wishing to use the
right to move freely within the EU and for firms operating international road
transport businesses to have their vehicles tested wherever is most convenient; (c)
to make it easier for people wishing to use the
right to reside freely within the territory of the Member States to have
previous tests in other MS recognised; (d)
to increase the scope for vehicle testing
stations to offer services to vehicles registered in other Member States,
provided that this does not lead to an unjustifiable reduction in standards; (e)
to make it easier for those carrying out PTIs
and roadside tests to have reliable information on the vehicle components (e.g.
specifications related to the equipment), including information on any
modifications made since the vehicle was first produced (this objective would
require improved data exchange); (f)
to support consumer protection in the second-hand
vehicle market taking into account the vehicle history, including milometer
readings. 5 Policy
Options 1.13. Definition of policy options
1.1.20.
5 E’s approach
1.108
To reduce road accidents researchers sometimes
refer to the “5 E’s approach”. [40]
These stand for: –
Education:
targets the road user and tries to change the attitudes and behaviour of
individuals through various forms of communication; –
Encouragement:
sometimes intertwined with education and can include some form of incentive
programmes; –
Enforcement:
legal actions such as traffic enforcement; –
Engineering:
measures taken to improve transport infrastructure; and –
Evaluation:
assesses if the strategy used was successful or not. 1.109
To achieve greatest effect the 5 E’s should be
used in combination. The policy options considered do aim to use elements of
each of these approaches.
1.1.21.
Eight pillars of PTI and roadside testing
1.110
Eight factors that affect the success of PTI and
roadside testing are: 1.
items to be inspected and inspection method
(these aspects can be amended through EU comitology proceedings); 2.
definition of defects and assessment of result
of test; 3.
equipment to be used; 4.
skills and application of staff; 5.
vehicle classes to be inspected; 6.
frequency of testing;[41] 7.
supervision of the testers and enforcement of
the system; and 8.
data / information exchange. 1.111
We refer to these as eight “pillars” on which an
ideal testing system would have to rest; or as eight features that would need
to be present in any effective system. 1.112
The following policy options are considered.
They are intended to be broadly incremental; so that Option 2 would follow
naturally from Option 1, Option 3 from Option 2, and so on. They may thus
provide a sense of direction, or a path on which policy might develop.
However, as the Options are developing along two dimensions (road safety and
single market), the exact ordering of the implementation of some aspects of
Option 4 (road safety) and Option 3 (single market), and similarly Option 2
(single market) and Option 1a (road safety), contains some flexibility; and
from some perspectives Option 4 (standardisation) might seem a natural
precursor to Option 3 (mutual recognition). The development of policy in
incremental steps has the advantage of allowing the best use by policy makers
of information which becomes available along the way – directing the end
solution to its most optimal position. 1.113
The main options considered are:
1.1.22.
Option 1: Continuation
of present policies
1.114
Option 1 provides the counterfactual case
against which the effects of other policy options are to be compared. It is
included in any impact assessment for this reason, and also as a partial check
against any tendencies towards over-regulation; the case for a new policy
intervention needs to be established. 1.115
Option 1 would maintain the present legal
framework for PTIs, roadside inspections and on the exchange of information, as
summarised in Section 1 above, and include established policies for its
evolution. 1.116
This option does not therefore imply freezing
present arrangements. Present policies include the use of comitology
proceedings to keep the system up–to-date, and any continued improvements by
Member States and others involved to the cost-effectiveness of the system. We
have already noted that EU Member States are currently engaged in seeking
greater efficiency from public sector activities; the increasing provision of
on-board diagnostic devices (OBD) by vehicle manufacturers is another example
of change likely to continue under existing policies. 1.117
It should also be noted that under present EC legislation
only the first “pillar” (the items to be inspected and the inspection method)
can be altered through comitology. Changes in other aspects of PTI and
roadside testing would remain largely at the initiative or discretion of
national governments and others involved.
1.1.23.
Option 1a: No new legislation, but enhanced
implementation and enforcement
1.118
This option would not introduce any new
legislation, but there would be increased effort by the Commission to improve
the standards of testing and to increase the advantages for citizens and EU
businesses of the single market. 1.119
Such increased activity would include the
screening of existing systems and the evaluation of strategies to overcome
their limits (e.g. encouraging better implementation and enforcement). 1.120
In particular, Option 1a would involve increased
use of some or all of the following: (a)
peer reviews and screening (EC); (b)
exploration of optimal levels of investment in
PTI and roadside testing (EC, MS); (c)
exploration of the scope for risk-based testing
regimes (e.g. taking account of warranty lives; taking account of mileage
covered as well as time passed; taking account of whether a vehicle has been
involved in an accident) (EC, MS); (d)
exploration of the scope for other measures to
help motorists to decide when vehicles should be tested (e.g. including
enforcement of legal responsibilities of the individual in some MS). These
might include PR campaigns focusing on the actions that vehicle owners should
be taking (EC, MS); (e)
Member State led enhancement of roadside
inspections and testing supervision (MS); (f)
voluntary action by vehicle manufacturers
(manufacturers) (g)
the Commission services could prepare to
institute infractions proceedings if required (EC).
1.1.24.
Option 2: Encourage bilateral agreements and
better implementation
1.121
Under this option, in addition to better
implementation of the present law as in Option 1a, Member States would be
encouraged to seek bilateral or multilateral agreements for the mutual
recognition of tests done in either country. 1.122
This option would involve the use of some or all
of the following: (a)
an EC guidance document; (b)
best practice exchange; (c)
information exchange (to reduce any risk of
fraud and to minimise the administrative burden data will need to be exchanged
e.g. information confirming that a vehicle has passed a PTI. Information exchange techniques could vary across Member States). 1.123
The Commission would be responsible for
facilitating these three actions, but decisions would be made by the Member
States. 1.124
As with Option 1a, no new legislation would be
needed to pursue Option 2.
1.1.25.
Option 3: Mandatory mutual recognition
throughout the EU
1.125
This option would introduce new legislation to
require each Member State to recognise the validity of vehicle testing carried
out in any other Member State. This would mean that: (a)
any vehicle could be inspected in any Member State; (b)
Member States would be obliged to recognise the
certificates issued by other Member States as equivalent to theirs (with no
additional requirements or conditions). 1.126
However, the frequency of the PTI in the Member
State of registration would have to be respected. 1.127
Option 3 might be politically feasible only if
the standards of testing in every Member State were acceptable to every other
Member State (although in theory it could be imposed through majority voting).
However, above such a minimum standard, there would be no requirement to make
the methods of testing the same. This would therefore follow the precedent in
other sectors, where mutual recognition does not depend on full standardisation
of methods. There is at present no evidence on whether or not Member States
would find mutual recognition based on present standards to be acceptable; this
is something the Commission would need to explore. 1.128
There would be a need to define the information
exchange standards required for mandatory mutual recognition and minimum data
visibility, and perhaps to provide infrastructure to facilitate data
exchange.
1.1.26.
Option 4: Impose a mandatory standard EU-wide
system for PTI and roadside testing
1.129
Under Option 4, in addition to requiring mutual
recognition new legislation would prescribe the minimum standard of testing to
be required. This could involve legislation to control all of the eight
‘pillars’ described above. 1.130
Thus PTI and roadside testing requirements would
include details of: (a)
items to be inspected and inspection method; (b)
definition of defects and assessment of result
of test; (c)
equipment to be used; (d)
skills or training of staff; (e)
vehicle classes to be inspected; (f)
frequencies of PTI;[42] (g)
the system for supervision and enforcement; and (h)
the system for information exchange. (In
addition to the information exchanged under Option 3 information would be
needed from the on board diagnostic (OBD) and the information from installed
equipment.)[43]
1.131
Under this policy option, Member States would be
permitted to apply tests that were above the minimum standards, but could not
require the same from other Member States whose certificates they would be
obliged to recognise, as is the case in the field of type approval where there
is a common minimum standard that must be respected.[44] Thus Option 4 would include
mutual recognition as in Option 3, but also require more standardisation of
testing methods. 1.132
Three different possible levels of PTI testing
have been outlined by DEKRA for the purposes of this impact assessment, and
these are now specified: –
Option 4a: Least rigorous –
Option 4b: Medium level –
Option 4c: High level.[45]
1.1.27.
Option 4a: Least rigorous
1.133
This is defined according to the existing
directive 2010/48/EU. Therefore it should be seen as the minimum standard
possible at which to impose a mandatory standard EU-wide system for PTIs, as in
DEKRA’s assessment nearly all Member States have already established their PTI
system above this level. 1.134
The following table summarises what is involved. Technology and procedures || Roller brake test bench, pit or power lift, head lamp aiming device, CO – Lambda for petrol and K – value measurement for Diesel engines Items only need to be visually inspected and procedures for the use of roller brake testing are as mentioned as a reference to ISO 26096. Frequency of tests || 4-2-2 M1N1 1-1 M23N23O34 and others* Vehicle categories covered || M123 - N123 - O34 Personal skills and qualifications || No definition Supervision and enforcement || RSI – Reporting to the Commission according to 2010/47/EU, special measures if non-public bodies are involved (Chapter 1/2, 2009/40/EU) * For taxis and ambulances Source: DEKRA
1.1.28. Option 4b: Medium
quality
1.135
Under Option 4b, a medium standard of PTI would
be defined, and made compulsory for all Member States as the minimum required.
It might involve: Technology and procedures || Roller brake test bench, suspension test bench, head light tester, power lift with hydraulic play detectors, automated data collection, brake pressure measurement for power brakes, OBD for emission testing, CO – Lambda for petrol and K – value measurement for Diesel engines Different fixed definitions of measures and procedures for undertaking the tests may be used. Frequency of tests || 3-2-2 M1N1O12L345 1-1 M23N23O34 (additional safety tests in between) Vehicle categories covered || M – N – L – O (all vehicles that are registered) Personal skills and qualifications || Technician with additional education for PTIs with yearly training of more than two days. Supervision and enforcement || Regular quality checks done by governmental departments – as well as roadside inspection targeted selection Source: DEKRA
1.1.29. Option 4c: High
quality
1.136
The highest standard envisaged for the purpose
of this assessment was defined as follows: Technology and procedures || Roller brake test bench, suspension test bench, head light tester, power lift with hydraulic play detectors, automated data collection and storage, load simulation for trucks, brake pressure measurement for power brakes, use of scan tools for the test of electronic components as well as for emission testing in addition to CO – Lambda and K – values also for motor cycles (L345) Frequency of tests || 3-2-2-1 M1N1O12L345 1-1 M23N23O34 (additional safety tests in between) Vehicle categories covered || M – N – L – O (all vehicles that are registered) Personal skills and qualifications || Qualified technician or engineer with additional education for PTIs with yearly training of more than three days. Supervision and enforcement || Regular quality checks done by governmental departments Roadside inspection for M1 and N1 as well as M23 and N23 (sufficient number and method to be statistically firm) Source: DEKRA 1.137
The three options 4a, 4b and 4c as described
above relate to the costings as calculated later in the report. 1.138
It is worth noting that some Member States
already require more stringent roadworthiness testing regimes than described in
4c. For instance, the UK and Slovakia both require a testing schedule of 3-1-1
for M1 vehicles. We base our description of the PTI frequency required
for cars for the high quality testing level on the optimum frequency as
determined in the AUTOFORE report. As additional studies on cost benefit
analysis of PTI frequency become available, the recommended highest frequency
level may need to be updated. 1.139
To illustrate the maximum levels of the
different components of the PTIs currently in place in different Member States
in the EU the following description is provided: 1.13.10.1. Most rigorous (not
considered in this report) Technology and procedures || Roller brake test bench, suspension test bench, head light aiming tester, automated data collection and storage, load simulation for trucks, brake pressure measurement for power brakes, use of scan tools for the test of electronic components as well as for emission testing in addition to CO – Lambda and K – values also for motor cycles (L345) Different fixed definitions of measures and procedures for undertaking the tests may be used. Frequency of tests || 1-1 M1N1O12L345[46] 0.5-0.5 M23N23O34 (additional safety tests in between) Vehicle categories covered || M – N – L – O (all vehicles that are registered) Personal skills and qualifications || Vehicle Engineer with additional education for PTIs with yearly training of more than four days Supervision and enforcement || Undercover tests, regular quality checks done by governmental departments – quality assurance system according to ISO 17020 Roadside inspection for M1 and N1 as well as M23 and N23 (sufficient number and method to be statistically firm) Source: DEKRA 1.140
The testing regime as described above is more
prescriptive than any currently in place in the EU and therefore is not an
option at this time. Based on future research a very high level of
roadworthiness testing such as this may become either more or less attractive
as an option in the future. 1.141
Three similar tables relating to different
possible levels for roadside inspections are given in Appendix 5: .
1.1.30.
Option 5: Deregulation at EU level
1.142
Under this option, the EU would withdraw from
the field and leave Member States to decide what forms of vehicle testing if
any they wished to implement. 1.14. Information exchange 1.143
Information sharing is part of all of the policy
options described, the level, value and necessity of information sharing
depending to some extent on the policy option. 1.144
As discussed in detail in Appendix 4, data
exchange is valuable for two fundamentally different reasons: (a)
it facilitates policy analysis; and (b)
it facilitates efficient operations of tests and
other transactions. 1.145
For the first purpose, details of individual
vehicles are not needed; and time is not generally of the essence. For
operational purposes, a different technology is appropriate, since little
analysis is needed, but records of individual vehicles and tests need to be
available promptly. Mutual recognition (under Options 3 or 4) would require
improved exchange of operational data, which would also assist in other
options. 1.15. Possible
combinations of policies 1.146
As this impact assessment is looking at
improving on two issues, road safety and single market aims, there are two
separate strands of action that can be taken, one relating mainly to road
safety improvements and the other to the creation of a single market in vehicle
testing. Either strand of action could theoretically be taken without
requiring any action towards the other objective. However, as the two issues
are linked by the fact that reforms to the system of vehicle inspections might
contribute to both their solutions, the most efficient solution is likely to be
a combination of both a push for the single market and increased efforts to
improve PTIs in the EU. We have also already noted that it is possible that
there may be a policy trade-off; e.g. mutual recognition without
standardisation at a high level could in theory reduce safety standards, whilst
standardisation at a high level might take a long time to achieve during which
progress on mutual recognition might be delayed. 1.147
The table below displays the two dimensions
along which action can be taken, and where the policy options fall into this
framework. Table Error! No text of specified style in
document..6: Policy options in relation to single
market and PTI improvements || No additional push for single market || Encourage bilateral agreements || Mandatory mutual recognition Continuing updates under comitology || Option 1 || Possible || Politically infeasible? Enhanced implementation and enforcement || Option 1a || Option 2 || Option 3 Imposition of minimum standards – requiring change of legislative framework || Single market effectively already exists in this case || Mutual recognition likely to be as easy to implement as bilateral agreements || Option 4 1.148
The interrelationships between policies are
explored in the following section. 6 Analysis
of Impacts 1.16. Scope of analysis 1.149
The IA guidelines require us to consider the
likely economic, social and environmental impacts of each of the short-listed
options, including where relevant impacts outside the EU, and including of
course both negative and positive effects and how impacts might develop over
time. The commentary should consider which social groups, economic sectors or
particular regions are affected; and the potential obstacles to compliance. 1.150
In this case we see little relevance for
countries outside the EU. 1.17. Initial overview of options in relation to objectives 1.151
An overview of the relation between each policy
option to the policy objectives is given in the following table. The impacts
of the policies are evaluated incrementally – so the impacts given relate to
the change that would be seen relative to the policy option before. To
illustrate: the table shows a reduction of accidents as a result of Option 1,
but no reduction from Option 2. Since Option 2 would include Option 1, there
would be an overall reduction, but no more from the additional components. Table Error! No text of specified style in
document..7: Policy options in relation to incremental
impacts Objective Policy option || Reduction in accidents || Favourable impact on environment || More integrated EU market || Improved provision of necessary information wherever needed || Reduction in administrative burden Option 1: No new policy action || Zero impact (by definition) || Zero impact (by definition) || Zero impact (by definition) || Zero impact (by definition) || Zero impact (by definition) Option 1a: No new legislation, but better implementation || Yes || Yes || No || No || Yes (best practice solutions) Option 2: Encourage bilateral agreements and better implementation || No || Small benefit || Yes || Yes || No Option 3: Mutual recognition of PTIs throughout the EU, made obligatory by new EU legislation || No (possible negative effect) || Uncertain || Yes || Yes || Uncertain Option 4: Impose through EU legislation a standard EU-wide system for PTIs || || || || || Option 4a: Basic standard || No (possible negative effect) || Uncertain || Yes || Yes || No (possible negative effect) Option 4b: Medium || Yes || Yes || Yes || Yes || No (possible negative effect) Option 4c: Most rigorous || Yes || Yes || Yes || Yes || No (possible negative effect) Option 5: Deregulation at EU level || No (negative effect) || No (negative effect) || No (negative effect) || No || Yes Source: Europe Economics, DEKRA, CENTIQ 1.152
We now discuss each of the options and consider
the likely impacts of alternatives to present policies. 1.18. Option 1: No new policy action 1.153
Option 1 provides the counterfactual against
which the likely effects of other policies are to be assessed. This option is
seen as suboptimal by DG MOVE, which believes that there is clear scope for
improvements in the effectiveness of testing, including through better exchange
of information, to which action at EU level could contribute. 1.18.1.1. PTIs 1.154
With a continuation of present policies, the
systems of PTI and roadside testing in use would continue to evolve. For
example, the AUTOFORE report recommended an increase in the minimum frequency
of tests.[47]
On the other hand, the Dutch Government has recently reduced the frequency of
tests for cars[48]
and the UK considered doing so, but decided that its present practice (which
involves some of the most frequent testing in the EU) was optimal for the UK.[49] 1.155
Nonetheless, under Option 1 the pattern of
frequency of tests might be expected to remain broadly as at present, and as
shown in the following table. Table Error! No text of specified style in
document..8: Present frequencies of PTIs || Private cars || Goods vehicles < 3,500 kg || Goods vehicles > 3,500 kg || Passenger vehicles < 8 passengers || Passenger vehicles > 8 passengers || Trailers < 3,500 kg || Trailers > 3,500 kg || Agricultural tractors || Motorcycles Belgium || 4/1/1 || 6m/6m/6m || 6m/6m/6m || 6m/6m/6m || 3m/3m/3m || 1/1/1 || 6m/6m/6m || 6m/6m/6m || n/a Bulgaria || 3/2/1/1 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Czech Republic || 4/2/2 || 4/2/2 || 1/1/1 || 4/2/2 || 1/1/1 || 4/2/2 || 1/1/1 || 4/4/4 || 4/2/2 Denmark || 4/2/2 || 4/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || n/a || 1/1/1 || n/a || n/a Germany || 3/2/2 || 2/2/2 || 1/1/1 || 1/1/1 || 1/1/1 || 3/2/2 (<750kg) 2/2/2 (>750kg) || 1/1/1 || 2/2/2 1/1/1 || 2/2/2 Estonia || 3/2/2/2/1 || 1/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 3/2/2/2/1 || 1/1/1 || 2/1/1/1 || 3/2/2/2/1 Ireland || 4/2/2 || 4/2/2 || 1/1/1 || 1/1/1 || n/a || 1/1/1 || n/a || n/a || n/a Greece || n/a || n/a || n/a || n/a || n/a || n/a || n/a || n/a || n/a Spain || 4/2/2/1 || 2(x3)/1(x4)/6m || 1(x10)/6m || 2/1/1/1/6m || 1(x5)/6m || 2(x3)/1(x4)/6m || 1(x10)/6m || 1(x10)/6m || 5/2/2 France || 4/2/2 || 4/2/2 || 1/1/1 || 4/2/2 || - || - || - || - || - Italy || 4/2/2 || 4/2/2 || 1/1/1 || 4/2/2 || 1/1/1 || 1/1/1 || 1/1/1 || - || 4/2/2 Cyprus || 4/2/2 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Latvia || 2/2/2 || 1/1/1 || 6m/6m/6m || 6m/6m/6m || 1/1/1 || 1/1/1 || 1/1/1 || n/a || 1/1/1 Lithuania || 3/2/2 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Luxembourg || 3.5/1/1 || 1/1/1 || 6m/6m/6m || 3.5/1/1 || 6m/6m/6m || 3.5/1/1 || 6m/6m/6m || 3.5/1/1 || 3.5/1/1 Hungary || 4/3/2/2 || 2/2/1/1 || 1/1/1 || 3/3/2/2 || 1/1/1 || 2/2/1/1 || 1/1/1 || 3/3/2/2 || 3/3/2/2 Malta || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Netherlands || 4/2/2/1 || 3/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || - || 1/1/1 || - || - Austria || 3/2/1 || 1/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 3/2/1 || 1/1/1 || 3/2/1 || 1/1/1 Poland || 3/2/1 || 3/2/1 || 1/1/1 || 1/1/1 || 1/1/1 || 3/2/1 || 1/1/1 || 3/2/2 || 3/2/1 Portugal || 4/2/2/1 || 2/1/1 || 1(x7)/6m || 1(x7)/6m || 1(x7)/6m || n/a || 1(x7)/6m || 1(x7)/6m || n/a Romania || 2/2/2 || - || 1/6m/6m || - || 1/1/1 || - || 1/1/1 || - || - Slovenia || 3/2/2 || 3/1/1 || 1/1/1 || 3/1/1 || 1/1/1 || 3/1/1 || 1/1/1 || 3/1/1 || 3/1/1 Slovakia || 3/1/1 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Finland || 3/2/1 || 3/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 2/2/2 || 1/1/1 || n/a || n/a Sweden || 3/2/1 || 1/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 4/2/2 || 1/1/1 || n/a || 4/2/2 United Kingdom || 3/1/1 || 3/1/1 || 1/1/1 || 3/1/1 1/1/1 || 1/1/1 || n/a || 1/1/1 || n/a || 3/1/1 Source:
AUTOFORE Study on the Future Options for Roadworthiness in the European Union:
WP540 – Analysis of pass/fail rates and accidents for different vehicle types
in relation to PTI – frequency and vehicle age; DEKRA 1.156
A number of Member States follow the minimum
frequencies as dictated by the EC, which are 4/2/2 for cars and 1/1/1 for goods
vehicles over 3,500kg. Some Member States implement PTI inspection frequencies
above this minimum level because they see value in the more stringent
standards.[50]
This is made possible by the freedom for Member States to choose their own
frequencies, above the prescribed minimum, under the current directives. 1.157
With regard to the content of PTIs, our
assessment for the purpose of this report is that 37 per cent of MS operate a
standard approximately equivalent to the least rigorous standard, as described
in Option 4a, 44 per cent in the medium category (4b), and 19 per cent in the
most rigorous category described as 4c. The countries with the most rigorous
standards (similar to those described for 4c) are deemed to be Germany, Sweden,
Belgium, Luxembourg and Finland. Those categorised as having a medium level of
rigour (similar to those described for 4b) are France, the Netherlands, Spain,
Portugal, the UK, Slovakia, the Czech Republic, Austria, Denmark, Estonia,
Ireland and Latvia. The remaining 37 per cent (with a PTI level currently
similar to that described in 4a) would face the most significant cost increases
if EU legislation were to require increased technical testing standards. These
are Italy, Poland, Malta, Hungary, Bulgaria, Lithuania, Slovenia, Romania,
Cyprus and Greece. 1.158
Very few Member States still directly control
and run the PTI system with staff employed by the government. Most have
privatised the system, but take active control of the work and results of PTI
measures. Close relations between governmental departments and the PTI organisations
can support an effective PTI system. 1.159
Private solutions can be found in some Member
States with the involvement of garages, licensed to do PTIs with staff from the
garage (after special training), and providing a combination of repair and testing
at one place. Measures have to be taken to prevent corruption against the
interests of the vehicle owner (if testers were to pretend there is more work
to be done than really necessary). In other Member States PTIs are separated
from repair work, to avoid conflict of interests. Some new Member States
provide PTIs in close connection with the police and other public authorities
or agencies. 1.160
An advantage of the garage-based system is the
high number of test locations spread over the country, reducing the distances
motorists have to travel for the test, and the time it costs them. For the
system in which testing stations focus exclusively on the tests, high
throughput and specialisation by the staff may help to achieve efficient
operations. Dedicated technology is efficient to use and the staff may be
better trained because of their experience (although a competent mechanic
should be able to administer a PTI efficiently). The authorities should also
be able to supervise the smaller number of testing stations more cheaply (there
are, for example, only 300 stations for the whole of Spain, where a high
throughput is supporting what DEKRA regards as a very effective test). 1.161
The overall cost to motorists of the tests,
including the system administration costs mentioned above, is indicated by the
following table from the 2004 AUTOFORE report. Table Error! No text of specified style in
document..9: Inspection fees per passenger cars, 2004 EU-Member State || Inspection costs in Euros per inspected vehicle without taxes Belgium || 24.5 Denmark || 53.8 Germany || 40 Greece || 36 Spain || 31 France || 55 Ireland || 48.4 Italy || 35 Luxembourg || 20.9 Austria || 37 Portugal || 24.63 Finland || 49 Sweden || 33 United Kingdom || 52.49 Czech Republic || 50 Estonia || 30 Hungary || 20.18 Poland || 21.29 Slovenia || 35 Source: AUTOFORE WP700: Cost-Benefit
analyses for roadworthiness options Inspection costs were not provided for
the Netherlands, Cyprus, Latvia, Lithuania, Malta or Slovakia. 1.162
Based on these values, the inspection costs in Table Error! No text of specified style in
document..9 and an average
age for scrapping vehicles of 17 years, we can estimate that the total cost of
PTIs in Europe is at least € 8.52 billion, expressed in current prices.[51] 1.163
Option 1 includes continued use of comitology to
implement improvements and to keep up with technological developments. An
example of an issue that might be addressed is tyre pressures. Currently a
significant number of accidents due to technical defects are from tyre defects
(30 per cent),[52]
such as low tyre-pressure or insufficient tread-depth. However, currently PTIs
in most EU countries (exceptions are France and Holland) do not check tyre
pressure, but the overall tyre condition as well as the correct size and type
of tyre for the vehicle and the wheels are tested. With tyre condition having
significant efficiency and safety effects, there could be benefits of adding to
the testing of tyre condition in future comitology proceedings.[53] 1.18.1.2. Roadside testing 1.164
Turning to roadside testing, in order to
understand present arrangements and to begin to assess how they might develop
under a continuation of present policies, DEKRA sent a questionnaire to the
Member States concerning roadside inspection. This included questions on the
selection of vehicles for roadside inspections and the equipment used for
roadside checks. 1.165
The following table presents the main results
(not all Member States replied). Table Error! No text of specified style in
document..10: Present practices in roadside testing MEMBER STATE || Vehicles tested || Authority in charge for RSI || Method / test equipment || Selection || Inspected items Ireland || HGV, Buses, Trailers || Road Safety Authority, Garda Siochana || Visual inspection + visual inspection trained || Statistical + pre-selection + targeted || all except petrol emissions Poland || HGV, Buses, Trailers, Passenger Cars || Road Transport Inspection, Police, Border Guard, Customs || Visual inspection trained + emission measurement || Statistical + pre-selection || all Germany || HGV, Trailers || Police, BAG || Visual inspection + visual inspection trained + brake test bench (external if needed) || Statistical + pre-selection + targeted || all Lithuania || HGV, Buses, Trailers || Ministry of Transport and Communications of the Republic of Lithuania, State Road Transport Inspectorate, Police Department und Ministry of Interior || Visual inspection + visual inspection trained + brake test bench + lift or pit + emission measurement device || Pre-selection + targeted || all except petrol emissions Slovenia || HGV, Buses, Trailers, Passenger Cars, Motorcycles || Ministry of the Interior, Transport Inspectorate of the Republic of Slovenia, Customs Administration of the Republic of Slovenia, police || Visual inspection + visual inspection trained + brake test bench + lift or pit + emission measurement device || Statistical + pre-selection + targeted (random checks of vehicles are allowed) || all except emissions petrol and speed limiting device installation Sweden || HGV, Buses, Trailers, Passenger Cars, Motorcycles || Swedish transport agency, police || Visual inspection trained + brake test bench + lift or pit + emission measurement device (at stationary test sites along main roads) || Pre-selection + targeted || all except emissions UK * || HGV, Buses, Trailers, Light Goods Vehicles || Department for Transport, VOSA || Visual inspection trained + mobile brake test bench || Pre-selection + targeted || all Austria * || HGV, Buses, Trailers, Light Goods Vehicles, Passenger Cars, Motorcycles || Ministry of Transport, federal countries || Visual inspection trained + brake test bench + wheel-play-detector + emission tester (special designed on site equipment || Pre-selection + targeted || all Luxembourg * || HGV, Buses, Trailers || Societe Nationale de Controle Technique SNCT, Administration des Douanes et Accises || Visual inspection trained + brake test bench + lift + emission tester (special designed on site equipment) || Pres-selection + targeted || all * information was obtained from other
sources because no response was received to the questionnaire 1.166
We assume for the purpose of the counterfactual that
the situation regarding roadside testing would not change significantly without
any action from the Commission. 1.167
There is a large range
in the number of inspected vehicles indicating that Member States place
different levels of emphasis on technical roadside inspections. 1.168
The share of non-compliant
vehicles out of the inspected vehicles in a Member State differs from 0.3 per
cent for Bulgaria to 63 per cent for Denmark. For 8 of the 19 Member States
where results are reported[54]
the rate of non-compliant commercial vehicles does not exceed 5 per cent, but
on the other hand in six countries the rate is higher than 30 per cent. This
difference is more likely to reflect different systems of pre-selection or
targeting of vehicles for roadside inspection than differences in the average
standards of vehicles on the roads. 1.169
To elaborate: There are
two reasons for the wide spread of results: (a) Selection of the inspected vehicles There is a
substantial difference in whether the vehicles to be inspected are selected on
a purely statistical basis (every vehicle has the same chance to be inspected)
or if the staff of the organisations in charge of RSIs use some kind of
pre-selection for the inspected vehicles. This might involve selecting
vehicles based on whether they appear not to be in roadworthy conditions. This
follows the intention of Directive 2000/30/EU, as it is given in the foreword
under paragraph 10 that: (10)
The method of inspection selection should be based on a
targeted approach, giving greatest effort to identifying vehicles that seem
most likely to be poorly maintained and thereby enhancing the authorities'
operational effectiveness and minimising the costs and delays to drivers and
operators. The consequence of
this method of targeting is that a high proportion of vehicles which are not in
roadworthy conditions are inspected. The inspection effort is focused on those
vehicles which are obviously not roadworthy, with no expectation that the
results are likely to be representative for all vehicles on the road. (b)
Methods, procedure and criteria for
inspection Clearly all
Member States do use visual inspection for the first steps in their check. Differences
in procedure may occur, depending on the training and experience of the staff.
In some cases further equipment is used (brake tester for evaluation of brake
efficiency, lift, pit, emission test devices), in others further equipment is not
used. DEKRA advises that many defects can only identified by use of such additional
equipment. 1.170
In any analysis of the
results of roadside inspections in the EU, comparisons between the results for
different Member States are highly uncertain. 1.171
Roadside inspections
are mandatory for commercial vehicles only. Some countries also carry out
roadside inspections for passenger cars, but currently there is no EU
legislation requiring any kind of standardisation. 1.172
Roadside inspections
are used in all Member States in addition to other measures like PTIs. They
are not as intensive as a periodical inspection, but they are an instrument for
the supervision of roadworthiness on the roads at any time, not just for
defined periodic intervals. In addition, in a Member State vehicles from any
country in the EU on the road can be the object of roadside inspection, while
periodical inspection only applies to vehicles registered in that Member State. 1.173
Roadside tests can incur a wide range of costs,
depending on the testing method chosen. Detailed investigations are very
expensive compared to the minimal costs involved in visual inspections of the
vehicle. Starting with screening methods, the costs for this are quite low
with approximations of costs around € 5-10 per vehicle. This includes the cost of checking the vehicle’s
papers and general condition. However, if the vehicle is recognised as
non-conforming it would then be moved to dedicated test areas to perform
further tests, the costs of which can amount to around €
200-300 per vehicle in Germany.[55] In Austria, maximum costs of € 100 have been reported.[56] 1.174
The implementation of remote sensing of
emissions for roadside testing is currently only in place in Austria. In Spain
the technology is used for enforcement, and in Sweden and Switzerland it is
being used for research purposes only. Introducing remote emissions testing
has the advantage of allowing the worst polluters to be identified at a low
cost per vehicle. However, in DEKRA’s view the results of the test are not
reliable enough on their own to be used to prove that a vehicle has too high
emissions, and therefore conventional emissions testing devices must continue
to be used in tandem when performing roadside tests. 1.175
The cost of undertaking a roadside emission test
with remote sensing technology is, however, less than € 1 per vehicle. Table Error! No text of specified style in
document..11: Cost of roadside emission testing € 100,000 || Cost per year (ESP AccuScan 4000 + staff operating costs + overhead costs)* € 600 || Cost per day (assuming 160 days / year) € 0.01 || Cost per vehicle (if 1000 vehicles per hour) Source: DG
MOVE, ESP (http://www.esp-global.com/en_US/RSD/FAQ) * Cost of
the equipment is estimated as the cost of one remote sensing device(€ 120,000), one van (€ 50,000) and additional drivers equipment (€ 30,000 – consisting of road signs, coins
etc) spread over five years, therefore € 40,000 a year. Estimated costs of the operator and overhead together
come to € 60,000 a year. 1.176
Section 3 above has described how we expect that
the trends in road accidents and single market issues would evolve under a
continuation of present policies (i.e. under Option 1). 1.19. Option 1a: No new EU legislation, but better
implementation 1.177
Policy objectives can be delivered in a number
of ways, for example through the provision of information, market incentives, and
the deterrent effect of penalties, or through legislation. Without
implementing any new legislation, DG MOVE would be able to continue to pursue its
policy objectives including through the provision of information or through
encouraging Member States to adopt appropriate penalties for unsafe vehicles.
The present legislation allows the use of infraction proceedings if necessary. 1.178
Therefore, some possible methods available to
improve implementation are: (a)
peer reviews and screening; (b)
exploration of optimal levels of investment in
PTI and roadside testing; (c)
exploration of the scope for risk-based testing
regimes (e.g. taking account of warranty lives; taking account of mileage
covered as well as time passed; taking account of whether a vehicle has been
involved in an accident); (d)
exploration of the scope for other measures to
help motorists to decide when vehicles should be tested, e.g. including use of
legal responsibilities of the individual in some MS (these might include PR
campaigns focusing on the actions that vehicle owners should be taking); (e)
MS enhancement of roadside inspections and
testing supervision; (f)
voluntary action by vehicle manufacturers; (g)
the Commission to prepare itself to institute
infractions proceedings if required. 1.179
If our analysis of the underlying reasons for
differences in practices and in the standards of testing is correct, the
interests of the Commission and of the other regulatory authorities involved
are well aligned and it should be possible to make considerable progress
without new legislation (also bearing in mind that the existing legislation in
Directive 2010/47/EU and Directive 2010/48/EU gives the Commission significant
powers.)
1.1.31.
Peer reviews and screening
1.19.1.1. Costs 1.180
The cost of a programme of peer review and
screening would not be large if one envisaged two meetings per year of national
experts, meeting with the Commission and presenting a mixture of comments and
discussion from existing knowledge, and the results of some studies that are
already in progress or have been completed. This would not cost more than the
time of the officials, and would not require any addition to the numbers. Even
allowing travel and some consultancy support, the cost would be measured in low
€ hundreds of thousands. 1.181
Two one-day meetings per year, each attended by
two national experts from each Member State, would amount to 108 trips to
Brussels. With a daily subsistence allowance (DSA) of around € 90 per day,
fixed additional allowance (FAA) of € 250 per day,[57] transport costs of around € 300
per trip and accommodation costs of around € 100 per trip, this would equate to
a cost of € 79,920.[58] 1.19.1.2. Benefits 1.182
The benefits are of course uncertain; but to
give an idea of the orders of magnitude of resources that could be saved
through policy analysis in this area, the UK study referred to earlier estimates
that to change the frequency of PTIs to three possible alternatives to the
present would have cost the UK society £67m for one scenario, £191m for the
second, and £887m for the third (approximately € 77m, € 220m and € 1,020m, respectively). Of course, the UK
is a large economy, and the study referred to was a significant piece of work,
but the example serves to show the potential advantages of disseminating and
making use of existing knowledge. 1.183
The World Health Organisation report on road
safety[59]
noted that many effective preventive strategies already exist in Europe, and
that the roads in many European countries are among the safest in the world.
Therefore, there is potential to reduce the burden of road traffic accidents by
applying lessons of good practice between different countries. In particular,
evidence from the different systems that have been implemented across the EU up
until now provides valuable information on the merits of alternative policy
options for PTIs. For instance, allowing private garages across a country to
perform PTIs, as currently implemented in some Member States, has the impact of
reducing the travel and emission costs of this burden, but may increase the
costs of ensuring compliance with testing regulations.
1.1.32.
Risk-based inspection regimes
1.184
It is a principle of good regulation to apply
regulatory resources where the risks are greatest, and we have noted that this
principle is reflected explicitly in the roadside-testing Directive. However,
the principle is at present applied only to a limited extent in the systems of
PTI, through the decisions made about frequency (increasing as vehicles become
older) and types of vehicles to test. There has been some discussion of applying
a more rigorous regime to cars used for business purposes, on the grounds that
they are likely to drive longer distances and therefore the maintenance
requirements recommended by the manufacturer may no longer fit with the mileage
actually travelled. Moreover, a business car which is not privately owned by
the driver may be less well maintained as the user has less incentive to keep
it in good condition (“company cars go over the kerb better than other cars”)
and the more frequent changes of driver typical for cars used for business
purposes may also have a negative impact. 1.185
It would be also possible to allow vehicles that
could be shown to have been used for low mileages a longer period before
testing; or for vehicles still covered by a maker’s warranty – during which
time the motorist has an incentive to check every rattle and to have the
manufacturers repair the slightest defect – to be exempt (although not all
items checked in a PTI are covered by all warranties).[60] On the other hand, vehicles
that have been involved in an accident might be required to have an additional
test (this idea was well supported in the on-line consultation, summarised in
Appendix 3). 1.186
It would also be useful to explore the optimal
balance between legal responsibilities of vehicle owners to maintain their
vehicles in a safe condition at all times, and the requirement to have a PTI.
If it is true that most vehicle defects could be prevented by more
knowledgeable and responsible behaviour by motorists, policy emphasis on
individual responsibility might be cost-effective. 1.187
As this is relatively unexplored ground the
costs of investigation and research would be higher than for peer reviews and
screening, and might be € 2-3 million a year for research. However, the
potential gains would easily be measured in larger orders of magnitude.
1.1.33.
PR campaigns
1.188
One method of delivering policy objectives is
through the provision of information on the costs and benefits of action. This
can help ensure that individuals recognise the benefits of acting in a
particular way, providing them with the incentive to act in their own benefit,
without forcing them to do so. An increase in awareness of the importance of
keeping vehicles roadworthy could be provided by either an EU PR campaign aimed
directly at citizens, or through the encouragement of national governments to
perform similar campaigns at a Member State level. The legal duty in some
Member States of motorists to keep their vehicles safe could be reinforced in
such a campaign. 1.189
The cost of sending out reminder letters to all
vehicle owners to inform them that the deadline for obtaining a new PTI is
approaching would come to around € 180 million a year.
This is calculated based on a total of 300 million vehicles being tested
annually, each at cost of € 0.60 (representing the cost of a stamp). The
benefits of such a measure are uncertain. 1.190
The costs of designing and distributing a PR
campaign can be very large, and it must be easy to waste money in PR campaigns
as achieving significant and sustained behavioural change through information
campaigns is challenging. 1.191
There are, however, several reasons to think
that there may be scope for cost-effective initiatives in this area: (a)
It is in motorists’ interests to know how to
keep their vehicles safe, and to be reminded of their legal obligations. (b)
There is already experience of government PR
campaigns to promote safe driving; [61]
and these could be extended or repeated with appropriate emphasis on vehicle
maintenance. (c)
Similar campaigns could be appropriate in
different Member States, allowing the possibility of economies of scale. (d)
Tyres and lights are some of the most important
technical defects that occur on vehicles; however, neither of these requires
trained mechanics to assess their basic functionality. In addition, the
condition of tyres and lights would ideally be checked monthly and rectified
immediately if a fault is discovered, rather than delaying until the next
scheduled PTI. (e)
Most fundamentally, it would address a root
cause of vehicles being unsafe – responsible care by motorists probably being
more important than the details of the testing regime. 1.192
A study by DEKRA[62] found that over 6 per cent of
inspected car accidents were caused by vehicle defects, mainly in braking
systems, lighting systems and tyres. The people most responsible by far for
accident-relevant defects in braking systems and tyres were the owners and
drivers of the vehicles. The proportion of accident-relevant tyre defects for
which owners or drivers were responsible (damage because of under-inflation or
age) was revealed to be 35 per cent, while fitting and repair defects accounted
for 7 per cent, operating damage (e.g. running over a nail) accounted for 17
per cent and manufacturing defects accounted for 6 per cent.[63] Similarly, drivers / owners
were found to be responsible for 46 per cent of accident-related braking
defects, caused by lack of maintenance, and almost 15 per cent of
accident-related defects were due to defective fitting or repairs, for which
owners may again be responsible if they have carried out private work on their
braking systems. This confirms the potential of policies focused on drivers’
and owners’ general responsibilities. 1.193
The road safety effect of correct tyre pressure
can be estimated using the DEKRA data, if we assume 6 per cent of crashes are
caused by serious vehicle defects, of which 1.5 per cent are a result of tyre
defects. If we then assume that, at most, a third of these tyre defects are
due to low tyre-pressure, we can obtain an estimated figure of 0.5 per cent of
all crashes that could be attributed to incorrect tyre pressure.[64] 1.194
If a PR campaign were implemented to advertise
to vehicle owners the benefits in terms of safety and vehicle efficiency that
would accrue from regularly checking their tyres and lights, significant
improvements in road safety and vehicle emissions might be obtained. Such an
awareness campaign could be implemented at petrol stations, where facilities
for checking tyre pressure are available. If we predict that between 5 and 20
per cent of people might react positively to a PR campaign on tyre pressures,
then this could lead to a 0.025 to 0.1 per cent reduction in accidents in the
EU, hence 10 to 39 fewer deaths and 400 to 1,600 fewer injuries a year.[65] This reduction can be valued
in the region of € 19 to 76
million.[66] 1.195
A more general PR campaign advertising the
benefits of keeping vehicles in a roadworthy condition may help reduce the
problem that PTI testing does not guarantee that a car will remain roadworthy
until the subsequent test. Ideally vehicles would be kept to a consistently
high level of repair, rather than only being checked at periodic intervals. 1.196
A 2009 study investigated whether road safety
campaigns are successful using a meta-analysis of road safety campaign effects.[67] The study used information on
427 individual campaign effects and associated variables extracted from 228
different campaign evaluation studies, most reported within the last 30 years
in 14 different countries. The results found that road safety campaigns result
in a 9 per cent decrease in accident levels.[68] 1.197
Indicative costs for some of the campaigns
investigated in the study were € 490,000[69]
for a Dutch seatbelt campaign carried out in 2008 and €
462,000[70]
for a child restraint campaign in Austria.
1.1.34.
Enhancement of roadside inspections and testing
supervision
1.198
We have shown that there is a wide variation in
the ways in which MS carry out roadside tests, and in the results. 1.199
This variation suggests that there may be
lessons to be learned by comparisons of practice. For example, some countries
clearly test a far higher proportion of vehicles on their roads than others,
reflecting a different assessment of the costs (to the motorists stopped and to
the testers) and the benefits (greater likelihood of catching a sub-standard
vehicle). Discussions between those involved could enable efficiency gains to
be made. 1.200
The value of roadside testing is far less
well-established than that of periodic technical inspections of vehicles. This
is evident by the fact that only three Member States[71] performed roadside tests
before this was made compulsory by EU Directive 2000/30/EC,[72] whereas most Member States
already had a system of periodic inspections in place before this was made
compulsory at EU level. During the course of our research we did not discover
any conclusive studies illustrating the magnitude of road safety benefits
achieved from roadside tests.[73] 1.201
Increased harmonisation of methods for roadside
tests in the EU might increase the value of test results to analyse levels of
vehicle roadworthiness between Member States. The most compelling arguments
for introducing EU-wide legislation harmonising roadside tests appear to relate
to the need for information to be collected on an internationally standard
basis in order to support the enforcement of other EC Regulations.[74] Enforcement requires reliable
information to be obtainable, but not necessarily in any standardised manner.
Therefore, an estimation needs to be made of the value of the availability of
such data before any harmonisation of roadside testing can be proposed.
Currently the quality of data collected from roadside tests is insufficient to
produce any kind of inter-country analysis. Additionally, the use of roadside
tests as a method of useful data collection is at odds with the original
justification for its introduction as a method of increasing road safety.
Higher quality data are achievable by strict statistical methods to choose
which vehicles to test whereas road safety aims require vehicles to be chosen
based on their perceived likelihood of being found unroadworthy. 1.202
Therefore there is currently no proven requirement
from a single market or from a road safety perspective for the EU to play any
role in roadside testing systems, or to attempt to insist on standardising the
methods of testing; the EC’s role under this policy option should be to
encourage improvements in practice by providing relevant information where it
can. 1.203
The costs of arranging this are likely to be
modest, particularly if it is arranged alongside the enhanced arrangements for
peer review and screening discussed above. The potential benefits are
significant. 1.204
An indication of the costs of roadside tests is
as follows: Table Error! No text of specified style in
document..12: Costs per year for a roadside testing
station Mobile testing unit || € 60,000 Truck || € 20,000 Technicians for operation || € 180,000 (three at € 60,000 per year each) Operating costs (fuel etc) || € 40,000 TOTAL || € 300,000 Source: DG
MOVE, Der Rechnungshof (2006) “Bericht des Rechnungshofes” Annual costs
for the mobile testing unit and the truck are calculated as the price of these
items, € 300,000 and € 100,000, respectively, spread over five
years. 1.205
Assuming the testing unit operates for 200 days
per year and that 20 heavy duty vehicles can be inspected each day, this
equates to an average cost of €
75 per truck tested.
1.1.35.
Voluntary action by vehicle manufacturers
1.206
Many research projects involving different
original equipment manufacturers (OEMs) are already in place. 1.207
A joint research project could be undertaken
aimed at developing better durability of car safety components by design. At
the present time, in DEKRA’s view the main focus at the vehicle-design stage
appears to be on the reliability and robustness of new vehicles, rather than
their longer-term durability. Emissions performance equipment already has
mandatory life-targets established. However, in practice the failure rate of
emissions-related equipment is about 10 per cent for vehicles as early as their
first emissions test,[75]
and not all deteriorations are covered by the regulations.[76] Such targets could perhaps be
tightened for emissions-performance equipment and also expanded to cover safety
components. 1.208
Vehicle warranties are thought to be offered for
longer periods for an increasing proportion of new vehicles, reflecting
improvements in vehicle design. Whilst a vehicle is under warranty, the owner
has every incentive to maintain it fully, so it would arguably be in the
general interest to make sure that PTI and roadside inspection systems support
this development. It might, for example, be useful: (a)
to allow vehicles under appropriate warranty to
be exempt from PTI requirements;[77]
(b)
to investigate a system whereby manufacturers
can be informed when components on vehicles which they have manufactured lead
to PTI tests being failed. 1.209
With regard to emissions, we note a submission
by one of those consulted, the Federation of European Motorcyclists'
Associations (FEMA). This has not been analysed but appears worth
consideration. FEMA considers the manufacturer of a
vehicle as the main party responsible for the level of emissions the vehicle is
producing. If the vehicle fails to comply with standardised emission limits
after a certain mileage, the user must not be held liable for the costs arising
from repair. If legislators require periodical checks of the emission level,
this burden must not be put on the consumer either.[78]
1.1.36.
Commission to prepare itself to institute
infractions proceedings if required
1.210
DG MOVE estimates that infraction proceedings
may be instituted under this option approximately every three to five years.
Therefore this would require the work of an official amounting to approximately
one month per year (at a cost of around € 10,000 pa), as well as the costs for a lawyer acting in front of
the court once every three to five years (potentially costing € 20,000 a time, so an average of € 4,000 to € 6,700
pa). 1.211
The Commission would be prepared to institute
infraction proceedings should this become necessary at any stage.
1.1.37.
Summary of Option 1a
1.212
Most of the likely costs and benefits cannot be
quantified, but orders of magnitude have been suggested. 1.213
The likelihood is that the benefits of Option 1a
would outweigh the modest costs. Table Error! No text of specified style in
document..13: Summary table Option 1a Main costs || € million p.a. || Main benefits || € million p.a. Peer reviews and screening || 0.2 – 0.3 || || 0-100 Research || 2-3 || || 0-100 PR campaigns || 1-2 || || 0-75 Infraction proceedings || 0.015 || || Not known Other || Not known || || Not known Total p.a. || 3-6 || || 0-500 1.20. Option
2: Encourage bilateral agreements 1.214
Bilateral agreements for the testing of
passenger cars are already in place between the Netherlands and Belgium; the
Netherlands and Spain; and Spain and Sweden. 1.215
Under these agreements, the PTI organisations in
the Member States concerned have agreed to recognise the validity of PTIs
carried out in specified testing centres in the other country. 1.216
Bilateral recognition of PTIs can be implemented
in a number of different ways. Either the PTI can be undertaken by inspectors
from the Member State where the vehicle is registered, travelling to the
country where the vehicle is located for defined periods of time each year and
testing the vehicles using equipment in local garages; or the PTI can be
undertaken by local inspectors, following an inspection process as agreed by
the registering Member State. 1.20.1.1. Current examples: (a)
Swedish vehicles in Spain – Bilprovingen, the inspection organisation of Sweden, has an
individual agreement with some Spanish testing locations. The idea is that
Swedish inspectors come to the Swedish vehicles in Spain to offer inspection
services for a few days each year. (b)
Dutch vehicles in Belgium and Spain – The supervising organisation for PTI services in the Netherlands
(RDW) will accept the inspection in some defined cases by inspectors in Belgium
and Spain from next year. The inspections are undertaken by local inspectors
to the standards of the local inspection regime. (c)
A number of Nordic countries are in the process
of making an agreement on the mutual recognition of test certificates,
beginning with passenger cars. Under the Nordisk Vägteknisk
Förbund (NVF) project, a technical committee was set up looking into vehicle
design and function in order to analyse the inspection processes in the Nordic
Countries. Members representing the governments of Denmark, The Faroe Islands,
Finland, Iceland, Norway and Sweden took part. According to the full report
received from the committee (NVF 2:2002) the common perception among members
was that a full harmonisation of national provisions was not necessary, as the
present level of the national application of Directive 96/96/EC was quite
sufficient to guarantee a high technical standard of vehicles in use. Since
this report was issued, the testing protocols of the participating countries
have converged even further.[79] 1.20.1.2. Costs 1.217
Using bilateral agreements, a country might in
theory need to make up to 26 separate agreements in order to allow vehicles
registered in their country to be tested anywhere in the EU. However, discussions
are only likely to be pursued if there are reasons to expect worthwhile
benefits, and the Nordic example shows that groups of countries might work
together. 1.218
Bilateral agreements involve set-up costs –
discussions must occur to reach an agreement with the partnering Member State.
Potentially this is inefficient when only a few vehicles may make use of
arrangements under the agreement in the end. 1.219
We understand that the set-up costs of the
bilateral agreements arranged so far have been low. RDW estimates that its
costs of setting up the bilateral agreement with Spain to allow tests to be
undertaken there have amounted to approximately € 50,000. These costs included some travel to Spain, several internal
meetings in RDW and several meetings with the Dutch government. In addition to
this, the law in the Netherlands needed to be changed in order to legalise the
testing of Dutch vehicles elsewhere than on Dutch soil. RDW estimated that the
cost to change this law (as financed by the Dutch government) amounted to
approximately between € 5,000
and € 10,000.[80] RDW now has plans in place to
set up a similar bilateral agreement with Poland. The costs to themselves of
arranging this and potentially other subsequent agreements were estimated at between
€ 20,000 and € 25,000. 1.220
A system would be required for reliable
information to be provided by the MS performing the test to the MS of
registration notifying that the vehicle has been inspected. 1.221
The absolute maximum number of bilateral
agreements that might need to be negotiated in the EU is 702.[81] If each Member State did
negotiate bilateral agreements with all other EU Member States in this way then,
based on the costing as given above, the total set-up costs of these
arrangements would amount to around € 15 million.[82]
In practice, however, the number of bilateral agreements put in place would
probably need to be far fewer than this. As a more conservative estimate, if
we assume each Member State only chooses to negotiate agreements with three
others (as this is the number of agreements the Netherlands is currently
looking to put in place) the total cost in the EU to set up the arrangements
will then be around € 2.4
million (say, € 2-3 million).[83] 1.222
Operating costs of bilateral agreements are
similarly likely to be low, although these will depend on the exact system
chosen to be put in place. Potentially, the only additional costs that might
occur relate to the eventuality where the MS feels it necessary to undertake
its own audit check of the tests being undertaken in the foreign testing
centres. 1.223
Under this policy option, there would be a one-off
cost if the Commission were to produce a recommended format for bilateral
agreements, to aid in the discussion between Member States. Such a paper might
take an official two months to prepare, including consultations, and therefore
would cost approximately €
20,000 to produce. This could be facilitated by the systems of mutual
information exchange envisaged in Option 1a (an example of the sense in which
the options are cumulative). 1.20.1.3. Benefits 1.224
A benefit of this approach is that tourists with
vehicles stationed in one of the countries concerned would no longer face the
costs of unnecessary journeys for the purpose of complying with the test
regulations. For instance, under the bilateral agreement between Spain and
Sweden, currently only around 1,000 Swedish cars are inspected in Spain
annually, which would otherwise have to make journeys back to Sweden every year
(if greater than five years of age, otherwise at three years old and five years
old) for the purpose of PTI testing. Similarly, the Netherlands estimates that
approximately 1,000 Dutch cars are also stationed in Spain, which are currently
having to make journeys back to the Netherlands every year if older than eight
years, or every two years if more than four years old. 1.225
Savings would be made in the form of a reduced
number of kilometres unnecessarily travelled; leading to cost savings for some
of the small number of private individuals who currently need to drive long
distances to return their holiday vehicle home for PTI testing. A reduction in
unnecessary kilometres travelled implies reduced road congestion, road wear and
tear, air pollution and accidents. 1.226
Although only a small proportion of EU citizens
are currently affected in this way, with only a small percentage of the fleet
of more than 220 million passenger cars used in foreign countries, those
individuals affected sometimes face substantial costs. If we look at the case
of the bilateral agreements between Spain and Sweden, and Spain and the
Netherlands, we can come to some estimates of potential benefits. Table Error! No text of specified style in
document..14: Cost savings from bilateral agreement || Sweden || Netherlands Approximate driving distance from Spain to MS and back[84] || 5,000 km || 3,000 km Estimated time taken to make this journey[85] || 48 hours || 28 hours Estimated number of vehicles stationed in Spain || 1,000 || 1,000 Approximate frequency at which vehicles need to return for a PTI[86] || 0.82 || 0.71 Total distance travelled annually by tourists in Spain for the purpose of a PTI || 4,118 thousand km || 2,118 thousand km Total time spent travelling annually by tourists in Spain for the purpose of a PTI || 1,647 days || 824 days Value of non-working time, per day[87] || € 106 || € 106 Cost of travelling, per thousand km[88] || € 371 || € 371 Estimated total-time cost of these journeys || € 174,000 || € 87,000 Estimated total monetary cost of these journeys || € 1,530,000 || € 785,000 TOTAL POTENTIAL COST SAVING || € 1,700,000 || € 872,000 1.227
So an estimate of the benefits possible from a
bilateral agreement between two countries can be placed at around € 1 million. If we assume that each of the
27 Member States might make agreements with three other Member States, this
would imply a total annual cost saving possible in the EU of € 81 million (say, €
75 to 100 million). 1.228
An additional benefit would be that in the
course of setting up such agreements there would be opportunities for either
country to point out possible weaknesses in the other system; one can imagine
that this process might lead to the adoption of higher standards in some cases. 1.229
However, it is acknowledged that this would not
be an EU-wide solution; in the absence of an EU-wide system of mutual
recognition there would continue to be the possibility of some people and
businesses facing these costs.
1.1.38.
Summary of Option 2
1.230
Most of the likely costs and benefits cannot be
quantified, but orders of magnitude have been suggested. 1.231
The likelihood is that the benefits of Option 2
would outweigh the modest costs. Table Error! No text of specified style in
document..15: Summary table Option 2 Main costs || € million || Main benefits || € million p.a. Set-up /negotiation costs || 2-3 || Reduction in unnecessary journeys || 75-100 Operating costs || 0.1-1 p.a. || || Total p.a. || < 1 || || 75-100 1.21. Option
3: Mandatory mutual recognition throughout the EU 1.232
Under this option, the Commission would bring
forward legislation that would require each MS to accept as valid the tests
carried out in any other Member State. 1.233
This would not require the same systems or
standards to be in place in every Member State; simply that the legislators
accepted that standards everywhere are satisfactory for this purpose. 1.234
This would mean that the legislation governing
PTIs was similar to the systems of mutual recognition of standards that are in
place for most goods and services in the EU. It is commonplace for goods and
services produced in one Member State to have access to the market in any part
of the EU, despite differences in the methods and standards of testing. 1.235
However, in the consultations carried out for
this impact assessment, a number of experts or stakeholders took the view that
it would be very difficult to implement this system for political and not
technical reasons, and that before it was considered the Commission would wish to: (a)
investigate standards in each Member State; (b)
present reports on whether standards are
acceptable; (c)
secure improvements to standards in an unknown
number of Member States. 1.236
Because of these possible requirements, it is
natural to see Option 3 as following on from Options 1a and 2. Some
stakeholders indeed held the view that mandatory mutual recognition would
actually only be politically feasible after a mandatory EU-wide system for PTIs
and roadside testing was introduced. 1.237
Mandatory mutual recognition of PTIs throughout
the EU would not need to be implemented for all categories of vehicle at once.
In particular, there appears to be a reasonable case for the introduction of a
single market for PTIs of trailers, perhaps accompanied by some changes to the
tests applied to trailers in some Member States. This could be put in place
without necessarily introducing a single market for PTIs of trucks or private
vehicles as well (although LLG tests are much the same for trucks and trailers).
As most roadside testing is currently undertaken on commercial vehicles, an
infrastructure already exists to police the testing quality of these vehicles
in different Member States.[89] 1.21.1.1. Costs 1.238
The cost of increased supervision and control
mechanisms required for enforcing that minimum quality standards sufficient for
mutual recognition are in place throughout the EU could be substantial.
Countries already have significant issues enforcing their own national
standards of testing and minimising fraudulent tests. Quality control was a
concern for stakeholders at the expert workshop. 1.239
In Spain, the system in place means that PTIs
are regionally administered, but Spanish roadworthiness certificates (ITV
certificates) are recognised all over Spain. We understand that the Spanish
experience is that private vehicle users do not travel between regions to take
advantage of the lower prices charged for PTIs in some regions. However, some
do travel to a neighbouring region in order to receive a less rigorous PTI
(even at potentially higher cost) in the hope that technical defects in their
vehicle are not discovered or do not need to be dealt with, and therefore
repair costs can be saved. 1.240
This suggests that the average quality of PTIs
taken could be lower under mutual recognition of PTIs with variable standards,
if individuals take advantage of the opportunity to choose lower quality
testing centres, potentially travelling long distances to pass a PTI in another
country where standards are lower in order to avoid expensive repair costs.
Some regions are likely to be more significantly affected by this than others;
particularly highly populated border regions between Member States with
substantially different testing regimes (for instance, the border between
Germany and Poland). In these regions, individuals looking to choose a testing
centre with less stringent PTI requirements may only have to travel a few
miles. 1.241
To illustrate the point, the cost to repair a
faulty anti-lock braking system may be at least €2,000.[90] Therefore, it will probably
be cheaper to drive a vehicle requiring a new PTI certificate abroad for a
vehicle inspection where the fault is irrelevant in order to receive a PTI
certificate. This would be the case if the AntiLock braking system is not
included in the list of components to be tested in one country, or if the
inspection procedure for safety relevant electronic systems just involves a
visual check in one country and a detailed analysis of the system by functional
tests and/or by use of the diagnostic interface in the other. In this case the motorist would save some money but the average
standard of vehicle roadworthiness in the EU could decrease. 1.242
However, this does not mean that such moves
should be prevented; it may be better to allow a vehicle to continue to use the
roads without a working anti-lock system than to require the repairs. Most
vehicles do not have such anti-lock systems; and provided that the driver knows
the situation (so that he does not drive harder assuming the system is in
operation when it is not) it is difficult to see why he should be prevented
from driving a vehicle that has a system which is not working. The same could
be said of safety airbags; these are useful devices, but not compulsory, so it
should not be illegal to drive with an airbag fitted but not operational. 1.243
The problem of travelling to alternative testing
centres to avoid the cost of vehicle repairs has the risk of being even more
pronounced for commercial vehicles, where increased flexibility
is available in choosing a testing site due to the further distance travelled
by commercial vehicles. If vehicles travel longer distances for their PTI in
order to achieve a lower price or a lower quality test, this will produce
additional traffic on the roads near Member State borders (there is a
comparable situation for traffic near borders where there is a difference in
the price of fuel between two neighbouring Member States). 1.244
It is also likely that the owners of some
expensive new vehicles would prefer to have the tests carried out in the most
fully equipped workshops, and would therefore travel from lower-income
countries to Germany, Sweden or other high cost/ high quality testing regimes.
They would benefit from the fuller service for which they were willing to pay.
No estimate has been attempted of the likely numbers of such cases. 1.245
We assume for the purpose of exploratory
calculation that two per cent of vehicles might choose to have their vehicle
tested in another Member State in order to take advantage of the difference in
level of testing. There is no evidence to support this assumption; it is
purely a judgement taking account of the Spanish experience. We also make the
assumption that the minimum relative effectiveness level of PTIs between Member
States which we assume would be acceptable within the EU to enable mutual
recognition is 80 per cent. This is also a matter of judgement that cannot be
supported by evidence at this stage. 1.246
In the table below, this fraction is expressed
as a number of vehicles escaping the test. Table Error! No text of specified style in
document..16: Potential reduction in PTIs Vehicles in EU || 301,749,500 Assumed number travelling for PTIs (2 per cent) || 6,034,990 Assumed number of vehicles that might effectively receive no PTI because of this (20 per cent) || 1,206,998 Source: EU energy and transport figures –
Statistical pocketbook 2010 1.247
Based on the estimates from the Department for
Transport study in 2008, the increase in probability of accidents from going
from a high level of PTIs to no PTIs would be (all 2004 values): Table Error! No text of specified style in
document..17: Increased probabilities of accidents Type of accident || Increase in number || UK vehicle stock || Increase in probability Fatal || 1,543 || 31,984,000 || 0.0048 % Serious || 9,473 || 31,984,000 || 0.0296 % Slight || 49,494 || 31,984,000 || 0.1547 % Damage only || 217,312 || 31,984,000 || 0.6794 % 1.248
Applying these probabilities to the estimated
total number of vehicles in the EU which would effectively receive no PTI if
mutual recognition was introduced, results in the following values: Table Error! No text of specified style in
document..18: Value of increased accidents || Probability || Number || Cost per accident (€)[91] || Total cost (€) Increase in fatal accidents going from high to no PTIs in place || 0.0048 % || 58 || 1,309,968 || 76,278,202 Increase in serious injury accidents going from high to no PTIs in place || 0.0296 % || 357 || 150,465 || 53,789,437 Increase in slight injury accidents going from high to no PTIs in place || 0.1547 % || 1,868 || 15,336 || 28,644,973 Increase in damage-only accidents going from high to no PTIs in place || 0.6794 % || 8,201 || 1,364 || 11,186,150 TOTAL || || || || € 170 million 1.249
In addition to this, if we assume that the average
additional distance travelled on a journey for this purpose is 100 kilometres,
taking an average time of one and a half hours, then the private cost per
vehicle would be € 44.[92] he total value of additional
travel cost would then be in the region of € 266 million. 1.250
If each vehicle travelling for a lower quality
PTI on average drives an extra distance of 100 kilometres for this purpose,
then the total extra volume of traffic on the road would be 603 million vehicle
kilometres a year, increasing CO2 emissions by around 121 million kilograms
annually,[93]
at a cost of approximately € 3.6 million.[94] 1.251
We stress that these figures are not based on
any firm evidence, but are to explore possible orders of magnitude on stated
assumptions. 1.252
If vehicle owners chose to travel increased
distances to receive a less expensive or rigorous PTI, this would be because
they expected that the benefits to them would outweigh the travel and other
costs. They might not take account of the externalities their decision would
impose, notably: (a)
the costs to others of any increase in the risk
of accidents; (b)
the costs of environmental emissions. 1.253
The question of whether PTI standards in some
Member States are below the socially efficient level is therefore fundamental
to the question of whether mutual recognition would be beneficial. However, we
do not yet have an answer to that question. 1.254
The costs of administration, including the
administrative burden in the sense used in EC impact assessments (which refers
only to the costs of providing information to show that regulations have been
followed) would also be significant. A system would be required for reliable
information to be provided by the MS performing the test to the MS of registration,
notifying that the vehicle has been inspected. 1.21.1.2. Benefits 1.255
Mutual recognition would bring direct cost
savings to some individuals and businesses, and further gains as a result of
increased competition for testers. All the potential single market benefits
would be achieved. 1.256
Savings would be made in the form of a reduced
number of kilometres unnecessarily travelled; leading to cost savings for
haulage companies and to the small number of private individuals who currently
drive long distances to return their holiday vehicle home for PTI testing. A
reduction in unnecessary journeys also implies reduced road congestion, road
wear and tear, air pollution and accidents (for the avoidance of doubt, there
would be an increase in the number of journeys made to take advantage of
cheaper or less rigorous testing, which might well outweigh this benefit). 1.257
In addition, time savings may be achieved in
some cases. UETR[95]
noted that a PTI is very often a time-consuming procedure and, in addition,
many PTI stations across the EU suffer congestion, with waiting times of more
than two hours quite common.[96]
In particular, UPTR[97]
highlighted the long waiting times in Belgium, where currently the PTI
association holds a national monopoly. If PTI testing is opened up to
competition between MS, inefficiencies such as these may be reduced. 1.258
The European Transport Board (which represents a
number of transportation and logistics companies in Europe) sent out a
questionnaire to its members in 2007 to estimate the costs incurred by EU
haulage companies annually because of the inability for trailers to be tested
in any other Member States than that which they were registered in. The
numbers extrapolated from this questionnaire indicate that around 14 per cent
of trailers have to make one empty trip back to their country of registration
annually for the purpose of a PTI. The cost incurred by haulage companies due
to the empty kilometres travelled amounts to € 101 million.[98]
In addition to this cost, empty journeys undertaken by trailers for the sole
purpose of returning to the country of registration for a PTI relate to 103 million vehicle kilometres and 65 million
kilograms of CO2 emissions (at a cost of approximately € 2 million).[99]
Biases in this result are likely to have occurred because the European
Transport Board only represents large companies, whose vehicles travel long
distances and who generally have good systems of intermediate testing in place. 1.259
Only trailers are
included in the calculation because there is evidence
that haulage companies would experience lower costs associated with trucks
returning to their country of registration for PTIs due to these vehicles
undertaking comparatively shorter rotation periods in general.[100] 1.260
This figure of 14 per cent of vehicles would
equate to approximately 0.25 per cent of all runs being undertaken empty for
the sole purpose of PTIs. Information held by DEKRA from German and Austrian
sources indicates that the share of empty rides has been decreasing over time. In
2007, the German Industry Association (BDI) published a position paper on
cabotage, in which they provided that the share of all runs being undertaken
empty was 19 per cent for regional operated transports and 10 per cent for long
distance travel.[101]
Another estimate of the numbers of empty runs in Germany is given by Bundesamt
für Güterverkehr, which is the regulatory authority for road transport. For
the year 2006, BAG published a number of 9 per cent for empty runs in
long-distance travel. Austrian data on the share of empty runs crossing the
Alps gave that in transit relations the share had decreased between 1994 and
2004 from 10 per cent to 5 per cent. 1.261
We expect that European haulers undertake a quality
of logistical planning comparable to German companies. Therefore, taking a
middle point of these estimates, assuming the share of all empty trailer rides
for European haulage companies is 9 per
cent, we notice that trailers are around one and a half times more likely to be
empty when returning for their PTI than for other journeys. Therefore the
logistical planning to ensure trailers do not have to return home empty for
their PTI is reasonably comparable, but slightly worse, than the average journey.
Empty journeys for the purpose of PTIs then represent less than 3 per cent of
all empty trailer journeys.[102] 1.262
For citizens living near a border between two
Member States, traffic may possibly be reduced and driving costs saved if the
option is given for the vehicle to have its PTI undertaken in a nearby testing
centre across the border rather than a more remote centre located in the Member
State of registration. 1.263
Leaseurope[103]
indicated that additionally some benefits may accrue to the automotive rental
industry: The lack of coherence in this area [mutual
recognition of inspections] complicates leasing and rental vehicle movements in
between Member States. The ability to allocate, utilise and ultimately sell
vehicles across borders can lead to significant efficiency gains, beneficial to
both drivers as well as the industry.
1.1.39.
Summary of Option 3
1.264
It is not certain whether the benefits of Option
3 would outweigh the costs, but they might well do so. Table Error! No text of specified style in
document..19: Summary table Option 3 Main costs || € million p.a. || Main benefits || € million p.a. Increased accidents || 170 || Reduced travel purely for purpose of test || 90-110 (adjusted ETB estimate) Increased travel cost to test centres || 266 || Reduced emissions from travel savings || 2 Increased emissions from travel to test centres || 3.6 || Reduced cost to motorists of tests and repairs not required || > 266 Increased technical standards of testing where desired by vehicle owners || Not known || || Increased competition between test centres || Not known || || Better functioning of vehicle leasing market || Not known Total || 439.6 || || >358 1.265 The benefits to vehicle owners of seeking out a lower-quality PTI
must exceed the increased travel cost, including the cost of their time, by a
significant margin to justify their going to the trouble. The savings achieved
must also exceed the motorist’s own valuation of any increased risk of an
accident (which would likely make up a large part of the total estimated cost
of the increased probability of an accident occurring). The longer-term benefits
of increased competition between testing centres and systems might complete a
justification of this measure. 1.22. Option
4: Impose a mandatory EU-wide system for PTIs and roadside testing 1.266
Under Option 4, a mandatory system for PTIs and
for roadside testing would be applied to every MS. It would include detailed
rules governing all eight ‘pillars’ of a PTI system. 1.267
A good balance of all eight “pillars” of the PTI
system would be desirable, as any gaps could reduce the overall effectiveness.
For instance, if testing centre staff do not possess the necessary skills to
undertake PTIs then a number of other pillars are likely to be compromised, and
if sufficient supervision and enforcement measures were not in place then the
whole system would fail. 1.268
As explained in Section 5, the definition could
be at various possible standards – we have used three, defined for the purpose
of this IA by DEKRA, to help to make the issues concrete. However, it should
be stressed that the detailed definition of any mandatory EU-wide system would
need to be discussed in more detail than has yet been possible. The
definitions suggested here are purely in an attempt to establish orders of
magnitude that may help the Commission to decide which path to follow. 1.269
Under Option 4 it would not be illegal to use
higher standards than those mandated; however, Member States would not be
permitted to insist on their standards being followed in other Member States,
since mutual recognition would be a component of Option 4. 1.270
This would be in line with the precedent set by
the current regulations on type approval.[104]
Member States must accept into circulation on their roads any vehicles which
have satisfied the requirements of the EU type approval Directive, as certified
by the Member State where the vehicle was manufactured. 1.271
Among the eight “pillars” it would seem simplest
to implement a common understanding for technology-driven parts of PTIs. For
the personal skills and qualifications there might be very different
definitions in EU Member States; there is no common standard for the education
of technicians and similar professions. Supervision and enforcement is also
very complex and undertaken quite differently in different Member States. 1.272
We now summarise DEKRA’s assessment of the costs
that would be involved in moving all MS from low to a medium or to a high
technical level of PTI testing. 1.273
In the EU there is at present a total of around
95,000 PTI test centres. This high number is due to the garages which
are involved in some MS, since garages often only do a few PTIs compared with
the test-only centres, which always have a high throughput per day. 1.274
From these test
stations we estimate: (a) 14% of the MS test stations are on low
level 10MS = 14,000 test stations (b) 43% of the MS test stations are on medium
level 12MS = 40,500 test stations (c) 43% of the MS test stations are almost on
high level 5MS = 40,500 test stations 1.275
In order to raise a station from a low level to
a medium level, the following costs would be incurred.
1.1.40.
Pillar 1 - Items to be inspected and method
1.276
This is one of the major issues for the
differences between Member State solutions. The additional effort for lifting
up the level from low to medium will lead to increased costs of staff and
equipment, as well as to the time necessary to complete a test. 1.277
This has to be seen in relation to the
additional equipment needed (pillar 3) and additional training needed for staff
(see pillar 4). In other words, it would be double-counting to cost both
Pillar 1 and Pillars 3 and 4.
1.1.41.
Pillar 2 - Definition of defects and assessment
of results
1.278
This will lead by an increased level of PTIs to
further repair costs and effort by the car owner. We have not provided an
estimate of this cost, since a repair ought to be made in any case,
irrespective of the testing system. If any of the higher technical standards
were not in fact justified, this assumption would lead to an under-estimate of
costs.
1.1.42.
Pillar 3 - Investment for lifting from low level
to medium level
1.279
The main costs would be: (a)
€ 10,000 for new shock-tester equipment; (b)
€ 8,000 for a modern roller-brake tester; (c)
€ 4,000 for equipment for testing modern
electronic devices. Total of € 22,000 1.280
Depreciating these costs over five to ten years
would lead to an annual cost of between € 2,200 and 4,400 a year; multiplied
by 14,000 test stations will lead to aggregate costs of between € 31 and € 62
million p.a
1.1.43.
Pillar 4 - Skills and applications of staff
1.281
For this improvement an increased income for
staff because of a higher grade of education should be assumed, as well as the
direct training costs. 1.282
We assume an increase
of approximately 20 per cent in labour costs. We would assume 28,000 testers
for the 14,000 test stations need to be qualified. (a)
estimated staff cost / inspector: €
50,000 /year (b)
+ 20% = €
10,000 /year (c)
times 28,000 inspectors €
280 million /year
1.1.44.
Pillar 5 - Vehicle classes to be inspected
1.283
For both vehicle categories as given below no
additional testing equipment is required. 1.22.5.1. Powered two
wheelers category L 1.284
Eurostat gives the
following numbers to registered two wheelers in the EU Member States: L3 - 12 million vehicles, L12 - each approximately 13 million vehicles. Although
the data are not complete for all Member States and are also a few years old,
they may be used as a base level assumption for these vehicles. 1.285
In most Member States
the test for L3 vehicles is
already mandatory. The cost implications for making the test mandatory can be
estimated as about € 100 million for all Member States assuming € 20 per test
every two years: Total cost: € 50 million/year.[105] 1.286
Training for a qualification for testing powered
two-wheelers can be seen as an additional cost but not significant. 1.22.5.2. Light trailer O2 0.75 to 3.5 tons 1.287
Today in 21 Member States testing of light
trailers is already mandatory. The UK, France, Portugal, Netherlands, Denmark,
and Malta do not see any justification for a mandatory inspection for light
trailers. 1.288
A calculation for the
whole EU gives an approximation of about 4.5 million additional trailers to be
tested every two years, therefore an average of 2.25 million trailers a year at
an average cost of € 35 a test, amounting to a total extra cost of € 80 million
a year.
1.1.45.
Pillar 6 - Test frequencies for PTIs
1.289
To increase test frequencies from low (4-2-2) to
medium (3-2-2) it can easily be seen that for new vehicles the first inspection
and each subsequent inspection would be one year earlier. In Member States
with 4-2-2 the cost for PTIs would increase by seven per cent over the lifetime
of the vehicles (17 years) to switch to 3-2-2. 1.290
About half of the vehicles are in Member States
where PTIs starts in year four. This is the situation for 100 million vehicles. –
17 years is the average period of use before
scrapping –
17 years by a 4-2-2 scheme: 7.5
inspections –
17 years by a 3-2-2 scheme: 8 inspections 1.291
This is half an inspection more over 17 years,
so an average of 1/34 extra inspections a year, for 100 million vehicles. At
an average inspection price of € 50, this comes to € 147 million per year.
1.1.46.
Pillar 7 - Supervision of inspection scheme and
enforcement of the system
1.292
Looking at the
solutions implemented by Member States already on a medium quality level,
average costs can be estimated of € 0.70 per year and vehicle for the effort of
quality insurance and other measures of the involved PTI organisations as well
as the governmental authorities. So the maximal additional cost a Member State
may be subject to can be seen as € 0.70 if - more or less - no supervision or
enforcement of the system exists today. In most of the Member States defined
as low quality a minimum amount of supervision might be in force, so the
additional cost can rather be estimated as € 0.30 per year and vehicle. 1.293
(We can give no more details; this is an expert
guess by DEKRA and is not supported by data.)
1.1.47.
Pillar 8 - Data
exchange
1.294
CENTIQ estimates that
increased spending on data exchange for both operational and strategic planning
purposes would cost approximately € 8 million per year.
Details are given in Appendix 4 and later in this section. Estimated costs to lift all Member States
at least to medium level 1.295
Taking into account which Member States are
currently implementing a low level of PTIs and their number of inspection
stations, we can make an overall estimation for the additional costs which
would be required to bring these Member States to a medium level of PTIs. If
we exclude the position taken to supervision by each Member State - which is
more or less dependent on each authority’s inside evaluation – we have
sufficient information to construct an estimate for reaching a medium level of
PTIs in all Member States. By summing up the rough estimations, we have for
low to medium additional costs of € 604 million per year. This is made up of: (a) € 47 million for Pillar 3 (b) € 280 million for Pillar 4 (c) € 130 million for Pillar 5 (L and O) (d) € 147 million for Pillar 6 (3-2-2) 1.296
We now give the corresponding estimates for
lifting all Member states to the highest level described.
1.1.48.
Pillar 3 Investment for lifting from medium to
high level
1.297
The costs would be: (a) € 2,000 for enhanced equipment for
testing (b) € 5,000 for enhanced emission testing (c) € 8,000 load simulation for brake
testing for 10,000 truck test stations.[106] 1.298 Estimating € 7,000 for 54,000 stations the
cost would be € 378 million. € 8,000 for 10,000 stations would cost € 80
million. Adding these one-off costs and depreciating over 10 years would give
an annual cost of € 45.8 million.
1.1.49.
Pillar 4 Skills and applications of staff
1.299 From medium to high level of staff qualification again an increase
of expenses by 10% is estimated. The cost per inspector, including on-costs as
well as wages, might be € 60,000 p.a.[107]
With 100,000 inspectors,[108] a 10 per cent increase would
cost € 600 million p.a.
1.1.50.
Pillar 6 Frequency of PTIs
1.300 More than half of all MS have already a yearly PTI for older
vehicles. For the rest, about 100 Mio vehicles average 17 years’ lifetime
before scrapping. With five additional inspections before scrapping and an
average inspection price of € 50 the cost would be (€ 250 /17 years =) € 14.71
/year and car. 1.301 This gives an estimate of € 1,471 million p.a. in additional cost. 1.23. Estimated
costs to lift all MS to HIGH level 1.302 In sum the cost to lift PTIs in the EU from medium to high level is
calculated as € 2,117 million: –
Pillar 3 €
46 million –
Pillar 4 €
600 million –
Pillar 6 €
1,471 million 1.24. Summary 1.303
Summarising this estimated cost gives a first
impression for the relation between the defined (but not always in reality
existing) levels in the Member States. In fact in some cases a mixture of
levels in Member States can be seen (high level in technology but low level at
staff qualification). 1.304
It may also be seen as a toolbox, where the
individual components can be arranged to make the most effective and best case
solution. It also has to be mentioned, that it would be obvious to switch to a
medium (+) level first, rather than going directly to the high level. 1.305
In general, a large
component of the total cost of moving up the levels relates to staff training
and wage increases rather than to equipment costs. Costs for additional
equipment moving from low to medium level amounted to only 8 per cent of the
total costs, and moving from medium to high level this cost only represented 2
per cent overall. 1.24.1.1. Benefits 1.306
The benefits from Option 4 would depend on the
standards imposed. Assuming these were at medium or higher levels, the
benefits should include a reduction in the numbers of unsafe vehicles and hence
in road accidents. Since Option 4 would include mandatory mutual recognition, some
single market benefits would also be obtained. However, these benefits would
be reduced to the extent that under Option 4 the scope for vehicle owners to
make savings by travelling to lower-cost testing centres was reduced. 1.307
Evidence in support of the view that higher
standards would be beneficial includes: (a)
The AUTOFORE report, which recommended an
increased minimum frequency of testing. (b)
A study undertaken by the UK Department for
Transport in 2008 found through random compliance surveys that currently some
10 per cent of all cars on the road have a significant defect of some
description, and are therefore not roadworthy. Based on the fact that at the
time 36 per cent of all cars were failing their MOT test each year, potentially
the percentage of defective cars on the road would increase to 42 per cent the
first year after testing was stopped, an increase of some 400 per cent on the
total number of unroadworthy cars on the road. The study estimated that if
testing were to be stopped altogether, there would be something like an 800 per
cent increase in the number of unroadworthy vehicles once a ‘steady-state’ had
been reached. These calculations assumed no behavioural responses, on the
grounds that they are unknown. (c)
Work by Professor Schultz, reported to the
experts’ workshop (see Appendix 1), which concluded that German frequency rates
of PTI should be increased for older vehicles. 1.308
However, a study by Christensen and Elvik (2007)[109] put the safety benefit of PTI
regimes of cars into question. The study looked at the effects on accidents of
periodic motor vehicle inspection in Norway, by investigating the impact of a
substantial change in the programme for PTIs in Norway in 1995. Negative
binomial regression models were fitted to data on accidents and inspections
supplied by a major insurance company and by the Norwegian Public Roads
Administration. The study came to the following conclusions: (a)
technical defects in cars are associated with a
small, but statistically significant increase in accident rate; (b)
periodic inspections lead to the repair of
technical defects; (c)
following periodic inspections, the accident
rate of inspected cars does not decline, but shows a weak tendency to increase. 1.309
To explain this apparently inconsistent result,
they consider potential behavioural adaptations of risk compensation amongst
car owners to the introduction of PTIs: When a car is inspected, and owners are
forced to repair at least the most serious technical defects, behavioural
adaptation may occur because owners now think that cars have become safer than
before. This hypothesis is speculation only; no data are available to test
it. Yet, the combination of selective requirement of unsafe drivers to poor
cars and behavioural adaption following technical inspection may explain the
apparently inconsistent findings of the study. 1.310 A study by Poitras and Sutter (2002)[110] in the US similarly found
that PTIs were a poor instrument for achieving policy goals. They analysed the
impact of PTIs on old cars in use and on repair industry revenue between
1953-1967 and found that inspection had no significant impact on either, which implies
that the presence of a PTI regime does not lead to an overall improvement in
the mechanical condition of vehicles, as this would involve costs which are not
realised. They took the reason for this to be that either drivers were already
voluntarily providing the efficient level of maintenance when considering only
private benefits (i.e. the maintenance externality might be infra-marginal), or
that PTIs were poorly enforced or unenforceable, so that vehicles were
generally approved without meeting the requirements. Their method ruled out
the possibility of interpreting the results as showing that drivers of
mechanically inferior vehicles might compensate by driving more cautiously. 1.311
However, we have little information about the
situation with regard to the ‘pillars’ other than frequency of testing; and no
information about the situation in those MS whose systems would need most
investment to bring them up to the DEKRA medium standard (DEKRA estimates that
about 25 per cent of MS currently fall significantly short of those standards). 1.312
A more standardised approach to roadside testing
might facilitate some policy analysis, but is not required for operational or
any other purposes. 1.313
We now review more evidence as to the likely
benefits from different components of Option 4. The picture available is very
far from complete. 1.24.1.2. Frequency of Tests 1.314
The effect of increasing the frequency of PTIs
is shown in the figure below. Figure Error! No text of specified style in
document..6: Benefits of increasing PTI frequency Source: CITA
(2007) “AUTOFORE Report: Study on the Future Options for Roadworthiness Enforcement
in the European Union” 1.315
As well as providing additional safety benefits,
increasing the frequency of PTIs may also provide some cost savings. This is
because defects, if left undetected for a period of time, can go on to cause
secondary defects which cost the motorist significantly more to repair e.g.
faulty steering components causing tyre wear or worn brake pads causing damage
to discs.[111] 1.316
In the AUTOFORE study undertaken in 2007[112] the finding was that, based
on cost-benefit analysis of different PTI frequencies in Germany, the optimal
system involved a testing frequency of 3-2-2-1 (up from the current system of
3-2-2). The total benefits achievable from this change were calculated as € 2.1 billion across the EU, or € 59 per
additional inspected car. In comparison, the costs of the additional test were
calculated as amounting to a total of € 1.3 billion, estimated using an average cost-unit rate for passenger
car inspections of € 35
(without any taxes). 1.317
Similarly, a study undertaken by the UK
Department of Transport (DfT), in 2008,[113]
determined that the optimal system was to continue their frequency of testing
at 3-1-1, rather than reduce the frequency to 4-2-2, 4-2-1 or 4-1-1. The key
road safety conclusions the study came to were (mid-range estimates): (a)
moving to a frequency of 4-2-2 would risk an
additional 408 road deaths per year[114]
(this would represent an 18 per cent increase over the record low of 2,222
deaths recorded in 2009[115]);
and (b)
moving to a frequency of 4-2-2 would risk an
additional 2,504 serious injuries per year.[116] 1.318
The estimated incremental annual cost to society
of the move to a PTI frequency of 4-2-2 was calculated as follows: Table Error! No text of specified style in
document..20: Incremental costs of increased PTI
frequency Incremental road deaths and injuries || € 1,718 million (DfT) Incremental air pollution || € 1 million (DfT) Incremental enforcement costs || € 15 million (DfT) Less motorist annual MOT cost saving || - € 626 million (DfT) Less motorist annual MOT personal time saving || - € 89 million (DfT) Net cost on median scenario || € 1,020 million Note: Original costings were given in
pounds sterling – these have been converted to Euros at the average exchange
rate September 2009 – September 2010 of 1.15 1.319
In addition, a frequency of 4-2-2 would mean a
significant loss of VAT/tax revenues due to reduced repair/parts sales. A
reduction in jobs would also be seen in the PTI industry, at an estimated cost
of € 552 million (trade
estimate – cost of 40,000 lost jobs, or 40 per cent of the current workforce at
€ 13,800 per head). 1.320
A stakeholder noted that since this review had
been completed the MOT failure rate in the UK has actually increased – from 33
per cent in 2006/2007 to 37 per cent in 2009/2010 – and that due to economic
reasons, motorists are currently buying fewer new vehicles and reducing
servicing/repairs on existing vehicles. 1.321
There is therefore some evidence that, at least
in the higher-income Member States of the EU, the frequency prescribed in the
current directive is below the optimal level. Both these frequency
recommendations correspond to somewhere between the medium and high frequency
levels as described in options 4b and 4c. 1.322
A recent review of the PTI frequency in the
Netherlands led to the decision to reduce the frequency of PTI required, from
3-1-1 to 4-2-2-1 in January 2008.[117]
Vehicles running on LPG or diesel are still required to undergo PTIs at the
3-1-1 schedule, since these vehicles tend to have a higher annual mileage than
vehicles with petrol engines. 1.323
In 2004, Sweden reduced the frequency of PTIs
required for the vehicles showing the best testing results and least mileage:
motorcycles, trailers and caravans. Before 2004, the first test was conducted
after two years and then every year for vehicles aged ten years or more, now
the first PTI is done after four years and subsequently every second year.
Since this reduction in PTI frequency, the PTI performance of these vehicles
has seen the following trend: Table Error! No text of specified style in
document..21: PTI failure rates for different vehicle
categories in Sweden, 2001-2009 Year || Motorcycles || Trailers || Caravans || Cars 2001 || 8% || 19% || 13% || 34% 2002 || 8% || 19% || 14% || 33% 2003 || 8% || 17% || 16% || 33% 2004 || 9% || 19% || 16% || 32% 2005 || 9% || 22% || 17% || 32% 2006 || 10% || 26% || 22% || 32% 2007 || 10% || 26% || 19% || 32% 2008 || 10% || 26% || 22% || 30% 2009 || 10% || 26% || 17% || 29% Source:
Statistics from Bilprovningen, Sweden 1.324
As PTI testing frequencies currently in place
across the EU are at different levels, any new level of minimum frequency
required will only affect some EU countries (as the others already test to this
frequency or above). The table below lists the countries that would be
affected if a new minimum frequency was set at one of the patterns discussed
above. Table Error! No text of specified style in
document..22: Countries which would be affected if the
frequency of PTI was changed to different levels Testing frequency: || 4-2-2-1 || 3-2-2-1 || 3-1-1 Source of recommendation: || Netherlands || AUTOFORE || UK Countries affected: || Denmark Germany Greece France Ireland Italy Czech Republic Estonia Hungary Lithuania || Belgium Denmark Germany Greece Spain France Ireland Italy Portugal Netherlands Czech Republic Estonia Hungary Lithuania || Belgium Denmark Germany Greece Spain France Ireland Italy Austria Portugal Netherlands Finland Sweden Czech Republic Estonia Hungary Lithuania Poland 1.24.1.3. Technology and
Procedures 1.325
Few studies have been carried out on the cost
benefit analysis of including the inspection of additional components in PTIs.
One exception to this is a 2006 study by Baum and Grawenhoff on “Cost benefit
analysis of the Electronic Stability Program (ESP)”.[118] This study found that the
yearly benefits of ESP-penetration of cars in EU-25 in 2006 were € 10 billion. Under the assumption that
seven per cent of ESP will not function properly, € 0.7 billion benefits were not being reached. On average in the
EU-25, 41 per cent of vehicles are inspected each year. The additional
inspection of ESP led to an assumed detection ratio of 80 per cent (based on
empirical findings in Germany). Therefore the total EU benefits of the
additional inspection of ESP are calculated as € 230 million. Conversely, the total EU costs of the additional
inspection of ESP are calculated as € 87.1 million. So the benefit-cost ratio for the additional testing
of ESP, as included in option 4c, is 2.6. 1.326
A study done by Rompe and Carlitz (2003)[119] found that new electronic
systems have failure rates of about one failure per million operating hours.
However, each vehicle will have many such electronic systems installed.
Looking specifically at ABS faults they found that, although the mean percentage
of M1-vehicles which had recorded trouble codes related to ABS disturbances /
faults in their CPU was 17 per cent, this goes up to 57 per cent for vehicles
aged five to eight years.[120] 1.327
Electronically controlled safety systems (ECS)
are becoming increasingly prevalent in modern vehicles and therefore are an
area of interest for the expansion of the technological requirements for PTIs.
A number of studies have investigated which ECSs have a high safety performance
and are cost-effective, and thus are potential targets for PTI inclusion. Table Error! No text of specified style in
document..23: Electronically controlled safety systems
evaluated as cost-effective by different studies eIMPACT[121] || eSafety[122] || ADVISORS[123] Electronic Stability Control || Electronic Stability Control || Interurban Adaptive Cruise Control (ACC) Full Speed Range || Active Cruise Control with Emergency Brake || Urban ACC with Stop & Go Emergency Braking || Blind Spot Monitoring || Lateral Support System Pre-Crash Protection of Vulnerable Road Users || Brake Assist || Driver Monitoring System Lane Changing Assist || Adaptive Headlights || Board Computer in Trucks Lane Keeping Support || eCall || Lane Warning and Collision Warning System NightVisionWarn || Obstacle and Collision Warning || Variable Speed Limiter Driver Drowsiness Monitor and Warning || Advance Hazard Warning || ECall || Lane Departure Warning || Intersection Safety || Seat Belt Reminders || Wireless Local Danger Warning || || Speed Alert || || 1.328
Germany has made the inspection of ECS within a PTI
mandatory for all vehicles registered since 1 April 2006. Up to a total of 43
different functions of ECS[124]
are required to be tested if they are safety critical. However, as these
functions are generally clustered, usually less than 6 ECS will be subject to a
PTI for any one vehicle. 1.329
Electronic components are typically
characterised by significant “infant mortality” followed by a low failure rate
during the intended lifetime of the component, then an increase in failure rate
once the end of the intended life is reached. Depending on the type of
component and the electronic parts manufacturer, electronic components are
often partly pre-aged to avoid “Infant Mortalities” after the component has
already been installed in a vehicle. Therefore, end-of-lifetime failures are
the most important consideration for PTIs of electronic components. 1.330
The European Garage Equipment Association (EGEA)[125] noted that often a visual
check of some safety components is not sufficient. For example, when checking
ABS valves, the malfunction indicator lamp (MIL) might be off but in reality
the ABS values may still not be working properly. In their response to the
public consultation they provided a detailed recommendation for an inspection
procedure to check relevant safety systems. They noted that in practice it is
not possible to check the functionality of driver assistance systems like ABS,
ESC and brake assistance under simulated conditions of these systems during PTIs.
It is, however, technically feasible, depending on the availability of the
appropriate equipment, to check the efficiency and plausibility of the results
from the involved sensors. 1.24.1.4. Vehicle Categories
Covered Category L 1.331
The number of motorcycles in circulation in the
EU has increased significantly in the last ten years. Between 2001 and 2008
the number grew from 16 million to more than 22 million; a growth of around 38
per cent. Taking all types of two-wheeled motor vehicles into account,[126] a total of approximately 33
million powered two-wheelers (PTWs) were in circulation in 2008. 1.332
Motorcycles are currently by far the most
dangerous means of transport. In 2008, the number of recorded fatalities amongst
motorcyclists was 5,126 (EU-24)[127]
or around 14 per cent of the total number of accidents recorded in these 24
Member States. This is to be contrasted to the fact that PTWs account for just
two per cent of all road users (2006 survey)[128]
or 10 per cent of road vehicles. In a number of countries the total of fatally
injured motorcyclists has been rising over the last ten years. 1.333
For the categories of vehicles representing
vulnerable road users, namely motorcycles and mopeds (category L), the part of
the cost of accidents which falls on individuals other than the driver or owner
is lower than that for other vehicles. Therefore it is less likely that owners
of these vehicles will maintain their vehicles to a level that is socially
sub-optimal, meaning a level below that which best reflects the possible costs
to both the drivers / owners and to others who might be affected by an accident.
Although the safety costs of maintaining their vehicle in good condition mainly
fall on PTW drivers, costs relating to emissions and excess noise from these
vehicles still fall on others. So the arguments for periodic emissions testing
of PTWs are the same as for other vehicle categories, albeit needing to be
adjusted to take into account the smaller quantities of pollution produced by a
PTW. 1.334
The Federation of European Motorcyclists’
Associations (FEMA) provided the following statement with regard to the
differences between owners of PTWs and other vehicles: Users of PTWs are well aware of the need to
maintain their machines in a safe condition. […] A motorcyclist has a closer
relationship to his vehicle and the majority perform basic vehicle maintenance
by themselves. Checking the PTW is easier in comparison to cars since all the
safety related parts are usually easy to access. Being a vulnerable road user, it is always
in the interests of the motorcyclist to reduce any possible risk of accident,
as he would be the first one to suffer. 1.335
For those vehicle owners who are maintaining
their vehicle regularly by themselves or having them regularly checked by a
private garage as part of a guarantee, PTI regimes would predominantly be just an
administrative burden. 1.336
In the 2010 DEKRA report,[129] the results of 700
motorcycles tested following an accident were reported. The report found that
8 per cent of vehicles involved in the examined accidents had defects “of
relevance to the accident”. This is similar in level to that found for cars.
From the available data, the assumption is that in a large number of cases
tyres were likely to blame (either the tread depth was too shallow, the tyres
were defective or the tyre pressure was too low). For PTWs, tyre pressure and
tyre condition have a direct impact on riding conditions and therefore in
theory need to be checked constantly. In the cases where the vehicle owner
checks these regularly themselves or is quick to respond to any perceived
deterioration by submitting the vehicle for repair (as it likely to be
necessary to continue riding) the benefits of PTIs in checking these features
is likely to be minimal. The position provided by FEMA[130] was that many other technical
failures of PTWs also require instant action, and therefore a reliance on
regular annual or bi-annual inspection is misleading. 1.337
In addition, a study was undertaken by the European
Association of Motorcycle Manufacturers (ACEM) in 2009[131] providing an in-depth
investigation of accidents involving PTWs. This study examined a sample of 921
accidents with PTW involvement in 5 EU MS. In a total of 3 cases (0.3 per
cent) vehicle failures which were to blame as the “primary accident
contributing factor” were reported. 1.338
However, the demographics of PTW users is
changing. Increasingly PTWs (in particular scooters) are being used as a cheap
and fast mobility option for urban transport, especially by young people or the
lower social classes, rather than being used to ride for pleasure. This
growing group of users is assumed to be less knowledgeable and to take much
less care in maintaining their vehicle, often due to price sensitivity to the
costs of running a PTW. 1.339
The AUTOFORE study[132] provided the following with
regard to the testing of motorcycles for safety purposes, bringing out the
differences between the two groups of users: In North-European countries like Germany
and the Netherlands (possibly the UK) and the Nordic countries, motorcycles are
mainly used for recreational purposes. They tend to belong to the upper market
ranges. Generally they are well maintained, and are replaced at a relatively
young age. Periodic inspection may not add much to the safety of such
vehicles, which was also the view expressed in an interview with a leading
Dutch motorcycle magazine. In south-European countries motorcycles are
much more the usual means of transport for either young people or the lower social
classes. The bikes are smaller and less expensive. They may not be replaced
so quickly either. Further information would be needed concerning maintenance
standards. PTI[s] may well have more benefits in such countries, but actual
data would be needed for such conclusions. 1.340
The high price sensitivity assumed for urban PTW
users means that the additional cost of running a PTW that would occur if PTIs
were introduced for this vehicle class might mean many users at the margin have
to give up their PTW. 1.341
A shortage of data has inhibited the undertaking
of a full economic analysis to quantify the magnitude of the benefits of
extending Directive 2009/40/EC to include two-wheeler vehicles, including
preventing any analysis of how this benefit has changed in line with the
evolving demographics of PTW drivers. Accident evidence on the current costs
is not sufficient on its own to justify the inclusion of PTWs in the Directive,
due to the high proportion of these costs which are private (this proportion
has not been calculated as far as we are aware). Category O2: 1.342
In all EU countries heavy trailers (weight
exceeding 3.5 tonnes – classes O3 and O4) are covered by
mandatory PTIs because of the large risk they pose to other road users in the
case of acquiring a technical defect. However, EU law does not require that
lighter trailers (weight less than 3.5 tonnes) must be covered by PTIs.
Currently O2 vehicles (trailers with a maximum mass exceeding 0.75 tonnes, but
not exceeding 3.5 tonnes) are not subject to PTIs in France, Portugal,
Netherlands, the UK, Denmark or Malta. The vehicle class O2 typically
contains caravan trailers for private use as well as transportation trailers,
and trailers with working machines for professional use. 1.343
Based on the 2009 data of DEKRA trailer
inspections in Germany (which recorded the results of the tests for more than
one million trailers) a lower share of O2 trailers were found to
have serious defects (11 per cent) than was the case for O3 or O4 trailers
(19 per cent). Compared to all trailers, O2 trailers showed higher
than average numbers of defects in the attachment parts and chassis, but lower
than average numbers of defects in brakes and steering.[133] Category M1 – in commercial
use: 1.344
A lot of M1
vehicles are registered by companies and not by private owners. For
roadworthiness purposes the question is whether these vehicles do run under
more straining conditions than the M1 vehicles in general. On the one hand a
lot of these vehicles are used in a similar way to privately owned vehicles,
for travelling between home and office and some additional journeys across the
country for business or personal use. On the other hand, some M1
vehicles registered for business use do have a very different profile of use
compared to privately owned vehicles. They may run to building sites, fully
loaded and on badly prepared country lanes, or drive high mileages with or
without load. 1.345
M1 vehicles
with very high mileage can be seen as comparable to taxis, which are definitely
in business use and for which additional requirements to PTI are already given
by the EU. In this case a definition of “vehicles registered for business use”
+ “high mileage (e.g. more than 40,000 km/year)” can be used to define a class
of vehicles for special focus in roadworthiness for adapted frequencies of
inspection. 1.346
Inspection results show
that the average rate of defects in the vehicles increases in relation to the
mileage travelled yearly, from about 14.8 per cent of defects (including 4.4
per cent of serious defects) up to 31.1 per cent of defects (including 10.7 per
cent of serious defects) for the vehicles in the highest mileage class. The
results for the vehicles in the highest mileage class (> 40,000 km/year) can
be seen as nearly similar to the results for taxis. In fact the average
mileage for vehicles in this vehicle class is about 66,810 km/year, which is
also close to the result for taxis with about 58,000 km/year. The number of
vehicles with a yearly mileage over 40,000 km is about four times the number of
taxis inspected during the same period. 1.347
While the criteria for
“vehicle registered for business use” can be handled in most cases by use of
vehicle documents or in some Member States by use of a direct data connection
in PTIs, the use of the additional mileage criteria is new. As this is not
standard in the EU, this information needs to be integrated into the vehicle
inspection procedure and reporting. In addition it requires a different kind
of signing for the control of vehicles, because a sticker on the license plate
or the windshield with the date to next inspection is no longer useful. A
solution using wireless communication may be feasible at some stage in the
future. Odometer-based measures also have to take care of fraud related to odometers,
which is already a problem in the used-car market. In Belgium, the mileage is
currently used as one indicator for the PTI–frequency of M1
vehicles. 1.348
The share of M1
vehicles (taxis already excluded) with very high mileage and up to 6 years of
age in all vehicles is 1.22 per cent. Therefore, the combination of the
criteria “registered for business use” and “very high mileage” would result in
additional inspections for 1.22 per cent of all vehicles in Germany. It can be
expected that the share of vehicles in business use might be lower in other
Member States. So as an overall assumption about 1 per cent of the M1
vehicles would be subject to an additional high-mileage based inspection for M1
vehicles in commercial use. Agricultural vehicles 1.349
According to the UPTR[134] and UETR[135] the road haulage business has
been suffering from unlawful competition from agricultural vehicles for a
number of years. Modern agricultural tractors have much higher maximum speeds
than in the past, leading to this increase in competitiveness versus trucks.
However, agricultural vehicles are currently still exempt in a large part from
EU provisions. Their conviction was that these vehicles should be made subject
to PTIs in order to make them less attractive for unlawful road transportation. Historic vehicles 1.350
The characteristics and use patterns of historic
vehicles[136]
are different to other vehicles and therefore potentially merit different
testing regimes. The current legislation (2009/40/EC) includes the provision
for MS, after consultation with the Commission, to set their own testing
standards for vehicles considered to be of historic interest. 1.24.1.5. Structural effects 1.351
There are a number of structural effects that
changes to PTI regulation may cause. For instance, if PTI requirements are
increased, more defects are likely to be discovered on vehicles, and therefore
repair costs may increase, in particular for older vehicles. Because of this,
the decision may be made to retire old vehicles earlier, as the costs of
maintaining roadworthiness become prohibitive earlier on. This would lead to a
decrease in the average age of vehicles on the road, and therefore, on average,
vehicles would benefit from more up-to-date safety technology. This would
increase the costs to vehicle owners of owning a vehicle, but improve road
safety and increase the market for new vehicles.
1.1.51.
Summary of Option 4
1.352
It is uncertain whether the benefits of any
version of Option 4 would outweigh the costs. 1.353
We assume little cost in implementing Option 4a,
since this was conceived as broadly the present lower technical level of PTI.
The benefits of Option 4a would be similar to those of mutual recognition at
present levels of testing. 1.354
In order to move all Member States to level 4b,
the orders of magnitude of annual cost are given below (capital or one-off
set-up costs having been amortised as explained in the text). Table Error! No text of specified style in
document..24: Implementing option 4b Pillar || Cost € million p.a. || Benefits 1 Items inspected || Covered in headings below || 2 Definitions of faults || Covered in headings below || 3 Equipment || 31-62 || No studies done 4 Staff || 280 || No studies done 5 Vehicles covered || 130 || No studies done 6 Frequency || 208 || Positive in rich countries 7 Supervision || Not known || Not known 8 Data[137] || 8 || Likely to be positive Total || >657 || Not known – no studies done 1.355
These costs would all fall on those Member
States which have up to now opted to implement a cheaper and less rigorous
system of PTI than defined by us as medium quality. 1.356
The following table summarises the costs of
moving to Option 4c. They would fall on all Member States except those already
operating the most technically rigorous forms of PTI. Table Error! No text of specified style in
document..25: Implementing option 4c Pillar || Cost € million p.a. || Benefits 1 Items inspected || Covered in headings below || 2 Definitions of faults || Covered in headings below || 3 Equipment || 46 || No studies done 4 Staff || 600 || No studies done 5 Vehicles covered || - || No studies done 6 Frequency || 833 || Significantly positive in rich countries 7 Supervision || Not known || Not known 8 Data[138] || 8 || Likely to be positive Total || 1,487 || Not known – no studies done 1.25. Option
5: Deregulation at EU level 1.357
This option was discarded as being politically
unrealistic in view of the recently adopted EC policy orientation. 1.358
Assessments of the value of roadworthiness
testing have shown positive impacts, and therefore deregulation at EU level
would come at an overall cost to the EU. 1.26. Information
exchange 1.359
Information sharing is an integral part of all
policy options described; the monitoring of a policy choice is only effective
when data to support or counteract the argument are available. The level,
value and necessity of information sharing will vary depending on the policy
option taken forward by the Commission. 1.360
A distinction needs to be made between: (a)
Those uses that are for strategic reporting
that, whilst not generally time critical, need very large data volumes to be
processed. (b)
Those uses that are operational in nature and
require rapid access to records of specific vehicles. 1.361
All of the policy options would benefit from
enhanced data exchange, and some would require enhancements as part of the
deployment. 1.362
Whilst this is not the place for an in-depth
technical design, which is a separate phase of EU policy-making, it is
important, as part of this economic impact assessment is to give expected costs
associated with such a systems delivery. In order to facilitate improved
testing standards an analysis was made of options for the best placement of information;
whether this should be centralised, distributed, or joined via interconnected
data links through the Member State systems. This also allows for indicative
architecture costs to be presented. Architectural Options are presented in Appendix
3: . 1.363
The final element covers the costs and benefits
and where these are qualified and quantified. Costs covered would include set-up
costs and ongoing costs, and the administrative burden costs to validate the
system and monitor and support service level agreements. These are highlighted
below and laid out in more detail within Appendix 3: . 1.364
A questionnaire was sent to the Member State
organisations to determine the current position and infrastructure of the
existing information systems pertaining to periodic testing. Where it was
shown that a Member State had one or more main contractors providing the
service the questionnaire was distributed to these organisations. 1.365
At the time of the Stakeholder meeting a total
of five Member States had submitted input to the main questionnaire, with an
additional two states providing answers to the subset questions. Following a
final request at the Stakeholder meeting a further four states provided input. 1.366
Results show that whilst there is some
consistency of applications across the Member States, omissions of what would
be deemed critical fields are common as shown below. Table Error! No text of specified style in
document..26: Data systems in place VIN || Recorded level 100% Registration plate || Recorded level 91% Engine type || Recorded level 100% except hybrids with 1 stated omission Engine euro class || Recorded level 82% Mileage / odometer reading || Recorded level 82% Failures || Recorded level 100% (yet may not be consistent recording) Failure details || Recorded level 82% and not consistent Date of first registration || Recorded level 100% Source: Questionnaire responses from
Member State organisations 1.367
The following aims and justification for a
central information exchange were provided. More detailed information on the
aims, benefits and comments is in Appendix 3: . Table Error! No text of specified style in
document..27: Aims and justification for a central
information exchange AIM || Aim description || Type || LEVEL of testing integration required || Ability to execute across Member States || Expected benefits and quantified value statement A1 || CO2 emissions and mileage analysis || Strategic reporting || All || Partial – full conformity of 2010/48/EU will facilitate || A2 || Vehicle demographics || Strategic reporting || All || Partial – full conformity of 2010/48/EU will facilitate || A3 || Consumer advice 1. Fault prevalence || Strategic reporting || From level 2, Optimum 3 + || Limited – requires standardisation of information || A4 || Roadside test authorities || Operational report || From Level 1, Optimum at level 3+ || Strong on limited data fields || A5 || Consumer advice 2 anti-fraud || Operational report || From Level 1, Optimum at level 3+ || Partial delivery by Member States in place || A6 || Type approval visibility within PTI test operation || Operational processing || From Level 1, Optimum at level 3+ || Requires new-type approval systems to be introduced || 0.5% reduction in road deaths p.a. A7 || Anti – Corruption, Fraudulent and Inaccurate pass rate reduction || Operational and strategic reporting || From Level 1 || Partial – full conformity of 2010/48/EU will facilitate || A8 || Information for those carrying out PTIs || Operational report || all || Requires clearer definition of information value. || The following aims were also suggested; however, these are deemed to be closely linked to, or subsets of, aims presented above or are out of scope for this report A9 || Easiness of the work of independent garages and parts manufacturers || Operational report || || || A10 || Police / agency vehicle checks || Operational reporting || || || A11 || Vehicle recalls || Operational || || || 1.368
The main anticipated costs to introduce
information exchange services based on currently available information are
estimates within a range of +/- 25% and are in addition to existing Member States’
IT budgets. 1.369
CENTIQ estimates that an EU central Strategic
Reporting System would take some five years to completion, and cost
approximately € 5 million (or an annual average over its life of € 1 million).
1.370
A distributed operational (minimal) information
exchange to support policy options 3 and 4 would take five years to complete
and cost approximately € 36.4 million (an annual average of approximately € 7 million).
1.371
In combination, therefore, the additional costs
of enhanced data exchange which would support all policy options would be approximately
€ 8 million p.a. 7 Comparison
of Options 1.27. PTI 1.372
Under Option 1 (continuation of existing
policies) the system would continue to improve, and it is possible that more
Member States may decide to implement bilateral agreements for mutual
recognition. However, the full potential single market benefits could not be
achieved, and scope for faster progress in reducing road accidents might be
missed. By definition, costs and benefits of Option 1 are zero. 1.373
Option 1a offers potentially very cost-effective
improvements. Improving road safety in a cost-effective manner is an objective
likely to be supported by all concerned, and the scope for system improvements
as a result of policy analysis facilitated by the Commission seems substantial;
at little cost. However, there is no guarantee that all single market issues
would be solved in this way. 1.374
Option 2 addresses the single market issues
directly, but on a partial basis. It is likely to be inexpensive; and to
reduce the scale of the single market issues while not offering a complete
solution. We see no reason not to pursue Option 2 as an increment to Option
1. 1.375
Option 3 is more problematic at this stage,
since although it would solve all single market issues it carries some risk of
lower road-safety standards. It is quite possible that the benefits of Option 3
would exceed these costs. 1.376
Option 4 would take the EU into new regulatory
territory, as the present legislation does not address all of the eight
“pillars” by which an ideal PTI system might be defined. Research into optimal
frequency levels has suggested that there is a case for increasing these, in
some high-income countries, but in current and prospective difficult economic
circumstances it would be important to be quite sure that the additional costs
would be justified for lower-income Member States in particular. We have found
no adequate research into the social costs and benefits of other “pillars”. 1.377
The options form a natural progression, in the
sense that by pursuing Options 1a and 2 more information would become available
that might inform a decision on Options 3 (mutual recognition) and 4
(imposition of more detailed technical standards at EU level). 1.28. Roadside
testing 1.378
We see no adequate justification for the EU to
specify details of roadside testing systems, since these can safely be left for
decision by Member States. Policy initiatives in this area would fail the ‘EU
added value’ test in impact assessments. 1.379
In particular, where a system is reasonably new
(as is the case for roadside testing) there are likely to be considerable
advantages of having more than one system being trialled, in order to discover
the most beneficial solution. The natural experimentation currently being
undertaken across different EU Member States will help provide important
evidence to direct the future research required to determine the case for
EU-wide legislation standardising roadside testing procedures. 1.29. Data 1.380
Under any option, it would be advantageous to
facilitate exchange of data between Member States (although not all of those
replying to the on-line consultation thought that this should be done). 1.30. Option summary Table Error! No text of
specified style in document..28: Summary of costs and benefits of policy options Policy option || Annual cost (€ million) || Annual benefit (€ million) || Emerging conclusion Option 1a || || || Peer reviews and screening || 0.2 – 0.3 || 0-100 || Benefits are greater than costs Research || 2-3 || 0-100 || Benefits are greater than costs PR campaigns || 1-2 || 0-75 || Benefits are greater than costs Infraction proceedings || 0.015 || Not known || Benefits are greater than costs Other || Not known || Not known || Benefits are greater than costs Option 2 || 0.5-1.6[139] || 75-100 || Benefits are greater than costs Option 3 || 440 || >368 + single market benefits || Initial impact uncertain, but likely to be beneficial in the long run due to single market improvements Option 4b || 673 + supervision costs || Not known || Pillar 3 - equipment || 31-62 (say, 47) || No studies done || Further in-depth studies required for individual items of equipment Pillar 4 - staff || 280 || No studies done || Further in-depth study required Pillar 5 - vehicles covered || 130 || No studies done || Further in-depth study required Pillar 6 - frequency || 208 || Positive in rich countries || Benefits are greater than costs for rich countries, unclear for poor countries Pillar 7 - supervision || Not known || Not known || Further in-depth study required Pillar 8 - data || 8 || Likely to be positive throughout EU || Benefits are likely to be greater than costs Option 4c || 1,487 + supervision costs || Not known || Pillar 3 || 46 || No studies done || Further in-depth studies required for individual items of equipment Pillar 4 || 600 || No studies done || Further in-depth study required Pillar 5 || - || No studies done || Further in-depth study required Pillar 6 || 833 || Significantly positive in rich countries || Benefits may be greater than costs for rich countries, unlikely for poor countries Pillar 7 || Not known || Not known || Further in-depth study required Pillar 8 || 8 || Likely to be positive throughout EU || Benefits are likely to be greater than costs Appendix 1: Expert
Workshop Attendance List Organisation || Name ACEA (European Automobile Manufacturers' Association) || Dolf Lamerigts ACEM (The Motorcycle Industry in Europe) || Antonio Perlot Belgium Ministry Transport || Michel Loccufier Centiq || Alastair Williams CITA (International Motor Vehicle Inspection Committee) || Eduard Fernandez CLEPA (European Association of Automotive Suppliers) || Pierre Laurent DEKRA || Hans-Juergen Maeurer DEKRA Representation Brussels || Oliver Deiters Estonian Road Administration || Karmo Uusmaa ETRMA (European Type & Rubber Manufacturers Association) || F. Cinaralp Europe Economics || Helen Gardner Europe Economics || Dermot Glynn FEMA (The Federation of European Motorcyclists' Associations) || Philip Vogt FEMA (The Federation of European Motorcyclists' Associations) || Aline Delhaye FIA European Bureau || Wilfried Klanner Fresenius University || Dr. Schulz, Wolfgang FSD (on behalf of BMVBS) || Jorg van Calker GOCA (Belgium) || Johan Cobbaut ITS (Poland) || Filip Skibinski Ministry of Transport || Cathy Bieth DG MOVE A3 || Jan Sculczyk DG MOVE B4 || Michael Schwarz DG MOVE D3 || Paola Cielo DG MOVE D3 || Walter Nissler RDW (Netherlands) || Hens Peeters Weem RDW (Netherlands) || Henk Bussink RDW Holland || Jan Klene Road Traffic Safety Directorate || Juris Puntaks SNCT Luxembourg || Camille Gonderinger TDT (Transportation Technical Supervision Poland) || Jan Bozewicz Trafi (Finnish Transport Safety Agency) || Erik Asplund Transport Malta || Lino Abela Morning Session 1.31. The
Policy Context and DG MOVE Objectives 1.31.1.1. Walter Nissler
(Unit D3 – Road Safety) A1.1
2011-2020 policy has now been approved by the
Commission. A1.2
Need to guarantee roads in market are kept to
certain conditions. A1.3
New vehicle features are not in the scope of the
inspection procedure given in the current directive. A1.4
The number of accidents caused by technical
defects is a small percentage but still represents a large total number of
accidents. A1.5
The ultimate aim is a harmonised system to allow
there to be a single market of vehicles / PTIs across the EU. A1.6
Currently, according to an ECJ judgement,
countries are allowed to ask individuals to re-test their car before it can be
registered in the new country. A1.7
Insufficient data are currently being collected
to be able to make use of EU models. 1.32. Social
and Economic Benefits of Road Safety 1.32.1.1. Professor Schultz A1.8
The study calculated the full costs of changing
the frequency of PTIs (analysis only on periodicity, not on individual PTI
components) and the benefits in terms of a reduction in accidents and
congestion. A1.9
Possible structural effects of changes to PTI
regulation: (a)
effect on vehicle stock; (b)
petrol-diesel price relation. A1.10
Noted that the value of QALYs is dependent on
GDP. The value of life used in the study was the official EU value. A1.11
They found using cost benefit analysis that the
system should be changed from the current system of 3-2-2 frequency to a
3-2-2-1 frequency. A1.12
The study did not take account of the time costs
amounting to individuals from the requirement to take their cars to be tested
more frequently. Professor Schultz noted that there may not be an overall
productivity loss from this – due to the counteracting effect of increased
employment in garages etc. A1.13
Sensitivity analysis on the data was completed. 1.33. Single
Market Aspects 1.33.1.1. Peter Sijs (EU
Transport Board) A1.14
From their experience, the increased testing
frequencies have had no impact on the number of defects found (potentially as
companies have high standards for more frequent, intermediate testing anyway). A1.15
Within the EU different countries currently
have: (c)
various test protocols; (d)
admin differences; (e)
in / out sourcing testing models. A1.16
Mr Sijs felt that of these three, the
administration differences would cause most problems in trying to move to
mutual recognition, due to national habits acquired. A1.17
Mr Sijs was in favour of EU registration, noting
that this would help the market for parts sales as one example. He pointed out
the inconsistency whereby vehicles are allowed to drive all over the EU if
registered with any EU country, but yet countries do not accept each others’
tests for cars registered with them. A1.18
Mr Sijs felt that the most simple solution would
involve the arrangement whereby, whatever country you were in at the time your
vehicle needed its PTI, you could just take the test there (e.g. if in Germany,
take the German test!). He did concede that potentially it might be prudent to
restrict the frequency of non-local tests, for instance needing to take a test
in the country of registration at least every second PTI. A1.19
There is no potential issue of drivers shopping
across borders to achieve testing costs savings, due to the high transport
costs which would be involved, negating any possible savings. For instance,
trucks would never drive to Germany from the Netherlands to achieve testing
cost savings, as costs of around €100 would be incurred in order to drive there. A1.20
The EU Transport Board sent a questionnaire
round to their 18 members in 2007, receiving 12 replies. In this questionnaire
they asked members how many times vehicles in their fleet have to go back to
their country of origin empty, just for the purpose of undertaking a PTI. A1.21
14 per cent of trailers were found to have had
to make an empty trip back to their country of registration for the purpose of
their PTI. A1.22
Biases in the results are likely to occur
because the EU Transport Board only represents large companies, whose vehicles
travel long distances and who generally have good systems of intermediate
testing in place. A1.23
They found that the majority of empty mileage
was run by trailers, not trucks. Trailers are generally rotated in triangles,
with one rotation taking between 8 days and 1 month. Therefore, sometimes the
case occurs whereby trailers end up being called up for testing during the period
in which they are outside the country. A1.24
The result obtained seemed high in light of the
fact that one might expect large haulage firms to be particularly good at
logistical planning. The comment was made that potentially companies may have
already made significant improvements to the 14 per cent figure since 2007,
after having had the costs highlighted to them by the previous survey. 1.34. Discussion A1.25
20 per cent of accidents due to technical
defects are from tyre defects. However, currently PTIs do not check tyre
pressure / homologation effect (exceptions are in France and Holland, where
type pressure is checked). Tyre condition has efficiency effects and safety
effects. A1.26
Tyres and lights are the most important
technical defects that occur – you do not need highly trained mechanics to test
these. Therefore, PTIs are almost irrelevant in this respect. However, a lot
of people are not checking their vehicles at all, as there is no policing of
this. A1.27
We may need to consider seriously the benefits
of PTIs in its role as an awareness tool. Potentially we may not be able to
escape from some sort of PTI system. A1.28
Spain has completed a study looking at the
impact their scheme has had on road deaths, for which the estimated figure is
that more than 4,000 deaths were saved in 2006. The study includes data
regarding airbags. A1.29
A Danish study which involved a questionnaire of
Danish Parliament (AUTOFORE) found that one in five vehicles were not using
type-approved tyres. A1.30
In Spain, PTIs were recently introduced for
mopeds. A1.31
There was some conflict regarding how easy it is
to implement changes to technical PTI requirements – Mr Sijs felt this would be
relatively easy, and that the administration requirements are the difficult
change to make, whereas DEKRA noted that it would be likely to take at least a
month just to settle upon any changes to the testing requirements of brakes. A1.32
Problem of quality control of testing –
countries see a movement of vehicles towards certain testing sites where the
testing quality is low. Therefore the issue exists of how to be sure that the
actual quality of inspection undertaken is up to the required standards. A1.33
Roadside inspections have brought to light
disastrous statistics. For instance, trucks may have passed a PTI in their own
country very recently, but RSI testers have had to stop them in another country
soon after for safety reasons. Therefore, it is very important to find a way
to ensure the quality of inspections and inspectors. Afternoon Session 1.35. Group
Discussion – Data systems 1.35.1.1. Moderator:
Alastair Williams (Centiq) A1.34
AW: In order for it to be worth collecting,
information has to have value against what we are trying to achieve. A1.35
There are three potential levels of data systems
for roadworthiness in the EU: (a)
government level; (b)
consumer level – no interaction with the system
except to see what is already there (e.g. look at old PTI results), entry of
data is done centrally; (c)
decentralised level – 1,000s of testing centres
etc. entering data into the system. A1.36
Others: similar work has been undertaken in
Geneva – where a database on car registrations has been implemented. A1.37
In Denmark, the feeling was that currently some
information necessary for the inspection of vehicles is unavailable.
Improvements could be achieved if more history of the vehicle was included in
the information available e.g. PTI dates, past accident occurrences and
rehabilitation procedures, plus any modifications made to the vehicle. At the
moment, the only data available is the information included on the document
each car is given at the time of leaving the production factory (i.e. just how
the vehicle was originally manufactured and not any information on alterations
made since). The feeling is that people see value in having available the
whole history of the vehicle, rather than just information on the PTIs which
have been undertaken on it. A1.38
AW: Important distinction between what data are
necessary for inspections and what data are useful for society. A1.39
Others: Currently instances occur where people
have difficulties registering their vehicle in another country due to
modifications having been made since production. This trouble would not exist
if a more comprehensive history of the car was recorded. In order to register
modified vehicles the country may require that an individual vehicle type
approval is undertaken, which costs €3,000. A1.40
Others: The opinion was voiced that RSIs are the
key to ensuring standards are kept up across the EU – data need to be available
on the condition of vehicles from other Member States in order to ensure
standards. A1.41
AW: It was noted that, in relation to the levels
of data collected, in order to improve accident management more information
than currently collected would be useful, and in order to provide useful data
to insurance companies and the police even more data would be needed. A1.42
Others: The information needed for a RSI is only
very high level and minimal e.g. for an individual vehicle, the only questions
requiring answers are: (a)
Did the vehicle recently pass a PTI? (b)
Did the vehicle recently pass a RSI in another
country? (c)
Is the vehicle stolen? (d)
ID for the vehicle (e)
Vehicle type A1.43
In addition, linked information on the
characteristics of each vehicle type would be needed. A1.44
Participants felt that roadside inspectors could
target vehicles for RSI more easily if they had specific driver / vehicle
information available to them in order to allow them to form an estimation of
whether or not the vehicle was likely to be faulty. A1.45
A problem with RSI results currently is that
different languages are used for reports across the EU – so even if access to
another country’s reports was made available, this may not necessarily be of
use to inspectors. A1.46
A point of agreement was that it would be useful
to have EU level co-ordination on the collection of vehicle type information,
as currently research on this ends up being duplicated. 1.36. Summary
from Group Discussion on Potential Impacts of Changes to PTIs 1.36.1.1. Dermot Glynn
(Europe Economics) A1.47
In depth studies on this have been done in
Sweden and a few other countries. A1.48
It is felt that an awareness campaign would be
useful to highlight the advantages of PTIs. A1.49
A medium standard of PTI across the EU came out
as the most popular option. 1.37. Costs
of Standardisation – the Case of RDW in the Netherlands 1.37.1.1. Hens Peeters Weem
(RDW, Netherlands) A1.50
RDW is part of the Ministry of Transport in
Netherlands. It performs registration administrative tasks and oversees PTIs
in the Netherlands. A1.51
If a car is registered in the Netherlands, then
the owner receives a fine automatically in the case that an inspection is done
late, and there is 100 per cent enforcement of this. A1.52
Because of these strict rules, vehicle owners
submitted complaints to RDW with regard to the inconvenience of the
requirements in the case that a vehicle registered in the Netherlands was
permanently situated abroad. Most complaints submitted to RDW were of this
nature. In response to these complaints, RDW has opened up a number of sites
in other countries, initially in Belgium. People in Belgium could then connect
to RDW to say that the vehicle is ready for inspection. A1.53
RDW now has several inspection stations
available in Spain. Dutch cars can be taken to these testing sites and tested
under Spanish PTI (the Netherlands does not have an estimate for the number of
cars being tested in this way at the moment). The Netherlands has satisfied
itself that Spanish PTI requirements are up to their required standards. A1.54
When a Dutch car completes a PTI at a Spanish
centre, the testers are able to record details of faults (and details of failed
cars) on the RDW website. The same design of RDW website is used as in the
Netherlands, with the only difference being that the site is translated into
Spanish. The costs involved in putting together this system of allowing tests
in Spain were low. In addition, Spanish testing centres are required to pay a €3.25 charge to RDW for each car tested and
a €90 yearly charge to be
allowed to test Dutch cars – through these charges the system pays for itself. A1.55
Later this year, the Netherlands is to adopt the
additional measure of changing their legislation in order to legally allow
tests to take place in another country. Potentially the Netherlands will
further expand their bilateral agreements to additional countries when
legislation requirements have been implemented. A1.56
The PTI quality control requirements undertaken
in the Netherlands are not imposed upon the foreign testing centres, e.g. the
Netherlands does not requires either BE or ES to undertake random checks on 3
per cent of tested vehicles, as is required in the Netherlands. A1.57
The RDW website includes the facility whereby
anyone can freely access each vehicle’s PTI information (a new field recording
the distance travelled by each vehicle is planned to be added in 1-2 years’
time). RDW is the only entity that has permission to alter data contained on
the website, with the exception of the information on car sale date – which the
seller can input themselves. The Dutch system is all automated such that no
paper is needed. A1.58
Similar agreements with Spain to that which
exists with the Netherlands are also in place with Sweden and France. The
French system arose due to the demand for residents in the south of France to
cross the border into Spain to undertake their PTI, because of the low
population density in the area. The model in France is different from the Dutch
model, with France hiring out facilities in Spain and sending inspectors to
these locations, instead of allowing French tests to be undertaken by Spanish
testers. Currently, around 1,000 Swedish cars per year are inspected in Spain. 1.38. Costs
of Standardisation – Presentation by Applus, Spain 1.38.1.1. Eduardo Fernandez
Ardevo (Applus, Spain) A1.59
It was felt that some level of database
co-ordination in the EU was needed, else there would be a continuation of the
current situation whereby there is unnecessary replication of effort and the
available data are not made as much use of as possible. A potential search
facility was suggested to link up national data. A1.60
At the moment, the procedure to allow different
types of tyres etc. is very different in different Member States. The systems
could be sufficiently improved if information was readily available across the
EU on whether a particular modification was safe. In addition, currently data
from vehicle manufacturers are provided in a standard format. A1.61
The production of such a database is already a
CITA recommendation, as was first given a number of years ago. A1.62
A couple of EU databases on vehicles do already
exist. National registration authorities in 18 Member States already
co-ordinate in order to track number plates as they cross country borders.
Data on accident information, BIN number etc. is contained in this database.
Potentially this set of information could be improved to also include PTI
information, although this would involve a significant increase in the data
flow through the database system. However, when the topic of a common EU
database was discussed by the registration authority group they rejected the
idea on the basis that currently they each have individual database systems in
place to collect national data, using which they can then inject the
appropriate information into the connected database. The compilation of
additional data variables between the Member States would therefore require
them to alter / standardise each of their national database systems. A1.63
The present situation with regard to another EU
database system has evolved in two steps. Initially sharing was arranged on a
voluntary basis between Member States. On the back of this, the Prüm treaty
was implemented. The Prüm treaty is currently agreed by 10 EU Member States
and will apply to all Member States from next year. This treaty is limited to
purposes related to crime (stolen vehicles, driving license fraud etc.). A1.64
A system linking national driving license
databases is required to be set up by 2013. 1.39. Group
Discussion - Mutual Recognition 1.39.1.1. Moderator: Dermot
Glynn (Europe Economics) A1.65
Enforced mutual recognition of roadworthiness
currently exists between all EU Member States in that vehicles are allowed to
travel freely between countries. A1.66
To change the country of registration of a
vehicle, ECJ precedent dictates that you cannot require vehicles to take an
“additional” roadworthiness test, but in practice you can ask for the vehicle
to undertake a test before registration if the new country has a different
testing procedure. A1.67
Differing frequencies of PTI across countries is
an issue for the spread of mutual recognition. A1.68
The largest issue identified by participants,
which is holding back the acceptance of mutual recognition between countries,
is the difficulties currently encountered with regard to the quality control of
vehicle testing. The feeling was that in order to allow complete mutual
recognition a system of quality control would need to exist – as at the moment there
are areas where quality control is not currently sufficient. Spain, for
instance, noted that on a national level they already found it difficult to
control the quality of testing, and that was when dealing with only a small
number of large manufacturers. Apprehension was therefore expressed regarding
the ability to ensure quality when dealing with 1,000s of vehicle inspectors. A1.69
Voluntary bilateral agreements give countries a
useful way of ensuring that foreign tests are of sufficient quality, as they are
able to threaten to remove the agreement if standards are inadequate. In
addition, when bilateral deals are set up, there is the opportunity for these
deals to be negotiated to include a requirement to increase testing standards. A1.70
However, bilateral agreements are not a perfect
system. A country has to put individual agreements in place with each of up to
26 Member States, of which each agreement may only cover maybe 500-1,000 cars
tested each year. A1.71
Country representatives expressed interest in
the EC providing a suggested format(s) around which countries could then
negotiate bilateral agreements. The ES-NL and ES-SE bilateral arrangements are
already very different from each other, and some level of standardisation of
bilateral agreements could be helpful. The ES-SE arrangement has been agreed
by an individual Swedish company, for instance, instead of as part of a
government initiative. If guidelines were provided by the EC this was
envisaged as helping to encourage the implementation of mutual agreements
between Member States – as it would potentially reduce the amount of work
required in order to set up these agreements. Would it be possible to annex to
the existing directive the kind of guideline needed? A1.72
The opinion was that a medium level of PTI across
all Member States would provide the right conditions to allow the
implementation of EU mutual recognition of PTI testing. From the study by
CITA, the conclusion had been reached that full harmonisation of PTI was not
necessary, as tests in other countries were already sufficient. However,
despite this, mutual recognition had not been triggered. A1.73
A note was made that the threat of sanction in
the case of insufficient quality testing by one Member State under full
harmonisation was already provided for in EU legislation. However, there was
the feeling that insufficient statistics are currently collected in RSI to
allow the EU to detect incompliant Member States sufficiently quickly. 1.40. Summary
from Group Discussion on Potential Cost Impacts of PTI 1.40.1.1. Walter Nissler (DG
MOVE) A1.74
Cost drivers identified: (a)
Equipment –
dependent on the existing system in place in a
Member State e.g. whether there are small / large garages; –
the basic equipment used in PTIs is the same
across the EU, as the same producers of inspection lanes are used by all
countries (with just the software switched to the individual Member State’s
specifications); –
training. (b)
Administration (€3.25 charge per car, €90 yearly charge per testing centre – current charges used by NL in
ES) A1.75
Consensus reached by participants on the level
of PTI testing that would give the best balance of cost / benefits was medium+
level (a level somewhere between medium and high). A1.76
In response to this, one participant commented
that, as the current average level of testing in the EU is already supposed to
be medium, will a requirement for all countries to have at least a medium PTI
level give any improvements? Appendix 2: Stakeholders’
Meeting Attendance List Organisation || Name ACEA (European Automobile Manufacturers' Association) || Heiner Hunold ACEA (European Automobile Manufacturers' Association) || Dolf Lamerigts ACEM (The Motorcycle Industry in Europe) || Antonio Perlot CITA (International Motor Vehicle Inspection Committee) || Wim Labro CSDD (Latvia Road Traffic Safety Department) || Juris Puntaks Danish Transport Authority || Victor Hollnagel DEKRA || Oliver Deiters DEKRA Automobil || Hans-Juergen Mäurer DEKRA Vertretung bei des EU || Anne-Charlotte Mazet EC DG MOVE A3 || Jan Szulczyk EC DG MOVE D3 || Isabelle Kardacz EC DG MOVE D3 || Paola Cielo EC DG MOVE D3 || Walter Nissler ECG (Association of European Vehicle Logistics) || Lola Uña Cardenas EGEA (European Garage Equipment Association) || Sylvia Gotzen EGEA ASA (Germany) || Frank Beaujean Estonian Road Administration || Karmo Uusmaa ETRMA (European Type & Rubber Manufacturers Association) || Jarmo Sunnari Europe Economics || Helen Gardner Europe Economics || Dermot Glynn FEMA (The Federation of European Motorcyclists' Associations) || Philip Vogt FIA EB || Frederic Melchior FSD / German BMVBS || Jörg Van Calker IRU (International Road Transport Union) || Marc Billiet Ministère des transports (France) || Cathy Bieth RDW (Netherlands) || Paul Eijssen SNCT (La Société Nationale de Contrôle Technique) || Arsène Hoffmann TDT (Transportation Technical Supervision Poland) || Jan Bozewicz TÜV SÜD || Günter Heim VdTÜV || Hans-Joachim Voss Morning Session Opening and introduction 1.40.1.2. Ms. I Kardacz (Head
of Unit D3 – Road Safety) (a)
Objective number four of the EC’s communication
“Towards a European road safety area: policy orientations on road safety
2011-2020” is for “Safer vehicles”. (b)
After being placed on the road, vehicles should
maintain their safety standards throughout their lifetime. (c)
The ultimate objective is to achieve mutual
recognition of vehicle inspections between Member States. Policy options under consideration:
initial outline 1.40.1.3. Dermot Glynn
(Europe Economics) A2.1
Questions raised by stakeholders on policy
options: (d)
1a – Will technical standards as required in
2004/EC be raised? (e)
4 – Will registration also be standardised? A standardised EU system of PTI and
roadside testing 1.40.1.4. Hans-Juergen Maurer
(DEKRA) (a)
Some companies in the EU require an extra eight
months of PTI training after gaining a vehicle qualification before being
allowed to undertake PTIs. (b)
Three different solutions are currently in force
for the market structure of PTI testing stations: –
private e.g. DE, UK; –
governmental; –
garage. A2.2
The Tyre and Rubber Association pointed
out that 70 per cent of road accidents are from tyre-related problems yet only
two Member States currently specifically check tyre pressure (one of which only
recently implemented this check). This is surprising given that maintaining
the correct tyre pressure is what keeps you on the road. However, someone else
noted that some countries do measure tyre pressure as this is required to
undertake suspension tests. Regardless, it was pointed out that checking tyre
pressure every 2-3 years is not really a suitable frequency and that rather a
tyre pressure monitoring system would be ideal – but it would be time-consuming
/ expensive. This was countered by the point that a once-per-year check would
still make a step change in the number of accidents. A2.3
Regarding roadside inspections, methods for the
pre-selection of vehicles make RSI pass rates incomparable and there are
different approaches to RSI in practice across Member States. 1.41. Discussion A2.4
Motorcycle Industry in Europe (ACEM) – The need to use a variable geometry approach – each element of
the proposal should be assessed separately? Response: Each element under the
five fingers would have to be assessed individually. A2.5
CITA – Regarding
mutual recognition, they saw there being a major risk if no standard is
required across the EU – the danger of people choosing a testing centre so as
to avoid the discovery of faults on their vehicle. A2.6
FEMA – Under
option 3 the consumer also might go to another country to have testing there –
is this a problem of the user / testing company? A2.7
CITA – Would
prefer to be on the safe side. Need a good quality assurance scheme and
therefore it would be useful to all work on the same level. They recognised
the conceptual attractiveness of giving the consumer the power to make their
own decision over who to go to for their PTI, but felt that the relevant bodies
needed to take responsibility for the (potentially harmful) decisions made. A2.8
FEMA – It was
noted that we need to ensure we are not equating high/low PTI requirements automatically
as good/bad, we need to find the most beneficial level of PTI. (Europe
Economics) – our objective will always be to find the optimal level) A2.9
DG MOVE –
Standardised frequencies would be needed for mutual recognition. A2.10
IRU – Creating a
harmonisation of test procedures is important across Member States. At the
moment outcomes of tests differ, which makes it harder to compare certificates
across countries. Commercial vehicles are often away from their Member State
of registration and it can cost up to €1,500-€2,000 to send
a vehicle home for a PTI. A2.11
In regard to RSIs, due to lack of co-ordination
between Member States a vehicle can end up being tested more than once a day if
it travels between two countries. A vehicle can have a certificate showing
that it passed an RSI in one Member State in the morning, 300km earlier, but
the second station it is stopped by will not accept the certificate and require
that another RSI is undertaken. A2.12
Whether or not a vehicle ends up returning empty
for a PTI depends on planning. Sometimes it is possible to plan a trip back
home to coincide with the timing of a PTI – and in this case the vehicle will
do so. A2.13
ETRMA – It was
noted that mutual recognition was a free-movement goal and single-market goal
but not an accident goal. It was questioned whether a high level of PTI
testing would be sufficient – it was felt that if this did not include a
tyre-pressure check then it would still not be sufficient. A2.14
DG MOVE –
Currently 50-60 per cent of questions received in the EC DG MOVE mailbox are
related to re-registration of vehicles. It seems odd that there is a single
market for people but not a single market for cars at the moment. DG MOVE
would like to see there become a single market for cars. A2.15
Ministère des transports (France) – They are in favour of a harmonised system. They feel the only
solution is a high level of PTI with good quality control. They were not sure
whether it would be a good thing to reduce periodicity, but felt that the
harmonisation of technical tests and people’s qualifications is important.
They queried where the quality control would be undertaken, noting that in
France they do not think this is undertaken well in garages. A2.16
DEKRA – Trailers
not trucks are the ones who have issues returning for PTI (EE –
standardising checks on trailers could be a possible early step). A2.17
BMVBS – There is
a type-approval problem (database). Would standardisation be set as a minimum
level or would everyone be required to have the same level? A2.18
DG MOVE – The
timeline for implementation will depend on which option is chosen. A2.19
RDW – The Spanish
and Dutch authorities already have a pilot system in place for mutual
recognition. In addition, a project with the Polish authorities is likely to
start later this year for heavy goods vehicles, due to the large flow of these
vehicles through the Netherlands. It was felt that a central database of test
results would not be much use from a government perspective – databases could
just be interconnected instead. A2.20
CSDD Latvia –
Found it hard to understand how mutual recognition would work in practice
without standardisation. He queried whether it might be technically and
legally impossible. (EE – mutual recognition would be logically
possible and legally possible in relation to type approval). In his view a
medium / high PTI level would be a good starting point for standardisation. In
the meantime bilateral agreements would be useful. A2.21
DG MOVE – Type
approval ISO EU standards have been passed in this area. Therefore type
approval is already standard across the EU. This standardised type approval
document allows vehicles constructed in the EU to be subsequently registered in
any Member State. Vehicle-use categories, however, can still differ between
Member States, with some tests being required in certain Member States in order
to allow some vehicles to be used for specific purposes. A2.22
BMVBS – The
roadmap for vehicle transport needs to include safety and environmental aims. A2.23
FEMA – From a
consumer’s point of view option three (bilateral agreements) would be the most
simple. The proportion of users that are willing to travel between countries
is likely to be negligible. It was felt that all EU Member States did not
necessarily have to have PTIs comparable to Germany’s. A2.24
IRTU – Their
members have reported some Member States persistently asking for testing
results of vehicles before letting them enter the country, as the Member State
in question does not believe the testing standards in the country the vehicle
comes from are high enough. Quite a number of 3rd country transport
is being undertaken in the EU (cabotage) – this does not require a vehicle to
return to their country of registration frequently e.g. an Estonian tractor
driving backwards and forwards on a route from Italy to Belgium. A2.25
ETRMA – If we are
considering only the cost of vehicle testing, then potentially we should choose
a lower PTI. However, consumers are the ones who ultimately die on the roads –
so they need to be impelled not to succumb to cost-saving measures. A2.26
FEMA – In Belgium,
some petrol stations require payment for checking tyre pressures. A2.27
Europe Economics –
The optimal safety level is not the highest safety level. People want to take
some risk and therefore an optimal risk level exists. A2.28
DG MOVE – There
exists a study looking at the impact of non-mutual recognition on the transport
goods sector. A2.29
RDW – The
Netherlands recently lowered the PTI frequency in order to lower the cost for
citizens. They feel the human factors involved with PTI-testing are much more
important. Regarding the Spanish and Dutch arrangement, Spanish testing
authorities can now dispense Dutch PTI certificates. However, problems have
been experienced with cars that have been tested in this way being stopped by
French police. Is it possible that producing a standard certificate might go a
long way to helping the situation? A2.30
Most vehicles are not taking part in
cross-border traffic and are travelling far fewer miles than trucks. We need
to be careful not to suddenly burden cars excessively - a staged approach might
be prudent. A2.31
Motorcycle drivers will sometimes save costs by
buying tyres which have not been type-approved – it was felt that potentially
there could be big improvements seen just by ensuring standardisation of the
testing of such motorcycle tyres. A2.32
The divergence between commercial and private
use of vehicles was emphasised – it was felt that a very different approach
needed to be used to evaluate the two. A2.33
BMVBS – It was
asked what the difference was between option 4c (low level standardisation) and
1a (improvement in current regulatory requirements). A2.34
Europe Economics
– The assumption had been confirmed with the EC that Member States would not be
stopped from performing higher level tests under option 4. A2.35
DG MOVE – At the
moment the regulation on roadworthiness testing consists of a list of items
that have to be checked but no way of evidencing that these checks have taken
place correctly (even if a roadworthiness certificate is issued). Therefore a
database is needed in order to enable mutual recognition, as this information
has to be available. A2.36
DEKRA – Currently
there are different levels required to pass the same vehicle test in different
Member States. For instance, one Member State might require a tread depth of
7mm on tyres to pass a PTI whilst another Member State might only require 5mm.
So the current EC regulation does not actually even dictate a minimal standard. A2.37
For European brake force tests there are
currently differences in the way brake force is calculated and measured, and
the tests are performed using different equipment (e.g. between Poland and
Germany). Without dealing with these differences, they felt that option 3
(mutual recognition) was impractical. A2.38
Unknown – If we
want a single market then we must have the same requirements in each Member
State. If vehicles are allowed to drive in all countries then they must be
safe to drive in all countries, not just in the country where the lowest safety
level would efficiently be chosen due to the particular situation on that country’s
roads. Additional tests should not stand in the way of mutual recognition. A2.39
Europe Economics
– Under mutual recognition vehicles might potentially go to either
lower-quality testing centres or else just more efficient testing centres. A2.40
FEMA – There is a
big difference between the commercial fleet and private fleet in terms of the
ability of vehicle-users to choose which Member State in which to undertake a
PTI. Private vehicles are much less likely to shop abroad. Afternoon Session 1.42. Improved
Flows of Information 1.42.1.1. Alastair Williams
(Centiq) A2.41
The main point was that everything desired with
regard to information provision could theoretically be delivered, but not
necessarily within one system and/or within reasonable costs. A2.42
It was felt that the estimate provided by one
Member State of a cost of less than €1,000 to add an extra field into their current vehicle database was
likely to be incorrect (too low).
1.1.52.
Discussion
A2.43
RDW – Have we
been looking at other vehicle information systems currently already in place or
else planned for the future? The existence of the EUCARIS (European Car and
Driving License Information System) system was noted, to which it was felt it
would likely be easy to add additional fields. It was asked whether a
potentially big disadvantage of using a centralised database was that it would
mean only one point of failure? (EE – this issue can be solved). A2.44
CITA – They have
been discussing the database problem for several years. Their members are
clearly in favour of a European centralised database. If mutual recognition
was implemented, they felt that PTI testers would need to be able to see the
data. A2.45
They put forward that for testing equipment a
database would be useful as an anti-corruption tool – it is possible to take
photos of the testing going on to ensure it takes place. For this to work the
database need to be linked automatically to the central national database, as
is currently the case in certain parts of Asia. If there are electronic
components in cars, information on these needs to be accessible in various
countries. 1.43. Interim
Analysis of the Internet Consultation 1.43.1.1. Helen Gardner
(Europe Economics) A2.46
It was noted that a number of stakeholders had
problems responding to the internet consultation due to it only having been
made available in English. 1.44. First
Analysis of the Options 1.44.1.1. Dermot Glynn
(Europe Economics) A2.47
With regard to option 1 it is necessary to keep
in mind the possibility of regulatory creep. A2.48
For option 2 it was noted that some spontaneous
examples already exist. Any such increase in testing standards required under
this option would stem from discussion between Member State pairs.
1.1.53.
Discussion
A2.49
Unknown – The
preference was for improving the minimum requirement under option 1a and then
implementing option 3 (mutual recognition). A2.50
DG MOVE – It was
noted that the EC had received complaints from the French that Spain now
accepts cars tested to Dutch standards but not those tested to French
standards. A2.51
Unknown –
Bilateral agreements would not be needed if vehicle owners just changed the
registration of their vehicle to that of the country it was being kept in.
Therefore would it be possible to just harmonise vehicle registration in the
EU? Then potentially registration could just be transferred easily across as
necessary. (DG MOVE – problem of different registration requirements
related to the taxation of vehicles.) A2.52
CSDD – Agreed
with DG MOVE that there was an issue of discrimination between EU citizens with
the use of bilateral agreements. People living in Member States with high
vehicle testing levels might feel discriminated against when comparing
themselves to Member States with low requirements. 1.45. Comments
and Discussion A2.53
Unknown – A
standardised system would be the best system, but not at the highest PTI
level. However, with a PTI level set at below the maximum some Member States
will still request additional tests from their residents. He believed that
standardisation and mutual recognition would be the best solution. A2.54
DG MOVE – When sitting
around a table with 27 EU delegates some delegates will always push for high
requirements which others would not be able to follow. So in order to
standardise it is necessary that all Member States are able to afford it (it
would not be possible for all Member States to pay for the highest PTI cost).
Recommendations need to be based on best practice but also have to be reduced
to a manageable level – compromise is necessary else the proposal would be
rejected immediately. 1.46. Concluding
Remarks 1.46.1.1. Walter Nissler
(Unit D3 – Road Safety) A2.55
It was felt the overall feeling derived from the
discussion was that the majority of people are for harmonisation of vehicle
tests, but not at the highest quality level. Noted the need for balance
between costs for different Member States, especially those which would be
least able to cope with any increase in costs. 1.46.1.2. Ms. I Kardacz (Head
of Unit D3 – Road Safety) A2.56
The idea of a step-by-step approach sometimes
helps a great deal. It enables later decisions on the more ambitious
objectives which would not be achievable in the short term. The preference for
allowing countries to implement higher quality PTIs than a minimum if they so
wished implied an EC Directive would have to be chosen rather than EC Regulation. Appendix 3: Public
On-line Consultation A3.1
The public consultation relating to Periodic
Technical Inspections (PTI) for motor vehicles and their trailers was made
available on-line using the Commission’s interactive policymaking tool. The
consultation was only made available in English due to the short time frame in
place. A3.2
The consultation period ran from 30 July 2010
until 24 September 2010. A3.3
Unfortunately the questionnaire was inaccessible
on 19 September 2010 due to an outage. A3.4
The anonymous on-line questionnaire was
structured as follows: –
respondent information; –
experience of PTIs; –
experience of roadside inspections; –
the inspections in the EU; –
vision on policy options. A3.5
Screen shots of the questionnaire as it appeared
on-line are given below: A3.6
A number of complaints were received regarding
the running of the consultation. The most frequent complaint was that the
consultation was only made available in English, therefore did not facilitate
responses from EU citizens whose English was not proficient. This was despite
the fact that the eventual results of the consultation would be used to direct
policy for all EU citizens. This limitation was taken into consideration when
analysing the survey data. A3.7
In order to aid members in responding to the
questionnaire, FEMA provided translations of the questionnaire into French and
Dutch on their website. A3.8
Design faults were uncovered in a number of
questions,[140] which would likely lead to biased results. Responses to these
questions have therefore not been taken into account in the analysis of the
consultation. A3.9
An analysis of the results of the public
consultation is provided below: Respondent profile A3.10
A total of 9,653 responses to the internet
consultation were received.[141] Of these, 9,207 responses were made on behalf of the individual
respondent and 446 were made on behalf of an organisation or public authority. Private citizens A3.11
For those responding as an individual, the break
down of responses by Member State was as follows: Table A3.1: Break down of respondents by Member State EU Member State || Number of responses || Percentage of individuals United Kingdom || 4,694 || 51.0% France || 2,292 || 24.9% Netherlands || 1,083 || 11.8% Germany || 317 || 3.4% Spain || 306 || 3.3% Belgium || 148 || 1.6% Finland || 126 || 1.4% Poland || 81 || 0.9% Ireland || 37 || 0.4% Sweden || 27 || 0.3% Estonia || 22 || 0.2% Portugal || 12 || 0.1% Greece || 11 || 0.1% Luxembourg || 11 || 0.1% Denmark || 10 || 0.1% Italy || 8 || < 0.1% Austria || 6 || < 0.1% Malta || 6 || < 0.1% Lithuania || 3 || < 0.1% Romania || 2 || < 0.1% Cyprus || 1 || < 0.1% Slovakia || 1 || < 0.1% Slovenia || 1 || < 0.1% Czech Republic || 1 || < 0.1% Hungary || 1 || < 0.1% Bulgaria || 0 || 0% Latvia || 0 || 0% A3.12
Of these individual respondents, 10.8 per cent
had been involved in an accident in the last three years and 8.97 per cent had
suffered a vehicle breakdown. A3.13
As there are several Member States from which
there were not enough responses for us to think that the sample is
representative enough, we will not report Member State level results for these
countries. Member State level results will only be reported for cases where we
feel the sample size is large enough (those which have over 80 responses), i.e.
the United Kingdom, France, the Netherlands, Germany, Spain, Belgium, Finland
and Poland. Together, these account for 98.26 per cent of all responses. A3.14
Moreover, we have determined a classification of
Member States based on the levels of testing standards. We will frequently use
this to report results, as all categories have sufficient representation and no
respondents need be excluded. The classification used is the same as in the
main report, as follows: Table A3.2: Classification of Member States according to level of testing
standards Classification || Member State High || Belgium, Finland, Germany, Luxembourg, Sweden Medium || Austria, Czech Republic, Denmark, Estonia, France, Ireland, Latvia, Netherlands, Portugal, Slovakia, Spain, United Kingdom Low || Bulgaria, Cyprus, Greece, Hungary, Italy, Lithuania, Malta, Poland, Romania, Slovenia A3.15
This classification applies only to private
citizens, so the organisations are included as a separate group. In terms of
this classification, a breakdown of the individual respondents is given below: Table A3.3: Responses by category Category || Number || Percentage High || 629 || 6.5% Medium || 8,464 || 87.7% Low || 114 || 1.2% Organisations || 446 || 4.6% A3.16
Only a small number of respondents (1.5 per
cent) had moved their residence from one Member State to another in the last
three years. The major directional flows in this regard were as follows: Table A3.4: Respondents moving residence Direction of move || Number || Percentage of moving respondents From || To France || Spain || 17 || 11.9% Netherlands || Germany || 9 || 6.3% France || Belgium || 8 || 5.6% Germany || United Kingdom || 8 || 5.6% France || Italy || 7 || 4.9% France || Germany || 6 || 4.2% United Kingdom || Spain || 6 || 4.2% United Kingdom || France || 4 || 2.8% Belgium || Netherlands || 4 || 2.8% France || United Kingdom || 3 || 2.1% Netherlands || Italy || 3 || 2.1% Netherlands || France || 3 || 2.1% Germany || Spain || 3 || 2.1% Italy || United Kingdom || 3 || 2.1% Other || || 62 || 41.3% A3.17
In reading this table, it must be kept in mind
that the number of responses varied widely across Member States. There were
also instances of respondents having moved to a different Member State from the
one that they listed as being residents of at the time of the survey. Organisations / public authorities A3.18
Of those replying on behalf of an organisation
or public authority, the breakdown of sectors from which respondents were
engaged was as follows: Table A3.5: Breakdown of organisations Sector || Number of responses || Percentage of organisations Testing organisation || 194 || 43.5 % Vehicle tester in garage || 146 || 32.7 % Others || 103 || 23.1 % Educational / training / research organisation || 54 || 12.1 % Government || 16 || 3.6 % Road breakdown service [e.g. in UK, RAC] || 15 || 3.4 % Vehicle manufacturer || 13 || 2.9 % Roadside vehicle tester || 11 || 2.5 % Traffic police || 3 || 0.7 % Entities responsible for health || 2 || 0.4 % Insurance company || 1 || 0.2 % Experience of PTIs A3.19
Familiarity with the system of PTI was high,
with 73 per cent stating that they were very familiar or fairly familiar with
the system of PTI in their country. Only 12 per cent of respondents had never
heard of the system of PTI before. Looking at countries from which there were
a relatively large number of responses, the frequency of respondents not having
heard of the PTI system was almost twice as high in the United Kingdom than in
France, nearly four times as high as in the Netherlands and five times as high
as in Spain. A breakdown of respondents who had not heard of the PTI system by
country is as follows: Table A3.6: Respondents who had not heard of the PTI
system EU Member State || Number of respondents who had not heard of the PTI system || Percentage of all respondents for corresponding Member State United Kingdom || 768 || 16.4% Poland || 13 || 16.0% Germany || 41 || 12.9% Belgium || 14 || 9.5% France || 194 || 8.5% Finland || 6 || 4.8% Netherlands || 50 || 4.6% Spain || 10 || 3.3% Table A3.7: Respondents who had not heard of the PTI
system by category Member State category || Number of respondents who had not heard of the PTI system || Percentage of all respondents for corresponding category High || 62 || 9.9 % Medium || 1,033 || 12.2% Low || 19 || 16.7 % Organisations || 18 || 4.0% A3.20
Private cars were most frequently involved in
the PTI, followed by motorcycles, then goods vehicles: Which vehicle category was involved or
most usually involved in the PTI? Impression of the overall efficiency and value for money of the test Satisfaction scores A3.21
Half of respondents felt that PTIs were
excellent value for money, and only 5 per cent found them insufficient: Efficiency and value for money
(1=insufficient, 5=excellent) A3.22
A breakdown of satisfaction scores by the
country in which the PTI was carried out is given below: Table A3.8: Satisfaction with PTI systems in selected
Member States Country where the PTI was carried out || Average customer satisfaction score (1=insufficient, 5=excellent) United Kingdom || 4.07 Spain || 4.00 Germany || 3.97 Poland || 3.64 Belgium || 2.55 France || 2.41 Netherlands || 2.31 Finland || 2.16 Table A3.9: Satisfaction with PTI systems by category Category of country where the PTI was carried out || Average customer satisfaction score (1=insufficient, 5=excellent) High || 3.25 Medium || 3.33 Low || 3.52 Organisations || 4.19 Room for improvement A3.23
Over three quarters of respondents did not see
any aspects of PTIs which would be improved; however, this means that almost
one quarter could see room for positive changes. A3.24
While 21.68 per cent of private individuals
could see room for improvement, this figure jumped to 58.97 per cent for
organisations. In addition, those respondents in Member States with a PTI
category of low or high were more than twice as likely to be able to see room
for improvement as those in Member States currently with a medium PTI
category. This may be in part due to the large number of responses received
from the UK, which falls in the medium PTI category, where a particularly low
percentage (10 per cent) of respondents could see room for improvement in the
system of PTI. Breakdowns of all respondents who could see room for
improvement by various categorisations are given below: Table A3.10: Respondents who saw room for improvement
in selected Member States Member State || Number of respondents that could see room for improvement || Percentage of respondents resident in that Member State Spain || 199 || 65% Belgium || 68 || 46% Germany || 144 || 45% Poland || 31 || 38% France || 738 || 32% Netherlands || 255 || 24% Finland || 28 || 22% United Kingdom || 469 || 10% Table A3.11: Respondents who saw room for improvement
by category Member State category || Number of respondents that could see room for improvement || Percentage of respondents resident in that category High || 256 || 41% Medium || 1,691 || 20% Low || 49 || 43% Organisations || 263 || 59% Table A3.12: Respondents who saw room for improvement
by type of vehicle owned Vehicle type || Number of respondents that could see room for improvement || Percentage of respondents with that vehicle type more than 8 seats || 71 || 38% carriage of goods less than 3.5 t || 125 || 25% less than 8 seats || 1,449 || 24% trailers and semi trailers less than 3.5 t || 28 || 17% none of the above || 492 || 17% taxi and ambulance || 6 || 17% carriage of goods more than 3.5 t || 14 || 12% Aspects to be improved A3.25
The aspect of PTIs most frequently identified as
wanting improvement were the braking systems (31 per cent), followed by the
safety equipment (28 per cent) and the mileage travelled by the vehicle (27 per
cent): Aspects of PTI that respondents would like
to see improved A3.26
In regards to the need for technical information
to improve PTIs, the strongest request was for on-board diagnostic connection
capacities, with 16 per cent of respondents indicating this would be necessary.
Active and passive safety installed components were the next most popular
requests: Which specific technical information from
the car manufacturer do you think would be necessary to improve PTI? Extension of PTIs A3.27
A reasonable number of respondents agreed that
PTIs should be extended to each of the listed vehicle category – with the
strongest feeling for caravans (23 per cent) and weakest feeling for
motorcycles >= 125 cm3
(6 per cent): Do you think PTI should be extended to
other vehicle categories? A3.28
The table below shows the percentages of owners
of each vehicle type that wanted PTIs to be extended to other vehicle
categories. Table A3.13: Preferences regarding the extension of
PTIs to other vehicle types Category for PTI extension || Type of vehicle owned / driven more than 8 seats || less than 8 seats || carriage of goods less than 3.5 t || carriage of goods more than 3.5 t || trailers and semi trailers less than 3.5 t || taxi + ambulance || none of the these Motorcycles >= 125 cm3 || 7% || 6% || 6% || 1% || 11% || 3% || 3% Motorcycles < 125 cm3 || 8% || 8% || 10% || 3% || 27% || 0% || 4% All trailers || 18% || 17% || 12% || 16% || 16% || 18% || 14% Passenger cars in business use || 17% || 16% || 16% || 12% || 16% || 13% || 13% Agricultural tractors || 18% || 15% || 12% || 24% || 17% || 18% || 14% Caravans || 20% || 24% || 21% || 31% || 18% || 29% || 21% Heavy quadricycles || 9% || 10% || 9% || 5% || 13% || 11% || 7% Small electrical vehicles || 17% || 12% || 12% || 8% || 30% || 18% || 10% A3.29
The fact that such small percentages in each
category favour extension may not be reflective of the actual preferences, as
this was an optional question and as many as 5,215 respondents did not provide
any answer. It is, however, apparent that there is a wide variation in
preferences among the owners of the different vehicle types who did respond.
For instance, extending PTIs to Motorcycles < 125 cm3 found more
support among owners of trailers and semi trailers less than 3.5 t than other
vehicle owners. Also, it is apparent that there was more support for extension
to some categories than others across the board. New technical inspections A3.30
More than half of respondents thought that
technical inspections should be required again after accidents: Do you think that a new technical
inspection should be required again after any of the following? Timing of first inspection date and
frequency of periodic inspections A3.31
The majority of respondents indicated that they
felt that both the current first inspection date and frequency for PTIs are
correct. However, for those that thought the current first date or frequency
should be changed, more individuals would prefer an later first inspection date
and lower frequency than an earlier date or higher frequency: Which should be the first date of PTI
compared with those currently required? Which should be the frequency of PTI
compared with those currently required? A3.32
However, as can be seen in the tables below,
these distributions varied widely across Member States. This is perhaps due to
the different current regimes in each Member State. Table A3.14: Opinions regarding the timing of the
first test in selected Member States Member State || Current year of first test for M1 vehicles || Current || Earlier || Later || Not applicable || Not known || Left blank Belgium || 4 || 41% || 3% || 32% || 7% || 5% || 12% Finland || 3 || 37% || 1% || 24% || 8% || 8% || 22% France || 4 || 31% || 1% || 36% || 15% || 4% || 12% Germany || 3 || 88% || 4% || 5% || 0% || 1% || 2% Netherlands || 4 || 25% || 2% || 38% || 16% || 6% || 13% Poland || 3 || 77% || 5% || 6% || 0% || 5% || 7% Spain || 4 || 30% || 54% || 9% || 2% || 0% || 5% United Kingdom || 3 || 72% || 6% || 7% || 3% || 1% || 11% Table A3.15: Opinions regarding the timing of the
first test by Member State category Member State category || Current || Earlier || Later || Not applicable || Not known || Left blank High || 64% || 3% || 17% || 4% || 3% || 9% Medium || 53% || 6% || 19% || 8% || 3% || 12% Low || 71% || 5% || 8% || 1% || 5% || 10% Organisations || 58% || 30% || 3% || 2% || 0% || 7% Table A3.16: Opinions regarding the frequency of
tests in selected Member States Member State || Frequency of M1 tests || Current || Higher || Higher for cars > 8 yrs old || Lower || Not applicable || Not known || Left blank Belgium || 4/1/1 || 37% || 1% || 5% || 38% || 7% || 3% || 9% Finland || 3/2/1 || 33% || 2% || 2% || 43% || 5% || 2% || 13% France || 4/2/2 || 29% || 1% || 5% || 37% || 14% || 4% || 11% Germany || 3/2/2 || 20% || 14% || 60% || 5% || 0% || 0% || 2% Netherlands || 4/2/2/1 || 25% || 1% || 4% || 43% || 13% || 2% || 12% Poland || 3/2/1 || 77% || 1% || 6% || 9% || 1% || 1% || 5% Spain || 4/2/2/1 || 21% || 61% || 4% || 10% || 1% || 1% || 3% United Kingdom || 3/1/1 || 76% || 1% || 2% || 9% || 2% || 0% || 10% Table A3.17: Opinions regarding the frequency of
tests by category Member State || Current || Higher || Higher for cars > 8 yrs old || Lower || Not applicable || Not known || Left blank High || 28% || 8% || 32% || 23% || 3% || 1% || 6% Medium || 55% || 3% || 3% || 21% || 7% || 2% || 10% Low || 69% || 2% || 10% || 11% || 1% || 1% || 7% Organisations || 54% || 14% || 20% || 4% || 2% || 0% || 6% Experience of Roadside Inspections A3.33
There was a strong feeling that all commercial
vehicles should be subject to roadside inspections, with 39 per cent of
respondents indicating this. A3.34
About three times as many people felt that the
items verified in roadside inspections did not need to be extended to the ones
foreseen for PTIs to avoid unfair treatment than those that did (47 per cent
compared to 16 per cent). A3.35
The top four pieces of technical information
from the car manufacturer listed as necessary to improve roadside inspections
corresponded exactly to those listed as necessary to improve PTIs (albeit with
brake capacity data moving up from fourth to second): Which specific technical information from
the car manufacturer do you think would be necessary to improve the roadside
inspections? Standardisation across Europe A3.36
Regarding inspections in Europe, three quarters
of respondents were against a fully standardised PTI system in the EU. A3.37
However, there was a difference in distribution
when private individuals were compared to organisations. On the whole, 24.4
per cent of organisations supported standardisation; this figure dropped to
13.5 per cent for private citizens, though this is largely driven by UK
responses. There was also a wide variation within private citizens. Responses
in this regard broken down by type of respondent are given below. Table A3.18: Opinions regarding standardisation of
inspection by category Type of respondent || Agree with standardisation || Disagree with standardisation || No opinion || Left blank High || 26% || 66% || 4% || 4% Medium || 12% || 76% || 6% || 6% Low || 27% || 58% || 4% || 11% Organisations || 24% || 64% || 4% || 7% Table A3.19: Opinions of organisations regarding
standardisation of inspection in selected Member States Type of organisation || Agree with standardisation || Disagree with standardisation || No opinion || Left blank Belgium || 42% || 41% || 9% || 7% Finland || 19% || 63% || 9% || 9% France || 24% || 57% || 13% || 6% Germany || 18% || 80% || 0% || 2% Netherlands || 19% || 65% || 8% || 8% Poland || 26% || 62% || 6% || 6% Spain || 29% || 62% || 5% || 3% United Kingdom || 4% || 89% || 2% || 5% A3.38
The views of the various types of organisations
in this regard are as follows: Table A3.20: Opinions of organisations regarding
standardisation of inspection Type of organisation || Agree with standardisation || Disagree with standardisation || No opinion || Left blank Vehicle manufacturer || 62% || 38% || 0% || 0% Vehicle tester in garage || 16% || 69% || 7% || 8% Testing organisation || 18% || 76% || 3% || 4% Roadside vehicle tester || 45% || 45% || 9% || 0% Traffic police || 33% || 33% || 0% || 33% Government || 38% || 50% || 6% || 6% Entities responsible for health || 50% || 50% || 0% || 0% Insurance company || 0% || 100% || 0% || 0% Road breakdown service [e.g. in UK, RAC] || 40% || 40% || 7% || 13% Educational / training / research organisation || 11% || 87% || 0% || 2% Others || 47% || 41% || 4% || 9% Level of standard A3.39
However, if a standardised system were to be
introduced, around equal numbers of respondents felt that the inspection
standard set should be the least rigorous standard currently in force anywhere
in the EU (29.6 per cent) and at the medium standard currently in force (29.4
per cent). Only 14 per cent thought that the standard should be set at the
most rigorous level currently in force. If a standardised EU vehicle inspection
system were to be introduced, should it be based on: A3.40
These results may be broken down as follows: Table A3.21: Opinions on levels of standards in
selected Member States Member State || Least rigorous || Medium standard || Most rigorous || Left blank Belgium || 26% || 45% || 14% || 14% Finland || 49% || 22% || 3% || 25% France || 38% || 37% || 5% || 20% Germany || 3% || 8% || 88% || 2% Netherlands || 39% || 31% || 5% || 25% Poland || 41% || 43% || 5% || 11% Spain || 7% || 14% || 73% || 6% United Kingdom || 29% || 28% || 7% || 36% Table A3.22: Opinions regarding standardisation of
inspection by category Category || Least rigorous || Medium standard || Most rigorous || Left blank High || 19% || 21% || 49% || 10% Medium || 32% || 31% || 9% || 29% Low || 33% || 47% || 7% || 12% Organisations || 4% || 14% || 67% || 15% Cost savings A3.41
Only 2.3 per cent of respondents felt that the
absence of a standardised PTI system had caused them some costs. A3.42
There was some variation in this regard across
Member States: Table A3.23: Costs arising from absence of a
standardised PTI system in selected Member States Member State || Number for whom absence of a standardised PTI led to additional costs || Percentage of all respondents from Member State Finland || 18 || 14.3% Belgium || 15 || 10.1% Spain || 20 || 6.5% France || 79 || 3.5% Poland || 2 || 2.5% Netherlands || 24 || 2.2% Germany || 5 || 1.6% United Kingdom || 21 || 0.5% Table A3.24: Costs arising from absence of a
standardised PTI system by category Category || Number for whom absence of a standardised PTI led to additional costs || Percentage of all respondents in category High || 39 || 6.2% Organisations || 27 || 6.1% Low || 4 || 3.5% Medium || 151 || 1.8% Access to Test
Results A3.43
Twenty seven per cent of respondents felt that
inspection results should be available to government authorities in the EU and
15 per cent felt they should be available to those carrying out tests, but
almost half (48 per cent) were of the opinion that inspection results should
not be available to either those carrying out tests or government authorities: Do you think that inspection results of
all vehicles should be available to those carrying out tests and to government
authorities in Europe? Level of Complexity
of the System A3.44
More than half (53 per cent) of respondents do
not think that the PTI administrative procedure is too complicated in their
country at the moment, but almost one quarter (24 per cent) does. There was
some variation across Member States, however, as can be seen below: Table A3.25: Opinions regarding whether the incumbent
system is too complicated in selected Member States Member State || Number of respondents that do not think the PTI procedure in their country is too complicated || Percentage of respondents from Member State Germany || 282 || 89% Spain || 219 || 72% Poland || 52 || 64% United Kingdom || 2,595 || 55% France || 1,044 || 46% Belgium || 61 || 41% Netherlands || 443 || 41% Finland || 35 || 28% Table A3.26: Opinions regarding whether the incumbent
system is too complicated by category Category || Number of respondents that do not think the PTI procedure in their country is too complicated || Percentage of all respondents in category Organisations || 304 || 68% High || 399 || 63% Low || 65 || 57% Medium || 4,351 || 51% 1.47. Exchange
of Data A3.45
The majority of respondents (55 per cent) were
of the view that the exchange of data would not be helpful to reduce the
administration burden faced by citizens, whilst 19 per cent felt it would.
Again, there was variation across Member States: Table A3.27: Opinions regarding whether information
exchange would reduce administrative burden in selected Member States Member State || Number of respondents that do not think information exchange would reduce administrative burden || Percentage of respondents from Member State United Kingdom || 3,008 || 64% Germany || 181 || 57% France || 1,249 || 54% Netherlands || 572 || 53% Belgium || 54 || 36% Poland || 24 || 30% Finland || 34 || 27% Spain || 43 || 14% Table A3.28: Opinions regarding whether information
exchange would reduce administrative burden by category Category || Number of respondents that do not think information exchange would reduce administrative burden || Percentage of all respondents in category Medium || 4921 || 58% High || 278 || 44% Low || 32 || 28% Organisations || 68 || 15% Testing in
other Member States A3.46
Only 1.1 per cent of respondents noted that they
had been required to travel from one Member State to another in order to have
their vehicle tested. A Member State-based break up is presented below. Table A3.29: Respondents who had travelled to another
Member State to have their vehicle tested, responses from selected Member
States Member State || Number of respondents that travelled to another Member State to have their vehicle tested || Percentage of respondents from Member State Belgium || 6 || 4.1% Poland || 3 || 3.7% Spain || 6 || 2.0% Netherlands || 21 || 1.9% Finland || 2 || 1.6% Germany || 5 || 1.6% France || 25 || 1.1% United Kingdom || 18 || 0.4% Table A3.30: Respondents who had travelled to another
Member State to have their vehicle tested, responses by category Category || Number of respondents that travelled to another Member State to have their vehicle tested || Percentage of all respondents in category High || 17 || 2.7% Low || 3 || 2.6% Organisations || 10 || 2.2% Medium || 74 || 0.9% Policy Options A3.47
Finally, when asked their view on which of the
proposed policy options they would support, almost two thirds (65 per cent) of
the respondents indicated that they would support Option 1: No action. The
next most popular choice was Option 2: Bilateral agreements (10 per cent). The
remainder of the options each received between 6 per cent and 4 per cent
support each: Which of the policy options would you
support? Note that Option 4c as above has been
renamed 4a in the rest of the report, as well as Option 4a being renamed 4c. A3.48
A break up by Member State and by category is given
as follows: Table A3.31: Opinions regarding policy options in
selected Member States Member State || Options 1: No action || 2: Bilateral agreements || 3: Full mutual recognition of PTI || 4a: A standard EU-wide system for PTI - Most rigorous || 4b: A standard EU-wide system for PTI - Medium quality || 4c: A standard EU-wide system for PTI - Least rigorous || Left blank Belgium || 41% || 9% || 5% || 9% || 19% || 7% || 11% Finland || 38% || 12% || 6% || 1% || 9% || 15% || 19% France || 47% || 12% || 7% || 2% || 10% || 11% || 11% Germany || 48% || 26% || 0% || 11% || 8% || 3% || 5% Netherlands || 64% || 8% || 5% || 2% || 7% || 7% || 6% Poland || 42% || 7% || 12% || 2% || 10% || 14% || 12% Spain || 8% || 54% || 9% || 12% || 7% || 3% || 8% United Kingdom || 84% || 4% || 3% || 3% || 2% || 1% || 2% A3.49
A break up by category is as follows: Table A3.32: Opinions regarding policy options by
category Category || Options 1: No action || 2: Bilateral agreements || 3: Full mutual recognition of PTI || 4a: A standard EU-wide system for PTI - Most rigorous || 4b: A standard EU-wide system for PTI - Medium quality || 4c: A standard EU-wide system for PTI - Least rigorous || Left blank High || 42% || 18% || 4% || 8% || 12% || 7% || 9% Medium || 69% || 8% || 5% || 3% || 5% || 5% || 5% Low || 42% || 6% || 11% || 4% || 14% || 10% || 14% Organisations || 33% || 20% || 9% || 25% || 6% || 1% || 8% A3.50
A break up according to type of respondent is
given below. Table A3.33: Opinions regarding policy options by
type of respondent Option || Type of respondent Organisation / public authority || Private citizen 1: No action || 33% || 66% 2: Bilateral agreements || 20% || 9% 3: Full mutual recognition of PTI || 9% || 5% 4a: A standard EU-wide system for PTI - Most rigorous || 25% || 3% 4b: A standard EU-wide system for PTI - Medium quality || 6% || 6% 4c: A standard EU-wide system for PTI - Least rigorous || 1% || 5% Left blank || 8% || 6% A3.51
A break up according to the type of vehicle is
given below. Table A3.34: Opinions regarding policy options by
type of vehicle owned Option || Type of vehicle owned more than 8 seats || less than 8 seats || carriage of goods less than 3.5 t || carriage of goods more than 3.5 t || trailers and semi trailers less than 3.5 t || taxi and ambulance || none of these 1: No action || 45% || 63% || 58% || 71% || 72% || 68% || 74% 2: Bilateral agreements || 17% || 10% || 7% || 8% || 10% || 8% || 7% 3: Full mutual recognition of PTI || 4% || 5% || 4% || 3% || 5% || 8% || 3% 4a: A standard EU-wide system for PTI - Most rigorous || 7% || 4% || 4% || 2% || 1% || 3% || 2% 4b: A standard EU-wide system for PTI - Medium quality || 7% || 6% || 9% || 8% || 5% || 5% || 4% 4c: A standard EU-wide system for PTI - Least rigorous || 8% || 5% || 9% || 5% || 3% || 5% || 4% Left blank || 12% || 5% || 8% || 3% || 4% || 3% || 6% Appendix 4: Improved
Information Availability
1.1.54. Introduction
A4.1
Whilst this project does not require an in-depth
technical design (which would take place at a separate phase of EU policy-making)
it is important as part of this economic impact assessment to consider expected
costs associated with different forms of data delivery. To this end a high-level
design is needed of typical infrastructure options that would meet the aims. A4.2
It is a common perception that with regard to
data transmission and analysis virtually anything is technologically possible,
and for the types of data analysis relevant for this study, this is true.
However, it is essential to recognise that whilst a single data handling system
(say, an EU-wide data bank) would have the potential to accommodate all
possible uses, this would be prohibitively expensive to install and maintain at
an acceptable performance level. For this reason, more than one system may be
required. A4.3
In thinking about the possible design of data-handling
systems it is critical to first understand the aims of data sharing, as defined
by the stakeholders, so that the purpose and usage of the supporting system is
designed around these aims. A4.4
In the context of this study, a basic
distinction is needed between data needed for the purpose of: –
strategic planning, which whilst not time
critical has high data processing needs; and –
operational support, reporting and transactional
processing, which require rapid access to specific records.
1.1.55.
Strategic and planning reporting
A4.5
Strategic and planning reporting systems (also
known as decision support systems or data warehouses) gather data from single
or multiple systems and analyse them as a whole with little or no value placed
in individual records. Complexity and system delivery costs depend not only on
the volume of data stored but also upon the number of data fields and therefore
number of queries that can be generated. The challenge is mapping these data
elements together to form a coherent question to produce an answer that can be
used in the context of a single or multiple projects. A4.6
The assumption is that a planner or strategy
advisor at any level would like, or needs, to know certain facts in order to
make more informed recommendations. The value placed initially on such systems
can be hard to quantify but may come in the form of correctly prioritising one
initiative over another, deploying an initiative faster as the evidence
promotes stakeholder acceptance, or dismissing potentially costly projects that
“feel” right yet are disproved by the evidence these systems provide. A4.7
Some examples given in the context of this
impact assessment are: –
total mileage travelled by all cars registered
within the 27 Member States; –
total mileage travelled by engine size; –
total mileage travelled by vehicle / car type; –
typical age of active cars; –
age against mileage per year; –
typical engine size by age of car. A4.8
Each of these give general trend data without
needing to identify individual vehicle information, but the information of each
and every vehicle in Europe should be considered to give the most accurate
results. A4.9
The main features of such a system are: –
huge amounts of data must be analysed, sometimes
more than once, in order to provide results; –
the information itself is not changed and
therefore does not require the application that created the data to arbitrate
access to retain integrity; –
time for retrieval is not usually critical; –
initially usage is limited; however, usage
quickly ramps up as planners see benefits.
1.1.56.
Operational support / reporting and transactional
processing
A4.10
Whereas the decision support system focused on
the expansive high-level trend view, operational support systems focus on
providing (or receiving) the optimum amount of information about an individual
unit item to allow users within the EU to work more productively, more
accurately or with greater security. A4.11
Within the context of this study the unit item
involved will be individual motor vehicles or road vehicles requiring PTI
testing and test results. A4.12
Likely users include: road-using citizens /
consumers of the EU and those that support them, roadside testing authorities, testing
centres and engineers requiring historical information, police authorities, tax
authorities, and fleet managers. A4.13
The information used will define whether the
user needs the facility to update or merely see specific information. A4.14
The defined provision terms should be: –
number of and type of users that would have
access to the system; –
the information required to be effective and the
timescales for that information to be available; –
number of times a procedure is used for
individual unit evaluation. A4.15
The main features of such a system are: –
Small amounts of specific data must be retrieved
randomly from the database in order to provide results. –
The Information itself could be changed in which
case this would require application arbitration. –
Time for retrieval is critical. In many cases
sub 5 second response would be expected. Retrieval times in excess of 1 minute
would be considered unacceptable as at this level of delay users typically lose
faith in the system and cease to use it. A4.16 Similar systems are already in use within the Commission, one
example being the Tachonet system in which HGV driver registration and key card
management information is shared between specific users (in this case the Card
Registration Authorities in Member States). Suggested Aims of a Harmonised Data
Exchange A4.17 Attendees from the Workshop and Stakeholder meetings were invited to
suggest specific benefits of a harmonised information exchange with regard to
vehicle testing. A questionnaire followed requesting input on what information
would need to be exchanged, what the value this information would have in the
process identified, and any problems or limitations that could be envisaged. During
the consultation process it was requested contributors focus on the benefit of
use rather than the use itself and provide figures supporting this where
possible. The response from stakeholders was limited with only three
contributors justifying data exchange under the aims suggested and one
quantified benefit provided, suggesting that whilst many uses for data exchange
can be envisaged there is currently a lack of justifying information. A4.18
The contributed benefit remarks associated with
each aim are entered in italics. Where figures are available to support these
comments these are entered underlined. Finally each nominated aim has been
evaluated against the policy options in discussion. AIM
A-1: CO2 emissions and mileage analysis - strategic reporting High level description || This information is required for policy planning within the EU to improve decision making, accelerate policy analysis and monitor legislative impact Ease of retrieving data for further planning and analysing the effectiveness of the current policies Monitoring Response times || Undefined Minimum information required || Vehicle type, Odometer, VIN (as primary key) Value || Undefined Disadvantages || Undefined Policy option comments || Information would come from Member States’ PTI testing systems, (regardless of policy option selected) and from questionnaires available in current systems, or which will be on completion of compliance with 2010/48/EU It is not mandatory for any specific policy option; however, it should be seen as highly useful in all scenarios. AIM
A-2: Vehicle demographics – strategic reporting High level description || May allow the definition of local policies Through improved PTIs, better knowledge of actual use of vehicles across the EU (for different purposes, directly related to PTIs, but also indirectly such as calculation of EU and national motor vehicle environmental impact, setting of related taxation, incentives etc.) Response times || Undefined Minimum information required || Vehicle type Value || Undefined Disadvantages || Undefined Policy option comments || Information would come from Member States’ PTI testing systems (regardless of policy option selected) and from questionnaires available in current systems, or which will be on completion of compliance with 2010/48/EU It is not mandatory for any specific policy option; however, it should be seen as generally useful. AIM
A-3: Consumer advice 1. Fault prevalence – strategic reporting High level description || To provide a centralised “portal” allowing consumer visibility of common failures within European vehicle fleet, promoting awareness of these faults which in turn could improve road safety standards Response times || None defined, seconds? Minimum information required || None defined Value || Undefined Disadvantages || Impact on existing service providers Policy option comments || Information would come from Member States’ PTI testing systems, including fault type and fault detail information. Requires a higher level of conformity of information recorded within the Member States than is currently seen; would be partially facilitated at level 2, fully facilitated at level 3 and above. Not mandatory for any policy option. Information currently provided by some Member States, prime contractors or independent organisations, as well as similar information provided within recognised consumer publications. AIM
A-4: Roadside test authority support - operational High level description || Significant amount of anecdotal evidence suggests that performance and capture rates of roadside test teams could be improved with visibility of PTI test results. The information used here centres on targeting suspect vehicles to improve road safety, and improving efficiency of inspection to minimise inconvenience to roadworthy vehicle users. Necessary complement to PTIs, the possibility of being checked within a RSI ensures a reasonable level of compliance. Better cost-effectiveness than more regular PTIs. (This statement has been challenged by another stakeholder) More efficient inspection: vehicles inspected according to their expected features (and) reduce the inspection time Response times || Seconds Minimum information required || All those related to vehicle-defined limits (emissions, noise when applicable, etc) CITA's recommendation 15 lists the information Because of the nature of roadside inspections, some technology will need to provide the information on handheld devices. An adequate definition of the COP (certificate of conformity), considering the information necessities of PTIs may be of use. Value || Undefined Disadvantages || With a full set of information, cost is to be considered in an appropriate cost/benefit analysis (see annex 4-C below for design considerations for an operational system) Policy option comments || Information would come from PTI testing systems and could be deployed from Level 1; however, is of most value and more effective at Levels 3 and above. Information required needs to be defined by roadside testing authorities. AIM
A-5: Consumer advice 2 – operational reporting High level description || Fraud avoidance, regarding mileage Modifications in the vehicle that must be approved in certain EU Member States; may withdraw the vehicle guarantee; may impeach the sale of the vehicle in certain Member States where the approval of modifications is mandatory More difficulties for stolen vehicles trade Providing vehicle PTI test results to the consumer, leading to greater awareness of vehicle history and condition, preventing fraud, contributing to internal market and improving safety Response times || Seconds Minimum information required || PTI records Accident records Value || Un-quantified From the consumers' point of view, sometimes it is hard to justify not having official records of a vehicle's life Disadvantages || Policy option comments || Information comes from PTI test results systems. This functionality already exists in a number of instances at Member State level. Can be facilitated from Level 1, complete deployment possible from Level 3 Not necessary pre-requisite to facilitate implementation for any policy option AIM
A-6: Past test and type approval visibility within PTI test operation – operational
processing High level description || Type approval checking of parts such as exhaust silencing system, tyres, and conformity to anti-tampering provisions Facilitate the detection of modifications, and their approval Shared information would be used by PTI testing personnel to validate the tested vehicle with manufacturers’ type approval registration and vehicle history. Checking of parts such as exhaust-silencing system, airbag configurations, tyres, and conformity to anti-tampering provisions; and ensuring PTI test parameters match the vehicle performance should the engine be modified in any way. Response times || Seconds Minimum information required || See CITA recommendation 15 Information would come from manufacturers’ type approval register or appropriate alternative which may include the setting up of a centrally administered or located database or integration to country specific alternatives and PTI systems. (Additional Information concerning AIM A-11 recalls should be considered within the design) Value || Results in greater awareness and subsequent correction of faults resulting in safer vehicles and a potential 0.5 – 0.9 per cent avoidable road deaths per year[142] Disadvantages || With a full set of information, cost is to be considered in an appropriate cost/benefit analysis (see annex 4-C below for design considerations for operational system) Policy option comments || The use and outcomes are in line with continual improvement of vehicle testing yet becomes most effective at level 3 and above.
1.1.57.
AIM A-7: Anti–corruption, fraudulent and
inaccurate pass rate reduction – operational / strategic reporting
High level description || To improve detection rates of rogue and poorly trained inspections with the effect of reducing unroadworthy traffic as overall quality and compliance rises, leading to improved safety and consumer protection Response times || Undefined Minimum information required || Information within the PTI system would be analysed both at the unit level to identify specific infringements and at the strategic level to spot trends. Would require tester ID and station to be logged and potentially photographic verifications as well. Value || Undefined Disadvantages || Cost and enforceability, may require change in law Policy option comments || No defined minimum policy level; however, becomes more critical with policy options 3 and 4 where confidence in partner states’ testing procedures is mandated rather than trusted.
1.1.58.
AIM A-8: Information for those carrying out PTIs
High level description || More efficient inspection: vehicles inspected according to their expected features Avoid burdening drivers with doubts about expected performances and equipment of the vehicles Reduce the inspection time Response times || Undefined Minimum information required || Undefined An adequate definition of the COP (certificate of conformity), considering the information necessities of PTIs may help a lot Value || Undefined Disadvantages || With a full set of information, cost is to be considered in an appropriate cost/benefit analysis Policy option comments || No defined minimum policy level. No minimum level of policy is defined. Is in line with ambition to provide greater levels of information sharing. It is not possible to design or cost systems to meet this aim at this stage. Excluded from further analysis
1.1.59.
AIM A-9: Ease of the work of independent garages
and parts manufacturers reporting
High level description || Facilitate free competition Block exemption. Regulation already considers this, but the practice is far from perfect Response times || Undefined Minimum information required || All additional vehicle information. Very much dependant on each case Value || Undefined Disadvantages || Cost and scope. May require individual states to change PTI delivery laws and policy Policy option comments || No defined minimum policy level. How Member States choose to deliver PTIs to the required standard is out of scope of this study. Parts manufacturer standards are out of scope of this study. Excluded from further analysis
1.1.60.
AIM A-10: Police interface
High level description || More control of the vehicles on the road, beyond the road side inspection Ease of communicating with PTI sites and other registration authorities for the control of stolen vehicles Response times || Seconds Minimum information required || Undefined Value || Undefined. Disadvantages || Alternative systems already in place for police Stolen vehicles may not be submitted to testing, or if sold on could be highlighted under AIM A-5. Policy option comments || No defined minimum policy level. Covered under other AIMs or systems, Excluded from further analysis
1.1.61.
AIM A-11: Recall campaigns
High level description || PTI centres, road side inspectors and police may know which vehicles are pending a recall campaign In many countries it is uncertain whether all vehicle owners are aware of recall campaigns Response times || Seconds Minimum information required || Undefined Value || Undefined Disadvantages || Ability of testing centre to resolve the recall issue, or re-charge manufacturer if warranty recall Policy option comments || No defined minimum policy level. See this as an extension of information provided under AIM A-6, or not directly relevant to PTIs unless defect causes failure. Excluded from further analysis A4.19 The report team also recognise that there are wider uses for data
exchange that have not been raised by stakeholders, and these are shown below. Table A4. 1: Benefits of improved communications
technology Stakeholder || Use Registration authorities || To facilitate the follow up of the vehicle, including property issues Taxation authorities || To check if any specification related to taxes has changed Insurance companies || To consider all the equipment covered by the vehicle insurance Independent workshops and parts manufacturers || Better position to compete with manufacturer-linked providers Transport authorities || Harmonisation of the approval of vehicles’ modifications during their life
1.1.62.
The present situation: results of survey for
this study
A4.20
In order to assess the implications of possible
new data exchange initiatives we wished to understand present arrangements. We
therefore held a number of discussions, and sent a questionnaire to experts in
different Member States. A4.21
The options discussed here are derived from
formal and informal discussions with vehicle industry specialists that have
responded to the study questionnaires and given input to workshops, stakeholder
meetings and follow-up meetings. The conclusions given are based on available
information, current computing best practice, experience, and reviews of
equivalent projects already delivered within the community. A4.22
The questionnaire was sent to the contact point
for the agency responsible for PTI testing in each Member State, (or named
personnel where that information was available), or to the main government
transport contact point. Where it was shown that a Member State had one or
more main contractors providing the service the questionnaire was further
distributed to these organisations. Reminders were sent, and in order to
promote additional responses a smaller subset of questions agreed with the Commission
as having the greatest potential value within an information exchange without
encroaching on potentially sensitive areas such as outsourcing contracts or
national security. This subset was distributed to the recipients previously
listed. A4.23
At the time of the Stakeholder meeting a total
of five Member States had supplied input to the main questionnaire with an
additional two states providing answers to the subset questions. A further
request was made at the Stakeholder meeting for completed questionnaires, which
has resulted in four more responses with varying degrees of completeness. A4.24
The full questionnaire was designed to
understand as much about Member States’ applications as possible. This
questionnaire was to give an accurate picture of the Member State technology
support for the implementation of 2010/48/EU, recognise where omissions may
exist that would impact on meeting the defined aims in Annex 4-A, and where
possible predict what costs could be incurred or where existing techniques
should be used to facilitate data sharing. Responders were invited to add any
information they felt was pertinent to the study. A4.25
The areas of study included: –
application topology; –
number of records held; –
number of vehicles recorded; –
number of authorised testing centres; –
database type and manufacturer; –
supporting Infrastructure; –
development cycles and methodology; –
existing data sharing techniques. A4.26
The critical subset questions asked specifically
whether information on the following aspects of PTI testing were recorded and
held electronically. A4.27
These fields are: –
vehicle Identification Number (VIN); –
registration Plate Number; –
engine Type – Petrol / Diesel / LPG / Electric /
Hybrid; –
emissions Euro Class; –
mileage / Odometer reading; –
failures; –
failure details recorded; –
date of first registration.
1.1.63.
Summary of findings
A4.28 Of those that responded (both full and partial) the following
results were seen. VIN || Recorded level 100 per cent Registration plate || Recorded level 91 per cent Engine type || Recorded level 100 per cent except hybrids with one stated omission Engine euro class || Recorded level 82 per cent Mileage / odometer reading || Recorded level 82 per cent Failures || Recorded level 100 per cent (yet may not be consistent recording) Failure details || Recorded level 82 per cent and not consistent Date of first registration || Recorded level 100 per cent A4.29
Further analysis of the more detailed responses
showed a far wider variance of response, the highlights of which are discussed
below.
1.1.64.
Topology, databases and infrastructure
A4.30
Whilst 100 per cent of systems were written against
relational databases, the manufacturers and versions of database used were for
the most part unique. Oracle was marginally more prevalent but not decisively
so, and of those Database systems used both commercial and non-commercial
versions were deployed along with a wide range of underlying hardware and
operating systems. In addition to the Oracle instances discussed, MySQL and
MSSQL Server were also installed. A4.31
It should also be noted that whilst most
information in these systems is held in structured format one nation also held
Blobs (these are typically scanned images or photos stored within the structure
of the database). This technique is often used to simplify the programming
overhead; however, it typically significantly increases the size of the data
store required. A4.32
Some respondents indicated that they perform a
level of archiving to maintain performance and remove legacy information. This
will impact the ability to make long-term trend analysis should this be
required.
1.1.65.
Records held
A4.33
The number of records held against the number of
vehicles managed varies widely across the Member States, and appears to reflect
the level of details stored rather than a build-up of historic records.
Database sizes vary widely and range from less than 50GB to over 200GB in size
with the maximum ratio of records to vehicles of 14:1.
1.1.66.
Information held
A4.34
Some fields, in addition to those referenced
above, are common to most systems. These include minor defects recorded and
brake-effectiveness tests. The following breakdown covers commonality of
recording. It should be noted that no one country records all details and
there is no apparent hierarchy of intensive to minimal data collection across
the responding Member States. –
71 per cent recorded: lighting system details; –
57 per cent recorded: SRS or airbag information; –
42 per cent recorded: ABS systems and/or emissions
and/or body kit modifications; –
14 per cent recorded: routine tyre tread levels. A4.35 It is noted that whilst the defects most contributing to accidents
and poorer accident outcomes are tyres and brakes, only one country records
tyre-tread information details and no country routinely records the levels of
perishable parts of the braking systems (such as pads and disks) although some
do include them as an advisory notice.[143]
1.1.67.
Existing information input and exchange
techniques
A4.36
Data input varies from respondent to respondent
with no common method showing from the small sample. Methods used include: direct
data input via terminal, web interface or XML data uploads, or FTP (file
transfer protocol) bulk uploads via the internet or other secured
communication.
1.1.68.
Development cycles, costs and methodology
A4.37
All respondents indicated that the Agile
methodology for application development was used to drive enhancements to the
system. This method is highly efficient at driving development and updates
quickly into production, and meeting and modifying requirements; however, a
common result of poorly managed Agile developments can be poor documentation or
duplication / unrepeatable effort. This study is not in a position to comment
on whether documentation standards are sufficient to aid swift transition to a
shared data model. A4.38
Where costs for development were provided, these
are very low compared to expected commercial rates; however, they are
consistent across all respondents. The charge expected to add a new data field
to an application is quoted at less than € 1,000.
1.1.69.
High level technical design
A4.39
Whilst this is not the forum for an in-depth
technical design which is a separate phase of EU policy decision–making, it is
important as part of this economic impact assessment to give expected costs
associated with such a systems delivery. To this end a high-level design is
needed, of typical infrastructure options, in order to meet the aims. A4.40
This section is not a detailed requirements
analysis, as defined by Commission policy. Strategic information analysis systems A4.41
The information required to meet the objectives
for these systems are, from the responses of the study, available at the
national level from the majority of Member States. Those that do not currently
store this information will be obliged to, under the 2010/48/EU regulations,
and are working towards including this. Where specific vehicle types, such as
motorcycles, are not tested by Member States the information will not be
available. A4.42
The key information is stored within the Member States’
roadworthiness databases. The nature of the information needed for strategic
planning is typically non-sensitive, and providing that personal data are held
in separate tables it should not cause any data protection issues in creating a
central store. Those systems that do hold personal and technical information
within the same tablespace could be made anonymous and obfuscated using
industry standard tools to satisfy any personal / private data concerns. A4.43
Strategic planning can occur at multiple levels
and therefore should be open and usable by regional agencies and Member State
central administrations, as well as the EU administration. With this in mind,
whilst the focus of this report is to provide reporting capability to the Commission,
Member States should be encouraged to use the extracted data for their own
use. Should all Member States agree to this it may be more cost-effective for
each state to submit reports (rather than raw data), and for the Commission to
amalgamate these manually. If this route is taken there will, however, be
compromises that need to be made. The first is that the burden on each Member State
will increase, the second is that flexibility and responsiveness to new
“questions” will decline. A4.44
The final step is to determine the most
efficient method to allow these various users to analyse the data without
impacting the source system and the users that created it, or burdening one
user group with all processing responsibilities. A4.45
Given that a single non-complex query could
require visibility of excess of 300 million rows of data scaling, an
interconnected data exchange would be cost-prohibitive and cause the vehicle
testing applications of each Member State to slow unacceptably. A4.46
Replicating centrally and merging databases is
also prohibitively expensive in terms of central infrastructure needs, and also
then places a restriction on Member State initiatives for modernisation and
innovation in case it disrupts the data integration. With many different
application vendors each rolling out updates this option is not feasible. A4.47
As such the suggested technical design is for a
standard Extract / Archiving tool that will support heterogeneous database
vendors in producing images of the PTI databases, selecting only those data
fields that are relevant to the planning requirements and omitting (or
privatising where omission is not feasible) all other records. Because only
limited fields are required the central integration is far simpler;
alternatively, each country could be analysed separately with suitable data
connectors. It is still recommended to centralise the information within the
EU to reduce the traffic overhead of multiple queries. The original images,
which remain in-country, could be used by the Member State if they do not
already have a decision support system. The final advantage of this method is that
historic data can be retained within the planning model where the production
system may undergo archiving of old data to maintain performance levels and
contain costs. A4.48
This model is effective for the emission / mileage
and vehicle demographics analysis aims (A1 & A2) discussed above. A4.49
This method is not best suited to the AIM A-3: Consumer
Advice – 1, which aims to show fleet inspection issues by vehicle type. Some
countries already provide this information free via web access to (their)
citizens, either through the testing partner or the central agency themselves.
Consideration needs to be made to those (non-)government organisations that
provide this information on a commercial basis either via web access or through
other mediums such as monthly magazines/ guides. A4.50
Implementing a web mashups interface to
consolidate existing web feeds and services, and then providing a web / mobile
enabled weblink to the consolidated data reuses existing technology and is cost–effective;
however, it will require monitoring to ensure the data access remains
consistent and up-to-date. An alternative is to request the raw data from the Member
State (VOSA is able to provide this in CSV format) and to centrally merge it. A4.51
In web development, a mashup is a web page or
application that uses and combines data, presentation or functionality from two
or more sources to create new services. The term implies easy, fast
integration, frequently using open-application interfaces and data sources to
produce enriched results that were not necessarily the original reason for
producing the raw source data. Operational infrastructure design A4.52 Based on the quantified benefits of aim A-6, the type approval
datastore should be seen as a critical complementary system for policy options
to support accurate testing to deliver rising safety standards as a result.
This system is currently in development in a number of Member States, and is a
recommendation of CITA and is under review by the ACEA (European Automobile
Manufacturers Association). The aim is an input of information to the PTI
testing process and therefore is applicable to all policy options. Whether
this should be maintained by Member States, centralised, or provided by
manufacturer is open to debate. A4.53
The factors influencing design include: –
expected numbers of standard approvals across
all Member States vs. number of Member State specific approval documents; –
frequency of update of an individual record to
meet Member State regulations; –
number and type of updates to vehicle fleet
registration as a whole; and –
the number of users who should reasonably expect
access. A4.54 The key design factor here focuses on who is responsible for the
supply and maintenance of this data; the Member State where the vehicle is
registered or the manufacturer of the vehicle. A4.55
The remaining operational aims concern the
recording and redistribution of information from the PTI test itself. The
policy choice will determine the level of information mandated for exchange;
however, all options could supply and benefit from information exchange. The
exception is that, in order to facilitate policy options 3 and 4, a data
exchange standard is required to ensure that application modernisation and
innovation in all forms is not restricted by interoperability testing with 26
other applications for PTIs and potentially an equal number of Roadside Test
databases. Determining the level of information exchange should be the subject
of detailed design requirements. A4.56
Implementing a data exchange does not require
the centralisation or standardisation of databases or applications if messaging
techniques are used. In fact it should be stated that implementation of a
centralised system for the running of PTI testing across Europe is cost-prohibitive,
compared to retaining ownership and responsibility of data at the Member State
level with a peer-peer connectivity with centralised routing. This has been
tried and tested with other systems such as Tachonet, and with costs of network
infrastructure decreasing and performance improving this still holds true. A4.57
Should significant volumes of detailed
information be shared, application providers should move toward conformity with
the failure notice codes laid out in directive 2010/48/EU to reduce
“translation” processing. This, however, is costly and should only be
undertaken where need is proven. A4.58
The current trend of using XML as the data
transfer protocol appears sound, with Tachonet performance within the Member States
for the most part meeting service level agreements. This and other similar
systems, however, transmit relatively few data fields and therefore careful
consideration is necessary to ensure that the minimum volumes of data are
transmitted to adequately meet the end user’s requirements. A4.59
Typical XML challenges include: –
The very nature of XML makes it 3 to 10 times
more expansive than traditional communications mechanisms, rendering XML
applications more computationally intensive and network-hungry. With an
increase in XML traffic, ensuring application performance and server efficiency
becomes problematic unless rigorously monitored. CITA have made a
recommendation to standardise the coding of information into the database (CITA
recommendation number 15 and complies for the most part with 2010/48/EU), which
results in excess of 400 data fields including photographic information.
Decisions on the PTI testing level will fundamentally affect the sizing of any
system capable of delivering this volume of data. –
In addition to the data size transported the
frequency also needs to be considered. Approximately one per cent of respondents
from the survey suggested they make specific inter-country journeys to undergo
PTI testing. Extrapolating this out suggests 3 million “transactions” will
occur through the defined testing cycle. This upload phase equates to
approximately 17 uploads per minute peaking at yearly testing cycles. –
Download data volumes are dependent on
individual need and have not been defined to a level where accurate assessments
can be made (see AIMs above). As such, a base exchange system is suggested
which could scale as required. When combining data volumes with throughput, it
is clear that unless the information required to meet a specified aim is
clearly defined there is a significant risk of escalating costs both in network
and server infrastructure. It is recommended that the majority of PTI test
data is retained in the system of the delivering Member State, with the minimum
transferred to meet business need so as to circumvent surplus initial data
transfers whilst avoiding long-term re-requesting of data through the exchange
system. –
New security threats arise with an increase in
XML traffic. When XML facilitates the sharing of common services outside
traditional security mechanisms, information often crosses trust boundaries
between applications. Additionally, new XML threats are regularly directed at
networks. This risk is minimised through the S-TESTA network; implementation,
however, would require strong authentication routines. With the potentially
large number of end-users in scope, careful consideration needs to be made on
what data are exchanged and the endpoint security measures required. It is
expected that Member States will have adequate security measures already in
place for the existing systems. This study has not investigated the security
designs as this would be a key phase of the detailed design. –
Availability and integration: the growth in the
number of users and the breadth and scope of applications make availability and
integration raise separate challenges. Ensuring availability and integration
across applications as the user base grows can require huge time and resource
investments, and can have a significant effect on application performance. It
is critical therefore to understand the true user population which should be
clearly defined at the detailed design phase. A4.60
The final operational aim A-5 involves consumer
access to previous and current test results to facilitate the exchange of goods,
avoid fraudulent purchases, and be aware of advisory notices that may have
become safety concerns since the test. A4.61 This system of review is already available in Member States through
the web (although some Member States do not yet provide this service). Charges
here are variable with some Member States providing this service free to the
enquirer. By opening up the back-end databases through the data exchange in
place for mutual recognition, historic information could be provided with
little change to the existing consumer front-end. The Commission will need to
discuss with its members a suitable EU method of charging for this service,
particularly where the service is currently free. The cost benefit for this
service cannot yet be defined as there is a lack of data relating to cross-border
sales rates for vehicles, and with web connectivity a consumer could still sign
into the originating country’s site rather than through a central portal.
Comments from the stakeholder meeting suggest that the majority of vehicles are
sold in the originating country, although this cannot be quantified or
substantiated. Cost Benefit Analysis A4.62 Due to the limited input from the stakeholders on the benefits of
information exchange, and where input has been made the level of quantifiable
value benefit is such that the cost/benefit analysis for information exchange
cannot be made, indications of rough order of magnitude costs (+/- 25 per
cent), rather than return-on-investment or payback statements are given. A4.63
The costs of implementation are broken down into
the following categories: –
one-off capital expenditure including
Infrastructure, application-modification cost, system-provisioning testing and
documentation, and high availability / business recovery elements (Initial expenditure
- Init.); –
ongoing operational support costs, such as hardware
and software maintenance, system and data backups, password and user management
(Maintenance costs - Maint.) –
administration service review costs, to provide
details of service delivery against defined service levels such as data or and
monitor for service outages / poor responses against agreed levels and to
reporting to the Commission / citizens of overall performance (Management costs
- Mgmt.). Aim reference || Type || Policy level || Ability to execute. Across Member States || Quantified benefits / value statement A1: CO2 and mileage planning || Strategic || All || Partial – full conformity of 2010/48/EU will facilitate || Undefined A2: Vehicle demographics || Strategic || All || Partial – full conformity of 2010/48/EU will facilitate || Undefined A3: Fault prevalence || Strategic || From level 2 Optimum 3 + || Limited – requires standardisation of information || Undefined A4: Roadside test authority support || Operational || From Level 1 Optimum at level 3+ || Strong on limited data fields. Requires greater definition || Undefined A5: Vehicle details consumer advice || Operational || From Level 1 Optimum at level 3+ || Full and existing within some Member States || Undefined A6: Type approval information within PTIs || Operational || All levels Optimum at Level 3+ || Limited, non-standard deployment limits reuse || 0.5-0.9% death reduction p.a. A7: Anti-corruption /performance checking of PTI establishments || Operational and strategic || Integral from Level 3+ || Low, limited by ability to prosecute across borders and by recognition of testing centre details || Undefined Strategic reporting cost breakdown AIM || Sizing qualification || Application change costs, per state (% of states impacted) || Member State costs (27) || Central costs || Total estimated TCO (5yr) Strategic A1 & A2 || Based on delivery and processing of 2TB of base data || Init. € 15,000 (20%) Maint. No change Mgmt. No change || Init. € 40,000 Maint. € 5,000 Mgmt. € 2,000 || Init. € 2,200,000 Maint. € 150,000 Mgmt. € 15,000 || Init. € 3,400,000 Maint. € 1,300,000 Mgmt. € 345,000 TOTAL central supply a data intelligence system || || || || || Total € 5,045,000 Strategic A3 || Based on providing central EU web Mashup over existing systems. Excluding network where existing infrastructure is deemed sufficient || Init. None Maint. No change Mgmt. No change || Init. None Maint. No change Mgmt. No change || Init. € 180,000 Maint. € 70,000 Mgmt. € 10,000 || Init. € 180,000 Maint. € 350,000 Mgmt. € 50,000 TOTAL for consumer support engine for common failures || On assumption that this information is already available within MS and simply merging data || || || || Total 580,000 Operational cost examples AIM || Sizing qualification || Application change costs, per state (% of states impacted) || Member State costs (27) || Central costs || Total estimated TCO (5yr) Aim A-6 || Development of existing applications to concurrently show type approval information based on VIN and Plus 50 data fields. Raw data feeds from manufacturers. This excludes requests to other Member States covered in Example 1 for over-border testing Central costs cover standard requirements statements || Init. € 100,000 (100%) Maint. € 20,000 Mgmt. No change || Init. € 20,000* Maint. € 4,000 Mgmt. No change *Costs for storage uplift and excluding performance uplifts or associated DB licenses || Init. € 80,000 Maint. None Mgmt. € 10,000 Excluded manufacturer costs to supply data || Init. € 2,120,000 Maint € 3,240,000 Mgmt € 50,000 Example 1 || Based on delivery of 10 standard data fields at a sustained rate of 50 enquiries per minute, excluding network charges (26Mill Transaction pa) || Init. € 150,000 (100%) Maint. € 25,000 (100%) Mgmt. No change || Init. € 80,000 Maint. € 30,000 Mgmt. € 10,000 || Init. € 750,000 Maint. € 200,000 Mgmt. € 20,000 || Init. € 6,960,000 Maint. € 8,425,000 Mgmt. € 1,450,000 Total € 16,835,000 Example 2 || Network costs 512Mbit LL 1Mbit LL 8Gbit LL || || € 500 (pm) € 750 (pm) || € 4,200 (pm) || € 810,000 € 1,215,000 € 252,000 Example 3 || Based on re-engineering application for 400 field changes, to enforce standardisation of failure notice codes (rather than translate in messaging) || Init. € 400,000 (100%) Maint. No change Mgmt No change || || || Init. 10,800,000 TOTALS for operational purposes for mandatory recognition (level 3) and above || Uplift of existing systems* to provide the “minimum” amount of data required to meet the need of confirming a vehicle has a valid PTI certificate, introduce a type approval register per country, and undertake a standardisation of failure coding to ease data exchange and optimise messaging overheads.[144] || Init. € 650,000 Maint. € 45,000 Mgmt. No change || Init. € 100,000 Maint € 43,000 Mgmt. € 10,000 || Init. € 830,000 Maint. € 250,400 Mgmt.. € 30,000 || 5yr TCO € 36,387,000 Total for voluntary mutual recognition Level 2 only || Based on providing access to Member State PTI interface through website to satisfy bi-lateral recognition agreements. Per agreement. Suggested costs include translation services. Assumption of average of 4 contracted testing sites per agreement. || Per agreement Init. € 10,000 Maint. € 3,000 Mgmt. € 3,000 || Per testing site contracted Init. € 2,000 Maint € 5,000 Mgmt. No change Uplifts for second agreements will be a fraction of initial costs. || || TOTALS for operational purposes || Based on 10 Member States each with 4 voluntary recognition agreements in place. Each using the same 4 “international” testing stations || || || || € 1,130,000 Note: Int. = Initial expenditure, Maint.
= Maintenance costs, and Mgmt. = Management costs Appendix 5: Potential Levels for Roadside Inspections
1.1.70. RSI: Basic level
Technology and procedures || Vehicle identification and visual inspection of all relevant parts on roadside Number of vehicles tested || Randomised. Not in relation to existing traffic situation in MS (no statistical background for inspection) Vehicle categories covered || Only HGV exceeding 3.5 tonnes Personal skills and qualifications || Policeman and others involved in traffic control Supervision and enforcement measures || Allowed to continue travelling after instant repair if defects are found * For taxis and ambulances
1.1.71. RSI: Medium level
Technology and procedures || Vehicle identification and visual inspection of all relevant parts on roadside. After vehicle is categorised as unsafe, the vehicle is taken to an inspection station where a roller brake tester, emission tester and all other PTI-equipment are available. Number of vehicles tested || Randomised and pre-selected. Not in relation to existing traffic situation in MS (no statistical background for inspection) Vehicle categories covered || M23N23O34 Personal skills and qualifications || Specially trained staff from police or other departments in region Supervision and enforcement measures || Evaluation supervision by road administration and Ministry of Transport as well as PTI organisations
1.1.72. RSI: High level
Technology and procedures || Special mobile equipment, like mobile roller brake tester or mobile lifting platform which includes play detectors and mobile emission devices capable for testing HGVs Number of vehicles tested || Pre-selected high volume of testing with re-testing of a lower number of vehicles in-depth (but significant share) in accordance with the overall traffic at MS level Vehicle categories covered || M23N23O34 Personal skills and qualifications || Specially trained staff from police or other departments in combination with PTI organisations Supervision and enforcement measures || Evaluation supervision by road administration and Ministry of Transport as well as PTI organisations A5.1
If the Commission wished to define a system of
roadside testing for all Member States, the first step would be to define
clearly the technology and processes to be used for RSI as well as the exact
definitions of what should be counted as a failure. The second step would be a
decision on the number of vehicles to be tested in relation to the existing
fleet and the known transit traffic in each MS. Pre-selection should be
disallowed in order to avoid biases in the data collected. A5.2
A two-step approach for RSI seems the most
effective, with a high volume of vehicles given a brief inspection and then the
smaller number of vehicles screened as likely to be incompliant sent off for
further checks. From the results of Member States who already use this
approach, it can be seen that approximately 10 per cent of vehicles will be
found non-compliant in the initial check. Appendix 6: European Approaches to Monetising
the Value of Road Safety A6.1
There is no one official estimate of the
monetary value of road safety. This appendix gives a brief overview of some of
the approaches followed in this regard. 1.48. ‘The
million Euros rule’ A6.2
In a Communication[145] promoting EU road
safety in 1997, the Commission estimated that avoiding one fatal injury would
be worth one million Euros.[146]
This value encompassed the economic loss due to a fatality, in addition to a
large portion of the economic loss due to injury and property damage. This was
based on the assumption that any measure that improved safety, and hence led to
a reduction in fatalities, would also have the effect of reducing injuries and
property damage. A6.3
This estimate is commonly used, but has the
disadvantage of not having being updated since 1997. HEATCO Recommendation A6.4
The HEATCO project[147] (aimed at
developing harmonised European approaches for transport costing and project
assessment) was completed in 2006. As part of the final report, methods for
evaluating costs of accidents were dealt with. A6.5
The final report recommended a two-stage
approach. –
In the first stage, there would be a correction
for under-reporting of road accidents. These correction factors are as shown in
the table below: Table A6.Error! No text of specified style in
document..29: Recommendation for European average
correction factors for unreported road accidents || Fatality || Serious injury || Slight injury || Average injury || Damage only Car || 1.02 || 1.25 || 2.00 || 1.63 || 3.50 Motorbike/moped || 1.02 || 1.55 || 3.20 || 2.38 || 6.50 Bicycle || 1.02 || 2.75 || 8.00 || 5.38 || 18.50 Pedestrian || 1.02 || 1.35 || 2.40 || 1.88 || 4.50 Average || 1.02 || 1.50 || 3.00 || 2.25 || 6.00 Source: HEATCO final report –
In the second stage, the adjusted number of
accidents would be evaluated using country-level estimates formulated using a
willingness-to-pay approach. If no estimate was available, then it was
recommended that the values in the following table be used. Source: HEATCO final report 1.49. Country-level
Official Estimates A6.6
Although there is no official EU level estimate
for the value of an avoided fatality, several Member States have published
country-level estimates formulated based on a willingness-to-pay approach. The
Commission has published a comparison of these levels on its website[148] based on reviews of
Sælensminde (2001), de Blaeij et al (2004) and Tecl and Konarek (2006).
This is reproduced below. Figure A6.Error! No text of specified style in
document..7: Monetary valuation of preventing a road
accident fatality in a number of countries Source: http://ec.europa.eu/transport/road_safety/specialist/knowledge/measures/monetary_valuation_of_road_safety/index.htm Other Estimates A6.7
In 2003, in a proposal for an amendment to a
Directive,[149]
the Commission provided the following estimates for valuing various types of
estimates. Accident risk || Value (€ per case) Fatal || 1,000,000 Serious injury || 135,000 Slight injury || 15,000 A6.8
These estimates, however, do not appear in the eventual
amendment.[150] Appendix 7: Calculating the Total Cost of
PTIs in Europe A7.1
The annual total number of inspections was
calculated using the present PTI frequencies shown in Table 7.2. Given an
approximate average age for scrapping vehicles of 17 years, annual inspection
frequencies were calculated for each vehicle type within each Member State. Where
no information was available for a Member State on the PTI frequency in
question, annual inspection frequencies were estimated using the average
frequency for other countries in the same PTI grouping (i.e. high / medium /
low). Where this estimation has been used in the calculations it is indicated
by a star (*) in the tables below. A7.2
Figures for the stock of vehicle types within
each Member State in 2008 (source: European Commission Statistical Pocketbook
2010: EU Energy and Transport in Figures) were multiplied by the relevant
inspection frequency to gain an approximation of the annual number of PTIs for
each vehicle type within each country. Table A7.1: Passenger car PTI totals Member State || PTI frequency || Car stock in 2008 (000) || Annual car PTIs (000) Belgium || 0.82 || 5,131 || 4,226 Bulgaria || 0.82 || 2,366 || 1,948 Czech Republic || 0.44 || 4,423 || 1,951 Denmark || 0.44 || 2,099 || 926 Germany || 0.47 || 41,321 || 19,445 Estonia || 0.71 || 552 || 390 Ireland || 0.44 || 1,953 || 862 Greece || 0.60* || 5,024 || 3,005 Spain || 0.71 || 22,145 || 15,632 France || 0.44 || 31,109 || 13,725 Italy || 0.44 || 36,105 || 15,929 Cyprus || 0.44 || 444 || 196 Latvia || 0.50 || 933 || 467 Lithuania || 0.47 || 1,671 || 786 Luxembourg || 0.85 || 329 || 281 Hungary || 0.41 || 3,055 || 1,258 Malta || 1.00 || 229 || 229 Netherlands || 0.71 || 7,542 || 5,324 Austria || 0.82 || 4,285 || 3,529 Poland || 0.82 || 16,080 || 13,242 Portugal || 0.71 || 4,408 || 3,112 Romania || 0.50 || 4,027 || 2,014 Slovenia || 0.47 || 1,045 || 492 Slovakia || 0.88 || 1,545 || 1,363 Finland || 0.82 || 2,700 || 2,224 Sweden || 0.82 || 4,279 || 3,524 United Kingdom || 0.88 || 29,279 || 25,834 Source: EU energy and transport in
figures – Statistical pocketbook 201; AUTOFORE Study on the Future Options for
Roadworthiness in the European Union: WP540 – Analysis of pass/fail rates and
accidents for different vehicle types in relation to PTI – frequency and
vehicle age; DEKRA Table A7.2: Bus & coach PTI totals Member State || PTI frequency || Bus/coach stock in 2008 (000) || Annual bus/coach PTIs (000) Belgium || 4.00 || 16 || 64 Bulgaria || 1.00 || 25 || 25 Czech Republic || 1.00 || 21 || 21 Denmark || 1.00 || 15 || 15 Germany || 1.00 || 75 || 75 Estonia || 1.00 || 4 || 4 Ireland || 1.00 || 9 || 9 Greece || 1.00* || 27 || 27 Spain || 1.82 || 62 || 113 France || 0.44 || 93 || 41 Italy || 1.00 || 98 || 98 Cyprus || 1.00 || 3 || 3 Latvia || 1.00 || 11 || 11 Lithuania || 1.00 || 14 || 14 Luxembourg || 2.00 || 2 || 3 Hungary || 1.00 || 18 || 18 Malta || 1.00 || 1 || 1 Netherlands || 1.00 || 11 || 11 Austria || 1.00 || 9 || 9 Poland || 1.00 || 92 || 92 Portugal || 1.00 || 15 || 15 Romania || 1.00 || 42 || 42 Slovenia || 1.00 || 2 || 2 Slovakia || 1.00 || 11 || 11 Finland || 1.00 || 12 || 12 Sweden || 1.00 || 14 || 14 United Kingdom || 1.00 || 114 || 114 Source: EU energy and transport in
figures – Statistical pocketbook 201; AUTOFORE Study on the Future Options for
Roadworthiness in the European Union: WP540 – Analysis of pass/fail rates and
accidents for different vehicle types in relation to PTI – frequency and
vehicle age; DEKRA Table A7.3: Goods vehicle PTI totals Member State || PTI frequency || Goods vehicle stock in 2008 (000) || Annual goods vehicle PTIs (000) Belgium || 2.00 || 712 || 1,424 Bulgaria || 1.00 || 299 || 299 Czech Republic || 1.00 || 607 || 607 Denmark || 1.00 || 531 || 531 Germany || 1.00 || 2,524 || 2,524 Estonia || 1.00 || 83 || 83 Ireland || 1.00 || 351 || 351 Greece || 1.10* || 1,290 || 1,424 Spain || 1.00 || 5,406 || 5,406 France || 1.00 || 5,212 || 5,212 Italy || 1.00 || 4,535 || 4,535 Cyprus || 1.00 || 122 || 122 Latvia || 2.00 || 130 || 260 Lithuania || 1.00 || 150 || 150 Luxembourg || 2.00 || 34 || 69 Hungary || 1.00 || 471 || 471 Malta || 1.00 || 48 || 48 Netherlands || 1.00 || 1,026 || 1,026 Austria || 1.00 || 381 || 381 Poland || 1.00 || 2,922 || 2,922 Portugal || 1.00 || 1,350 || 1,350 Romania || 1.94 || 645 || 1,253 Slovenia || 1.00 || 84 || 84 Slovakia || 1.00 || 249 || 249 Finland || 1.00 || 425 || 425 Sweden || 1.00 || 510 || 510 United Kingdom || 1.00 || 3,874 || 3,874 Source: EU energy and transport in
figures – Statistical pocketbook 201; AUTOFORE Study on the Future Options for
Roadworthiness in the European Union: WP540 – Analysis of pass/fail rates and
accidents for different vehicle types in relation to PTI – frequency and
vehicle age; DEKRA Table A7.4: Powered two-wheel PTI totals Member State || PTI frequency || Two-wheel stock in 2008 (000) || Annual two-wheel inspections (000) Belgium || - || 388 || 0 Bulgaria || 0.52* || 107 || 55 Czech Republic || 0.44 || 893 || 394 Denmark || 0.45* || 205 || 92 Germany || 0.50 || 5,852 || 2,926 Estonia || 0.76 || 18 || 13 Ireland || 0.45* || 39 || 18 Greece || - || 1,389 || 0 Spain || 0.41 || 4,912 || 2,022 France || - || 2,704 || 0 Italy || 0.44 || 9,189 || 4,054 Cyprus || 0.52* || 43 || 22 Latvia || 1.00 || 51 || 51 Lithuania || 0.52* || 46 || 24 Luxembourg || 0.85 || 40 || 34 Hungary || 0.44 || 142 || 62 Malta || 0.52* || 14 || 7 Netherlands || - || 1,480 || 0 Austria || 1.00 || 691 || 691 Poland || 0.82 || 1,607 || 1,324 Portugal || - || 550 || 0 Romania || 0.52* || 72 || 37 Slovenia || 0.88 || 82 || 72 Slovakia || 0.45* || 70 || 32 Finland || - || 422 || 0 Sweden || 0.44 || 554 || 244 United Kingdom || 0.88 || 1,322 || 1,166 Source: EU energy and transport in
figures – Statistical pocketbook 201; AUTOFORE Study on the Future Options for
Roadworthiness in the European Union: WP540 – Analysis of pass/fail rates and
accidents for different vehicle types in relation to PTI – frequency and
vehicle age; DEKRA A7.3
To estimate the current total cost of PTIs, 2004
inspection fees for passenger cars were taken from Table 7.4 as an estimate of
the cost of a PTI within a country. Again, where these were not available for
a Member State they were estimated by the average cost in other Member States
with the same PTI category. These values were then adjusted in line with price
rises between 2004 and 2010.[151]
These were then multiplied by the total number of PTIs in each country and
summed to give an estimate of € 8.5 billion for the current total cost for PTIs
in the EU. Table A7.5: PTI totals by Member State Member State || PTI price in 2010 (€) || Total PTI (000) || Total cost (€ million) Belgium || 28.07 || 5,713 || 160 Bulgaria || 33.79 || 2,328 || 79 Czech Republic || 57.28 || 2,974 || 170 Denmark || 61.64 || 1,564 || 96 Germany || 45.83 || 24,970 || 1,144 Estonia || 34.37 || 491 || 17 Ireland || 55.45 || 1,240 || 69 Greece || 41.24 || 4,456 || 184 Spain || 35.52 || 23,173 || 823 France || 63.01 || 18,978 || 1,196 Italy || 40.10 || 24,615 || 987 Cyprus || 33.79 || 343 || 12 Latvia || 48.67 || 788 || 38 Lithuania || 33.79 || 974 || 33 Luxembourg || 23.94 || 387 || 9 Hungary || 23.12 || 1,809 || 42 Malta || 33.79 || 286 || 10 Netherlands || 48.67 || 6,361 || 310 Austria || 42.39 || 4,611 || 195 Poland || 24.39 || 17,580 || 429 Portugal || 28.22 || 4,477 || 126 Romania || 33.79 || 3,345 || 113 Slovenia || 40.10 || 650 || 26 Slovakia || 48.67 || 1,654 || 80 Finland || 56.14 || 2,660 || 149 Sweden || 37.81 || 4,292 || 162 United Kingdom || 60.14 || 30,988 || 1,863 Total || 191,708 || € 8,524 Source: AUTOFORE (2007) “WP 700:
Cost-benefit analyses for roadworthiness options” [1] An exception to this would be if a Member State were
to use roadside testing as a way of deterring commercial vehicles registered in
another country. As far as we know, this has not been suggested. In addition,
EC Directive 2000/30/EC specifically states that technical roadside inspections
must be carried out without discrimination on grounds of the nationality of the
driver or the country of registration or entry into service of the commercial
vehicle. [2] For roadside testing, this would relate to the number
of vehicles targeted for roadside tests each year. [3] Communication from the Commission (2010) “Towards a
European road safety area: policy orientations on road safety 2011-2020”
COM(2010) 389 [4] Defined as: an inspection of a technical nature, not
announced by the authorities and therefore unexpected, of a commercial vehicle
circulating within the territory of a Member State carried out on the public
highway by the authorities, or under their supervision. [5] Regulation (EC) No 1071/2009 of
the European Parliament and of the Council of 21 October 2009; establishing
common rules concerning the conditions to be complied with to pursue the
occupation of road transport operator and repealing Council Directive 96/26/EC [6] As stipulated by Art. 4 and 5 of Directive
2004/38/EC [7] Rechnitzer, George, Haworth, Narelle and Kowadio,
Naomi (2000) “The effect of vehicle roadworthiness on crash incidence and
severity” Monash University Accident Research Centre, Report No. 164 [8] CITA (2007) “AUTOFORE Study on the Future Options for
Roadworthiness Enforcement in the European Union: WP700 – Roadworthiness
testing evaluation” [9] Source: DG MOVE, based on “EU energy and transport
in figure: Statistical Pocketbook 2010” [10] DEKRA (2009) “Road Safety Report
2008” [11] Source: DEKRA [12] Rechnitzer, George, Haworth, Narelle and Kowadio, Naomi
(2000) “The effect of vehicle roadworthiness on crash incidence and severity”
Monash University Accident Research Centre, Report No. 164 [13] Rompe, K and Seul, E (1985) “Final Report Commissioned
by the Directorate General for Transport, 7/G2 of the Commission for the
European Communities” TÜV Rheinland, rheinland Technical Inspection Authority [14] ‘MOT Scheme Evidence-base’ Department for Transport,
UK, 2008, p25. The study explains the difficulties of estimation and the
assumptions used. [15] Bulgaria, Cyprus, Denmark, Ireland, Lithuania, Latvia,
Malta, Poland, Portugal, Romania and Sweden. [16] Exhaust system, smoke opacity, gaseous emissions, steering
linkages, suspension, chassis, tachograph, speed-limiting device, evidence of
fuel and/or oil spill. The low frequency of data given for detection of these
deficiencies in some cases are due to not all Member States testing for faults
in these systems. [17] EC (2010) “Report from the Commission to the Council
and the European Parliament on the application by the Member States of
Directive 2000/30/EC of the European Parliament and of the Council of 6 June
2000 on the technical roadside inspection of the roadworthiness of commercial
vehicles circulating in the community: Reporting periods 2005-2006 and
2007-2008” [18] Hemenway, David (1989) “A failing grade for auto
inspections – And motorists like it that way” Journal of Policy Analysis and
Management 8:321-325 [19] In Spain, there are differences in the systems used in
different Autonomia; and in the UK, Northern Ireland designs its own system;
there are probably similar examples in other countries. [20] It is in theory possible that officials employed in a
government or other regulatory authority may have been bribed or “captured” by
stakeholders, so that their objectives depart from those of the people under
their jurisdiction. The term “captured” is used here in the sense in which it
is defined in the economic / regulatory literature, of having become
over-influenced by some stakeholders. [21] EU (2007) “Commission interpretive communication on
procedures for the registration of motor vehicles originating in another Member
State (2007/C 68/04)” Official Journal of the European Union [22] Since every individual must register his vehicle in the
Member State in which he is normally resident. Article 7 of Directive
83/182/EEC (1) and Article 6 of Directive 83/183/EEC (2) set out precise rules
for determining normal residence in situations where the persons concerned are
respectively temporarily or permanently living and driving in a Member State
other than their own (having to live more than 185 days per year in a given
place) . [23] Directive 2007/46/EC of the European Parliament and of
the Council of 5 September 2007; establishing a framework for the approval of
motor vehicles and their trailers, and of systems, components and separate
technical units intended for such vehicles [24] Judgment of the court (First Chamber), 20 September
2007, Case C-297/05 Commission of the European Communities v Kingdom of the
Netherlands supported by Republic of Finland; and Judgment of the Court (First
Chamber) of 5 June 2008 – Commission of the European Communities v Republic of Poland,
Case C-170/07. [25] For instance, in order register a vehicle in Spain an
individual may have to contact a number of different authorities - incurring
significant costs and potentially requiring the use of professional support. [26] Trucks are less likely than trailers to be left on site for
long periods, and so may more frequently run into the time when a new PTI is
required, necessitating a journey that would not otherwise have been planned. [27] For instance, their road infrastructure and conditions (fast
autobahn in Germany - which has a lower fatality rate than rural German roads,
winding country roads on Malta etc.), climate, social welfare and education
levels of citizens, and the average age of their vehicle fleet. [28] Such as speed limitation systems and enforcement, and road
design [29]
Source:
http://ec.europa.eu/enterprise/e_i/news/article_7009_en.htm [30] Source: CARE (EU road accidents database) [31] Source: Summary of the ERSAP scenario as provided by
DG MOVE [32] Source: CARE (EU road accidents database) and national
data [33] The log linear trend is found to have an adjusted
R-squared fit value of 0.9652, which is less than the corresponding value for
the linear trend of 0.9699. [34] Estimated using a figure of six per cent for the
proportion of accidents where defects are a contributor. [35] The Commission proposes to add an “injuries reduction
target” for the European road safety policy orientations up to 2020, as soon as
sufficient progress has been made in creating a common definition of injuries.
If this target is decided at a rate of greater than 10 per cent reduction in
numbers of injuries by 2020, further action on the part of the Commission or of
Member States may be necessary to achieve these aims. [36] Judgment of the court (First Chamber), 20 September
2007, Case C-297/05 Commission of the European Communities v Kingdom of the
Netherlands supported by Republic of Finland. [37] For instance, by recognition of
the proof issued in another Member State showing that a vehicle registered in
the territory of that State has passed a roadworhiness test, together with
cooperation by the Netherlands customs authorities with their counterparts in
another Member State concerning any data that may be missing. [38] Judgment of the Court (First Chamber) of 5 June 2008 –
Commission of the European Communities v Republic of Poland, Case C-170/07. [39] An exception to this would be if a Member State were to
use roadside testing as a way of deterring commercial vehicles registered in
another country. As far as we know, this has not been suggested. In addition,
EC Directive 2000/30/EC specifically states that technical roadside inspections
must be carried out without discrimination on grounds of the nationality of the
driver or the country of registration or entry into service of the commercial
vehicle. [40] Campaigns and Awareness-Raising Strategies in Traffic
Safety (CAST) (2009) “A theoretical approach to assess road safety campaigns:
Evidence from seven European countries” Project co-financed by EC DG Energy and
Transport [41] For roadside testing, this would relate to the number
of vehicles targeted for roadside tests each year. [42] For roadside testing, this would relate to the number
of vehicles targeted for roadside tests each year. [43] See proposal from EGEA for a new functionality test for
electronic safety devices. [44] Type approval is a set of harmonised design,
construction and environmental standards that allows manufacturers to build to
one set of requirements for the European market – ECWVTA (European Community Whole
Vehicle Type Approval). [45] Please note that in the internet consultation these
three sub-options were presented in the order: most rigorous – medium – least
rigorous. The order has been changed in this report as it provides a more
natural presentation, and conforms with the idea of each policy option
following naturally from the previous option. [46] To be considered (see cost evaluation) [47] CITA (2007) “AUTOFORE Report: Study on the Future
Options for Roadworthiness Enforcement in the European Union” [48] From 3-1-1-1 until 1 January 2008 to 4-2-2-1 from this
date. Source: SWOV Institute for Road Safety Research (2009) “SWOV Fact
sheet: Periodic Vehicle Inspection for cars (MOT)” Leidschendam, the
Netherlands [49] Department of Transport (2008) “MOT Scheme
Evidence-base” [50] Member States such as Portugal and Spain have old
vehicle stocks and poorly maintained roads, which may help to explain their
requirement for a more stringent PTI frequency. [51] A detailed calculation is presented in Appendix 7:
Calculating the Total Cost of PTI Inspections in Europe. [52] Federal Statistics Office, Germany; DEKRA Safety
report; ETR MA Tyre and Rubber Manufacturers association. [53] The US has recently required new vehicles to fit
devices to show tyre pressures to the driver and we have noted earlier that a
similar requirement is planned for the EU. [54] EU27 without Czech Republic,
Spain, Slovakia, Italy, Ireland, Finland and Lithuania – no results available -
and Cyprus – seems to have another kind of evaluation method as the rate of non
compliant vehicles is reported at about 200 per cent. [55] DEKRA [56] DG MOVE; Der Rechnungshof (2006) “Bericht des
Rechnungshofes” [57] http://ec.europa.eu/enlargement/taiex/pdf/experts/guide_for_experts.pdf [58] (€90+€250+€300+€100)x108 [59] World Health Organisation (2009) “European status
report on road safety: towards safer roads and healthier transport choices”
Copenhagen, WHO Regional Office for Europe [60] Key safety critical items such as lights, braking, steering
and tyres are not always covered by warranty (Source: Consultation response
from the Chief Executive of a major business involved in MOT testing, UK). [61] See www.cast-eu.org [62] DEKRA (2005) “Internationale Strategien zur
Unfallvermeidung” In: Technische Sicherheit im Strassenverker. DEKRA
Fachschrift 58/05. DEKRA Automobil GmbH, Stuttgart [63] These findings were based on an investigation of 400
cases of tyre damage between 2001 and 2004. [64] SWOV Institute for Road Safety Research (2009) “SWOV
Fact sheet: Periodic Vehicle Inspection of cars (MOT)” SWOV, Leidschendam, the
Netherlands [65] Based on the recorded levels for these in 2008.
Source: CARE database [66] Based on a value of road accident fatalities of € 1,309,968 and road accident injuries of € 15,336 (derived from DfT figures) [67] Campaigns and Awareness-Raising Strategies in Traffic
Safety (CAST) (2009) “A theoretical approach to assess road safety campaigns:
Evidence from seven European countries” Project co-financed by EC DG Energy and
Transport [68] According to weighted average effects and calculated
after accounting for publication bias. The results also showed that road
safety campaigns resulted in a 25 per cent increase in seatbelt use, a 16 per
cent reduction in speeding, a 37 per cent increase in yielding behaviour and a
16 per cent increase in risk comprehension. [69] This included costs for concept development
(advertising agency), production (TV and radio spots, billboards, posters,
website), dissemination (broadcasting and placement) and research (pre-testing,
effect measurement). An additional €72,500 was also
spent on the evaluation study after the campaign had been put in place. [70] This included personal costs (FACTUM + INFAR,
evaluation and audit), travel costs, campaign materials (gadgets, posters
etc.), subcontracting (song producer, web design, layout folder and posters)
and indirect costs. An additional €43,700 was spent on
the evaluation study. [71] Source: DG MOVE [72] This Directive was implemented on the rationale that
the regulated annual roadworthiness test for commercial vehicles was not
considered sufficient to guarantee that commercial vehicles are in roadworthy
condition throughout the year, and that effective enforcement through targeted
additional technical roadside inspection is an important cost-effective measure
to control the standard of maintenance of commercial vehicles on the road. [73] The AUTOFORE report found that the only empirical
evidence existing looking into the impacts of roadside inspection on accidents
comes from the US. This data cannot easily be applied to European conditions
due to the different contents of the roadside inspection procedure and road
conditions in the two regions. [74] For instance Regulation (EC) No 1071/2009, 1071/2009
and 1073/2009. [75] In Germany, separate periodical tests are undertaken on
safety and emissions. [76] Source: ZDK – Failure evaluation in Germany [77] The content of the warranty would have to include safety
features of the vehicle. [78] FEMA (2010) “Position statement on periodical technical
inspections / road worthiness testing” [79] Utländsk
Reserapport “SE input about mutual recognition of Inspection Certificates of
periodical technical inspections” [80] This seems a low cost. Its basis has not been explored. [81] 27x26 – assuming the bilateral agreements are one-way
agreements such as those already in place, so that two agreements would need to
be made between each pair of Member States. [82] (€50,000x1+€20,000x25)x27 [83] (€50,000x1+€20,000x2)x27 [84] Source: Google maps [85] Source: Google maps [86] Estimated based on an average age at which vehicles are
scrapped of 17 years – therefore Swedish cars, with an inspection frequency of
3/2/1, will take a total of 14 PTIs during their lifetime; whereas Dutch cars,
with an inspection frequency of 4/2/2/1, will take a total of 12 PTIs during
their lifetime. So average inspection frequencies are calculated as 14/17 and 12/17,
respectively. [87] Based on the value of UK non-working time, calculated
as £4.46 in 2002, adjusted to reflect the change in GDP per capita between 2002
and 2009 (multiplying the value by £28,800/£25,300) then converting to Euros at
the 2009 exchange rate (0.89094) to obtain an approximate current value of
non-working time in the EU of €4.40. [88] Source: http://www.theaa.com/allaboutcars/advice/advice_rcosts_petrol_table.jsp.
Based on the running costs given per kilometre for new cars costing up to £12,000, converted into kilometres and then
converted to Euros at the average exchange rate September 2009 – September 2010
of 1.15. [89] Recent cabotage regulation (REGULATION (EC) No
1072/2009) implemented in the EU has removed some restrictions on the single
market in haulage, reducing the limits on transit traffic crossing EU MS
areas. Before this regulation, freight vehicles were not allowed to transport
goods internally in a foreign Member State. The new regulation still restricts
HGVs registered in a foreign MS from doing more than three cabotage tours in a
Member State with the same vehicle if they come in with freight, or only one
cabotage tour in three days if they come in without freight. This new
regulation will increase the likelihood of trucks staying away from their MS of
registration for long periods of time, but will have minimal effect on the
movement of trailers. [90] Source: DEKRA [91] A discussion regarding approaches to quantify the costs
of accidents in the EU is included in Appendix 6: European Approaches to
Monetizing the Value of Road Safety. [92] Based on an average monetary cost per kilometre of € 0.37 and a time cost of € 4.40 per hour. [93] Based on an average emission rate of CO2 by vehicles of 200 g/km. [94] Cost per tonne of CO2 taken as € 30
(based on the value determined for CO2 capture and storage projects in the EU, see e.g. http://ec.europa.eu/research/energy/pdf/synopses_co2_en.pdf) [95] UETR is an umbrella organisation representing more than
200,000 European freight transport SMEs from Western and Eastern EU Member
States associations, with a total capacity of more than 430,000 commercial
vehicles. [96] Source: UETR internet consultation response. [97] UPTR represents the transport and logistics sector in
Belgium [98] This is based on an estimated average distance
travelled for the purpose of returning for PTI of 400km and a cost of
travelling empty of € 0.98 per
km (derived from ETB’s survey results). Therefore each individual journey for
this purpose is calculated as having an average cost of € 392. This cost is below the estimate
provided by the International Road Transport Union (IRU), who questioned their
members on this topic, finding that costs can come to around € 1,000 for a forced and empty return. [99] Based on 90.6 g/tonne km obtained from the European
Environmental Agency [100] Although the IRU noted that trucks can sometimes be away
from base for a long period, especially those active in cross trade. For
example, a Dutch registered vehicle can be based for a long period of time in
the South of France, working on a route travelling between Italy and Spain
(which is a perfectly legal international intra-EU transport route without
restrictions). The vehicle can spend several months out on the route in a row
with crews being brought in and out by plane and / or working with local crews. [101] BDI (2007) “BDI Position on the liberalisation of
cabotage in Europe and on further liberalisation of cross-border haulage” http://www.bdi.eu/download_content/InfrastrukturUndLogistik/Position_paper_Cabotage.pdf [102] The calculation is based on the information obtained
from the ETB about the average number of journeys per trailer per year. While
smaller trailers can make 3 trips a day, the majority of trailers travel long
distances where one journey takes on average 8 days. Taking these two options
into consideration we assume the average number of trips per trailer per year
to be 60. [103] Leaseurope brings together 45 member associations
representing the leasing, long-term and/or short-term automotive rental
industries in the 32 European countries in which they are present. The scope
of products covered by Leaseurope members ranges from hire purchase and finance
leases to operating leases for all asset categories (automotive equipment and
real estate). It includes the short term rental of cars, vans and trucks. In
2009, Leaseurope members financed a fleet of 14.1 million cars, or
approximately six per cent of all passenger cars in the EU. [104] Directive 2007/46/EC of the European Parliament and of
the Council of 5 September 2007; establishing a framework for the approval of
motor vehicles and their trailers, and of systems, components and separate
technical units intended for such vehicles [105] This is consistent with an estimate given by the Commission: take the number of all registered two
wheelers: about 33 Mio average price for PTI: 20€ total: 657Mio € [106] Source: Estimation by DEKRA based on the overall number
of test stations in Member States [107] Source: Estimation by DEKRA [108] Source: Estimation by DEKRA [109] Christensen, Peter and Elvik, Rune (2007) “Effects on
accidents of periodic motor vehicle inspection in Norway” Accident Analysis
and Prevention 39:47-52 [110] Poitras, Marc and Sutter, Daniel (2002) “Policy
ineffectiveness or offsetting behaviour? An analysis of vehicle safety
inspections” Southern Economic Journal 68(4):922-934 [111] Consultation response from the Chief Executive of a
major business involved in MOT testing, UK. [112] CITA (2007) “AUTOFORE Study on the Future Options for
Roadworthiness Enforcement in the European Union: WP700 – Roadworthiness
testing evaluation” [113] Department of Transport (2008) “MOT Scheme
Evidence-base” [114] Low estimate 177 additional deaths per year, high
estimate 523 additional deaths per year. [115] Department of Transport (2010) “Reported Road Casualties
Great Britain Main Results: 2009” Accessed: http://www.dft.gov.uk/pgr/statistics/datatablespublications/accidents/casualtiesmr/rrcgbmainresults2009 [116] Low estimate 1,088 additional serious injuries per year,
high estimate 3,210 additional serious injuries per year. [117] SWOV Institute for Road Safety Research (2009) “SWOV
Fact sheet: Periodic Vehicle Inspection for cars (MOT)” Leidschendam, the
Netherlands [118] Baum, H, Grawenhoff, F (2006) “Cost-Benefit-Analysis of
the Electronic Stability Program (ESP)” Cologne [119] Rompe, Klaus and Carlitz, Andreas (2003) “Periodical
Inspection of Electronically Controlled Systems on Vehicles: Report on the
CITA WG VII Research Project” Future Technical Vehicle Inspection in Europe,
4th Aachen Workshop, 16.01.2003,
http://ika.rwth-aachen.de/forschung/veroeffentilichung/2003/16.01/VdTUEV_Folien_en.pdf [120] Note that these results were obtained from a small
sample size, with 148 cars tested in total and only seven falling into the 5-8
years category. [121] TNO – Organisation for Applied Scientific Research
(2008) “eIMPACT Assessing the Impacts of Intelligent Vehicle Safety Systems” [122] SafetyNet (2009) eSafety Project, co-financed by the
European Commission, Directorate-General Transport and Energy [123] SWOV Institute for Road Safety Research, Dr. Marion
Wiethoff (2003) “ADVISORS – Action for advanced driver assistance and vehicle
control systems Implementation, Standardisation, Optimum use of the Road
network and Safety” [124] active head-restraint, active bonnet, active steering,
adaptive cruise control, adaptive headlights, adaptive stop lamps, airbag /
belt tensioner, anti lock brake, auto hold, automatic emergency brake,
automatic headlight activation, brake assist system, car and trailer train
stability programme, cornering light, countersteer support, emergency braking
signal, electro mechanic brake system, electric power steering, electronic
brake system, electronic differential lock, electronic four-wheel steering ,
electronic parking brake, electronic stabilisation programme, electronic
steered rear axle, electronic steering damper, headlamp self-levelling system,
high-beam assistant, hill descent control, lane changing assist interfering
with steering system , lane keeping assist interfering with braking system,
lane keeping assist interfering with steering system, lighting redundancy
(front) , lighting redundancy (rear), preventive safety systems, retarder, roll
stability programme, roll over protection (active), self-levelling air
suspension, soft hold, speed limiter, start-up aid, trailer stability programme
and traction control [125] The EGEA heads 12 national professional associations,
who represent the interests of both manufacturers and importers of garage and
test equipment. [126] Vehicle category L includes all motor vehicles with less
than four wheels. Mopeds come under sub-category L1: two-wheeled vehicles with a maximum
design speed not exceeding 50 km/hour, and motorcycles come under sub-category
L3: two-wheeled
vehicles with a design speed exceeding 50 km/hour. Categories L2, L4 and L5
relate to three-wheeled vehicles and motorcycles with sidecars. [127] Source: CARE database. Data is not provided for
Bulgaria, Cyprus or Lithuania. [128] Source: DEKRA (2010) “Motorcycle
road safety report 2010: Strategies for preventing accidents on the roads of
Europe” [129] DEKRA (2010) “Motorcycle Road Safety Report 2010:
Strategies for preventing accidents on the roads of Europe” [130] FEMA (2010) “Position statement on periodical technical
inspections / road worthiness testing” [131] MAIDS (2009) “In-depth investigation of accidents
involving powered two-wheelers: Version 2.0” [132] CITA (2007) “AUTOFORE Study on the Future Options for
Roadworthiness Enforcement in the European Union: WP700 – Roadworthiness
testing evaluation” [133] 2009 data of DEKRA trailer inspections in Germany, data by KBA. [134] UPTR represents the transport and logistics sector in
Belgium [135] UETR is an umbrella organisation representing more than
200,000 European freight transport SMEs from Western and Eastern EU Member
States associations, with a total capacity of more than 430,000 commercial
vehicles. [136] Currently defined as those manufactured before 1 January
1960 in Directive 2009/40/EC, Article 4.2. [137] See following section [138] See following section [139] Set up costs are included in this value, depreciated
over five years. [140] Specifically, “To improve road safety and reduce
emissions, how much could the PTI cost reasonably increase for you?” [141] As of 11:30am, 07/09/2010. [142] “Estudio para la Incorporación del Diagnóstico Electrónico en las
ITV”. FITSA / Universidad Carlos III de Madrid / Applus Idiada. Nov. 2008 [143] based on Dekra information and anecdotal evidence from tyre
manufacturer focus group. [144] Systems are assumed to be electronic. Costs to bring these systems
in line with 2010/48/EU are not included as these are assumed to be already in
plan for each MS [145] Communication from the Commission to the Council, the
European Parliament, the Economic and Social Committee and the Committee of the
Regions: Promoting road safety in the European Union: - the programme for
1997-2001 [COM (97) 131 final - Not published in the Official Journal]. [146] See
http://europa.eu/legislation_summaries/transport/road_transport/l24055b_en.htm
for details on the calculation of this figure. [147] See http://heatco.ier.uni-stuttgart.de/. [148] See http://ec.europa.eu/transport/road_safety/specialist/knowledge/measures/monetary_valuation_of_road_safety/index.htm. [149] A proposal for an amendment to Directive 1999/62/EC on
the charging of heavy goods vehicles for the use of certain infrastructures
[COM(2003) 448 final]. See http://www.alpnap.org/com2003_0448en01.pdf. [150] See Directives 2006/38/EC amending Directive 1999/62/EC
on the charging of heavy goods vehicles for the use of certain infrastructures
(http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:157:0008:0023:EN:PDF). [151] HICP annual average index for EU27
in 2004 was 97.77 and in August 2010 was 112.01. So 2004 prices have each been
multiplied by 112.01/97.77 to find a present Euro value. Source: Eurostat,
HICP-all items-annual average indices; and HICP-all items-[teicp000]. Table of content 1................ Procedural
issues and consultation of interested parties. 3 1.1............. Organisation and timing. 3 1.2............. Consultation and expertise. 3 2................ Problem Definition. 6 2.1............. General Context 6 2.2............. Description and scope of the problem.. 6 2.3............. Underlying drivers of the problem.. 10 2.4............. Who is affected by the problem?. 20 2.5............. Evolution of the problem (baseline scenario) 21 2.6............. Does the EU have the right to act?. 22 3................ Objectives. 23 3.1............. General objective. 23 3.2............. Specific objectives. 23 3.3............. Operational objectives. 24 4................ Description of Policy Options. 24 4.1............. Policy Option 0 - 'No policy change' approach. 26 4.2............. Policy Option 1 - Soft law approach. 27 4.3............. Policy Option 2 - Legislative approach. 28 4.4............. Policy Option 3 – Soft law and legislative approaches
combined. 37 4.5............. Summary of identified Policy Options. 37 5................ Analysis of impact 37 5.1............. Assessment of Policy Option 1 (PO1) 38 5.2............. Assessment of Policy Option 2a (PO 2a) 40 5.3............. Assessment of Policy Option 2b (PO2b) 47 5.4............. Assessment of Policy Option 2c (PO2c) 51 5.5............. Assessment of Policy Option 3 (PO3) 54 5.6............. Considerations on administrative costs. 54 5.7............. Impact on SMEs. 55 5.8............. Impact on citizens. 57 5.9............. Impact on public administrations. 57 6................ Comparison of options. 58 7................ Monitoring and evaluation. 63 COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT Accompanying document to the REGULATION OF THE EUROPEAN
PARLIAMENT AND OF THE COUNCIL on
periodic roadworthiness tests for motor vehicles and their trailers and
repealing Directive 2009/40/EC
and
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on
the technical roadside inspections of the roadworthiness of commercial vehicles
circulating in the Union and repealing Directive 2000/30/EC
and
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
amending Council Directive 1999/37/EC on the registration documents for
vehicles 1. Procedural issues and consultation of
interested parties Lead DG: Directorate
General for Mobility and Transport Agenda planning: 2010/MOVE/014 Proposal for a Regulation of the European
Parliament and of the Council amending Directive 2009/40/EC of the European
Parliament and of the Council of 6 May 2009 on roadworthiness tests for motor
vehicles and their trailers. Proposal for an amendment of Directive 2000/30/EC
of the European Parliament and of the Council of 6 June 2000 on the technical
roadside inspection of the roadworthiness of commercial vehicles circulating in
the Community. 1.1. Organisation and timing The work on this impact assessment (IA) was
launched at the beginning of 2010[1]. An Impact
Assessment Steering Group (IASG)[2] was set-up on 2 July 2010 and 8 meetings were organised between
July 2010 and April 2011. 1.2. Consultation and expertise A public
consultation, which met the Commission's minimum standards on public
consultation, was launched on 29 July and lasted 8 weeks ending on 24 September
2010. It aimed at collecting the opinion of the broader public about a possible
modification of the Periodic Technical Inspection (PTI) systems in Europe and
about the ways to tackle the problems identified in the current system. 9,653
responses were received from citizens, Member State authorities, equipment
suppliers, test centres, garage associations and vehicle manufacturers. An expert
meeting was held on 31 August 2010, followed by a stakeholder meeting on
8 September 2010. These meetings identified as most important issues
related to the current PTI system in Europe the differences in terms of quality
and modalities of testing leading to the lack of mutual acceptance of PTI
results between Member States, and the lack of data exchange (in particular the
fact that important data on vehicle history is not available to PTI stations).[3] It is worth mentioning that Prof. Dr W. Schultz from the University
of Cologne, who participated in the stakeholder meeting, presented a model for
the cost-benefit analysis in the field of PTI, which has been used for in this
IA report for the analysis of impacts of different policy options. The internet
consultation showed relatively strong support for changes in the PTI system,
notably in what concerns the inclusion of additional types of vehicle and the
enhanced exchange of data between Member States, as well as for the extension
of roadside inspections (RSI) to all vehicles. The results of the consultation
need to be seen in the light of the fact that it triggered a campaign of the
Federation of European Motorcyclists' Associations (FEMA)[4],
launched one month after the start of the consultation, which resulted in about
5 000 responses supporting FEMA's position, which is against the inclusion of
powered two wheelers (PTW) into periodic inspections.[5] The IA report is also supported by a study
completed on behalf of the European Commission by Europe Economics.[6] This study was mainly related to the calculation of the expected
impacts of the different policy options envisaged and is attached to this IA.[7] Finally, the study used several scientific
and evaluation reports, notably as sources of models and data for the
estimation and monetization of the costs and benefits of the different policy
options. The list of studies most extensively used include: ·
The Report from the Commission to the Council
and the European Parliament on the application by the Member States of
Directive 2000/30/EC of the European Parliament and of the Council of
6 June 2000 on the technical roadside inspections of the
roadworthiness of commercial vehicles circulating in the community - Reporting
periods 2005–2006 and 2007–2008 (COM(2010) 754 final, ·
"MOT Scheme Evidence-base" Department
of Transport (UK, 2008), ·
DEKRA Road Safety Report 2008 – Strategies for
preventing accidents on Europe's roads, ·
DEKRA Road Safety Report on Trucks 2009, ·
DEKRA Motorcycle road safety report 2010, ·
TÜV Reports 2009 / 2010. 1.3. Results of the
consultation of the Impact Assessment Board The draft report for
this impact assessment was submitted to the Impact Assessment Board (IAB) on 8
June 2011. In its opinion of 11 July 2011, the IAB made a number of
recommendations which were taken into account in the final draft. The most
important amendments in comparison to the version submitted on 8 June are the
following: ·
More evidence has been provided on the link
between higher roadworthiness requirements and improvement of road safety: a
table indicating the correlation between the occurrence of fatalities and the
Periodic Technical Inspection (PTI) requirements has been added; the general
objectives have been changed to better reflect the link to the achievement of
targets announced in the Communication "Towards a European road safety
area (2011-2020)". A table has been added clearly explaing the different
areas where the absence of availability of PTI related data constitutes a
problem. ·
The subsidiarity argument has been strengthened:
the whole part on subsidiarity has been considerably extended notably to
explain where extension of EU competences is foreseen, and where Member States
should remain competent; the proportionality of the options has been explicitly
addressed; finally, the reasons for choosing the preferred option have been
explained in more details. ·
The presentation of costs for vehicle owners and
the assessment of some other impacts have been improved: the impacts on
additional groups of stakeholders have been assessed in details, and emphasis
has been put on the impact on SMEs who operate the vehicles, in particular
micro-enterprises. The issue of the impact of the options on the competition on
the internal market has also been addressed. Finally, other impacts on citizens
– in particular other road users – have been assessed. ·
Greater transparency has been provided on the
assumptions underlying the quantitative estimates: the importance of the
assumptions and their impact on the final results has been underlined; a
sensitivity analysis has been held on major assumptions to check the robustness
of the results. Finally, the methodology for calculating the average annual
cost of testing per vehicle owner has been described in more details in a new
annex. ·
Apart from these major changes, many additional
recommendations of the IAB have been taken into account to increase the quality
and clarity of the report. Notably, a discussion on the adequate level of
risk-based approach has been included in part 4. 2. Problem Definition 2.1. General Context The EU legislation concerning PTI dates
from 1977.[8] Currently, the PTI system in Europe is governed principally by
Directive 2009/40/EC,[9] which mandates all Member States to carry out periodic safety and
emission inspections for certain types of motor vehicles. It also sets minimum
requirements for those inspections and their intervals. The legislation on
roadside checks[10] completes the one on PTI by providing the requirement to control
the technical state of commercial vehicles in between periodic inspections.[11] Directive 2009/40/EC allows Member States
to apply higher requirements for PTI concerning, notably, the frequency of
testing, the items to be inspected, the vehicles covered or the minimum
standards for braking efficiency.[12] Similarly,
Directive 2000/30/EC on roadside inspections, while imposing only the visual
inspection of commercial vehicles, allows Member States to "carry out
inspections not covered by this Directive or to check other aspects of road
transport".[13] On 20 July 2010 the European Commission
adopted policy orientations on road safety[14]. To
reach the announced target (i.e. reducing the number of road fatalities by 50% between
2010 and 2020), the Commission proposed amongst other things a two-pronged strategy
for safer vehicles: harmonisation/strengthening of EU legislation on
roadworthiness tests and on technical roadside inspections (including the
extension to powered-two wheelers) and the study of the setting-up of a
European electronic platform with a view to harmonise and to exchange vehicle
data (type approval, registration, results of inspections, etc.). On 2 December 2010, EU Transport Ministers
confirmed that safety technical requirements should be maintained and checked
during the whole vehicle-life cycle through a strengthening of roadworthiness
and roadside inspections, as well as an improved data exchange between Member
States on inspections.[15] 2.2. Description and scope of the
problem Too many vehicles with technical defects
on the road… The role of PTI is to ensure that vehicles
in operation are properly maintained and tested, so that their performance
remains in accordance with the type-approval[16]
throughout their lifetime. However, it is, alas, observed, that a large number
of vehicles are circulating on public roads in the European Union with
technical defects, i.e. the performance of some of their safety or environment
related parts is not any more in accordance with the requirements of the type
approval. First of all, many vehicles in use present
technical defects which would make them fail the national roadworthiness tests.
A Commission report[17] indicated that the share of non-compliant commercial vehicles out
of the inspected vehicles in a Member State was higher than 30% for
7 countries.[18] A 2008 study by the UK Government[19] found that about 1/3 of vehicles tested in the UK failed PTI and
that this proportion had remained at about this level for some years. It also
estimated that about 10% of cars on roads in the UK at any point in time have a
defect that would cause them to fail the PTI test.[20] Another
study on the UK established that in 2004 around 4% of heavy goods vehicles and
trailers and 3.4% of large passenger vehicles had defects that were
sufficiently serious for them to be prohibited immediately from any further
use.[21] It was also established that out of 3
million passenger vehicles inspected in 2004 in Germany, more than 10% of the
vehicles that were 5 years old at the time of inspection, had "serious
defects"[22].[23] Secondly, there are indications that many
vehicles on the roads present defects which are not inspected in the course of the
national PTI or roadside inspections as they are carried out today. For
instance 14 Member States do not require powered two wheelers (motorcycles and
mopeds[24]) to undergo regular PTI,[25] despite
documented high defect rates: the UK reports 20% of failures at PTI[26], and Germany as much as 27%.[27] Also,
in most Member States the electronic safety and environmental systems such as
ABS, ESC and airbags are not – or not sufficiently – tested. The importance of
these systems is capital: for example, the Electronic Stability Control (ESC)
reduces the risk of being involved in a crash by between 20% and 40%.[28] …which cause
accidents, injuries, fatalities… The link between higher roadworthiness
requirements and improvements in terms of road safety can be divided into two
elements: on the one hand, the impact of the technical condition of the
vehicles on road safety; on the other hand, the relation between higher
roadworthiness requirements and better average technical condition of vehicles. The CARE database[29], which
contains an assessment of the main causes of accidents, is for the Commission
the main source of empirical evidence on the link between the condition of the
vehicles and road safety. However, the assessment of the causes of the
accidents is mostly performed on the spot by policemen who typically don't have
the expert technical knowledge necessary to identify a technical defect. The
data is therefore not fully reliable. Having said that, a large body of
literature is available on the causes of road accidents. Studies of vehicles
involved in accidents have shown that technical defects contributed to between
3% and 19% of accidents.[30] Empirical evidence from Germany has shown that technical defects
are contributing to around 10% of accidents.[31] For
this IA, a broadly agreed and more conservative average figure of 6%
responsibility of technical defects in accidents of cars is used.[32] The defects of safety related electronic systems are estimated to contribute
even more to accidents.[33] Solid investigation results also show that 8%
of the accidents involving motorcycles are caused or linked to technical
defects.[34] Motorcycle riders are the group of road users with the highest
safety risk, which moreover defies the overall diminishing trend in the number
of fatalities.[35] Also moped drivers are overrepresented in the number of fatalities,
with more than 1,400 drivers killed on the roads in 2008. In what concerns the relation between
higher roadworthiness requirements and better average technical condition of
vehicles, available scientific data is scarce. In order to check if such a
relation exists, the Commission classified the Member States according to the
level of requirements they set in their national PTI systems, ranging from the
minimum requirements as set in Directives 2009/40/EC and 2000/30/EC to very
high requirements.[36] In table 1 below, this level of requirements is compared to the
number of road fatalities per million inhabitants (used as a proxy for road
safety). This comparison indicated a clear correlation between the level of
stringency of PTI and the level of road safety[37]. Table 1: Correlation fatalities per million
inhabitants and test-quality requirements and member States Member State || Fatalities per million inhabitants || Requirements on test quality Malta || 36 || No more as in EU Legislation Netherlands || 41 || Higher than in EU legislation Sweden || 43 || very high UK || 43 || Higher than in EU legislation Germany || 55 || very high Ireland || 63 || Higher than in EU legislation Finland || 65 || very high Spain || 68 || Higher than in EU legislation France || 69 || Higher than in EU legislation Luxembourg || 72 || very high Denmark || 74 || Higher than in EU legislation Italy || 79 || Higher than in EU legislation Austria || 81 || Higher than in EU legislation Portugal || 83 || Higher than in EU legislation Belgium || 88 || very high Estonia || 98 || Higher than in EU legislation Hungary || 99 || No more as in EU Legislation Slovakia || 103 || No more as in EU Legislation Czech Republic || 103 || Higher than in EU legislation Cyprus || 103 || No more as in EU Legislation Slovenia || 106 || No more as in EU Legislation Greece || 138 || No more as in EU Legislation Bulgaria || 139 || No more as in EU Legislation Latvia || 139 || Higher than in EU legislation Romania || 142 || No more as in EU Legislation Poland || 143 || No more as in EU Legislation Lituania || 148 || No more as in EU Legislation In 2009, 35,000 fatalities on European roads
have been reported.[38] Assuming that technical defects contribute to fatalities
proportionately to their contribution to accidents, more than 2,000 fatalities
per year in the European Union may be linked to technical defects of vehicles.[39] Based on available studies,[40] between
900 and 1,100 of these could be avoided if adequate improvements to the
roadworthiness testing system were put in place. The range of 900-1100
fatalities is retained in this report as an indication of the conventional
(without using most costly measures) life-saving potential, of measures aimed
at enhancing PTI rules. …and environmental damage Vehicle defects also increase emissions
(e.g. CO, HC, NO and CO2) by some 1.2% and 5.7%,[41] depending on the vehicle and fuel type. A large fraction of total
emissions is due to a minority of vehicles with malfunctioning emission control
systems.[42] 5% of the vehicle fleet causes 25% of all pollutant emissions and 20%
of vehicles cause 60 % of pollutant emissions.[43] The
problem is aggravated by so-called 'gross-emitters': the difference in hydrocarbon
and carbon monoxide emissions of petrol engines between a properly adjusted and
maintained engine and one that is poorly adjusted can amount to a factor of
four or more.[44] It has been shown that, by identifying
vehicles that have maintenance problems and requiring that they are repaired,
the average vehicle emissions could be reduced substantially.[45] In this respect, the Commission's report on the Auto Oil II
Programme[46] concluded that: ·
with regard to three way catalyst equipped
vehicles (TWC), a properly operating inspection program for TWC cars could have
the potential to reduce emissions in the order of 35% for CO, 25% for HC and 5%
for NOx; ·
with regard to non-catalyst and oxidation
catalyst equipped vehicles, such inspection program would have the potential to
achieve a 15% reduction in CO emissions; ·
with regard to Diesel vehicles, the emission
reduction potential is about 25% in particulate matter (PM). 2.3. Underlying
drivers of the problem The results of the stakeholder consultation
and the analysis undertaken by the Commission have allowed to identify two main
root causes to the problem described in section 2.2 above. First, the scope of
EU legislation is too narrow and the level of requirements it sets is too low.
Second, information and data vital for the effectiveness of testing and
enforcement of test results is not exchanged between concerned actors. 2.3.1. The scope of EU legislation is
too narrow and the level of requirements it sets are too low The EU roadworthiness
control system is based on seven pillars: Table 2: The seven
pillars of the EU roadworthiness testing (1) Items to be inspected and inspection method (2) Definition of defects and assessment of result of test (3) Equipment to be used (4) Skills and application of staff (5) Vehicle classes to be inspected (6) Frequency of testing[47] (7) Supervision of the testers A comparative analysis of national PTI
systems indicates that most Member States have set national requirements for
several of the seven pillars at a level which is higher than required by EU
legislation. Table 3 provides the classification of Member States for pillars 4
and 7.[48] The situation is similar for other elements of the roadworthiness
control system.[49] Table 3:
Classification of Member States according to the level of qualifications and
supervision of inspectors Requirements for the qualifications (pillar 4) and supervision of inspectors (pillar 7) || Member States No requirements as in Directives 2009/40/EC and 2000/30/EC || Bulgaria, Cyprus, Greece, Hungary, Italy, Lithuania, Malta, Poland, Romania, Slovenia. Higher requirements than in the EU legislation || Austria, Czech Republic, Denmark, Estonia, France, Ireland, Latvia, Netherlands, Portugal, Slovakia, Spain, United Kingdom Very high requirements || Belgium, Finland, Germany, Luxembourg, Sweden Source: Europe Economics, op. cit. It therefore appears that the requirements
of European legislation are probably set below what is perceived as an adequate
scope and level of requirements by the majority of Member States. This
conclusion is supported by the results of the stakeholder consultation. Box 1: Consequences in terms of recognition of
test results between Member States The low level and scope of the European standards results in a heterogenous transposition of Directive 2009/40/EC into national legislations. As a result, some Member States refuse to fully honour Article 3 of the Directive which stipulates that "each Member State shall, on the same basis as if it had itself issued the proof, recognise the proof issued in another Member State showing that a motor vehicle registered on the territory of that other Member State, together with its trailer or semi-trailer, has passed a roadworthiness test complying with at least the provisions of this Directive"[50]. This provision has been in place in the PTI legislation since Directive 77/143/EEC. Despite this fact, Member States often refuse to recognise the certificates issued by other Member States for re-registration purposes and require a new test to be performed according to national rules before re-registration can take place. The European Court of Justice has stated at many occasions on the illegal character of such practices (the last time in case C-170/07 Commissions vs. Republic of Poland), but the problem has not so far been entirely resolved. The analysis that follows identifies the
main gaps and shortcomings of current EU legislation, classified according to
the seven pillars identified in Table 3. (1)
Items to be inspected and inspection method It has already been
explained above that Directive 2009/40/EC does not set the obligation to thoroughly
inspect electronic safety devices such as ABS, ESC, airbags, etc…[51] Even more items are left outside the scope of Directive 2000/30/EC
on roadside inspections, which requires only the inspection of the braking
system and exhaust emissions and requires as little as a visual assessment of
these elements or checking of a recent PTI certificate.[52] This
led to the introduction of more stringent inspection standards in several
Member States. In light of the above,
it is not surprising that there are huge differences between how roadside
inspections are carried out in Member States.[53] The
proportion of vehicles found at the roadside inspection not to be compliant
with roadworthiness requirements ranges from as little as 0.3% in Bulgaria to
63% in Denmark[54], with significant differences even between neighbouring countries.[55] Some Member States perform an elaborated test procedure close to a
PTI test where others – still complying with the minimum requirements of the Directive
- do a visual inspection or simply control the documentation. The huges
differences in the failure rates at roadside checks result also from the choice
between a risk-based approach in some Member States (UK, Luxembourg, Austria,
etc…) against random checks in others (Poland, Germany, etc…), both being
compliant with the requirements of the Directive. (2)
Definition of defects and assessment of result
of test Annex II to Directive 2009/40/EC
contains a description of the reason for failure for each of the items to be
inspected. However, Art. 5 thereof allows Member States to require higher
minimum standards for braking efficiency than those specified, and several
Member States decided to use this opportunity.[56] This
is understandable in the light of the fact that the standards for brakes
contained in Directive 2009/40/EC are very old, and a strong case exists for
their re-examination.[57] In 2010, the Commission has issued a Recommendation
on the assessment of defects.[58] While it is too early to make conclusions on the effect of these
recommendations, the fact that they are not binding will always leave the
possibility for major or dangerous defects being considered as minor in some
Member States and vice versa, leading to inconsistent messages being sent to vehicles
owners. (3)
Equipment to be used Current EU legislation mostly does not
contain specific requirements for the equipment to be used during testing. Whereas
Directive 2010/48/EU[59] has introduced some general requirements[60], there
is a variety of equipments in use. Several of equipment types on the market do
not make possible the detection of serious defects such as loose axles. The
fact that inspection centers are not obliged to use the most efficient tools
therefore means that even the defects which are already covered by Directive
2009/40/EC can not always be properly detected. (4)
Skills and application of staff Directive 2009/40/EC does not set
minimum requirements for the education and skills of staff performing the PTIs.
In view of the rising complexity of testing, the insufficient qualifications of
testers can be a major hindrance to the effectiveness of controls and the level
of detection of defects. (5)
Vehicle classes to be inspected Directive 2009/40/EC does not require to
test certain categories of vehicles, including light trailers, powered
two-wheelers or agricultural tractors. As a result, 14 Member States do not
provide for periodic inspections of motorcycles, 10 Member States – of light
trailers, and 16 – of agricultural tractors.[61] Among
these, at least for powered two-wheelers there is strong evidence supporting
their inclusion among the vehicle types which are regularly inspected. (6)
Frequency of testing Annex I to Directive 2009/40/EC defines
minimum frequency of testing for different categories of vehicles.[62] Evidence suggests that for certain of these categories the
frequency is too low to ensure optimal levels of roadworthiness of vehicles in
use. The problem concerns in particular three types of vehicles: –
passenger cars in business use, which despite belonging
to the group of high mileage vehicles, caracterised by high defect rates, are
treated for PTI frequency purposes like normal cars; –
older vehicles: according to available evidence,
defect rates are proportional to the age of the vehicle; despite that fact,
Directive 2009/40/EC foresees the same, not increasing frequencies for all
vehicles above 4 years of age. –
commercial vehicles, which deteriorate at a much
higher rate than passenger vehicles due to their higher weight and mileage, but
are inspected only twice as frequently.[63] (7)
Supervision of the testers Insufficient supervision of testing centres
can have a negative impact on road safety. This has been confirmed by the
recent experience of Denmark, where complete liberalisation of PTI was
accompanied by an increase in the number of fatalities.[64] Also
in Germany, competition for clients between the two major players on the market
of PTI – DEKRA and TUV – and the liberalisation of the PTI market was assessed
by the German authorities as detrimental to the quality of testing and pushed
the latter to strongly enhance supervision with additional inspections, mystery
shopping, etc... Despite these examples, Directive
2009/40/EC contains very little requirements on the supervision of testing
centres.[65] This leaves a lot of flexibility to the Member States concerning
the choice of the supervision model and does not prevent them from opting for
suboptimal solutions like in the above mentioned examples. 2.3.2. Information
and data vital for the effectiveness of testing and enforcement of test results
is not exchanged between concerned actors As illustrated in Figure 1, PTI and
roadside inspections are part of a wider regulatory scheme[66], governing the vehicles throughout their lifetime. Despite existing
interconnections and interdependences (notably with type-approval and
registration), EU legislation does not regulate the exchange of information
between the different elements of the scheme and related authorities. This has
a negative impact on the effectiveness and enforcement of roadworthiness
testing. In the course of PTI and roadside inspections, an important amount
of data on the vehicle and its performance is collected. This data could
potentially be used by the different authorities to ensure the follow up of the
detection of defects, to organise targeted checks, but also to enhance their
policy making. Similarly, PTI and roadside inspections would be more effective
if they had access to complete information on the history of the vehicle and
its technical characteristics. However, as it will be explained below, current
scarce provisions in EU legislation about the exchange of PTI-relevant data are
not sufficient to allow the effective flow of data to and from PTI centres. Figure 1: Roadworthiness testing as a part of the
vehicle control regulatory scheme Source: DG MOVE (1)
Data for testing electronic safety components is
often not available The importance of testing electronic safety
components (ESC, ABS, Airbags, etc) during PTI has been explained in section 2.2.
However, testing of electronic systems needs the possibility to have access to
their control units[67] to be able to communicate failure codes or to check the
functionality of the electro-mechanical components. Currently, these tests cannot
be performed by many PTI test centres because necessary technical information
from the manufacturers is not available to them in an electronic format. Electronic safety
components have become essential tools for reducing the risk and the negative consequences
of road accidents. The Electronic Stability Control (ESC) reduces the risk of
being involved in a crash by as much as between 20% and 40%.[68] Airbags, according to different studies, reduce the risk of
fatality in case of a frontal crash by 8-18% both those wearing seat-belts and
those who don't.[69] The impossibility to test these equipments – imputable to the lack
of a proper system for the PTI test centres to access the necessary information
– has therefore a very serious impact on the safety of the road users, taking
into account the fact that electronic safety components brake down as often as
mechanical parts. Article 6 of Regulation 715/2007/EC on type-approval requires
manufacturers to "provide unrestricted and standardised access to vehicle
repair and maintenance information […] through websites using a standardised
format".[70] However, this requirement was designed mainly to ensure access to
data by independent repair shops. As a result, it is not precise enough concerning
the data requirements of PTI centres.[71]
Moreover, Article 7 of the same Regulation allows manufacturers to "charge
reasonable and proportionate fees for access to vehicle repair and maintenance
information", which makes it costly for PTI centres to access the data.
According to the best knowledge of the Commission, only one Member State
(Germany) has so far decided to centrally purchase the data from the
manufacturers and provide it to the testing centres. In the remaining 26 Member
States, the situation is more complicated.[72] (2)
The potential of odometer readings is not used Information on the real mileage is crucial
for a second hand vehicle's price and the buying decision by the consumer.
Mileage fraud is considered to affect between 5% and 12% of used car sales
(30% to 50% for cross-border transactions) having a yearly economic effect of
€ 5.6 billion to 9.6 billion (EU 25).[73]
Properly collected and aggregated odometer readings would also provide valuable
input to transport statistics, where currently yearly mileage of different vehicle
classes is modelled, often showing a significant difference to reported real
data.[74] As an answer to these problems, Directive
2010/48/EU has introduced the requirement to test the odometer for signs of
manipulation and for defects[75], and to register the odometer reading on the roadworthiness
certificate.[76] Without further legislation, the effect of the two provisions will
be limited. Indeed, the most effective manner to detect odometer fraud is to
compare the present reading with previous ones, checking if mileage grows with
time. Currently, there is no obligation to present certificates from previous
tests when passing a PTI, and information on odometer readings is not exchanged
between testing centres. In what concerns statistics, Directive
2010/48/EU requires PTI centres to check odometer readings, but does not impose
on Member States the obligation to collect the data and does not provide any
standards for doing it. As a result, there is no uniform framework that would
allow the monitoring of the total and average mileages of different categories
of vehicles registered in Europe. Data is provided only on a commercial basis
by a number of private analysts, but it is expensive and not always entirely
reliable. (3)
PTI certificates are not fraud-proof The PTI certificate
often constitutes the only proof against which enforcement authorities (police,
roadside inspectors, etc…) check if the vehicle meets the environmental and
safety standards of roadworthiness. Despite this capital importance for
enforcement, the EU legislation does not define requirements for the security
of the document. Directive 2010/48/EU only says that "the vehicle operator
or driver must be notified in writing of the defects, the results of the test
and the legal consequences". Very often, the PTI certificate is therefore
a simple printout, which can easily be subject to fraud. As the exchange of
data between PTI centres and the authorities is not regulated (see below), this
fraud can go undetected most of the time. (4)
Data on PTI results not available to enforcement
authorities PTI centres are in charge of inspecting
the technical state of the vehicles, but the enforcement of the results –
taking defective vehicles off the roads and punishing their drivers – is the
role of authorities such as the police, roadside inspectors, registration
authorities, which have a number of tools at their disposal: fines, de-registration
of vehicles, withdrawal or refusal to renew operator permits for access to the
international transport market, etc… The availability of PTI results in
electronic format would help performing targeted roadside checks based on
number plate recognition, sending reminders by registration authorities and
enforcing circulation bans. However, the current lack of rules at European level
governing the exchange of information between PTI centres and enforcement
authorities makes the use of these tools difficult. The situation is further aggravated by
the persisting lack of recognition, at re-registration, of PTI certificates
issued by another Member State (see Box 1). This recognition is particularly
important for ensuring the continuity of roadworthiness enforcement for the 3.4
million vehicles which are re-register yearly in another Member State.[77] The continuity of enforcement is notably essential for detecting
odometer fraud, defects resulting from tampering and those which are the
consequence of accidents. It is also worth to mention that additional tests
after re-registration constitute unnecessary cost in terms of money and time
for the vehicle owner. The table below presents in details the
areas where data related to PTI is crucial but currently often unavailable. Table 4: Areas where the availability of PTI
related data is crucial Area || Issue || Description Inspection || Certificate of Conformity (CoC) Data + technical information || For assessing the compliance of a vehicle with its technical composition at the time when it was put on the market, the information based on the CoC data (e.g. approved dimension of tyres, number of seats) as well as additional technical information for each single vehicle (e.g. secondary braking system, suspension system) is needed ABS / ESC || For an enhanced testing of ABS or ESC communication has to set up between the testing equipment (OBD-connector) and the on board control unit of these systems to trigger the actuators (interface between pure electronic system and the mechanic/hydraulic system) e.g. to apply certain brake force to a certain wheel. Airbag || Set up communication between the testing equipment (OBD-connector) and the on board unit of the airbag(s) to check their presence and to read out fault codes Market || Odometer fraud and second hand vehicles market || Information on the real mileage is crucial for the vehicle's price and the buying decision by the consumer.[78] The absence of mandatory odometer reading contributes to the low level of buyers' confidence. Mileage fraud is considered to affect between 5% and 12% of used car sales having an economic effect on a EU25 scale between 5,6 and 9,6 billion €.[79] At the cars2010 conference[80] a study on mileage fraud[81] has been presented providing the following estimation of the problem: Mileage fraud is for national transactions in the range of 5% to 12% and at cross border transactions at a range of 30% to 50%. In the case of Germany these values would lead to a monetary effect in the range of €725 Mio to €1.357 Mio per year. The scale of the problem was confirmed by different other presentations from UK, CZ, HU and FR. Extrapolating the quoted figures for EU 27 the monetary effect would be in the range of €4.030 Mio to €7.539 Mio. Re- registration || Data for vehicle registration are derived from the Certificate of Conformity (CoC) document which is generally only available at first registration. Re-registration is done with the information contained in the registration document of the previous registration. If data is missing - as the amount of mandatory data on registration documents is minimised – such data has to be retrieved from the vehicle manufacturer. Box 2: Current
situation concerning PTI-related data storage and exchange Today data for and from roadworthiness testing is stored in disparate locations and following disparate methodologies: Certificate of conformity For each single vehicle, produced in series, that is put on the market the vehicle manufacturer is issuing a Certificate of Conformity (CoC) which contains the basis technical information retrieved out of the type-approval certificate. The content of the CoC document is fully harmonised[82] and can be provided in an electronic format. For single approved vehicles, following the single approval requirements[83], the national approval authorities are issuing a single approval certificate which has to follow the CoC requirements regarding its content. Single approval certificates are electronically stored on a national basis by the majority of Member States. German’s Kraftfahrtbundesamt is currently hosting an EU wide database on type-approval certificates. Registration Vehicles that are allowed to be used on public roads have to be registered[84] by the Member States. Member States operate for the administration of this registrations national registration databases where the required data[85] are kept. PTI results Vehicle testing authorities / organisations are in general using IT solutions to gather the information during vehicle testing for establishing the roadworthiness certificate. The content of such certificates is EU wide harmonised[86] and uses the numerical system for test items and related defects as provided by the existing roadworthiness legislation. The above figure and the description above clearly show that most of the data which is needed to make the roadworthiness system more effective (in particular technical specifications from type approval, as well as data on registration and PTI results, but not technical specifications for testing electronic equipment) is already individually collected and stored. However, the different databases are currently not connected, which makes it impossible to exploit their potential for increasing the effectiveness and strengthening the enforcement of roadworthiness. 2.4. Who
is affected by the problem? Road users –
including pedestrians – are the group most affected by the problem, since they
are the victims of accidents involving vehicles with technical defects. The
citizens at large are affected by the second major impact of defectious
vehicles, i.e. excessive air pollution. Inhabitants of cities are
disproportionately more affected by this problem since the concentration of air
pollution is highest in the urban environment. Owners and operators of commercial
vehicles can also be seen as affected by the
problem, since unequal roadworthiness standards across the European Union
distort the competition between road transport undertakings. Vehicle owners will necesseraly be concerned by any policy solutions that bring
changes to the roadworthiness system. In particular, an increase in the
stringency of tests and controls will imply higher compliance costs.[87] Vehicle manufacturers and PTI centres might be affected by any solution which requires them to share data
for free. Currently, manufacturers can sell technical data and PTI centres are
selling data on vehicle mileages. However, vehicle manufacturers will benefits
from the possibility to provide information in one single format and not to be
obliged to adapt vehicles to 27 conflicting testing systems. Moreover,
inspection centres will not have to gather any more data necessary for the
inspection, as it will be readily available via the data exchange system. Testing
equipment manufacturers are affected since low testing requirements limit
the value of their market and they have to follow 27 different requirements. Finally, authorities are concerned
in two ways: most importantly, the lack of easily available information on PTI
results greatly limits the possibilities of enforcing roadworthiness through
roadside inspections, registration policy and operating permits; secondly, the
fact that odometer readings are not properly collected means that the national
and European authorities do not have reliable statistics on vehicle use. 2.5. Evolution
of the problem (baseline scenario) The failures identified as drivers of the
problem are regulatory in nature. They could evolve in any direction
depending on the policy choices of Member States. The Commission has hardly any
knowledge on the possible orientations of such choices in the future, apart
from the fact that Netherlands and the United Kingdom have been looking at
possibilities to reduce the frequency of PTI to save costs for vehicle
owners, which would by definition have a negative impact on roadworthiness. On
the EU side, the technical annexes to Directive 2009/40/EC will be updated
regularly to take into account technological advances, as it has happened so
far.[88] However, since the Directive allows only the list of test items and
testing methods to be updated through commitology, no change to the scope and
frequency of testing, and to the framework for data exchange, can be achieved in
the baselie scenario. Available projections concur to conclude
that the vehicle fleet in Europe will increase in the future. The Commission
estimates that, in a no policy change scenario, the number of passenger cars
will increase from 220.2 million in 2005 to 307.1 million in 2050.[89] More vehicles in principle increase the risk of accident
occurrence. At the same time, the ambitious policies
announced in the Road Safety Policy Orientations for 2010-2020 are expected to
increase road safety. In particular, large hopes are related to the development
and deployment of Intelligent Transport Systems (ITS) and related pervasive
technologies and tools. On the other hand, the latter will increase the complexity
of on-board electronic equipment, which is difficult to test under the present
conditions since the technical data from manufacturers are not currently
available in functional form. Overall, it is expected that the downwards trend
in fatalities is maintained,[90] but it is probable that the share of accidents caused by technical
defects will rise from the current 6%. On the environment side, pollutant
emissions will be drastically reduced as vehicles compliant with older Euro
classes are gradually scrapped and new, zero-emission vehicles are marketed. As
it happens, the incidence of heavy polluters (due to technical defects) on air
quality will become proportionally higher. Finally, according to a recent report on the
Second Hand Car Market[91], the number of cross-border re-registrations of vehicles in the EU
is likely to increase from the current 3.4 million to 5.3 million in 2050. This
will increase the magnitude of the problems related to the absence of exchange
of data between the authorities and the testing centres in different Member
States. 2.6. Does
the EU have the right to act? The right to
act for the EU in the field of transport is set out in the Treaty on the
Functioning of the European Union. More particularly, Art. 91 of the Treaty
puts on the legislators the obligation to lay down measures to improve road
safety. Road transport
– individual, passenger and particularly commercial – has a strong cross border
aspect. This is particularly important for enforcement, where effectiveness
depends on the seemless flow of information about the technical state of
vehicles, the compliance history and fraud detection between different
authorities in different Member States. Similarly, vehicle manufacturing is
global, and action addressing the provision of data for PTI purpose by the
manufacturers clearly has to be taken at the highest possible level. Out of the seven pillars of the EU
roadworthiness testing, as presented in Table 2, the following are fully or
nearly fully within the competence of MS: the definition of defects and
assessment of results; equipment to be used; skills and application of staff;
supervision of the testers. For the remaining pillars, which are partly
covered by the existing Directives 2009/40/EC and 2000/30/EC, exemption
possibilities and a lot of flexibility is left to the Member States in their
transposition. Most notably, the Directives give the MS the possibility to
define themselves high PTI standards which reflect the common objectives in
terms of road safety and environment protection. The reality shows that these
opportunities have not been seized by all the MS to establish high levels of
roadworthiness control, resulting in a diversity of testing qualities across
the continent. The baseline scenario considerations above show that this
situation is likely to continue and even worsen in the future. This trend can
be only reversed by concerted action at EU level. The optimal level of intervention of the EU
remains to be established. In order to avoid falling in the trap of looking at
legislative solutions only, the Commission will also analyse the impacts of an
intervention based purely on soft-low, including peer reviews and screening,
research on optimal PTI solutions, awareness campaigns focusing on vehicle
owners, enhancement of roadside inspections and testing as well as supervision
by Member States, as well as recommendations for voluntary action by vehicle
manufacturers. A mixed soft and legislative approach will also be assessed. The Commission believes that some aspects
of the review of the roadworthiness system should be left to the MS, who can
achieve the goals in a more effective way. In particular, this would concern
the following aspects: · Roadside technical inspections: while the amendment of the relevant
Directive would set general rules and objectives, the choice of the exact way
on how to reach these objectives would be left to the MS. · Training: In the policy options based on legislative action, DG MOVE
intends to provide general curricula for the training of the inspectors, but
would leave the organisation of these trainings to the MS. · Supervision: DG MOVE believes that the Commission should provide the
standards for supervision, but leave their execution to the MS. 3. Objectives 3.1. General objectives As indicated
above, the Commission adopted in July 2010 the policy orientations on road
safety 2011-2020, with the target of halving the overall number of road deaths
in the European Union between 2010 and 2020. The 2011 White Paper on Transport
provides the additional goal of moving to zero fatalities in road transport at
the horizon 2050. There is also an ongoing debate and a number of ongoing
initiatives addressing the problems of air pollution and climate change.[92] In this
context, the two general objectives of this initiative are: 1. To
contribute to the achievement of the goal of halving the overall number of road
deaths in the European Union between 2010 and 2020 and moving to zero
fatalities in road transport by 2050, through measures aiming at increasing the
quality and better coordinating national PTI and roadside inspection systems,
and 2. To
contribute to the reduction of the emissions of GHG and air pollutants from
road transport through measures aiming at detecting more effectively and
removing from circulation vehicles which are over-polluting because of
technical defects. 3.2. Specific
objectives In light of the root
causes identified in section 2.3 above, the general objective can be translated
into two specific objectives: (1)
Increase the scope and the level of requirements
for roadworthiness testing and roadside controls across the European Union; (2)
Create the appropriate framework for seamless
flow of information between actors and Member States involved in the
enforcement of PTI results. Table 5:
Correspondence between problem, problem drivers and objectives Problem || Drivers || General objectives || Specific objectives Too many vehicles with technical defects on the road || 1. Scope and level of requirements for roadworthiness testing and roadside controls are too low || 1. To increase road safety through better and more coordinated PTI and roadside inspections || 1. To increase the scope and the level of requirements for roadworthiness testing and roadside controls across the European Union 2. Information and data is not exchanged between concerned actors || 2. To reduce emissions from road transport through better and more coordinated PTI and roadside inspections || 2. To create the appropriate framework for seamless flow of information 3.3. Operational objectives The specific objectives
can be translated in turn into the following two operational objectives, to be
reached three years after the entry into force of all elements of the new
legislation (including the set-up of the data exchange system): (1)
Reduce the number of fatalities caused by
technical defects by as close as possible to 1,100 yearly, which has been
estimated as the maximum potential; and (2)
Move towards eliminating the "gross
emitting" vehicles from the fleet in use. The choice of the time
horizon (three years after the entry into force of the legislation) is dictated
by the delay in the effectiveness of proposed measures. In particular, any
change to the PTI system will have a direct impact on vehicles only at the
moment when they are called for a PTI. Currently, as a minimum standard,
vehicles of four years and more of age must undergo a PTI every two years. 4. Description
of Policy Options In light of
the above, the Commission has identified a set of policy
options – besides the baseline scenario – that combine
specific EU actions across the two areas for action
described in section 2 above. The design of policy options builds on the
achievements and deficiencies of current policies outlined in section 2. All policy options have been designed to be
able to address both specific objectives defined in section 3 on a standalone
basis. At this stage, it is worth noting that the
Commission has also considered the discontinuation of EU action. Under this
option, the EU would withdraw from regulating the requirements for PTI and
leave it to the Member States to decide on the optimal testing needs to ensure
the roadworthiness of vehicles. However, this Policy Option has been discarded
at an early stage, since 'doing less' would not be in line with the recently
adopted EU policy orientation on road safety and the strategic policy
directions outlined in the Commission's White Paper – Roadmap to a Single
European Transport Area,[93] Further, 'doing less' at EU level would most probably result in
more diverse national PTI schemes within the EU. It can therefore not be
excluded that the developing differences at national level may also lead to
less rigorous PTI testing procedures in some cases. This could ultimately
result in more accidents due to technically non-fit vehicles and therefore
impact negatively on road safety and air pollution and climate change. Policy options 2a-c (on a standalone basis
and as part of options 3a-c) reflect the need to move towards a more risk-based
approach to PTI and roadside inspections. In PTI, such risk factors as vehicle
age and mileage (passenger cars in business use) are proposed to be taken more
into account for the testing frequency. In roadside inspections, options 2a-c
foresee targeted checks, which are more sophisticated in options 2b and 2c. As regards targeted technical roadside
inspections the Commission is aware of the fact that some countries have
adopted a more comprehensive risk-based approach to roadworthiness testing.
Notably in the UK, company profiling is used for targeted checks in the context
of roadside inspections. A similar system at the European scale could be
imagined. Based on the result of RSI a risk rating of companies could be set
up. A similar system is already in place for the purpose of checking driving-
and resting time (Article 9 of Directive 2006/22/EC) and for the rules
concerning the conditions to be complied with to pursue the occupation of road
transport operator (Regulation (EC) No 1071/2009 Article 16). National
registers on road transport undertakings containing the most serious
infringements have to be installed and will be interconnected by a European
network (ERRU) mentioned in Figure 2 of the IA report. Compliant transport undertakings benefit
from targeted roadside checks as they are less likely to be interrupted in
their operational activities by unpredicted ad hoc controls. The concept of targeted roadside control is
already established in the aquis communautaire for the control of driving time
and resting periods for the professional transport of goods and passengers.
Given that, Member States may use the arrangements established for those
purposes without any additional investments. Therefore all policy options (apart
from business as usual) include the concept of targeted checks to be applied to
technical roadside inspections. As regards periodic roadworthiness tests
the targeted approach through company profiling could also be used to determine
different frequencies of periodic roadworthiness testing for compliant and
non-compliant operators. To avoid unfair competition and destruction of the
market, such a regime would have to be put in place in all Member States and
become effective once the data exchange and the profiling of companies is fully
operational. Estimating that 20% of commercial vehicles
are operated by the best performing operators and such vehicles will have to
show up for PTI every second year instead of every year until the age of 6
years[94] would lead to a reduction of up to 8.9 million tests per year for
commercial vehicles. This would result in a reduction of the overall compliance
costs by € 890 million. However, the potential benefits of the
profiling of European transport companies have to be seen in the light of the
potentially very large costs of the set up and maintenance of such a profiling
system. Those costs being probably much higher than the benefits, it was
decided not to include company profiling system for periodic roadworthiness
tests in any of the policy options but to generally foresee targeted technical
roadside inspections. 4.1. Policy Option 0 - 'No policy
change' approach Policy option 0 (PO 0) provides the reference case against which the
effects of other policy options are compared.[95] Within
this option, the present EU legal framework for PTI and roadside inspections
would be maintained. Also, there would be no short-term adaptation of the
technical annex of Directive 2009/40/EC, since the annex has been recently
amended through comitology (with Directive 2010/48/EU). The scope and frequency
of PTI will therefore not change in PO 0, and no further measures related to
the exchange of information will be adopted. The absence of a framework for
exchanging data will persist. Table 6 below describes the baseline in
more details. Table 6: Current legal framework at EU level Components || Elements || Content Minimum EU standards for PTI and roadside inspections || Technology and Procedures || General: pit or power lift Brake testing: roller brake test bench, brake pressure measurement for power brakes Lights testing: head lamp aiming device Emissions testing: CO – lambda for petrol and K-value measurement for Diesel engines Items only need to be visually inspected and procedures for the use of roller brake testing are as mentioned as a reference to ISO 26096. Frequency of Tests || For passenger cars (M1) and vans up to 3.5t (N1):[96] first inspection after four years, then every two years (4-2-2); For buses and coaches (M2,3), trucks (N2,3), heavy trailers (O3,4), taxis and ambulances: every year (1-1-1) Vehicle Categories Covered || Vehicles with at least four wheel carrying passengers (M1M2M3) Vehicles with at least four wheel carrying goods (N1N2N3) Heavy trailers (O3O4) Personal Skills and Qualifications || no definition Supervision and Enforcement || special measures if non-public bodies are involved (Art. 2 of Directive 2009/40/EU) Road side inspection || Roadside Inspections – Reporting to the Commission System for data exchange || Data exchange || none 4.2. Policy Option 1 - Soft law
approach Policy Option 1 (PO 1) would consist in a
better implementation and better monitoring of the application of existing legislation. This option would not introduce new
legislation, but there would be new and increased efforts by the Commission to
improve the standards of testing and enforcement, as well as actions to
incentivise the exchange of data. In practice, these efforts would encompass
an increased use of peer reviews and screening by the Commission and the
exploration of optimal levels of investment in PTI and roadside testing in
cooperation with the Member States. Furthermore, under this policy option, the
Commission and Member States would explore the scope for risk-based testing
regimes, including e.g. vehicle warranty and age, mileage, or the previous
involvement of the vehicle into an accident. The option would also include
looking into the enforcement of legal responsibilities of individuals not
presenting their vehicles to required PTI. Enforcement measures would include
awareness campaigns focusing on vehicle owners, enhancement of roadside
inspections and testing as well as supervision by Member States. Finally, to
ensurre better availability of data for inspections, PO 2 would include
recommendations for voluntary action by vehicle manufacturers. 4.3. Policy Option 2 - Legislative approach Policy Option 2 would be based on two
components. In order to meet the first specific
objective, the first component is to revise upwards the minimum EU standards
for PTI and RSI and define mandatory standards for all the seven pillars of the
roadworthiness system.[97] This is essential to avoid that gaps in the system (eg. one of the
pillars left over) reduce the effectiveness of roadworthiness enforcement as a
whole. Three alternative scenarios for minimum standards will be identified
(see section 4.3.1). In order to meet the second specific
objective, the second component is to put in place a harmonised data exchange
system linking the existing databases and ensuring: ·
the access by all PTI centres to data at the
level of the Certificate of Conformity and the data on electronic safety
systems (such as ABS/ESC/airbags/…); ·
the exchange of inspection results between
Member States, with accessibility of most important enforcement authorities to
the system; ·
the reporting of inspection results – and in
particular odometer readings – by PTI centres to national and European
authorities for enforcement and statistical purposes. Figure 2 provides an illustration of how
such a system would complete and connect existing databases to untap their
potential for increasing the effectiveness of testing and roadworthiness
enforcement. Figure 2 should be compared with Figure 1 in section 2.3.2. Figure 2: The harmonised data exchange system ("vehicle administrative
platform") in the context of existing and foreseen PTI-related databases *ERRU is the European Register of Road Transport
Undertakings (Commission Regulation EU/1213/2010); **EoL stands for "End of Life" (Directive
2000/53/EC). Source: DG MOVE. In order to protect the fundamental rights
of those citizens whose data might be exchanged through the new system, the
following three principle will have to be respected: · The purpose of the system is to exchange only data related to the
vehicles, not to their owners or operators; · Any personal data linked to the vehicles will have to be kept at
national level in registration databases; · The definition of access rights will have to guarantee that only
technical, non sensitive data can be accessed. 4.3.1. Identification of sub-options Policy Option 2 will be broken down in
three suboptions (from a to c) according to the level of requirements. The data
exchange platform will be a common element to the three suboptions for the
reasons explained in section 4.3.2. below. Policy Option 2a: Moderate increase of minimum requirements and
system for data exchange PO 2a increases the scope of RSI beyond
checking emissions and brakes; sets detailed requirements for the equipment to
be used at PTI; puts in place the obligation for government departments to
perform regular quality checks on PTI centres; includes motorcycles (L3,4,5,7) and
light trailers (O2) among vehicles to be inspected at PTI; pushes forward the date of
the first mandatory PTI from the fourth year after registration to the third;
and sets regular training requirements for inspectors, both for PTI and RSI. Table 7 summarises the content of PO 2a with
changes in comparison to the baseline highlighted in grey. Table 7: Policy
Option 2a: Moderate increase of minimum requirements and system for data
exchange Components || Elements of test || Content Minimum EU standards for PTI and roadside inspections || Technology and Procedures || General: pit or power lift, automated data collection Brake testing: roller brake test bench, brake pressure measurement for power brakes, suspension test bench Lights testing: head lamp aiming device Testing of safety related electronic systems: access to On-board diagnostics (OBD) to read out defect codes Emissions testing: CO – Lambda for petrol and K-value measurement for Diesel engines, On-board diagnostics (OBD) Frequency of Tests || For passenger cars (M1), vans up to 3.5t (N1), light trailers (O2) and motorcycles (L3): first test after three years, then evey seond year (3-2-2) For busses and coaches (M2,3), trucks (N2,3), heavy trailers (O3,4), taxis and ambulances: every year (1-1-1) Vehicle Categories Covered || Vehicles with at least four wheel carrying passengers (M1M2M3) Vehicles with at least four wheel carrying goods (N1N2N3) Light and heavy trailers (O2O3O4) Motorcycles (L3,4,5,7) Personal Skills and Qualifications || Personnel with technical background with yearly training on PTI of more than two days. Supervision and Enforcement || Undercover tests, regular quality checks done by governmental departments – quality assurance system following the priciples of ISO 17020. Road side inspection || targeted selection of commercial vehicles, which are obviously badly maintained. Checks covering all test items which are inspected at the PTI System for data exchange || Vehicle administrative platform || centrally defined but regionally administered data stores holding local information only Policy Option 2b: Advanced increase of minimum requirements and
system for data exchange Policy Option 2b, in addition to Policy
Option 2a sets higher standards for testing equipment at PTI centres (including
for testing electronic safety components) and for RSI (testing 15% of vehicles at
roadside inspections with mobile roadside inspection units); increases the
specific training requirements for ispectors (PTI and RSI) to 4 days a year;
includes mopeds (L1,2,6) among vehicles tested at PTI and vans (N1) with
commercially used small trailers (O1,2) among vehicles
tested at RSI; increase the testing frequency for older small vehicles (every
year instead of every two years for M1N1O1,2L3,4,5,7);
sets a minimum requirement of 10% of commercially used vehicles being tested at
RSI; and increases the quality of supervision of PTI centres. Table 8 summarises the content of Policy Option
2b with changes in comparison to Policy Option 2a highlighted in grey. Table 8: Policy
Option 2b: Advanced increase of minimum requirements and system for data
exchange Components || Elements of test || Content Minimum EU standards for PTI and roadside inspections || Technology and Procedures || General: pit or power lift, automated data collection and storage Brake testing: roller brake test bench, brake pressure measurement for power brakes, suspension test bench, load simulation for trucks Lights testing: head lamp aiming device Testing of safety related electronic systems: On-board diagnostics (OBD), use of scan tools and functionality tests Emissions testing: CO – Lambda for petrol and K-value measurement for Diesel engines, On-board diagnostics (OBD), use of scan tools Frequency of Tests || For passenger cars (M1), vans up to 3.5t (N1), light trailers (O1,2): first test after three years, then after two years, then every year (3-2-1) For motorcycles (L3,4,5,7) and mopeds (L1,2,6): first test after three years, then every year (3-1-1) For busses and coaches (M2,3), trucks (N2,3), heavy trailers (O3,4), taxis and ambulances: every year (1-1-1) Vehicle Categories Covered || All vehicles that are registered (M – N – L – O) Personal Skills and Qualifications || Personnel with technical background with yearly training on PTI of more than four days. Supervision and Enforcement || Undercover tests, regular quality checks done by governmental departments – quality assurance system following the priciples of ISO 17020. Road side inspection || Roadside inspection for vans (N1) and light trailers used for commercial purpose (O1,2) in addition to M2,3, N2,3 and O3,4; 15% targeted checks with mobile inspection units out of the 10% of commercial vehicles checked System for data exchange || Vehicle administrative platform || centrally defined but regionally administered data stores holding local information only Policy Option 2c: Highest increase in mimimum standards and
system for data exchange Policy Option 2c, in addition to Policy Option
2b, introduces emission testing for all categories of vehicles at RSI by the
use of remote sensing technology with a target of 15% of vehicles tested;
expands RSI to all categories of vehicles; and increase the frequency of
testing of light vehicles (M1N1O1,2 L3,4,5,7) to
yearly counting from the moment of registration and for heavier vehicles to
every half a year instead of every year for M2,3N2,3O3,4. Table 9 summarises the content of Policy
Option 2c with changes in comparison to option 2b highlighted in grey. Table 9:Policy
Option 2c: Highest increase in mimimum standards and system for data exchange Components || Elements of test || Content Minimum EU standards for PTI and roadside inspections || Technology and Procedures || General: pit or power lift, automated data collection and storage Brake testing: roller brake test bench, brake pressure measurement for power brakes, suspension test bench, load simulation for trucks Lights testing: head lamp aiming device Testing of safety related electronic systems: On-board diagnostics (OBD), use of scan tools and functionality tests Emissions testing: CO – Lambda for petrol and K-value measurement for Diesel engines, On-board diagnostics (OBD), use of scan tools Frequency of Tests || For passenger cars (M1), vans up to 3.5t (N1), light trailers (O1,2), motorcycles (L3,4,5,7) and mopeds (L1,2,6):every year (1-1-1) For busses and coaches (M2,3), trucks (N2,3), heavy trailers (O3,4), taxis and ambulances: every half a year (0.5-0.5-0.5) Vehicle Categories Covered || M – N – L – O (all vehicles that are registered) Personal Skills and Qualifications || Personnel with technical background with yearly training on PTI of more than four days. Supervision and Enforcement || Undercover tests, regular quality checks done by governmental departments – quality assurance accreditation system according to ISO 17020. Road side inspection || 15% targeted checks with mobile inspection units out of the Roadside inspection for 15% of commercial vehicles vehicles, 15% emission screening with remote sensing units; RSI of other categories of vehicles recommended System for data exchange || Vehicle administrative platform || centrally defined but regionally administered data stores holding local information only 4.3.2. Choice
of the optimal data exchange system The Commission initially considered all
three potential technical solutions for ensuring the exchange of data from and
for PTI between the involved stakeholders, being: ·
Centralised data store – merging all current
national databases into one single database at EU level, containing all PTI
relevant information for the 27 Member States; ·
Centrally defined data store with full
replication of all data to each Member State – existence of national databases
with information on vehicles from the whole EU; all databases would update
automatically to changes introduced in one of them; ·
Centrally defined but regionally administered
data stores holding local information only – national databases would continue
to contain only information on the vehicles registered in the given Member
State, but an additional functionality would allow consulting and importing
data from the other 26 national databases and from the central type-approval
and technical databases. The Commission has asked an IT expert to
analyse the pros and cons of each option.[98] Very
rapidly, it turned out that, given the extremely high number of inputs (over
300 million vehicles are concerned) and the diversity of types of national
databases in place, only the last option is technically feasible. The
centralised data store, according to the analysis, "would be
cost-prohibitive and cause the vehicle testing applications of each Member
State to slow unacceptably". Also full replication and merging of
databases (second solution) would be "prohibitively expensive in terms of
central infrastructure needs", and also "[place] a restriction on
Member State initiatives for modernisation and innovation in case it disrupts
the data integration. With many different application vendors each rolling out
updates this option is not feasible". For the above reasons, it has been decided
to discard the first two solutions for putting in place a data exchange system
and retain for further analysis only the solution of "centrally defined
but regionally administered data stores holding local information only",
which has the additional benefit of having been tested for other applications
such as the Tachonet.[99] This solution will therefore be the common element of all the three
sub-options 2 a to c. 4.3.3. Discussion on the legal instrument for Policy Option 2 The European legislation on PTI is currently
in the form of a Directive (Directive 2009/40/EC). The nature of this legal
instrument has partly led to the large heterogeneity of the PTI systems in
Europe, since the Directive in question leave a wide margin of interpretation
to the Member States in the implementation of the minimum rules. One of the
consequences of this heterogenity, described above, is the persisting lack of
recognition of PTI certificates issued by another Member State at the occasion
of a re-registration; others include the difficulties with enforcing
roadworthiness rules based on unharmonised documentation and the impossibility
to precisely benchmark the PTI systems due to the lack of a common reference
standard. An overall consequence of the large
flexibility given to the Member States in the implementation of the Directive
is that the perception of a common European road safety area is lost to the
detriment of one of conflicting and competing 27 national systems. This is
incompatible with the approach presented in the 2011 White Paper on Transport[100] and the 2010 Policy Orientations on Road Safety, which explore
common solutions for common problems. This is indeed already the approach taken
by Directive 77/143/EC[101], the recital to which says that "the
growth of road traffic and the resultant increase in danger and nuisances
present all Member States with safety problems of a similar nature and
seriousness". Finally, Policy Option 2 in its three forms
proposes to set more detailed minimum standards in a much wider range of
aspects than it is currently the case. Notably, the new legislation considered
under Policy Option 2 would regulate the testing equipment, the supervision
regime over garages, as well as encompass vehicle categories which are
currently left out. It is probable that a Directive would not any more be the
most effective instrument for setting such detailed rules. On the basis of the above argumentation, a
Regulation would probably be a more appropriate tool for translating the
changes to the PTI system in policy option 2 into legislation. The choice of
this instrument would also be compatible with the rest of the legislative body
in the vehicle control regulatory scheme (see figure 1
for more details), and notably Regulation 715/2007/EC on type-approval. On the other hand, in what concerns the
roadside inspections, experience with Directive 2006/22/EC, which determines the minimum level of enforcement required to ensure
compliance with the rules set out in Regulation (EC) 561/2006
(driving times and rest periods) and Regulation (EEC) 3821/85
(tachograph), shows that a Directive can be an
efficient tool for regulating roadside inspections. In
this situation, subsidiarity suggests to go for the least stringent legislative
tool and not to change Directive 2000/30/EC into a Regulation. In addition, two
policy elements analysed in this report will require refinement before they can
be turned into legislation. These are the curricula of the training for
inspectors and the detailed specifications of the data exchange systems. Both
elements, foreseen by Policy Option 2a-c, will be adopted through implementing
measures as annexes to the new Regulation on PTI specifications of the data
exchange system and training curricula). 4.3.4. Considerations on fundamental rights The data exchange system that Policy Option
2 puts in place relates only to vehicle related data. Strictly speaking it does
not concern personal data and therefore does not affect fundamental rights.
Nevertheless, there is a risk that the information exchanged becomes personal
data in the meaning of Art. 2 of Directive 95/46/EC[102] once
technical data can be linked to the owner of the vehicle or the driver. The
legislation should be designed in a way to limit the possibility of such
linking. However, it is impossible to avoid it completely, since eg. The
registration authorities will have access to the details of the vehicle
together with the personal data of the owner. It is therefore essential that data
processing is carried out in accordance with the principles enshrined in
Directive 95/46/EC, such as purpose limitation, accuracy of data,
relevance of data, data collected should not be excessive, storage of data no
longer than necessary for the purpose of collection, etc....Strict and adequate
safeguard measures will need to be put in place to prevent unlawful or
unauthorised access and processing of the collected data. In particular, it is
important that not more of the personal data than what is strictly needed is available
publicly. Measures will be in compliance with relevant fundamental rights and
principles as embodied in the Charter of Fundamental Rights of the European
Union. 4.4. Policy Option 3 – Soft law
and legislative approaches combined For reasons further
explained in section 5 below, but basically related to the high cost-efficiency
of Policy Option 1 and the much higher effectiveness of Policy Option 2 in all
the sub-options, the combination of both options will also be analysed. 4.5. Summary of identified Policy Options Table 10: Summary table of Policy Options || Minimum EU standards for PTI and roadside inspections || Data exchange Policy Option 0 || No policy change Policy Option 1 (PO 1) || Soft law Policy Option 2 || Legislative approach PO 2a || Moderate increase in the minimum standards for PTI and roadside testing || Data exchange platform PO 2b || Advanced increase in the minimum standards for PTI and roadside testing PO 2c || Highest increase in the minimum standards for PTI and roadside testing Policy Option 3 || Soft law + Legislative approach PO 3a || PO 2a + PO 1 || PO 2 + PO1 PO 3b || PO 2b + PO 1 PO 3c || PO 2c + PO 1 5. Analysis of impact The analysis of impacts follows the logic
of a partial cost-benefit analysis. The main economic, social and environmental
impacts are classified according to whether they constitute costs or benefits.
Of course, what is a cost for one group can be a benefit for another: for
example additional PTI generate costs for vehicle owners and benefits for the garages.
The analysis below therefore deals with what can be perceived as social costs
and benefits. In the end of the section, impacts concerning particular
stakeholder groups are detailed, eg. impacts on SMEs, citizens and public
authorities. All the costs are presented in a monetized
form. On the benefit side, most of the impacts related to road safety and
environment were monetized, and gains in term of new jobs created are also
quantified. However, some important benefits could not be quantified and are presented
in qualitative terms. Annex 13 explains the methodology used for estimating
major impacts. Annex 13a contains the detailed tables with disaggregated
results of the calculations. The major weakness of the cost-benefit
approach is that the conclusions to which it leads are valid under the
condition that the right assumptions have been made. In particular the
estimated benefits of the different options in this IA are based on assumptions
concerning: the percentage of accidents which are due to defects, the detection
rate of defects at PTI and the costs of congestions. In what follows, benefits
are estimated based on literature-derived most probable values for the above
indicators. However, in order to explore the impact on the choice of the
preferred option of uncertainties related to the assumptions made, the results
of a sensitivity analysis are provided in section 6. Table 24 in section
6 presents a summary of the assessment of impacts for the envisaged Policy
Options. 5.1. Assessment of Policy Option 1 (PO1) 5.1.1. Costs The costs of this PO1 would be mainly
related to additional peer reviews and screenings. Such costs could be
calculated on the basis of two additional one-day meetings of experts from
Member States per year in Brussels. If these meetings were attended by two
national experts from each Member State, this would result in 108 return trips
to Brussels. With a daily subsistance allowance (DSA) of around € 90 per day,
fixed additional allowance (FAA) of € 250 per day,[103]
transport costs of around € 300 per return trip and accommodation costs of
around € 100 per trip, this would equate to a cost of € 79,920.[104] Exploring the optimal levels of investment
in PTI and roadside testing would not be related to high costs, when based on
exchange of best practice between Member States. Investments themselves could
be done in a stepwise approach with a reduced impact on Member States' budgets.
Within international organisations for vehicle testing, like the International
Motor Vehicle Inspection Committee (CITA), or roadside enforcement, like
Euro-Contrôle-Route (ECR), systematic exchange of best practice is already
established. Furthermore, ECR has established bi- and multilateral trainings
for roadside inspectors where high quality roadside inspections are trained
(with or without the use of equipment). An increase in awareness of the importance
of keeping vehicles roadworthy could be achieved with a communication campaign
aimed directly at citizens. The campaign could be initiated at EU level, or the
EU could encourage Member States to perform campaigns at national level. The
legal obligation of motorists in some Member States to keep their vehicles safe
could be reinforced in such a campaign. For instance, reminders could be sent
to drivers at the approach of the next date for a PTI. The costs of designing and leading such a
campaign could be large: the average cost of comparable EU-wide information
campaigns were around €200,000 per year[105],
although campaigns with significantly higher costs are not rare in the field of
road safety.[106] The results of such a campaign – in the form of a significant and
sustained behavioural change of vehicle owners – are alo subject to
uncertainty. Regarding roadside inspections, the costs
of arranging better implementation are likely to be modest, particularly if it
takes place alongside the enhanced arrangements for peer review and screening
as discussed above. 5.1.2. Benefits The direct benefits of this PO1 are
improved average PTI testing standards and a changed behaviour of vehicle
owners with regard to keeping their vehicles technically fit. Both are likely
to translate into a reduction of fatalities on the roads, but it is very
difficult to quantify these impacts. A 2009 study investigating the effects of
road safety campains[107] found out that they can result on average in a 9% decrease in
accident levels.[108] Applying this estimation to the accidents caused by technical
defects (6% - see part 2 above) and taking the simplifying assumption that the
campaigns will become effective in countries with a lower level of
qualifications and supervision of inspectors (see table 2) – which can be used
as a proxy for the lower level of PTI as a whole – the number of fatalities
reported there is about 7,605. With 6% of these fatalities linked to technical
defects, about 456 fatalities have to be considered. The potential of a
reduction by 9% results in the range of saving of 41 lives. Using the figure of
average number of fatalities, serious and slight injuries per accident provided
in the CARE database, it can be derived that also 1,885 accidents, 6,930
serious injuries and 38,498 slight injuries could be avoided. Using the standard values for monetising
the cost of accidents (see annex 13 for more details on the methodology), this
could be translated into a saving of € 183.7 million. The reduction in
congestion resulting from the reduced number of accidents translates into an
additional saving of € 9.4 million. Additional peer reviews and screeenings,
and of the exploration of optimal levels of investment in PTI and RSI are also
expected to result in some increase of the average scope and level of
requirements at PTI and RSI in national legislations. With the available
evidence, it is not possible to quantify or even estimate the order of magnitude
of these effects. The analysis of the impacts of POs 2 a-c gives however an
idea of the overall potential – in terms of road safety and environment
protection – of measures aimed at increasing the level and scope of PTI
requirements. Table 11 Summary of estimated costs and benefits of
PO 1 Estimated costs (annually) || Estimated quantified benefits Peer reviews and screenings || Communication campaign || Total || less accidents/ fatalities (monetised value) || Cost savings due to less congestion € 79,920 || € 200,000 || € 279,000 || 1,885/41 (€ 183.7 million) || € 9.4 million || || || Estimated non quantified benefits || || || Increased road safetyy and less environmental pollution resulting from: – additional peer reviews and screenings – exploration of optimal levels of investment in PTI and roadside testing 5.2. Assessment of Policy Option
2a (PO 2a) 5.2.1. Costs Equipment PO 2a includes the setting of basic
requirements for the equipment to be used at PTI centres. A major share of the
testing centres in the EU already use compliant equipment, but exact numbers
are not available. In order to estimate the total costs of necessary upgrades,
and with the approval of PTI experts from DEKRA,[109] the
classification according to the level of qualifications and supervision of testers
(see table 2) was used as a proxy. It was assumed that the Member States which
did not set additional requirements for these two elements are also the ones
where PTI centres do not meet the basic requirements for testing equipment as
set in PO 2a. Table 10 below indicates the number of PTI centres in each of the
three categories of Member States. Table 12: Number of testing stations per category of Member States,
established according to the requirements for the qualifications and
supervision of inspectors Requirements for the qualifications and supervision of inspectors || Member States || Estimated number of test stations[110] No requirements as in Directives 2009/40/EC and 2000/30/EC || Bulgaria, Cyprus, Greece, Hungary, Italy, Lithuania, Malta, Poland, Romania, Slovenia || 14,000 Higher requirements than in the EU legislation || Austria, Czech Republic, Denmark, Estonia, France, Ireland, Latvia, Netherlands, Portugal, Slovakia, Spain, United Kingdom || 40,500 Very high requirements || Belgium, Finland, Germany, Luxembourg, Sweden || 40,500 || Total (approx.) || 95,000 Source: DG MOVE analysis based on Europe
Economics, DEKRA, CITA. The main costs for upgrading equipment to
the level imposed by PO 2a would be the following[111]: –
€ 10,000 for new suspension test bench; –
€ 4,000 for equipment for testing modern
electronic devices (OBD read out); –
the "automated data collection"
mentioned in PO 2a will use existing equipment. Depreciating the above total costs of
€ 14,000 over five years would lead to an annual cost of € 2,800 a
year, which would lead to an aggregated annual of € 39.2 million for the
technical upgrade. Staff It has been estimated[112] that ensuring that inspectors have a technical background and that
they are trained specifically for the purpose of PTI at least two days a year
will increase the labour costs by approximately 20% for those PTI stations
where this is not yet the case. Grosso modo, this corresponds to the
centres located in the Member States belonging to the first category in table 10.
These 14,000 testing centres employ approximately 28,500 testers.[113] Based on the wages for technical staff of the countries concerned
provided in the Standard Cost Model, the 20% increase in the employment costs
for PTI inspectors will translate into € 73.1 million per year. The requirement to use inspectors with
technical background set in PO 2a also applies to roadside inspections. The
cost of technical labour for RSI at € 12 per vehicle on average.[114] There are about 3.6 million RSI performed in the EU per year.[115] This means that the overall staff costs reach approximately
€ 43.2 million. Approximately half of Member States are already using
staff with technical skills for the purpose of the RSI, with the other half
relying on regular (non specialised) police force.[116] For
these Member States, additional technical staff costs for RSI would therefore
reach € 21.6 million (0.5*€ 43.2 million). Vehicle classes to be inspected PO 2a extends the PTI obligation to the
motorcycles and light trailers. The cost implications to the vehicle owners for
making the test can be estimated at € 20 per test.[117]
However, in many Member States the test for motorcycles (L3) is
already mandatory. The introduction of the tests in countries where it's not
mandatory yet,[118] and the increase of the frequency in those countries where the
frequency is lower than 3-2-2 will result in an additional 3.49 million tests,
translating into additional costs of € 70 million for all Member States. Training for a qualification for testing
powered two-wheeler can be seen as an additional cost but these costs are not
significant. PTI for light trailers is currently
mandatory in 21 Member States. Applying a similar methodology as for
motorcycles and assuming a cost of € 35 per test, it can be estimate that
including light trailers in the list of vehicles which must undergo PTI in the
remaining Member States would cost approximately € 80 million. Testing frequency PO 2a pushes one year forward the date of
the first mandatory PTI and of all subsequent PTIs for private cars. This means
that the minimum number of PTI in a statistical life of a car moves from 7.5 to
8 inspections per vehicle. As indicated in table 11 below, currently nine
Member States have testing frequencies which translate into 7.5 inspections per
vehicle. For these Member States, on average 1/34 extra inspections per year
would be necessary for about 85 million vehicles. At an average inspection
price of € 50, this results in an annual costs of approx. € 125 million. Table 13: Overview on the number of PTI in the
lifetime of a passenger car per Member State Number of inspections during average life of private cars (17 years) || Member States || Number of registered private cars * 1000 || Number of inspections per year *1000 7.5 || Czech Republic, Denmark, Greece, Ireland, France, Italy, Cyprus, Hungary, Malta || 84,441 || 37,253 8 || Germany || 41,321 || 19,445 8.5 || Lithuania, Romania || 5,698 || 2,849 11 || Spain || 22,145 || 14,329 12 || Estonia, Portugal || 4,960 || 3,501 13 || Slovenia || 1,045 || 799 14 || Belgium, Austria, Finland, Sweden, Poland || 32,475 || 26,744 15 || Luxembourg, The Netherlands, UK, Slovakia || 38,695 || 34,143 17 || Latvia || 933 || 933 Source:
Eurostat, Europe Economics, op. cit. Supervision of testing centres PO 2a imposes on Member States the
obligation to regularly check the quality of PTI centres. According to the
Netherlands, which already proceed with such checks, average costs can be
estimated at € 0.70 per year and vehicle.[119] This includes
quality insurance and other measures of the involved PTI organisations such as
audit-inspection, 'mystery shopping' or statistical analysis as well as
administrative costs for governments. Although there are differences in the
wage levels, it was assumed that this is a good estimate for the EU average
cost for supervision. At present, some Member States (UK, S,
AT, LV, NL, H, RO, EE) are having a certain level of supervision already in
place, which means that the additional cost could be rather lower than
€ 0.70. For this reason, we apply an average value of € 0.30 per year and
vehicle as the cost of adapting to the quality check requirement across the EU.[120] Following this methodology, the total costs for supervision is
estimated at about € 42.6 million. Data exchange Setting up a data exchange system as
foreseen by PO 2 (independently of the sub-option) would entail costs, both for
the Member States and centrally for the EU. The costs can be divided into the
(i) one-off capital expenditure, (ii) the ongoing operational support costs
(maintenance) and (iii) the administration service review costs (management).[121] The costs for PTI centres are negligible, since they wouldn't need
more than a computer and an internet connection to be able to supply and
receive data. Table 12 presents the costs according to this classification. Table 14 Cost of setting up the data exchange
system[122] Yearly Costs (€ million) || Member States || EU || Total One-off (5-year amortisation assumed) || 4.3 || 0.6 || 4.9 Maintenance || 2.5 || 0.4 || 2.9 Management || 0.3 || 0.04 || 0.3 Total || 7.0 || 1.0 || 8.0 Source: Commission
calculations using cost estimates in Europe Economics, op. cit., pp.
173-176. Cost for vehicle owners, drivers
and operators Higher PTI and RSI standards will result in
a higher number of vehicles failing the tests and more defects being detected.
Vehicle owners, drivers or operators will be forced to perform a higher number
of repairs after inspections, and will also be subject to a higher number of
fines and more time lost at roadside inspections. These costs are difficult to
estimate, but are obviously directly linked to the benefits resulting from
taking dangerous and/or polluting vehicles off the roads. Summary of costs for PO 2a Table 15 below provides a summary of the
quantifiable costs arising from the measures foreseen in PO 2a. The overall
cost estimate would be around € 459.5 million per year. Table
15: Estimated costs of PO
2a Cost item || annual costs (in million €) 1 || Equipment || 39.2 4 || Staff || 73.1+21.6=94.7 5 || Vehicle classes to be inspected || 70+80=150 6 || Testing frequency || 125 7 || Supervision of testing centres || 42.6 8 || Data exchange || 8 Total cost estimate || 459.5 5.2.2. Benefits 5.2.2.1. Road safety The
major impact of the measures contained in PO 2a relates to increased road
safety. Annex 13 provides the methodology for estimating these benefits. Quantified benefits Based on the methodology used, it is
estimated that PO 2a will lead to a yearly reduction of 7,391 in the number of
accidents and allow avoiding 749 fatalities. In particular, 333 lives would be
saved thanks to the mandatory testing of electronic safety components (testing
of ESC 158 and testing of Airbag 175). Expanding the scope of vehicles tested
to motorcycles will avoid 220 fatalities per year. Using the values of
statistical life and risk values for injuries[123], the
monetised social benefit arising from the reduction in accidents, saving of
lives and avoided injuries can be estimated at € 1,576 million. The reduction
in congestion resulting from the reduced number of accidents translates into an
additional saving of € 16.67 million.[124] Non-quantified benefits Although no data is available to
support this claim, not all defects which are detectable with the available
equipment and testing methods are actually detected at PTI. The reasons for
this can be numerous, among which the lack of appropriate competence of the
staff on the one hand, and fraud on the other. It can therefore be expected that
the specific requirements on the training of inspectors and on the supervision
of PTI centres, which are introduced under PO 2a, will increase the rate of
detected defects. Given the high share of vehicles with defects in the entire
fleet (6%), even a small increase in the detection rate can have a substantial
impact on road safety and the environment. However, given the lack of concrete
data, it is not possible to estimate in quantitative terms the increase in the
detection rate which can be expected as a result of the measures described
under PO 2a. PO 2a also introduces the requirement
to make targeted roadside inspections for commercial vehicles, meaning that
obviously badly maintained (rusted, body damaged, etc…) vehicles are inspected
in priority. Those countries which already apply targeted checks (notably the
United Kingdom, Austria, Cyprus, Denmark) proceed to the immobilisation
(forbidding further operation) of a very significant share of the inspected
vehicles – approximately 50% - while immobilisation rates in other Member
States are much lower (for reference, 2.3% in Germany)[125]. On
this basis, it can be expected that expanding targeted checks to all 27 Member
States will have a positive impact on the effectiveness of RSI in taking off
the roads vehicles with defects (in particular serious defects, which lead to
immobilisation). As a result, it will have a positive impact on overall road
safety, which it was however not possible to estimate in quantitative terms. The establishment of a data exchange
system, which is introduced by PO 2a, will allow better enforcement of
roadworthiness test results by the authorities. For instance, registration
authorities will be able to proceed to de-registration of vehicles which have
not passed their PTI in the foreseen time. Similarly, police forces and
roadside inspectors will have easier access to roadworthiness related data
which are needed to detect and fine non-compliant drivers. Finally, the
availability of data from the Certificate of Conformity and the PTI will
enhance the functioning of the re-registration process for vehicles originating
from another Member State. It was not possible to quantify these impacts, but
it is reasonable to expect that they will be positive and significant. 5.2.2.2. Environment More frequent testing of vehicles will
allow higher detection level of big polluters. This will allow to decrease the
overall yearly CO2 and NOx equivalent[126] emissions of road vehicles in the EU by 0.1%. In absolute terms,
this corresponds to approximately 900,000 tons of CO2 and 300
tons of NOx equivalent per year, translating into monetary savings
of respectively € 27.9 million and € 1.4 million. [127] The testing of emissions using on-board
diagnostics (OBD) will ease the process and therefore reduce the costs of
testing for PTI centres and for the drivers, but available evidence does not
suggest that it will increase the rate of detection of defects. 5.2.2.3. Employment The higher frequency of PTI introduced by
PO 2a will translate into some 6.3 million additional test per year (2.5
million test for passenger cars, 2 million test of light trailers and 1.8
million tests of motorcycles). Around 1,450 additional PTI inspectors would be
needed to fulfil these requirements.[128] 5.2.2.4. Statistics and internal
market PO 2a introduces the requirement for
PTI centres to report the odometer readings of tested vehicles. These readings
will be collected at Member State level according to common EU standards. This
will allow their use for statistic purposes, notably to feed in policy
supporting models developed by the European Union and the Member States. The availability of odometer readings with
centralised access will also allow to combat more effectively the mileage
fraud, which is currently distorting the second hand car market. As already
mentioned, this problem is said to currently affect 5% and 12% of used car
sales (30% to 50% for cross-border transactions) having a yearly economic
effect of € 5.6 to 9.6 billion (EU 25) (Cf. section 2.3.2 above). It is difficult to estimate in quantitative
terms the potential of the centralised collection of odometer reading on the
quality of policy making and on the internal market for second-hand cars, but
it can be reasonably expected that the effects will be positive and
significant. 5.2.3. Summary The table below provides a summary of the
costs and benefits expected from PO 2a. Table 16: Estimated costs and benefits of PO 2a Estimated costs (annually) || Estimated benefit (annually) || reduced accidents/fatalities || additional jobs || avoided congestion || CO2 || Air pollutants € 459.5 million || 7,391/749 € 1,576 million || 1,450 || € 16.67 million || 0.97 million tons (€ 27.9 million) || 308.2 tons NOx equivalent (€ 1.4 million) || Estimated non-quantified benefits || – increase in the rate of detected defects thanks to better training of inspectors and supervision of PTI centres; – more "heavy offenders" detected at RSI thanks to targeted roadside inspections; - better enforcement of PTI results by the authorities thanks to data exchange; - better policy making and more reliable second-hand car market thanks to data exchange; - better functioning of re-registration process for vehicles originating from an other Member State due to the availability of data (CoC and PTI). 5.3. Assessment of Policy Option 2b (PO2b) 5.3.1. Costs Equipment PO 2b includes more advanced brake testing
in heavy duty vehicles with load simulation. The necessary technical
adaptations to the existing roller brake testers would cost € 8 000 per
unit.[129] Approximately 10,000 test stations[130] in
Europe would need to upgrade their equipment to stay in line with this
requirement. Around 54,500 stations[131] would
not yet be equiped with the enhanced equipment for testing the functionality of
electronic safety components during brake tests, worth € 2,000 the piece.
Overall, the investment in equipment required in PO 2b, additional to the one
already required by PO 2a, would amount to € 189 million. Depreciated over 5 years,
this would translate into an annual additional cost of € 37.8 million. PO 2b also introduces the obligation to
perform targeted checks with the so called "mobile inspection units".
The number of mobile units required to ensure a sufficient degree of targeted
checks (15% of all roadside inspections) across the EU has been estimated at
130.[132] Under these assumptions, the additional annual cost of this measure
would amount to € 2.08 million. Staff In comparison to PO 2a, PO 2b increases
the training requirements for PTI inspectors to at least 4 days a year. This
would translate – in addition to the investment needed to meet the training
requirements set under PO 2a – into an increase of labour costs by 10% in 54,500
stations.[133] These stations employ approximately 80,000 inspectors.[134] Based
on the Standard Cost Model, this would mean an aggregated additional yearly
cost of € 164.5 million. The mobile test units would need to be
operated by additional specialised staff. Assuming one inspector per unit this
would result in an additional cost of employment reaching € 4.1 million
per year.[135] PO 2b also introduces a mandatory threshold
of 10% commercial vehicles checked yearly at roadside inspections. This will
require some Member States to deploy additional inspectors on the roads. It
could be estimated that this would increase RSI costs for the EU as a whole by
approximately € 5.5 million.[136] Vehicle
classes to be inspected PO 2b
extends the PTI obligation to mopeds. The cost of the tests are similar to the
ones for motorcycles (average cost of € 20 per vehicle). In some Member
States the test for mopeds is already mandatory. The introduction of the tests
in countries where it's not mandatory yet, [137] and the
increase of the frequency in those countries where the frequency is lower than
3-1-1 will result in an additional 6.17 million tests, translating into
additional costs of € 123.5 million. Testing frequency PO 2b increases the frequency of the
testing for older cars (at least six year old) to every year instead of every
second year. This means that the minimum number of PTI in a statistical life of
a car moves from 8 inspections per vehicle under PO 2a to 14 inspections under PO
2b. Based on the information provided in table 11, such an increase in the
frequency will require an additional 50.4 million car tests per year compared
to the situation under PO 2a. At an average inspection price of € 50, this
translates into additional annual costs of approximately € 2,520 million. PO 2b also increases the frequency of
the testing for motorcycles to annual after the third year. This will result in
an additional 11.23 million tests, translating into an additional cost of
€ 224.6 million; 15% of all road side inspections would be
done using the mobile inspection units at an estimated cost of € 75[138] per
vehicle. Given that it would be required to test some 3.2 million vehicles,
this would result in overall cost of € 36 million per year at the scale of the
EU. Cost for vehicle owners, drivers
and operators The same considerations as for PO 2a apply. Summary of costs for PO 2b Table 17 below provides
a summary of the quantifiable costs arising from the measures foreseen in PO 2.
These costs include the costs of meeting the requirements set in PO 2a. The
overall cost estimate would be around € 3,350 million. Table 17: Estimated
costs of PO 2b Cost item || annual costs (in million €) 1 || Equipment || 39.2 + 37.8+2.08 = 79.08 2 || Staff || 94.7+ 164.5+4.1 = 263.3 3 || Vehicle classes to be inspected || 150 + 123.5 = 273.5 4 || Testing frequency || 125 + 2,520 + 36 = 2,681 5 || Supervision of testing centres || 42.6 6 || Data exchange || 8 Total cost estimate || 3,347.48 5.3.2. Benefits 5.3.2.1. Road safety Quantified benefits Like for PO 2a, the major impact of the
measures contained in PO 2b relates to increased road safety. Using the
methodology presented in annex 13, it is estimated that PO 2b will lead to a
yearly reduction of 36,562 in the number of accidents and allow avoiding 1,241
fatalities. In comparison to PO 2a, the measure with the greatest effect seems
to be more frequent testing of older vehicles, but also the inclusion of mopeds
will have an important positive impact. Finally, performance testing of
electronic safety systems is expected to have the potential to save an
important number of additional lives, but available evidence is not sufficient
to quantify this impact. The monetised social benefit arising from the
reduction in accidents, saving of lives and avoided injuries can be estimated
at € 4,928 million. The reduction in congestion resulting from the reduced
number of accidents translates into an additional saving of € 119.3
million. Non-quantified benefits The same non-quantified benefits as in
PO 2a can be expected. In addition, PO 2b extends the RSI to
other categories of vehicles than commercial vehicles and sets a minimum target
of 10% commercial vehicles undergoing RSI in any given year. It was not
possible to quantify the impact of these measures in terms of road safety. It
can nevertheless be expected that such expansion of roadside testing will allow
a greater detection rate of defects and therefore increase road safety. Moreover, in comparison to PO 2a, PO 2b
introduces higher training requirements for the inspectors involved in roadworthiness
testing. While it is not possible to quantify the exact impact it will have in
terms of an increased rate of detection of defects during tests, it is
reasonable to expect that this impact will be positive and significant. 5.3.2.2. Environment It was estimated that the measures
contained in PO 2b would allow to decrease the overall yearly CO2
and NOx equivalent emissions of road vehicles in the EU by 2%. In
absolute terms, this corresponds to approximately 18,165 million tons CO2
and 6,979.5 tons of NOx equivalent per year. These can be translated
into monetary savings of respectively € 545 million and € 30.7 million.[139] 5.3.2.3. Employment The higher frequency and the increased
scope of PTI introduced by PO 2b will translate into some 61.7 million additional
passenger car tests, and 6.4 million moped tests in addition to what would be
performed under PO 2a. Around 12,000 additional PTI inspectors would be needed
to fulfil these requirements.[140] 5.3.3. Summary The table below provides a summary of the
costs and benefits expected from PO 2b. Table 18: Estimated costs and benefits of PO 2b Estimated costs (annually) || Estimated benefit (annually) || reduced accidents/fatalities || additional jobs || avoided congestion || CO2 || Air pollutants € 3,347.48 million || 36,562 / 1,241 (€ 4,928 million) || 12,000 || € 119.3 million || 18.2 million tons (€ 545 million) || 6,979 tons NOx equivalent (€ 30.7 million) || Non-quantified benefits (additional to PO 2a): || Increased road safety resulting from the extended RSI (mandatory target for commercial vehicles and inclusion of other vehicle types) Higher increase in the rate of detected defects thanks to better training of inspectors 5.4. Assessment of Policy Option 2c (PO 2c) 5.4.1. Costs 5.4.1.1. Equipment PO 2c introduces the emission screening
of vehicles at RSI (measurement of emission components of vehicles passing by
without the necessity of stopping them) which requires the remote sensing
technology. This technology is comparable to speed controls with speed-cameras.
To screen the emission behaviour of 15% of the whole EU vehicle fleet 74 remote
sensing units would be needed (nearly all Member States would need to upgrade
their emission testing systems). Each remote sensing unit would cost € 0.2
million and could perform emission tests for 1,000 vehicles per hour.[141] This would create costs of about € 2.6 million a year, applying a 5
year period of depreciation for the investments. Staff The remote sensing units would need to
be operated by additional specialised staff. Assuming three inspectors per unit
and provided an annual average cost of € 55,000 per specialist this would
result in an additional cost of employment reaching € 1.2 million per
year.[142] PO 2c also introduces a mandatory threshold
of 15% of commercial vehicles being checked yearly at roadside inspections.
This will require all Member States to deploy additional inspectors on the
roads. It was estimated that establishing a 15% threshold for RSI of commercial
vehicles would increase costs for the EU as a whole by approximately € 8.8
million in comparison to PO 2b. Vehicles
to be inspected Also 15%
of vehicles will be subject to an emission screening. This would result in some
71 million emission measurements. The operational costs is about € 0.1 per
tested vehicle,[143] meaning that the overall yearly operational costs of the remote
emission testing would amount to € 7.1 million. Testing frequency PO 2c increases the frequency of the
testing for passenger cars, vans, light trailers and powered two wheelers to
annual from the first year. It also increases the frequency of testing heavy
vehicles to twice a year instead of once a year. This means an additional 38.4 million
PTIs for passenger cars, with costs of about € 1,920 million; an
additional 7.6 million tests of motorcycles with costs of € 151.3
million; an additional 7.4 million tests for mopeds with associated costs of
about € 147.8 million; an additional 2.25 million tests of light
trailers with associated costs of about € 78.8 million; and 47.5
million additonal tests for heavy vehicles with associated costs of € 3,562.5
million[144]. In total, the cost of higher frequency of testing in PO 2c in
comparison to PO 2b would amount to approximately € 5,860.4 million. Cost for vehicle owners, drivers
and operators The same considerations as for PO 2a and
2b apply. Summary of costs for PO 2c Table 19 below provides a summary of the
quantifiable costs arising from the measures foreseen in PO 2c. These costs
include the costs of meeting the requirements set in PO 2a and 2b. The overall
cost estimate would be around € 9,227 million. Table 19: Estimated costs of PO 2c Cost item || annual costs (in million €) 1 || Equipment || 79.08+2.6=81.68 2 || Staff || 263.3+1.2+8.8=273.3 3 || Vehicle classes to be inspected || 273.5+7.1=280.6 4 || Testing frequency || 2,681+5,860=8,541 5 || Supervision of testing centres || 42.6 6 || Data exchange || 11.2 Total cost estimate || 9,227.18 5.4.2. Benefits 5.4.2.1. Road safety Quantified
benefits Like for PO 2a and 2b, the major impact of
the measures contained in PO 2c relates to increased road safety. Using the
methodology presented in annex 13, it is estimated that PO 2c will lead to a
yearly reduction of 60,162 in the number of accidents (23,600 less compared to PO
2b) and allow avoiding 1,441 fatalities (200 more than PO 2b). The monetised
social benefit arising from the reduction in accidents, saving of lives and
avoided injuries can be estimated at € 6,175 million. The reduction in
congestion resulting from the reduced number of accidents translates into an
additional saving of € 199 million. Non-quantified benefits The same non-quantified benefits as in PO
2b can be expected. 5.4.2.2. Environment Following the methodology indicated in
annex 13, it was estimated that the measures contained in PO 2b would allow to
decrease the overall yearly CO2 and NOx equivalent
emissions of road vehicles in the EU by 2.2%. In absolute terms, this
corresponds to approximately 19.9 million tons CO2 and 12,224 tons
of NOx equivalent per year. These can be translated into monetary
savings of respectively € 599 million and € 53.8 million.[145] 5.4.2.3. Employment The higher frequency of
PTI introduced by PO 2c will translate into some 47.5 million heavy duty
vehicle tests, 38.4 million passenger car tests, 7.6 million tests of
motorcycles, 7.4 million tests for mopeds and 2.25 million tests of light
trailers in addition to what would be performed under PO 2b. Around 34,260 additional
PTI inspectors would be needed to fulfil these requirements.[146] 5.4.3. Summary The table below provides a summary of the
costs and benefits expected from PO 2c. Table 20: Estimated costs and quantified benefits
of PO 2c Estimated costs (annually) || Estimated benefit (annually) || reduced accidents/fatalities || additional jobs || avoided congestion || CO2 || Air pollutants € 9,227.18 million || 60,162/1,441 (€ 6,175 million) || 34,260 || € 199 million || 19.9 million tons (€ 599 million) || 12,224 tons NOx equivalent (€ 53.8 million) || Estimated non quantified benefit || Same as in PO2b 5.5. Assessment of Policy Option 3 (PO3) PO 1 provides some
benefits in terms of road safety and environment protection at a relatively low
cost. It seems that it allows the collection of "low hanging fruits"
while PO2 contain much more costly, but also much more effective measures. It
seems reasonable to combine the two approaches to achieve high results without
foregoing the easiest gains. Table 21 provides the estimated costs and benefits of the PO 3 a to c. Table 21:Estimated
costs and quantified benefits of Policy Option3 Policy option || Estimated costs (annually) || Estimated benefit (annually) || || reduced accidents/fatalities || additional jobs || avoided congestion || CO2 || Air pollutants PO 3a || € 459 million || 9,276/790 € 1,759 million || 1,450 || € 26.07 million || 0.97 million tons (€ 27.9 million) || 308.2 tons NOx equivalent (€ 1.4 million) PO 3b || € 3,347 million || 38,447/1,282 € 5,122 million || 12,000 || € 192.5 million || 18.2 million tons (€ 545 million) || 6,979 tons NOx equivalent (€ 30.7 million) PO 3c || € 9,227 million || 62,047/1,482 € 6,359 million || 34,260 || € 208.4 million || 19.9 million tons (€ 599 million) || 12,224 tons NOx equivalent (€ 53.8 million) 5.6. Considerations on
administrative costs The establishment of a system for data
exchange (PO 2a-c and 3a-c) will help reduce the administrative costs of
complying with the PTI requirement for vehicle owners and also reduce the administrative
procedures for authorities and PTI test stations. This will be achieved through
a replacement of manual procedures with electronic data input and exchange. The
related benefits are difficult to estimate in a reliable way, since cost
savings are very different in each Member State, depending on their current PTI
system. The effect of the policy options on the
administrative costs has been estimated in terms of time needed to complete the
PTI cerficate after the test. That time concerns both the vehicle owner and the
person in charge of the PTI. The data exchange platform could speed up the PTI
certification process in the following manner: up to 7 minutes saved for the
PTI on trucks and up to 5 minutes saved for the PTI on passenger cars.[147] Since these reductions
are limited and variable from a Member State to another, they were not included
in the evaluation of the benefits. 5.7. Impact on SMEs from the PTI sector Periodic technical
inspections are, in many Member States (among which such big Member States as
the UK and Italy), performed by independent garages. It is therefore important
to identify if the proposed policy options do not impose excessive burden on
SMEs. PO 1 will not have a
quantifiable impact on the garages, either in terms of costs or benefits. The
additional costs for SMEs under PO 2 will mainly relate to the cost of
additional equipment, cost of staff training and hiring additional staff. On
the benefit side, PO 2 will increase the number of PTI performed in Europe,
therefore creating additional business opportunities for PTI centres. The table
below provides an overview of these costs and benefits at EU level. While this
approach does not take account of the regional differences, it has the merit of
allowing a full cost-benefit analysis. It shows that all sub-options of PO 2
have a positive benefit/cost ratio. The costs and benefits presented below are roughly
the same for PO 3. Table 22: Costs and benefits for SMEs in the PTI
sector Policy option || Costs (€ million) || Benefits (€ million) || Benefits/costs (€ million) PO 2a/PO 3a || Equipment: 39.2 Training: 73.1 Employment: 51.4 Total: 163.7 || Additional tests: 275 || 1.68 PO 2b/PO 3b || PO 2a + Equipment: 37.8 Training: 164.5 Employment: 425.5 Total: 791.5 || Additional tests: 2,643.5 || 3.34 PO 2c/PO 3c || PO 2b + Employment: 1,214.8 Total: 2,006.3 || Additional tests: 5,860.4 || 2.92 5.8. Impact on vehicle owners
and operators The requirement to undergo roadworthiness
testing, can be seen as generating compliance costs (related to the necessity
to return to base to undergo the PTI) for the commercial vehicle
owners/operators, many of which belong to the category of small/micro
businesses. These costs must however be estimated in light of Figure 4 in Annex
12, which shows that commercial vehicles under normal circumstances anyway need
to undergo regular service and maintenance at least 4-5 times a year. The
annual PTI can easily be combined in time with one of these checks. The cost of
a PTI being negligible (on average 100 euro/year for a heavy commercial
vehicle) in comparison with other operating costs, and neither of the policy
options considering the increase of testing frequency to below 6 months, no
considerable impacts in terms of increasing the compliance costs are to be
expected from the proposed measures. Another issue is the burden of PTI for SMEs
using low-mileage vehicles, which need to undergo regular tests like any other
commercial vehicles. The lack of reliable tools for monitoring the mileage of
these vehicles is however an obstacle for designing special rules for them.
Section 2.3 explains the wide spread problem of fraud on the odometer, and
another recent IA study[148] showed the possibility of fraud on the tachograph (which in any
case is not fitted in all vehicles). Therefore any special measures for
low-mileage vehicles would require retrofitting all/parts of the fleet with
reliable mileage-monitoring tools, which would probably be prohibitively
costly. Moreover, the technical condition of the
vehicles deteriorates not only with mileage, but also with age. Therefore, the
frequency of PTI for low-mileage commercial vehicles could be reduced only to
the level applied to non-commercial vehicles of the same category (eg. Taxies
with low mileage could be tested with the same frequency as private cars). To sum up, while the
compliance costs for low mileage commercial vehicles can be seen as
administrative burden in a limited number of situations, it is overall a minor
issue, and addressing it with currently available technology would be
prohibitively costly. 5.9. Impact on citizens Increasing the
frequency and scope of PTI will impose additional costs on vehicle owners. With
over 300 million vehicles on the roads in Europe, the average additional annual
burden per vehicle owner will be close to € 1 under PO 2a, close to € 9 under
PO 2b and close to € 19 under PO 2c. The same estimates are valid for PO3 a-c.[149] These figures include the time cost per capita of the time spent
for an additional PTI which is equal, on average, to € 2.75.[150] However, the same
vehicle owners will also be among the main beneficiaries of the increased road
safety and reduced congestion, but also reduced noise thanks to removing
vehicles with technical defects from circulation, which will compensate the
additional cost of testing. This will be also the case under PO1, which does
not incur additional costs for vehicle owners. All these benefits will even
more apply to the most vulnerable road users – the pedestrians and cyclists. 5.10. Impact on public
administrations Under PO 1, the EU
would cover the – limited – costs of additional peer reviews and screenings and
of the information campaign. Together they would amount to ca. € 279,000. Under
PO 2, the additional yearly costs for public administrations would be linked to
more frequent and sophisticated RSI, the supervision of garages and the set-up
of the vehicle exchange data. Under PO 2a, these costs would arise to € 72.2
million, under PO 2b – to € 112.3 million, and under PO 2c – to € 129.4
million. Under each of the PO 2a-c, the yearly cost for EU – linked to the data
exchange system – would be 1 million; the rest would be costs for the Member
States. Under PO 3, additional
yearly costs for public authorities will be the sum of the costs they would
incur under PO 1 and PO 2. The direct benefits to
both national and EU authorities would relate to the availability of more reliable
statistical data. 5.11. Impact on competition in
the internal market Changes to the PTI and roadside inspection
system could potentially affect the competition on the international road
haulage market by reducing the possibility of gain competitive advantage
through non-complying with roadworthiness rules. However, the international
haulage is an extremely competitive market, with notably high pressure on
delivery times. In order to meet the expectations of the customers, hauliers
typically invest in most modern fleets and their regular maintenance to reduce
break downs and other delays. In this respect, the technical condition of the
vehicles is typically not – in the reality of this market segment –an element
of competition between the market players. The impact of the different policy
options on the competitive situation on the internal market would be therefore
negligible. 6. Comparison of options All the policy options have been designed
in such a way that they can meet, on a stand-alone basis, the specific
objectives as set in section 3.2. However, they differ in their effectiveness
in reaching these objectives: PO 1, which relies exclusively on soft
law, is expected to have an impact on the scope and level of
requirements for roadworthiness testing and roadside controls across the
European Union (specific objective 1), but this impact is impossible to
estimate and probably limited. In what concerns the second specific objective,
relating to the seamless flow of data, PO 1 addresses only one element
of the identified problem driver (see section 2.3.2), i.e. the availability of
data for testing electronic safety components. It does so by setting the
framework for voluntary action by manufacturers. PO 2, which relies on legislation,
addresses the two specific objectives in a more complete manner. All three
sub-options expand the minimum scope and increase the minimum requirements for
PTI and RSI in Europe. In this respect, PO 2a introduces relatively less
stringent changes, while those brought up by PO 2c are the most stringent. As a
consequence, PO 2c can be seen as meeting in the most effective way the first
specific objective. In terms of data exchange, all three
sub-options of PO 2 propose the same solution, i.e. setting up a system for the
exchange of data between all the stakeholders. Therefore they are equally
effective in meeting the second specific objective. The table below provides a
classification of the policy options according to their effectiveness in
reaching the specific objectives. The effectiveness of PO 3 in meeting the
objectives is similar but slightly higher than for PO2. Table 23: Compared effectiveness of PO in meeting
the objectives (1 – most effective, 4 – less effective) || PO1 || PO2a/3a || PO2b/3b || PO2c/3c Specific obj. 1:"increase scope and level of PTI and RSI" || 4 || 3 || 2 || 1 Specific obj. 2:"ensure seamless flow of information" || 2 || 1 || 1 || 1 In section 5
"Analysis of impacts", it was possible to quantify and monetize most
costs and a major part of benefits of the four policy options against the
baseline. However, some important benefits could not be monetized (impacts on
employment) while others could be evaluated only in qualitative terms. The
policy options can be therefore compared on the basis of a partial cost-benefit
analysis, where net quantified benefits are confronted with the qualitative
assessment of the other benefits. The results of this comparison are provided
in table 22 below. Table 24: Comparison of policy options (partial cost-benefit analysis) Policy option || Cost (€ million) || Monetized benefit (€ million) || Monetized benefit/cost ratio || Other benefits PO1 || 0.28 || 184 || 656:1 || Increased average scope and level of PTI and RSI resulting from additional peer reviews and screenings and from the exploration of optimal levels of investment in PTI and roadside testing. PO2a || 459.5 || 1,622 || 3.53:1 || - 1,450 additional jobs created; - increase in the rate of detected defects thanks to better training of inspectors and supervision of PTI centres; - more "heavy offenders" detected at RSI thanks to targeted roadside inspections; - better enforcement of PTI results by the authorities thanks to data exchange; - better policy making and more reliable second-hand car market thanks to data exchange. PO2b || 3,347 || 5,623 || 1.68:1 || Benefits of PO 2a plus: - 12,000 additional jobs created - increased detection of defects at RSI due to increased scope (target numbers and all vehicle categories checked); - higher increase in the rate of detected defects thanks to better training of inspectors. PO2c || 9,227 || 7,027 || 0.76:1 || Benefits of PO 2b plus: - 34,260 additional jobs created. PO3a || 460 || 1,806 || 3.93:1 || Benefits of PO 1 plus benefits of PO 2a PO3b || 3,347 || 5,807 || 1.73:1 || Benefits of PO 1 plus benefits of PO 2b PO3c || 9,227 || 7,211 || 0.78:1 || Benefits of PO 1 plus benefits of PO 2c From the
analysis in table 22, it appears clearly that PO 1 has by far the best
cost-benefit ratio, with an estimated € 656 benefit per each invested Euro.
This result is based on assumptions carrying an important degree of uncertainty
(see section 5.2 for the details), but the extremely high benefit-cost ratio
makes this option a clearly interesting solution. The weak point
of PO 1 is that its effects are limited, with a mere 41 avoided fatalities.
This raises the question of the coherence of this policy option with the EU
goal on road safety as stated in the 2011 White Paper on Transport, i.e.
"By 2050, move close to zero fatalities in road transport. In line with
this goal, the EU aims at halving road casualties by 2020".[151] The second element of this goal was made the general objective of
the Policy Orientations on road safety 2011-2020[152],
which described concrete actions needed to reach it. PO 1 does not
include any of these concrete actions, and generally contributes to a limited
extent only to the road safety goals. On the contrary,
PO 2, in its three versions, has been inspired by the concrete actions proposed
in the Policy Orientations on road safety, and has been designed in a way to
allow considerable improvements in road safety, estimated at 749 lifes saved
under PO 2a, 1,241 under PO 2b and 1,441 under PO 2c. However, the measures
foreseen under POs 2a-c are also very costly. As a result, the PO 2a has a
cost-benefit ratio of 3.53:1, PO 2b – of 1.68:1, while the monetized benefits
of PO2c are lower than the required investments. Finally, PO 3a
allows saving 790 lifes with a benefit-cost ratio of 3.93; PO 3b allows saving
1,282 lifes with a benefit-cost ratio of 1.73; and PO 3c allows saving 1,482
lifes with a benefit-cost ratio of 0.78 which means that its monetized benefits
are below the required investments. Preferred
policy option The above
analysis indicates that PO 1 allows reaching the "low hanging fruit",
i.e. achieving a limited increase in road safety and environment protection at
a very low price. It is however far from exploiting the full potential of the
roadworthiness system in contributing to increasing road safety, which is
estimated in different studies at 900-1,100 avoided fatalities per year (see
section 2.2). The tools contained in PO 2a are far more effective, since they
allow avoiding 749 fatalities yearly. PO 2b – after taking into account the
possible margin of error in the estimation of impacts – probably allows
unleashing the full potential of roadworthiness systems in avoiding accidents,
injuries and fatalities. PO 2c goes beyond what can be considered as the
"normal" potential with 1,441 avoided fatalities, which explains its
prohibitive cost. In the light of
the above considerations and of the EU's overarching goals in terms of road
safety, the following conclusions can be made: ·
PO 1 is very cost-efficient, but does not
sufficiently contribute to the EU goals on road safety and environment; ·
PO 2a is relatively cost-efficient and allows
considerable increases in road safety and environment protection, but below
what is commonly estimated as the "conventional" potential; ·
PO 2b allows exploiting the
"conventional" full potential of roadworthiness testing in increasing
road safety and environment protection, and still has a positive cost-benefit
ratio; ·
PO 2c allows achieving slightly better results
than PO 2b, but at a much higher cost (benefit to cost ratio below 1). ·
PO 3 in all its versions combines the advantage
of the cost-efficiency of PO1 with the effectiveness of PO 2. The above
analysis indicates that options 3a-c each allows to reach a decent level of
achievement of the general objectives, and in particular the objective of
contributing to halving the number of road fatalities in Europe in the upcoming
10 years. Policy option 3b offers the highest reduction in fatalities under
a positive cost-benefit ratio, and is thus seen as the preferred option. It
must however be stated that, depending on the relative preference for road
safety on the one hand, and cost minimisation on the other, options 3a and 3c
constitute viable alternatives. Table 25 below
provides the results of the sensitivity analysis, under which alternative
assumptions concerning the percentage of accidents which are due to defects,
the detection rate of defects at PTI and the costs of congestions have been
explored. Calculations have been made for the following values, which were
estimated as corresponding to extreme assumptions: Table 25: Extreme and average values used in the
framework of the sensitivity analysis || Value corresponding to the highest benefits || Average value (used in main calculations)* || Value corresponding to the lowest benefits % of accidents due to defects || 10% || 6% || 2% Detection rate of defects at PTI || 80% || 60% || 40% Cost of congestion [€] || 15000 || 5000 || 5000 Table
26 provides the comparison of the results in terms of benefits and cost/benefit
ratio under the different assumptions. One can observe that under most extreme
circumstances option 3b has a slightly negative cost/benefit ratio (when the
lowest benefits of policies are assumed); similarly, when the highest
responsiveness to policies is assumed, the cost/benefit ratio for option 3c
becomes slightly positive. Overall however the sensitivity analysis indicates
that the results of the analysis are relatively robust. Table 26: Results of the sensitivity
analysis for PO3 || Option 3a || Option 3b || Option 3c Costs million € || 460 || 3,347 || 9,227 max benefit || mil € || 1,930.9 || 8,285.7 || 9,818.8 Cost/benefit || 4.20:1 || 2.48:1 || 1.06:1 normal benefit || mil € || 1,806 || 5,807 || 7,211 Cost/benefit || 3.93:1 || 1.73:1 || 0.78:1 low benefit || mil € || 1,451.2 || 3,079.5 || 3,785.1 Cost/benefit || 3.16:1 || 0.92:1 || 0.41:1 7. Monitoring
and evaluation Within five years after
the entry into force of all elements of the new legislation (including
the set-up of the data exchange system), the Commission will report to the
Council and the Parliament on the effectiveness of the measures in reaching the
objectives. In particular and in line with the operational objectives, the
Commission will commission a scientific study to estimate if the number and
proportion of accidents, injuries, fatalities and emissions attributed to
technical defects has decreased and to what extent. The Commission will use the results
extracted form the national risk rating system of road transport companies for
the monitoring of the compliance of commercial vehicles with the roadworthiness
requirements and its impact on the number and proportion of accidents related
to this category of vehicles. The Commission will use the potential
synergies stemming from the revision of the legislation on type approval for
motorcycles.[153] This new regulation on type-approval for powered two- and three
wheelers foresees requirements on anti-tampering measures. The enforcement of
these measures, as indicated in the accompanying IA report, will be subject to
roadworthiness testing (both PTI as well as RSI) and create together with the
elements related to market surveillance further input for monitoring. Further synergies will be used for
monitoring and evaluation in correlation with the recently started preparation
for a legislative initiative on re-registration[154]. As
one of the main problems at re-registration, the availability of data will be
solved via the Vehicle Administrative Platform, which will provide a deep
insight into the functionality of the intra EU information exchange and will allow
real time monitoring of the system. The Commission will also use the existing
reporting system for roadside technical inspections, as required by Article 6
of Directive 2000/30/EC on roadside technical inspections, to monitor that
Member States perform the required number of inspections of commercial
vehicles. These reports will also allow to monitor the changes in the frequency
of occurrence of defects resulting from the enhanced PTI system. Annex 1: Main acronyms and abbreviations CARE: Community database on road accidents CITA: Comité international de l'Inspection Technique
Automobile CoC: Certificate of Conformity CoD: Certificate of Distruction DfT: UK Department for Transport DG CLIMA : Direction General Action for
Climate of the European Commission DG ENTR : Direction General Industry and
Enterpreneurship of the European Commission DG INFSO : Direction General Information
Society and media of the European Commission DG MOVE : Direction General Mobility and
Transport of the European Commission DSA: Daily Subsistence Allowance EAP: Environmental Action Programme FAA: Fixed Additional Allowance ITV: Spanish Technical Vehicle Inspection KBA: Federal motor transport authority in
Germany OIB : Office for infrastructure and
logistics of the European Commission PTI: Periodic Technical Inspections PTW: Powered Two Wheelers RSI: Roadside inspections SG : Secretariat General of the European
Commission TAXUD : Direction General Taxation and
customs union of the European Commission TFEU: treaty on the functioning of the European
Union TWC: three way catalyst Annex 1a: Bibliography White Paper 2011 - Roadmap to a Single European Transport Area
- Towards a competitive and resource efficient transport system http://ec.europa.eu/transport/strategies/2011_white_paper_en.htm Communication from the Commission to the
European Parliament, the Council, the European Economic and Social Committee
and the Committee of the Regions, Towards a European road safety area: policy
orientations on road safety 2011-2020, COM(2010) 389 final http://ec.europa.eu/transport/road_safety/pdf/road_safety_citizen/road_safety_citizen_100924_en.pdf European Commission report on the
technical roadside inspection of the roadworthiness of commercial vehicles,
COM(2010) 754 final http://www.eur-Lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0754:FIN:EN:PDF Eurostat: http://epp.eurostat.ec.europa.eu/ http://ec.europa.eu/transport/publications/statistics/statistics_en.htm CITA, AUTOFORE report: (http://ec.europa.eu/transport/roadsafety_library/publications/autofore_executive_summary.pdf,) CITA, Idelsy report: http://ec.europa.eu/transport/road_safety/projects/doc/idelsy.pdf UK Department of Transport Study, 2008
‘MOT Scheme Evidence-base’ Department for Transport, UK, 2008 http://webarchive.nationalarchives.gov.uk/+/http://www.dft.gov.uk/pgr/roads/vehicles/mot/mot/ CARE Database, DG MOVE http://ec.europa.eu/transport/road_safety/specialist/statistics/care_reports_graphics/index_en.htm FEMA position on PTI http://www.fema-online.eu/uploads/documents/vehicle%20aspects/20100903_FEMA_Position_Statement_PTI.pdf Air Pollution from motor vehicles, A.
Faiz, C. Weaver, M. Walsh, 1996 http://www.walshcarlines.com/pdf/air_pollution_from_moto.a72.pdf Auto Oil Study, 2000, http://www.ec.europa.eu/environment/archives/autooil/pdf/auto-oil_en.pdf Denmark's State Audit report after
liberalisation of PTI http://www.rigsrevisionen.dk/media(1073,1033)/11-2008.pdf Study of the economical impact of
mileage fraud, CRM used car management (in Proceedings of Cars 2010 conference,
Brussels, 18 November 2010 www.cars2010.eu DG Clima, European second hand car
market analysis, February 2011 http://ec.europa.eu/clima/studies/transport/vehicles/docs/2010_2nd_hand_car_en.pdf Campaigns and Awareness-Raising
Strategies in Traffic Safety (CAST) (2009) “A theoretical approach to assess
road safety campaigns: Evidence from seven European countries” Project
co-financed by DG Energy and Transport www.ec.europa.eu/transport/road_safety/pdf/projects/cast.pdf CITA General Questionnaire, 2009 www.cita-vehicleinspection.org Handbook on estimation of external costs
in the transport sector (2008) http://ec.europa.eu/transport/sustainable/doc/2008_costs_handbook.pdf EGEA (European Garage Equipment
Manufacturers) http://www.egea-association.eu/publications.php?PHPSESSID=4fa9b2be38a42f478136d6dd9973078d ACEM http://www.acem.eu/cms/marketfigures.php Annex 2: Procedural Issues Procedural step || Date IASG[155] meeting || 02.07.2010 IASG meeting || 26.07.2010 Internet Consultation || 29.07.2010-24.09.2010 IASG meeting || 24.08.2010 Experts' meeting || 31.08.2010 Stakeholders' meeting || 08.09.2010 IASG meeting || 29.10.2010 IASG meeting || 15.11.2010 IASG Meeting || 03.02.2011 IASG Meeting || 23.02.2011 IASG Meeting || 27.04.2011 Last consultation of the IASG by e-mail || 31.05.2011 Annex 3: List of participants and summary of the
findings of the expert meeting & the stakeholder meeting Expert meeting – list of organisations,
Brussels, 31 August 2010 ACEA (European Automobile Manufacturers'
Association) ACEM (The Motorcycle Industry in Europe) Belgium Ministry Transport Centiq CITA (International Motor Vehicle
Inspection Committee) CLEPA (European Association of Automotive
Suppliers) DEKRA Estonian Road Administration ETRMA (European Type & Rubber
Manufacturers Association) FEMA (The Federation of European
Motorcyclists' Associations) FIA European Bureau Fresenius University FSD (on behalf of BMVBS) GOCA (Belgium) ITS (Poland) Ministry of Transport RDW (Netherlands) Road Traffic Safety Directorate SNCT Luxembourg TDT (Transportation Technical Supervision Poland) Trafi (Finnish Transport Safety Agency) Transport Malta Stakeholders meeting – list of
Organizations, Brussels, 8 September 2010 ACEA (European Automobile Manufacturers'
Association) ACEM (The Motorcycle Industry in Europe) CITA (International Motor Vehicle
Inspection Committee) CSDD (Latvia Road Traffic Safety
Department) Danish Transport Authority DEKRA ECG (Association of European Vehicle
Logistics) EGEA (European Garage Equipment
Association) EGEA ASA (Germany) Estonian Road Administration ETRMA (European Type & Rubber
Manufacturers Association) FEMA (The Federation of European
Motorcyclists' Associations) FIA EB FSD / German BMVBS IRU (International Road Transport Union) Ministère des transports (France) RDW (Netherlands) SNCT (La Société Nationale de Contrôle Technique) TDT (Transportation Technical Supervision
Poland) TÜV SÜD VdTÜV Summary of the findings The most
important issues identified by the participants of the expert meeting
(participants' list see annex 2) were the lack of mutual acceptance of PTI
results between EU Member States, the difficulties encountered with regard to
quality of vehicle testing and that in some Member States it is observed that
vehicles are moved towards testing sites where the testing quality is lower. Experts agreed
that there is a lack of information on vehicles, which would be needed for a
proper inspection. Participants stated that the inspections could be improved,
if information about the history of the vehicle would be available for the PTI
test stations. Missing data on the vehicle would include in particular
information on past PTI results, past accident occurrences and rehabilitation
procedures, plus any modifications made to the vehicle. Participants proposed a
harmonisation of PTI standards across the EU at least at a medium standard. The stakeholder
meeting was attended by various organisations, among others ACEA for the
car manufacturers, ACEM representing the motorcycle industry, CITA for
organisations in charge of vehicle inspections, CLEPA for the automotive
suppliers, FEMA representing the motorcyclists and IRU for the road transport
operators (for full list of participants see annex 2). At the
stakeholder meeting participants confirmed that the system of PTI in the EU is
highly fragmented in terms of the items to be checked[156],
vehicle categories, testing frequencies[157] and
quality control & supervision. Several participants informed the Commission
about the fact that important data, essential for the inspection of the
vehicles, is often not available at the test stations. The majority of participants were strongly
advocating to harmonise the different national PTI systems and to establish an
EU-wide common PTI system. The level of harmonisation requested by stakeholders
included, inter alia, higher testing standards, quality control and
availability of technical data. Furthermore, according to the ETB (European
Transport Board), 14% of commercial vehicles travel empty once a year to their
country of registration to undergo PTI. In addition, the stakeholder meeting
discussed the calculation models related to cost-benefit-analysis in the field
of PTI[158], which are used in this IA report for the analysis of impacts of
the different policy options. Finally, the Dutch Royal Service for Road
Safety (RDW), the organization in charge of PTI and roadside checks in the
Netherlands, explained the bilateral agreement with Belgium and their future
project in Spain. Annex 4: Result of the Internet consultation The internet consultation was launched on
29 July and lasted 8 weeks ending on 24 September 2010. It aimed at collecting
the opinion of the citizens about a possible modification of PTI system in
Europe. More than 9000 responses were received from citizens, Member State
authorities, equipment suppliers, testing centres, garages associations and
vehicle manufacturers. The results of the consultation are affected by a
campaign conducted by the motorcyclists who are in general against the
inclusion of Powered two wheels (PTWs) in the PTI system, according the
position of the representative association. After the launch of this campaign[159] (around
mid August 2010) the number of contributions raised from 400 to 9000. Moreover,
some motorcyclists' websites published misleading information with respect to
the internet consultation[160]. Therefore the strategy for analysing the
results of the consultation is as follows: presentation of the results before
the beginning of the motorcyclists' action and presentation of the overall
results of the consultation. The main results of the consultation after
3 weeks (roughly 400 answers on 17.08.2010) are: 43.6 % of respondents could see room for
positive changes in PTI (e.g. 44% were in favour of the inclusion of caravans,
37% of the inclusion of all trailers, 35% of the inclusion of passengers cars
in business use; 68% thought that a new technical inspection is necessary after
an accident and 52% after a modification of the vehicle), 57% thought that
roadside inspections should be extended to all vehicles. Moreover, 51% of the
respondents were in favour of data exchange on PTI between Member States.
Concerning the policy options proposed, 40% of the respondents chose the
"no action" option and 30% voted for option 4a (application of the
most rigorous system in the EU). This can be explained looking at the countries
of origin of the respondents: 94% were from UK where the PTI system is one of
the stricter in Europe. The main result after 8 weeks is the
following: more than three quarter of respondents did not see any aspects of
PTI which could be improved; 39 % of respondents think that all commercial
vehicles should be subject to roadside inspections; three quarters of
respondents were against a fully standardised PTI system in the EU. These
results need to be seen in the light of the fact that it triggered a campaign
of the Federation of European Motorcyclists' Associations (FEMA)[161], launched one month after the start of the consultation, which
resulted in about 5 000 responses supporting FEMA's position, which is against
the inclusion of powered two wheelers (PTW) into periodic inspections.[162] Concerning the exchange of PTI results
between Member States, 27 % of respondents felt that they should be available
to government authorities in the EU and 15 % felt that they should be available
to those carrying out tests, but almost half (48 %) were of the opinion that
inspection results should not be available to either those carrying out tests
or government authorities. Annex 5: Current legislative framework for PTI
and Roadside inspections PTI Directive 2009/40/EC (Periodic
inspections of vehicles) Directive 2009/40/EC was adopted in May 2009
as recast of Directive 96/96/EC. It Requires that vehicles registered in each
Member State shall be tested for roadworthiness after a certain period; defines
the categories of vehicles to be tested, how frequently the tests must then
take place and the items to be tested; requires that proof of having passed a
test be available; allows some exemptions[163]; Member States may bring forward the date for the first compulsory
roadworthiness test and, where appropriate, require the vehicle to be submitted
for testing prior to registration; shorten the interval between two successive
compulsory tests; make the testing of optional equipment compulsory; increase
the number of items to be tested; extend the periodic test requirement to other
categories of vehicles; prescribe special additional tests; require for
vehicles registered on their territory higher minimum standards for braking
efficiency than those specified in Annex II and include a test on vehicles with
heavier loads, provided such requirements do not exceed those of the vehicle’s
original type-approval. It allows the Commission to adopt further
Directives to lay down more specific rules regarding the minimum standards to
be used in tests. Requires that no later than three years after the
introduction of regular testing of speed limitation devices, the Commission
examine whether, on the basis of the experience gained, the tests laid down are
sufficient to detect defective or manipulated speed limitation devices or
whether the rules need to be amended. Directive 2010/48/EU (Periodic
inspections of vehicles) Directive 2010/48/EU seeks to achieve
further harmonization of road worthiness testing, requires that specified
testing methods should be introduced for each of the test items and includes
electronic systems among the items to be tested. Recommendation 2010/378/EU (Periodic
inspections of vehicles) The Recommendation provides a guideline on
standards and testing methods referred to in 2009/40/EC for inspectors
conducting vehicle tests in order to ensure a harmonized assessment of the
failures listed in Annex II of the Directive. Three categories of failure are
introduced (minor, major and dangerous defect), to reflect the seriousness of
the defect, with the consequences for the use of the vehicle in that condition
given. Roadside
checks Directive 2000/30/EC (Roadside checks) Directive 2000/30/EC was adopted in June
2000. It required all Member States to introduce technical roadside
inspections[164] designed to improve road safety and the environment by ensuring
that vehicles comply with certain technical conditions. These roadside inspections were required to
comprise at least a visual assessment of the maintenance condition of the
commercial vehicle (whilst stationary) or else a check on a recent document attesting
to the vehicle’s technical roadworthiness. The inspection may also include a
check for irregularities in one or more of the vehicle parts. Directive 2010/47/EU (Roadside checks) This new Directive updates Annex I of
Directive 2000/30/EC concerns the roadside checks reports. Recommendation 2010/379/EU (Roadside
checks) The Recommendation provides a guideline on
standards and testing methods for the assessment of deficiencies listed in
Annex II of Directive 2000/30/EC for inspectors conducting technical roadside
inspections in order to achieve a more harmonized roadside testing system and
to avoid unequal treatment at technical roadside inspections. Three categories
of failure are introduced (minor, major and dangerous defect). Interpretative communication on car
registration and its impact on PTI In order to encourage Member States to be
more flexible about the registration of cars coming from another Member State,
the European Commission has issued an interpretative communication on car
registration issues[165]. The communication highlights that Member
States can require a new PTI before the re registration of a vehicle coming
from abroad for those elements that are not covered by the previous PTI. The
communication specifies that duplication of control should be avoided. Annex 6: Failure rates in roadside tests,
2007-2008 Reporting Member State || Vehicles checked || % non-compliant vehicles^ Austria || 12,658 || 41.4 % Belgium || 18,732 || 13.3 % Bulgaria || 472,324 || 0.3 % Cyprus || 919 || 197.3 %^^ Czech Republic || 52,842 || Not available Germany || 2,679,907 || 2.3 % Denmark || 265 || 63.0 % Estonia || 2,236 || 19.2 % Finland || 9,267 || Not available France || 1,669,391 || 3.3 % Greece || 22,360 || 14.2 % Hungary || 351,690 || 6.5 % Ireland || 5,204 || Not available Italy || 13,577 || Not available Lithuania || Not available || Not available Luxembourg || 896 || 33.0 % Latvia || 9,294 || 0.5 % Malta || 3,579 || 55.2 % Netherlands || 4,147 || 2.8 % Poland || 1,254,706 || 0.6 % Portugal || 558 || 5.0 % Romania || 43,700 || 36.8 % Sweden || 165,263 || 20.0 % Slovenia || 3,179 || 3.8 % Slovakia || 4,631 || na United Kingdom || 165,927 || 48.9 % TOTAL || 6,967,252 || 4.2 % Source:
EC, Report on the technical roadside inspection of the roadworthiness of
commercial vehicles COM(2010)754 final ^ The
percentage of non compliant vehicles can be more than 100 % due to the counting
of vehicle combinations "road train" and "articulated
vehicles" as single vehicles where both vehicles or the combination or
only one of them could be counted as a non compliant one. ^^ The figure of 197.3 % in Cyprus is
probably based on a different method of counting. Annex 7: National PTI frequencies Member States State || Private cars || Goods vehicles < 3,500 kg || Goods vehicles > 3,500 kg || Passenger vehicles < 8 passengers || Passenger vehicles > 8 passengers || Trailers < 3,500 kg || Trailers > 3,500 kg || Agricultural tractors || Motorcycles Belgium || 4/1/1 || 6m/6m/6m || 6m/6m/6m || 6m/6m/6m || 3m/3m/3m || 1/1/1 || 6m/6m/6m || 6m/6m/6m || na Bulgaria || 3/2/1/1 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Czech Republic || 4/2/2 || 4/2/2 || 1/1/1 || 4/2/2 || 1/1/1 || 4/2/2 || 1/1/1 || 4/4/4 || 4/2/2 Denmark || 4/2/2 || 4/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 2/2/2 || 1/1/1 || na || na Germany || 3/2/2 || 2/2/2 || 1/1/1 || 1/1/1 || 1/1/1 || 3/2/2 (<750kg) 2/2/2 (>750kg) || 1/1/1 || 2/2/2 1/1/1 || 2/2/2 Estonia || 3/2/2/2/1 || 1/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 3/2/2/2/1 || 1/1/1 || 2/1/1/1 || 3/2/2/2/1 Ireland || 4/2/2 || 4/2/2 || 1/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || na || na || na Greece || 4/2/2 || 4/2/2 || 1/1/1 || na || 1/1/1 || na || na || na || na Spain || 4/2/2/1 || 2(x3)/1(x4)/6m || 1(x10)/6m || 2/1/1/1/6m || 1(x5)/6m || 2(x3)/1(x4)/6m || 1(x10)/6m || 1(x10)/6m || 5/2/2 France || 4/2/2 || 4/2/2 || 1/1/1 || 4/2/2 || - || - || - || - || - Italy || 4/2/2 || 4/2/2 || 1/1/1 || 4/2/2 || 1/1/1 || 1/1/1 || 1/1/1 || - || 4/2/2 Cyprus || 4/2/2 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Latvia || 2/2/2 || 1/1/1 || 6m/6m/6m || 6m/6m/6m || 1/1/1 || 1/1/1 || 1/1/1 || na || 1/1/1 Lithuania || 3/2/2 || - || 1/1/1 || - || 1/1/1 || 3/2/2 || 1/1/1 || - || - Luxembourg || 3.5/1/1 || 1/1/1 || 6m/6m/6m || 3.5/1/1 || 6m/6m/6m || 3.5/1/1 || 6m/6m/6m || 3.5/1/1 || 3.5/1/1 Hungary || 4/3/2/2 || 2/2/1/1 || 1/1/1 || 3/3/2/2 || 1/1/1 || 2/2/1/1 || 1/1/1 || 3/3/2/2 || 3/3/2/2 Malta || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Netherlands || 4/2/2/1 || 3/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || - || 1/1/1 || - || - Austria || 3/2/1 || 1/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 3/2/1 || 1/1/1 || 3/2/1 || 1/1/1 Poland || 3/2/1 || 3/2/1 || 1/1/1 || 1/1/1 || 1/1/1 || 3/2/1 || 1/1/1 || 3/2/2 || 3/2/1 Portugal || 4/2/2/1 || 2/1/1 || 1(x7)/6m || 1(x7)/6m || 1(x7)/6m || na || 1(x7)/6m || 1(x7)/6m || na Romania || 2/2/2 || - || 1/6m/6m || - || 1/1/1 || - || 1/1/1 || - || - Slovenia || 3/2/2 || 3/1/1 || 1/1/1 || 3/1/1 || 1/1/1 || 3/1/1 || 1/1/1 || 3/1/1 || 3/1/1 Slovakia || 3/1/1 || - || 1/1/1 || - || 1/1/1 || - || 1/1/1 || - || - Finland || 3/2/1 || 3/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 2/2/2 || 1/1/1 || na || na Sweden || 3/2/1 || 1/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || 4/2/2 || 1/1/1 || na || 4/2/2 United Kingdom || 3/1/1 || 3/1/1 || 1/1/1 || 1/1/1 || 1/1/1 || na || 1/1/1 || na || 3/1/1 Source: AUTOFORE Study on the Future
Options for Roadworthiness in the European Union: WP540 – Analysis of pass/fail
rates and accidents for different vehicle types in relation to PTI – frequency
and vehicle age; DEKRA Annex 8: Yearly Vehicle Kilometres Annex 9: Vehicle categories Category M: Motor vehicles with at least four wheels designed and constructed for the carriage of passengers. Category M1: Vehicles designed and constructed for the carriage of passengers and comprising no more than eight seats in addition to the driver's seat. Category M2: Vehicles designed and constructed for the carriage of passengers, comprising more than eight seats in addition to the driver's seat, and having a maximum mass not exceeding 5 tonnes. Category M3: Vehicles designed and constructed for the carriage of passengers, comprising more than eight seats in addition to the driver's seat, and having a maximum mass exceeding 5 tonnes. Category N: Motor vehicles with at least four wheels designed and constructed for the carriage of goods. Category N1: Vehicles designed and constructed for the carriage of goods and having a maximum mass not exceeding 3,5 tonnes. Category N2: Vehicles designed and constructed for the carriage of goods and having a maximum mass exceeding 3,5 tonnes but not exceeding 12 tonnes. Category N3: Vehicles designed and constructed for the carriage of goods and having a maximum mass exceeding 12 tonnes. Category O: Trailers (including semi-trailers). Category O1: Trailers with a maximum mass not exceeding 0,75 tonnes Category O2: Trailers with a maximum mass exceeding 0,75 tonnes but not exceeding 3,5 tonnes. Category O3: Trailers with a maximum mass exceeding 3,5 tonnes but not exceeding 10 tonnes. Category O4: Trailers with a maximum mass exceeding 10 tonnes. Category L : Category L1: Mopeds Category L2: 3 and 4 wheel light Motorcycles Category L3: Motorcycles Category L4: Motorcycles with sidecar Category L5: Motortricycles Category L6: Light quadricycles Category L7: Heavy quadricycles Annex 10: Changes in the PTI legislation since
1977 The first EU legislative act in this field
is Council Directive 77/143/EEC on the approximation of the laws of the Member
States relating to roadworthiness tests for motor vehicles and their trailers.
Since then, EU legislation has been amended several times to reflect the
increasing importance attributed to road safety, and also with a view to
incorporating technological developments. The scope of this legislation in
terms of vehicles to which it applies has also continually been broadened since
then. Originally it only applied to commercial vehicles of more than 3.5 tons,
taxis and ambulances, which were subject to testing once a year (1-1-1). As of
1988 the scope also includes light goods vehicles, with a test frequency 4-2-2,
and as of 1991 also passenger cars, with a test frequency 4-2-2. In terms of
technical content, the brake section was updated and the 'reasons for failure'
were added in 1992. Then the exhaust emission testing was included and the
brake performance and efficiency values were updated in line with type approval
requirements. Some additional amendments have been made from 1999 to 2010,
concerning emissions limits, the introduction of roadside inspections for
trucks and new testing items, such as airbags, ABS, EBS. The current
legislation on roadworthiness and on roadside testing is laid out in the
following Directives: Commission Directive 2000/30/EC (Roadside technical
checks) and Commission Directive 2009/40/EC (Roadworthiness directive);
Commission Directive 2010/47/EU (amending Directive 2000/30/EC) and Commission
Directive 2010/48/EU (amending Directive 2009/40/EC), Recommendation
2010/378/EU (Assessment of defects during roadworthiness testing), Recommendation
2010/379/EU (Risk assessment of deficiencies detected during technical roadside
inspections of commercial vehicles). Annex 11: Roadworthiness testing as a part of the
vehicle regulatory scheme Before a vehicle is allowed to be put on the
market, it has to fulfil all the relevant type or individual approval
requirements[166].
These are covered by more than 50 European legislative acts as well as more
than 110 UN/ECE regulations guarantying an optimal level of safety and
environmental standards. After passing the approval tests vehicle manufacturers
are obliged to issue for each single vehicle that is put on the market a
“Certificate of Conformity” (CoC), which contains its basic technical
characteristics[167].
Every Member State has the obligation to register for the first time any
vehicle that got the European type-approval on the basis of the CoC. The
registration is the official authorisation for the use on public roads and
enforces the different introduction dates of different vehicles' requirements. Following the approval, cars in use have to
undergo regularly PTI to check the compliance of the vehicles and its
fulfilment of retrofitting requirements. Tests include also whether the safety
and environmental performance is guaranteed. Commercial vehicles are
additionally covered by the regime of technical roadside inspections by which
their environmental and technical condition can be verified anytime and
anywhere inside the EU. During a vehicle's lifetime it may be
subject to re-registration, due to a change of ownership, or a transfer to
another Member State for permanent use[168].
When a vehicle is taken out of service and scrapped, a “Certificate of
Destruction” – confirming the proper dismantling of parts and de-pollution of
materials – has to be issued and registration authorities have to be informed
thereof.[169] Figure 1:
Roadworthiness testing as a part of the vehicle control regulatory scheme Source: DG MOVE Annex 12: Categories of vehicles which are
particularly subject to too low PTI frequencies according to the provisions of
Directive 2009/40/EC Passenger cars in business use Mileage travelled is an important factor
influencing the roadworthiness of vehicles. Inspection results show that the
average rate of defects in the vehicles increases in relation to the yearly
mileage, from about 14.8% of defects (including 4.4% of serious defects) up to
31.1% of defects (including 10.7% of serious defects) for the vehicles in the
highest mileage class.[170]
This is why taxis and ambulaces, which belong to the group of high mileage
travelling cars (above 40,000 km/year), are inspected once per year, while
other cars and vans are inspected every second year and only 4 years after
initial registration for the first time.[171] Passenger cars in business use (registered
by companies) often belong to the group of vehicles with high mileage. In fact,
the average mileage for such vehicles is over 68 thousand km/year, which is
even more than for taxis (58 thousand km/year). However, this fact is not
acknowledged in the legislation which does not set for passenger cars in
business use a higher testing frequency. Older vehicles Statistics on the failure rate of vehicles
at PTI have been analysed during the AUTOFORE study (see figure 2) showing that
the number of vehicles not passing the test is strongly correlated with the
vehicle's age. In line with the results of PTI, statistics
indicate that twice as many vehicles which are eight years or older are
involved in accidents attributable to technical defects than newer vehicles.
Even if the accident figures are compared on the basis of the distances
travelled, older vehicles are involved in accidents twice as often as newer
vehicles. Furthermore, older vehicles are responsible for fatal accidents
disproportionately more often than newer vehicles.[172] Despite this evidence,
Directive 2009/40/EC foresees the same, not increasing frequency of testing
(every two years) for all the vehicles after a certain age (4 years for
passenger cars, one year for commercial vehicles). Figure 3 presents in
schematic manner the impact of age on the rate of vehicle deterioration and the
benefits arising from more frequent testing of older vehicles. Figure 2 Failure rates at PTI as a
function of vehicle age Source: AUTOFORE Figure 3 Benefits of increasing PTI inspection frequency Source:
AUTOFORE Commercial vehicles As indicated in the AUTOFORE study, it
is well accepted that commercial vehicles deteriorate at higher rates than
passenger vehicles due to their higher weight. In addition, many heavy vehicles
travel between 50 and 200 thousand km/year, which is well above even the high
mileages observed for taxis and ambulances.[173]
The British Department of Transport provides guidance for the maintenance
inspection intervals for such heavy vehicles, based on the expected time to
failure (see figure 4 below). These intervals are similar to what is
recommended by vehicle manufacturers.[174]
While the recommended inspection frequency depends on the yearly mileage, it is
never lower than once every 13 weeks, and can be as high as once every 4 weeks.
Directive 2009/40/EC is far away from these standards, as it sets as minimum
requirement to test heavy commercial vehicles once a year. Figure 4
Typical routine maintenance inspection intervals from the British Guide to
Maintaining Roadworthiness Source:
AUTOFORE Annex 13: Assumptions and methodologies used for
calculating the benefits of policy options 2a-c The
methodology for estimating the benefits in terms of avoided accidents,
fatalities and injuries, as well in terms of reduced air pollution, is based on
two main sources: ·
The AUTOFORE Study, Working Paper 700, which
provides a methodology for calculating the impact of increasing the testing
frequency. ·
FITSA / Universidad Carlos III de Madrid / Applus
Idiada, November 2008, "Estudio para la Incoperación del Diagnóstico
Electrónico an las ITV". The
policy options presented in the impact assessment report contain each a number
of individual measures. Below it is explained what methodology has been used
for estimating the impacts of each type of measures. 1.
Estimating the benefits of increased testing
frequency In
the AUTOFORE Study, the following calculation formula has been elaborated by
the University of Cologne (Prof. Dr. Schulz): Number of avoided accidents = Acc * TD *
RED * RAT * DefVeh, Where: –
[Acc] is the number of accidents of vehicles in
a given year; –
[TD] is the percentage share of accidents caused
by technical defects (we assume 6% - see part. 0 of the main report for
explanation); –
[RED] is an empirical derived reduction ratio
for the percentage share of accidents (assumed to be equal to 0.6 in the
AUTOFORE study); –
[RAT] is the ratio for number of additional
inspections and number of inspections under the existing regime; –
[DefVeh] is the percentage share reflecting how
many of all defect cars belong to the period with annual inspections It
is important to mention that this methodology provides rather conservative
estimates. For example, a study by the UK Department for Transport (DfT) of
December 2008), "MOT Scheme Evidence-base"[175], estimated that moving back from the 3-1-1 frequency to 4-2-2 would
result in an increase in the number of fatalities of 408. The above described
model would estimate this same impact at a mere 48 additional fatalities. The
CARE database[176]
provides estimations of the number of fatalities, serious and slight injuries
per accident. The Handbook on estimation of external costs in the transport
sector[177]
provides estimated monetized costs of fatalities, serious and slight injuries: || Costs per unit in € Saved life || 1 500 000 Avoided serious injury || 195 000 Avoided slight injury || 15 000 These
two sources allow the translation of the number of avoided accidents in
monetary terms. The
following table provides, as an example, the calculation of the impact of
moving from the current testing frequency of 4-2-2 to 3-2-1 in France: Acc || TD || RED || RAT || DefVeh || Reduced Acc 74487 || 5,8% || 0.6 || 0,86667 || 1,000065 || 2286 This
number of avoided accidents then translates into the following number of
fatalities and injuries: Reduced Acc || Fatalities rate || Saved lives || Severe injuries rate || Avoided severe injuries || Slight injuries rate || Avoided slight injuries 2286 || 0.0296 || 68 || 0.4694 || 1073 || 0.7898 || 1806 Using
the estimations of the monetary value of fatalities and injuries, we can
estimate the monetised benefit of increasing the testing frequency of cars in
France at € 338.3 million. 2.
Estimating the benefits of testing the
electronic safety components (airbag and ESC) The
electronic safety components are crucial for reducing the severity of accidents
and their consequences. Their impact in terms of life saving is therefore
proportionately much higher than their potential to reduce the number of
accidents. For facility, we therefore decided to estimate only the impact in
terms of reduced number of fatalities – omitting the benefits related to the
lower number of accidents – while being conscious of the fact that it provides
saving estimations which are lower than in reality. ESC The
following equation was used to estimate the number of lives saved with the
testing of ESC during PTI: Number of fatalities avoided = POT * DEF
* RED, Where: –
[POT] is the overall life-saving potential of ESC
for the whole European fleet (estimated at 2 250 by the "Cost-benefit
assessment and prioritisation of vehicle safety technologies" study[178]; –
[DEF] is the defect rate of ESC. IDELSY
estimates this rate at 17%, taking into account all the defects of the ESC,
some of which can only be detected with advanced tools introduced by option 2b.[179] AUTOFORE only deals with the
defects which are stored in the control unit, which can be detected with simple
OBD testing introduced by option 2a, and comes with a lower figure of 7%; –
[RED] is the ratio of detection of inspected
defects during PTI. For ESC, it has been estimated at 80% by AUTOFORE. The
above methodology leads us to the estimates of the life-saving potential of ESC
inspections in options 2a and 2b: –
In 2a, it is: 2 250 * 0.07 * 0.8 = 126 lives –
In 2b, it is: 2 250 * 0.17 * 0.8 = 306 lives Airbags According
to the FITSA study, 0.5% of all fatalities could be avoided if airbags were
better inspected. With a total number of fatalities of 35 000 in the EU[180], 175 lives could be saved if
airbags were included in the PTI. As no more precise estimations are available,
we assume the same potential for the testing as introduced by options 2a and
2b. 3.
Estimating the benefits of better
implementation As
a main element of better implementation the raising of awareness by
communication campaigns has been identified. As a result of the meta-analysis
carried out in the CAST study[181]
a reduction of 9% of accidents levels may be achieved by such campaigns. Assuming
that the effect of campaigns will become effective in countries at lower
quality level of PTI the number of fatalities reported there is about 7,605.
With 6% of these fatalities linked to technical defects about 456 fatalities
have to be considered. The potential of a reduction by 9% results in the range
of saving of 41 lives. This would lead to a reduction by 1,885 accidents ending
up in 41 lives saved and 6,930 serious and 38,498 slight injuries avoided. Emissions: CO2 saving; reduction of
toxic local emissions To
derive the quantities of NOx-, HC- and CO-emissions, we use emission
factors provided in the AUTOFORE study. The emission factor for NOx is 0.0845 g per km, for HC
the emission factor has the value 0.0663 g per km, and the emission factor for
CO is 0.9808 g per km. The reduction which is achievable with an annual inspection
of older cars with petrol engines is a lowering of 6% in NOx-emissions,
12% lowering in HC-emissions and 13% lowering in CO-emissions. The
HC and CO-emissions can be transformed into NOx-units. The toxicity
factor for HC is 1.5 and for CO the toxicity factor is 0.003. Using
the AUTOFORE model, DG MOVE calculated for all Member States the environmental
benefits from the annual testing for vehicles older than eight years due to a
reduction in local toxic emissions from petrol powered cars. The following
table provides the example calculation for PO 2b. Relevant Member States || Number of additional Inspected Passenger Cars || Share of Petrol Cars [%] || Reduction of Emissions in Tons NOx || HC || CO || NOx-Equivalent BELGIUM || 0 || 42% || 0,0 || 0,0 || 0,0 || 0,0 DENMARK || 879.565 || 90% || 80,3 || 126,0 || 2.018,5 || 275,2 GERMANY || 10.813.765 || 74% || 658,4 || 1.033,3 || 16.558,8 || 2.258,0 GREECE || 1.356.971 || 70% || 60,5 || 95,0 || 1.522,4 || 207,6 SPAIN || 2.002.059 || 51% || 131,9 || 207,1 || 3.318,2 || 452,5 FRANCE || 5.452.353 || 46% || 359,3 || 563,9 || 9.036,6 || 1.232,2 IRELAND || 652.447 || 80% || 43,0 || 67,5 || 1.082,5 || 147,6 ITALY || 8.411.841 || 60% || 511,7 || 803,0 || 12.869,2 || 1.754,8 LUXEMBOURGH || 0 || 40% || 0,0 || 0,0 || 0,0 || 0,0 NETHERLANDS || 0 || 80% || 0,0 || 0,0 || 0,0 || 0,0 AUSTRIA || 0 || 46% || 0,0 || 0,0 || 0,0 || 0,0 PORTUGAL || 433.059 || 50% || 26,3 || 41,3 || 662,5 || 90,3 FINLAND || 0 || 83% || 0,0 || 0,0 || 0,0 || 0,0 SWEDEN || 0 || 90% || 0,0 || 0,0 || 0,0 || 0,0 UK(GB) || 0 || 74% || 0,0 || 0,0 || 0,0 || 0,0 CYPRUS || 154.088 || 91% || 6,9 || 10,8 || 173,1 || 23,6 CZECH REPUBLIC || 1.303.824 || 77% || 58,2 || 91,3 || 1.462,8 || 199,5 ESTONIA || 49.824 || 77% || 1,9 || 3,0 || 47,6 || 6,5 HUNGARY || 1.022.029 || 81% || 45,6 || 71,5 || 1.146,6 || 156,4 LATVIA || 0 || 76% || 0,0 || 0,0 || 0,0 || 0,0 LITHUANIA || 405.479 || 75% || 14,9 || 0,0 || 375,0 || 16,0 MALTA || 65.696 || 71% || 2,7 || 4,2 || 67,0 || 9,1 POLAND || 0 || 66% || 0,0 || 0,0 || 0,0 || 0,0 SLOVAK REPUBLIC || 0 || 70% || 0,0 || 0,0 || 0,0 || 0,0 SLOVENIA || 42.960 || 70% || 1,9 || 3,0 || 48,2 || 6,6 BULGARIA || 0 || 70% || 0,0 || 0,0 || 0,0 || 0,0 ROMANIA || 938.559 || 72% || 41,9 || 65,7 || 1.053,0 || 143,6 Total || 33.984.517 || || 2045,4 || 2.074,9 || 33.252,7 || 6.979,5 Source:
Based on: Autofore (2007),op.cit. Savings
of CO2 have been calculated as proportional to the reduction in fuel
consumption, considering the fuel savings resulting from more frequent
inspections. According to AUTOFORE, a reduction of 2% of CO2
emissions is achievable. This results in a saving of 342.5 kg of CO2
per vehicle inspection. The
below data for the Netherlands on the number of defects related to emissions
for vehicles of different ages shows that the potential for reducing CO2
emissions with more frequent inspections of younger cars (aged 3 years or less)
is very small. This fact has been taken into consideration for calculations on
the CO2 savings for options with an annual test for all vehicles by
assuming only a 2.2% emission reduction potential. Source:
AUTOFORE 4.
Estimating the benefits in terms of reduced
congestion resulting from the smaller number of accidents Indirect benefits for the society include the
reduced amount of congestion due to accidents. AUTOFORE estimations for congestion
costs resulting from an accident range from € 5,000 to € 15,000. In
this report, we used the more conservative value of € 5,000. 5.
Estimation of additional staff needed for PTI The time for testing of a car is 25
minutes.[182]
We assume that an inspector works 8 hours a day and therefore completes 20
inspections per day. The average number of working days per year being 220, one
inspector can complete 4,400 inspections per year. In order to estimate the
number of additional staff needed under each policy option, we simply divide
the additional number of tests by 4,400. 6.
Estimation of additional staff costs for RSI It is assumed that a RSI of a commercial
vehicle in average takes 20 minutes.[183]
Therefore, in order to estimate the cost of additional RSI, we multiply the
number of such inspections by the average hourly wage of a technician
(according to the Standard Cost Model) divided by 3. The number of additional
inspections is estimated on the basis of the table below. Table: Cost of
additional staff for more RSI – describe methodology, using the table Reporting Member State || RSI performed || registered HDV || 10% RSI || 15% RSI || difference to 10% || difference to 15% || labour cost per h * || 10% RSI || 15% RSI || costs today Austria || 13.360 || 362990 || 36.299 || 54.449 || 22.939 || 41.089 || 11,84 || 90502 || 162108 || 52.710 Belgium || 19.265 || 662780 || 66.278 || 99.417 || 47.013 || 80.152 || 9,45 || 148093 || 252483 || 60.686 Bulgaria || 472.324 || 273570 || 27.357 || 41.036 || -444.967 || -431.289 || 1,03 || 0 || 0 || 162.322 Cyprus || 919 || 119795 || 11.980 || 17.969 || 11.061 || 17.050 || 8,51 || 31368 || 48355 || 2.606 Czech Republic || 106.470 || 589598 || 58.960 || 88.440 || -47.510 || -18.030 || 3,00 || 0 || 0 || 106.534 Germany || 2.833.493 || 2346678 || 234.668 || 352.002 || -2.598.825 || -2.481.491 || 14,04 || 0 || 0 || 13.256.060 Denmark || 265 || 34629 || 3.463 || 5.194 || 3.198 || 4.929 || 22,99 || 24507 || 37777 || 2.031 Estonia || 2.236 || 75317 || 7.532 || 11.298 || 5.296 || 9.062 || 2,62 || 4624 || 7912 || 1.952 Finland || 14.198 || 424498 || 42.450 || 63.675 || 28.252 || 49.477 || 14,63 || 137745 || 241229 || 69.224 France || 1.669.391 || 5569683 || 556.968 || 835.452 || -1.112.423 || -833.939 || 12,86 || 0 || 0 || 7.158.243 Greece || 24.431 || 1180000 || 118.000 || 177.000 || 93.569 || 152.569 || 8,02 || 250188 || 407944 || 65.324 Hungary || 351.690 || 419416 || 41.942 || 62.912 || -309.748 || -288.778 || 2,80 || 0 || 0 || 327.674 Ireland || 5.204 || 345874 || 34.587 || 51.881 || 29.383 || 46.677 || 18,50 || 181177 || 287810 || 32.088 Italy || 13.863 || 4437638 || 443.764 || 665.646 || 429.901 || 651.783 || 9,49 || 1359707 || 2061484 || 43.846 Lithuania || 31.197 || 128733 || 12.873 || 19.310 || -18.324 || -11.887 || 2,28 || 0 || 0 || 23.724 Luxembourg || 896 || 28571 || 2.857 || 4.286 || 1.961 || 3.390 || 14,88 || 9729 || 16816 || 4.445 Latvia || 9.441 || 113978 || 11.398 || 17.097 || 1.957 || 7.656 || 2,29 || 1494 || 5847 || 7.210 Malta || 3.579 || 44402 || 4.440 || 6.660 || 861 || 3.081 || 6,07 || 1742 || 6231 || 7.238 Netherlands || 4.147 || 951282 || 95.128 || 142.692 || 90.981 || 138.545 || 14,36 || 435345 || 662939 || 19.843 Poland || 1.328.828 || 2511677 || 251.168 || 376.752 || -1.077.660 || -952.076 || 3,07 || 0 || 0 || 1.358.507 Portugal || 558 || 1350000 || 135.000 || 202.500 || 134.442 || 201.942 || 4,16 || 186337 || 279892 || 773 Romania || 43.700 || 612179 || 61.218 || 91.827 || 17.518 || 48.127 || 2,03 || 11882 || 32643 || 29.640 Sweden || 165.263 || 502036 || 50.204 || 75.305 || -115.059 || -89.958 || 14,90 || 0 || 0 || 820.926 Slovenia || 4.026 || 74238 || 7.424 || 11.136 || 3.398 || 7.110 || 5,27 || 5968 || 12487 || 7.071 Slovakia || 5.637 || 246893 || 24.689 || 37.034 || 19.052 || 31.397 || 2,41 || 15327 || 25258 || 4.535 United Kingdom || 165.927 || 3652061 || 365.206 || 547.809 || 199.279 || 381.882 || 17,67 || 1173658 || 2249103 || 977.231 Spain || 0 || 5192219 || 519.222 || 778.833 || 519.222 || 778.833 || 8,06 || 1395495 || 2093243 || 0 Total || 7.259.111 || || 3.225.074 || 4.837.610 || || || || 5.464.889 || 8.891.560 || 24.602.444 || || || || || || || *_standard cost model || Annex 13a || || || || || Total employed time lost for PTI (min)* || time cost per capita, per MOT (€) COUNTRY || National Average Per Capita Income using PPP method (€)** || Average working minutes per Year || Average Income per minute worked (€/min) || PTI Price in 2004 (€) || Low || Medium || High || Low || Medium || High BELGIUM || 21100 || 345600 || 0,0611 || 24,5 || 36,4 || 55,4 || 79,3 || 2,22 || 3,38 || 4,84 DENMARK || 18800 || 345600 || 0,0544 || 53,8 || 36,4 || 55,4 || 79,3 || 1,98 || 3,01 || 4,31 GERMANY || 22700 || 345600 || 0,0657 || 40 || 36,4 || 55,4 || 79,3 || 2,39 || 3,64 || 5,21 GREECE || 18200 || 345600 || 0,0527 || 36 || 36,4 || 55,4 || 79,3 || 1,92 || 2,92 || 4,18 SPAIN || 19100 || 345600 || 0,0553 || 31 || 36,4 || 55,4 || 79,3 || 2,01 || 3,06 || 4,38 FRANCE || 22100 || 345600 || 0,0639 || 55 || 36,4 || 55,4 || 79,3 || 2,33 || 3,54 || 5,07 IRELAND || 19700 || 345600 || 0,0570 || 48,4 || 36,4 || 55,4 || 79,3 || 2,07 || 3,16 || 4,52 ITALY || 19400 || 345600 || 0,0561 || 35 || 36,4 || 55,4 || 79,3 || 2,04 || 3,11 || 4,45 LUXEMBOURG || 38901 || 345600 || 0,1126 || 20,9 || 36,4 || 55,4 || 79,3 || 4,10 || 6,24 || 8,93 NETHERLANDS || 20900 || 345600 || 0,0605 || 20,9 || 36,4 || 55,4 || 79,3 || 2,20 || 3,35 || 4,80 AUSTRIA || 22200 || 345600 || 0,0642 || 37 || 36,4 || 55,4 || 79,3 || 2,34 || 3,56 || 5,09 PORTUGAL || 15600 || 345600 || 0,0451 || 24,63 || 36,4 || 55,4 || 79,3 || 1,64 || 2,50 || 3,58 FINLAND || 20200 || 345600 || 0,0584 || 49 || 36,4 || 55,4 || 79,3 || 2,13 || 3,24 || 4,64 SWEDEN || 20800 || 345600 || 0,0602 || 33 || 36,4 || 55,4 || 79,3 || 2,19 || 3,33 || 4,77 UK(GB) || 21800 || 345600 || 0,0631 || 52,49 || 36,4 || 55,4 || 79,3 || 2,30 || 3,49 || 5,00 CYPRUS || 19000 || 345600 || 0,0550 || 36 || 36,4 || 55,4 || 79,3 || 2,00 || 3,05 || 4,36 CZECH REPUBLIC || 13300 || 345600 || 0,0385 || 50 || 36,4 || 55,4 || 79,3 || 1,40 || 2,13 || 3,05 ESTONIA || 10600 || 345600 || 0,0307 || 30 || 36,4 || 55,4 || 79,3 || 1,12 || 1,70 || 2,43 HUNGARY || 11000 || 345600 || 0,0318 || 20,18 || 36,4 || 55,4 || 79,3 || 1,16 || 1,76 || 2,52 LATVIA || 9100 || 345600 || 0,0263 || 35 || 36,4 || 55,4 || 79,3 || 0,96 || 1,46 || 2,09 LITHUANIA || 11400 || 345600 || 0,0330 || 35 || 36,4 || 55,4 || 79,3 || 1,20 || 1,83 || 2,62 MALTA || 12772 || 345600 || 0,0370 || 36 || 36,4 || 55,4 || 79,3 || 1,35 || 2,05 || 2,93 POLAND || 11500 || 345600 || 0,0333 || 21,29 || 36,4 || 55,4 || 79,3 || 1,21 || 1,84 || 2,64 SLOVAK REPUBLIC || 13000 || 345600 || 0,0376 || 35 || 36,4 || 55,4 || 79,3 || 1,37 || 2,08 || 2,98 SLOVENIA || 16000 || 345600 || 0,0463 || 35 || 36,4 || 55,4 || 79,3 || 1,69 || 2,56 || 3,67 ROMANIA || 8500 || 345600 || 0,0246 || 35 || 36,4 || 55,4 || 79,3 || 0,90 || 1,36 || 1,95 BULGARIA || 5600 || 345600 || 0,0162 || 35 || 36,4 || 55,4 || 79,3 || 0,59 || 0,90 || 1,28 || average time costs per citizen: || 1,81 || 2,75 || 3,94 *Europe Economics, UK-MOT Scheme Evidence Base ** EUROSTAT Table:
Main results of Benefit calculations: || Option a || Option b || Option c lives saved || injuries avoided || lives saved || injuries avoided || lives saved || injuries avoided measures || severe || slight || severe || slight || severe || slight Testing items || ESC || 158 || || || 158 || || || 158 || || Airbag || 175 || || || 175 || || || 175 || || Shock-absorber || 181 || 403 || 2079 || 181 || 403 || 2079 || 181 || 403 || 2079 Enhanced HDV brake test || || || || 70 || 1293 || 17361 || 70 || 1293 || 17361 category & frequency of testing || cars 3-2-2 || 15 || 183 || 1019 || || || || || || cars 3-2-1 || || || || 289 || 5337 || 21910 || || || cars 1-1-1 || || || || || || || 320 || 5944 || 24486 PTW 3-2-2 || 220 || 1275 || 2947 || || || || || || PTW 3-1-1 || || || || 279 || 3585 || 7086 || || || PTW 1-1-1 || || || || || || || 352 || 4523 || 8941 Moped 3-1-1 || || || || 89 || 1142 || 3134 || || || Moped 1-1-1 || || || || || || || 173 || 2336 || 6509 HDV 0,5-0,5-0,5 || || || || || || || 12 || 222 || 2976 Total || 749 || 1861 || 6045 || 1241 || 11760 || 51570 || 1441 || 14721 || 62352 || || || || || || || || || Benefit to society [million €] || 1577 || 4928 || 5967 || || || reduction of accidents || 7391 || 36562 || 60162 || || || Reduction of congestion [million €] || 16.6 || 119.3 || 199.8 || || || CO2 emission saving || [million ton] || 0.9 || 18.2 || 19.9 [million €] || 27.9 || 545.0 || 599.0 || || || NOX equivalent saving || [ton] || 308.2 || 6979.5 || 12224 [million €] || 1.4 || 30.7 || 53.8 Cost Benefit – Roadside Inspections Cost Benefit ratio related to road
safety and reduction of administrative burden. Cost (€ million) || Monetized benefit (€ million) || Monetized benefit/cost ratio || Other benefits 36 || 812.5 || 22.7:1 || Avoid unnecessary testing of 2.3 Mio trucks due to targeted selection € 80.4 Mio Benefit of
proposed changes: Area || Issue || Description || Estimated Benefit 10% of registered HDV to be tested || Targeted vehicle selection || The change from a pour random vehicle selection with a detection rate of ~ 1% of defect vehicles the targeted approach leads to a detection rate of ~40% of defect vehicles. This leads to up to a reduction of 2.3 Mio trucks tested without defects detected. Total number of tests would not change || Reduction of administrative burden: - for transport operators € 80.4 Mio - for national administrations No impact More elaborated tests with mobile inspection units || 15% of the pre-selected vehicles would be subject to a more elaborated test on a mobile inspection unit. It can be estimated that ~ 20 % of these tests result in detection of dangerous defects avoiding more than 2300 accidents || 205 lives saved 672 serious injuries avoided 24936 slight injuries avoided € 812.5 Mio Total benefit road safety || € 812.5 Mio Total benefit reduction of administrative burden || € 80.4 Mio Cost of
proposed changes: Yearly Costs (€ million) for Member States || Total Perform more elaborated tests with mobile inspection units || 36 Total || 36 Cost Benefit – Vehicle Administrative
Plattform Cost Benefit ratio related to road
safety and reduction of administrative burden. Cost (€ million) || Monetized benefit (€ million) || Monetized benefit/cost ratio || Other benefits 8 || 536.5 || 67:1 || 2nd hand car market and re-registration € 2,979 Mio - € 4,733 Mio Purpose areas of the Vehicle Administrative
Platform and estimated benefits: Area || Issue || Description || Estimated Benefit Inspection || Certificate of Conformity (CoC) Data + technical information || For assessing the compliance of a vehicle with its technical composition at the time when it was put on the market, the information based on the CoC data (e.g. approved dimension of tyres, number of seats) as well as additional technical information for each single vehicle (e.g. secondary braking system, suspension system) is needed. One single harmonised set of data will replace 27 different information requests. || Reduction of administrative burden: - for vehicle manufacturers € 18 Mio[184] - for national administrations € 20 Mio ABS / ESC || For an enhanced testing of ABS or ESC communication has to set up between the testing equipment (OBD-connector) and the on board control unit of these systems to trigger the actuators (interface between pure electronic system and the mechanic/hydraulic system) e.g. to apply certain brake force to a certain wheel. || 158 lives saved € 237 Mio Airbag || Set up communication between the testing equipment (OBD-connector) and the on board unit of the airbag(s) to check their presence and to read out fault codes || 175 lives saved € 262.5 Mio Market || Odometer fraud and second hand vehicles market || Mileage fraud[185] is for national transactions in the range of 5% to 12% and at cross border transactions at a range of 30% to 50%. In the case of Germany these values would lead to a monetary effect in the range of €725 Mio to €1.357 Mio per year. The scale of the problem was confirmed by different other presentations from UK, CZ, HU and FR. Extrapolating the quoted figures for EU 27 the monetary effect would be in the range of €4.030 Mio to €7.539 Mio. || Estimation that 50% of odometer fraud might be reduced: €2.015 Mio to € 3.769 Mio Re- registration || Data for vehicle registration are derived from the Certificate of Conformity (CoC) document which is generally only available at first registration. Re-registration is done with the information contained in the registration document of the previous registration. If data is missing - as the amount of mandatory data on registration documents is minimised – such data has to be retrieved from the vehicle manufacturer. || Reduction of administrative burden at re-registration[186] € 964 Mio Estimated benefit related to road safety || € 499.5 Mio Estimated benefit related to reduction of administrative burden || € 38 Mio Estimated benefit related to single market issues || € 2,979 Mio - € 4,733 Mio Estimated total benefits || € 3,516.5 Mio - € 5,266.5 Mio Cost of
setting up the data exchange system[187] Yearly Costs (€ million) || Member States || EU || Total One-off (5-year amortisation assumed) || 4.3 || 0.6 || 4.9 Maintenance || 2.5 || 0.4 || 2.9 Management || 0.3 || 0.04 || 0.3 Total || 7.0 || 1.0 || 8.0 Source: Commission
calculations using cost estimates in Europe Economics, op. cit., pp.
173-176. Annex 14: Europe Economics, final report, February 2011, Report of
contribution to impact assessment of policy options to improve the EU system of
PTI and of roadside vehicle testing Attached as separate
document. [1] Annex 2 summarises the main steps of the process in
chronological order. [2] DGs CLIMA, ENTR, INFSO, OIB, TAXUD and the SG
participated in the IASG meetings. The last IASG meeting took place on 27 April
2011 and the final version was circulated on 31 May 2011. Annex 2 summarises
the main steps of the process in chronological order. [3] Annex 3 contains the full list of participants and a
more detailed summary of the findings of both meetings. [4] See
FEMA position on PTI http://www.fema-online.eu/uploads/documents/vehicle%20aspects/20100903_FEMA_Position_Statement_PTI.pdf, and www.motorcyclenews.com, 22 September 2010. [5] A detailed summary of the results of the consultation
is contained in annex 5 and is also available on the Commission website http://ec.europa.eu/transport/road_safety/take-part/public-consultations/pti_en.htm. [6] Europe Economics, final report, February 2011, Report
of contribution to impact assessment of policy options to improve the EU system
of PTI and of roadside vehicle testing, attached as annex 14. [7] Ibid. [8] Council Directive 77/143/EEC of
29 December 1976 on the approximation of the laws of the Member States relating
to roadworthiness tests for motor vehicles and their trailers. [9] Directive 2009/40/EC of the European Parliament and
of the Council of 6 May 2009 on roadworthiness tests for motor vehicles and
their trailers: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:141:0012:0028:EN:PDF.
[10] Directive 2000/30/EC of the European Parliament and of
the Council of 6 June 2000 on the technical roadside inspection of the
roadworthiness of commercial vehicles circulating in the Community: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32000L0030:EN:HTML.
[11] Annex 10 presents in more details the legislative
framework on PTI testing in the EU. [12] The full list of allowed exceptions can be found in
Article 5 of Directive 2009/40/EC. [13] Article 1 of Directive 2000/30/EC. [14] Communication from the Commission to the European
Parliament, the Council, the European Economic and Social Committee and the
Committee of the Regions, Towards a European road safety area: policy
orientations on road safety 2011-2020, COM(2010) 389 final. [15] Council Conclusions TRANS 16951/10. [16] The "type-approval" is defined in Directive
2007/46/EC of the European Parliament and of the Council of 5 September 2007
establishing a framework for the approval of motor vehicles and their trailers,
and of systems, components and separate technical units intended for such
vehicles. [17] European Commission report on the technical roadside
inspection of the roadworthiness of commercial vehicles, COM(2010) 754 final. [18] See also Annex 6: Failure rates in roadside tests,
2007-2008. [19] ‘MOT Scheme Evidence-base’ Department for Transport,
UK, 2008. [20] Ibid., p.25. [21] VOSA (2005), after: CITA (Comité international de
l'inspection technique automobile), AUTOFORE Report: Study on the future
options for roadworthiness enforcement in the European Union, Brussels
2008. [22] The concept of "serious defect" is not defined
in the study. Commission Recommendations 2010/378/EU qualify defects as
"minor", "major" and "dangerous". [23] Comité international de
l'inspection technique automobile (CITA): AUTORE Report on the Future Options for Roadworthiness Enforcement,
2007 [24] Motorcycles include heavy quads, mopeds include light
quads. [25] Cf. Annex 7. [26] ‘MOT Scheme Evidence-base’, op. cit. [27] AUTOFORE (2007), op.cit. after Federal Motor
Transport Authority (Kraftfahr Bundesamt KBA) 2008 [28] Thatcham research News, Special edition 2009, http://www.thatcham.org/research/pdfs/research_news_vol4_issue6_se.pdf. [29] Community database on Accidents on
the Roads in Europe; Council Decision 93/704/EC. [30] Ibid. [31] Federal Statistics Office, Germany Amtliche
Verkehrsstatistiken, 2009. [32] This figure is contained in a study covering Europe:
DEKRA (2005) “Internationale Strategien zur Unfallvermeidung”, in
"Technische Sicherheit im Straßenverkehr", DEKRA Fachschrift 58/05.
DEKRA Automobil GmbH, Stuttgart. [33] AUTOFORE (2007), op. cit. [34] Motorcycle Road Safety Report 2010 (DEKRA) [35] Between 2001 and 2010, fatalities among motorcycle
drivers increased by 13% to 5,115, while overall road fatalities fell by 43% -
source: CARE Database, DG MOVE. [36] The methodology for establishing this classification is
further explained in section 2.3.1 below and in Annex 14. [37] Malta is an exception, but due to the small size of the
country the figures are not representative [38] CARE Database, DG MOVE [39] Number of fatalities linked to technical defects
calculated as 6% of total 35,000 fatalities. [40] AUTOFORE (2007) and ‘MOT Scheme Evidence-base’, op.
cit. [41] AUTOFORE (2007), op.cit. [42] Air Pollution from motor vehicles, A. Faiz, C. Weaver,
M. Walsh, 1996. [43] Lenz, Stricker, a.o., Identification of gross emitters,
Wien 2001. [44] A damaged catalytic converter or a malfunctioning
oxygen sensor can increase hydrocarbon and carbon monoxide emissions by a
factor of 20 or more. Similar malfunctions could increase nitro oxide emissions
by a factor of three to five. In diesel vehicles a worn out or damaged fuel
injection system can increase emissions of particulate matter at least twenty
fold. [45] Ibid. [46] Auto Oil Study, 2000, http://ec.europa.eu/environment/archives/autooil/pdf/auto-oil_en.pdf.
[47] For roadside testing, this would relate to the number
of vehicles targeted for roadside tests each year. [48] This classification compares the organisation of PTI in
different Member States, in particular the level of independency of PTI
centres, the education requirements for testers and the existing accreditation
systems. [49] Annex 7 indicates for instance, that only 8 Member
States have set testing frequency at the minimum level required by the
Directive, while 19 apply more stringent requirements; 18 Member States
expanded the obligation of PTI to categories which are not covered by Directive
2009/40/EC, notably motorcycles, agricultural tractors and light trailers;
finally, most Member States roadside inspections involve more than the visual
inspection of the vehicles required by Directive 2000/30/EC (Cf. table 6.4. in
annex 15). [50] Directive 2009/40/EC, Article 3.2. [51] By the amendment brought by Directive 2010/48/EC visual
inspection of the “malfunction indicator lamp (MIL) for electronic safety
systems has been introduced. [52] Directive 2000/30/EC, Art. 4.1. [53] European Commission report on the technical roadside
inspection of the roadworthiness of commercial vehicles, COM(2010)754. [54] Cf. Annex 6. [55] For example, suspension defects are found in 1.3% of
inspected vehicles in Belgium and over 15% in the Netherlands. On the contrary,
chassis defect concern only 9.2% of vehicles stopped in the Netherlands against
close to 25% in Belgium. [56] E.g. While EU legislation allows maximum brake
difference of 30% between the left and right side, Germany and Austria have put
in place more stringent standards (respectively, 25% and 20%). [57] AUTOFORE, op. cit. Only brake efficiency limits for new
vehicles have been updated by Directive 2010/48/EU. [58] Commissions recommendations of 5 July 2010
(2010/378/EU). [59] Commission Directive 2010/48/EU of 5 July 2010 adapting
to technical progress Directive 2009/40/EC of the European Parliament and of
the Council on roadworthiness tests for motor vehicles and their trailers. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:173:0047:0072:EN:PDF.
[60] such as, e.g. "Visual inspection with vehicle over
a pit or on a hoist. Wheel play detectors may be used and are recommended for
vehicles over 3,5 tonnes gross vehicle mass". Directive 2010/48/EU, Annex
II point 4.5.1.1. [61] Cf. Annex 7. [62] Based on time elapsed. [63] Cf. Annex 12 for deeper analysis of the testing
frequency of these vehicles. [64] PTI was completely liberalised in Denmark in 2005. An
internal audit, performed by Denmark's State Audit (http://www.rigsrevisionen.dk/media(1073,1033)/11-2008.pdf),
on the liberalised PTI sector concluded that the expectations to quality have
not been fulfilled. The auditors stated that of all re-inspections of recently
inspected vehicles carried out by the Ministry's Transport Agency in 2008, 47%
disclosed inadequate tests against 41% in 2007 (one-quarter of all errors
detected in 2007, and one-third of all errors detected in 2008 were
significant). The auditors therefore underlined the importance of supervision
by the authorities to ensure consistent vehicle testing and equal criteria to
pass or fail PTI. At the same time accident statistics from Denmark showed an
increase in the number of fatalities between 2006 and 2007 by 30%. The number
of fatalities remained at that level also in 2008. [65] Article 2 of the Directive only vaguely mentions that
"where establishments designated as vehicle testing centres also perform
motor vehicle repairs, Member States shall make every effort to ensure the
objectivity and high quality of testing". [66] Annex 11 contains a more detailed description of the
general vehicle regulatory scheme. [67] Control units are microcomputers which control the activities
of electronic safety components (eg regulating brake forces on different wheels
when ABS is active). [68] Thatcham research News, Special edition 2009, http://www.thatcham.org/research/pdfs/research_news_vol4_issue6_se.pdf. [69] Peter Cummings, Barbara McKnight, Frederick P Rivara,
David C Grossman, Association of driver air bags with driver fatality: a
matched cohort study, http://www.bmj.com/content/324/7346/1119.full.pdf;
And: Elisa
R. Braver, Susan
A. Ferguson, Michael
A. Greene, Adrian
K. Lund, Reductions in Deaths in Frontal Crashes Among Right Front
Passengers in Vehicles Equipped With Passenger Air Bags, http://jama.ama-assn.org/content/278/17/1437.abstract. [70] Regulation (EC) No 715/2007 of the European Parliament
and of the Council of 20 June 2007 on type approval of motor vehicles with
respect to emissions from light passenger and commercial vehicles (Euro 5 and
Euro 6) and on access to vehicle repair and maintenance information, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:171:0001:0016:EN:PDF. [71] AUTOFORE, op.cit.: "At present, except for exhaust
emission control systems, […] there are no agreed standards for on-board
diagnostic systems. Each manufacturer has developed its own systems and
protocols […] and defined the failure threshold levels. This makes
interrogation of the operational integrity of the systems very difficult and
expensive for inspection agencies." [72] A recent Belgian study found that 18% of a sample of
vehicles could not be checked for faults in items such as ABS and airbag
because of data problems. (source: AUTOFORE, op. cit). [73] Study of the economical impact of mileage fraud, CRM
used car management (in Proceedings of Cars 2010 conference, Brussels, 18
November 2010). [74] For example, emissions from road traffic can only be
calculated based on calculation models for the annual mileage of vehicles.
These models result in significant discrepancies to real mileage of vehicles.
Differences up to 400% have been identified as shown by the tables in Annex VI
(Mobility Study in Germany vs Fleets/Tremove calculation model). [75] Directive
2010/48/EU, Annex II, par. 4, point 7.11. [76] Directive
2010/48/EU, Annex II, par. 3. [77] DG Clima, European second hand car market analysis,
February 2011. [78] Source: DG Sanco,
Fourth edition of the Consumer Markets Scoreboard - "Making markets work
for consumers"(working document, draft version, August 2010) [79] Study of the
economical impact of mileage fraud, CRM used car management (in Proceedings of
Cars 2010 conference, Brussels, 18 November 2010) [80] www.cars2010.eu. [81] The economical impact
of mileage fraud and the
cost benefit analysis of the Car-Pass system [82] Regulation (EC) No 385/2009. [83] Art. 24 of Directive 2007/46/EC on the type approval
for vehicles and their parts and components. [84] Directive 1999/37/EC on the registration documents for
vehicles defines registration as the official authorisation for the use on
public roads and the issuing of a number (registration number) for its
identification. [85] Directive 1999/37/EC provides in its Annex I a
harmonised set of mandatory and optional data for registration documents. [86] Directive 2010/48/EU introduces a harmonised
roadworthiness certificate. [87] The cost of maintaining vehicles to a higher standard
and a higher cost of inspections themselves. [88] The last amendment was Directive 2010/48/EU. [89] Primes-Tremove, reference scenario. [90] The goal set for the next ten years in the Policy
Orientations on Road Safety is to reduce yearly fatalities by 50%. [91] Öko-Institut e.V., Transport & Mobility Leuven,
COWI, European second-hand car market analysis – Final report, February
2011. [92] On 18 January 2011 the Commission held an orientation
debate (PV(2011)1944) to discuss further elements of the air quality programme.
The meeting concluded that improving air quality is a pressing need and a
shared responsibility requiring joint efforts. The Commission also prepared a
staff working paper on the implementation of EU Air Quality policy (SEC
(20011)342). In this document, the promotion of clean and energy efficient road
transport vehicles plays a strong role, in line with the Communication a
European Strategy on clean and energy efficient vehicles (COM(2010) 186 final).
The EU also adopted an integrated energy and climate change policy in December
2008 (COM(2008) 30 final) including ambitious targets for 2020, the so called
"20-20-20 strategy", which notably envisages to cut greenhouse gases
by 20% (30% if international agreement is reached). Finally, in the 2011 White
Paper on Transport (COM(2001) 144 final), the Commission set the goal of
reducing the greenhouse gas (GHG) emissions from transport in Europe by 60%
till 2050 compared to 1990 levels. [93] COM (2011)144 final. [94] TÜV Bus-Report
2010/2011 and Verkehrssicherheitsreport LKW 2009(DEKRA) [95] See in this respect section 2 above on problem
definition for the description of the baseline scenario. [96] An
explanation on the vehicle categories is contained in annex 9. Vehicle categories in accordance with Annex
II of Directive 2007/46/EC establishing a framework
for the approval of motor vehicles and their trailers and of systems,
components and separate technical units intended for such vehicles (OJ L 263,
9.10.2007, p.1). [97] Cf. point 0 for the list of the seven pillars of
roadworthiness. [98] This analysis, performed by Centiq (www.centiq.co.uk), is presented in Appendix
4 to: Europe Economics, final report, February 2011, Report of contribution
to impact assessment of policy options to improve the EU system of PTI and of
roadside vehicle testing (see the separate annex to this IA report, pp.
153-176. [99] TACHOnet is a telematic network in
operation across the EU to allow an automated exchange of information between
Member States concerning the use of tachographs and tachograph driver cards.
More information can be found under: http://ec.europa.eu/transport/road/social_provisions/tachograph/tachonet_en.htm. [100] White Paper on transport, op.cit., initiative 16. [101] The first PTI Directive – see section 2 for more
details. [102] Directive 95/46/EC of the European Parliament and of the
Council of 24 October 1995 on the protection of individuals with regard to the
processing of personal data and on the free movement of such data [OJ L 281 ,
23/11/1995 P. 0031 – 0050]. [103] http://ec.europa.eu/enlargement/taiex/pdf/experts/guide_for_experts.pdf. [104] The following calculation was made: (€90+€250+€300+€100)x108. [105] Sonja Forward and Ali Kazemi (ed.), Campaigns and
Awareness-Raising Strategies in Traffic Safety (CAST) (2009), A theoretical
approach to assess road safety campaigns: Evidence from seven European
countries, Project co-financed by DG Energy and Transport. [106] A Dutch seatbelt campaign carried out in 2008 costed €
490,000, and a campaign for child restrain in Austria - € 462,000. Source: Campaigns
and Awareness-Raising Strategies in Traffic Safety (CAST) (2009) “A theoretical
approach to assess road safety campaigns: Evidence from seven European
countries” Project co-financed by DG Energy and Transport [107] Sonja Forward and Ali Kazemi (ed.), op.cit. [108] According to weighted average effects and calculated
after accounting for publication bias. The results also showed that road
safety campaigns resulted in a 25% increase in seatbelt use, a 16% reduction in
speeding, a 37% increase in yielding behaviour and a 16% increase in risk
understanding. [109] DEKRA is one of the world’s leading expert organisations,
which was a partner of Europe Economics in the preparation of their report for
the present Impact Assessment. [110] DG MOVE estimate based on figures from DEKRA and CITA. [111] Data provided by EGEA (European Garage Equipment
manufacturers Association). [112] Europe Economics, op.cit. [113] CITA, General Questionnaire, 2006, op.cit. [114] Europe Economics, February 2011, op.cit.. [115] Report from the Commission to the Council and the
European Parliament on the application by the Member States of Directive
2000/30/EC of the European Parliament and of the Council of 6 June 2000 on the
technical roadside inspection of the roadworthiness of commercial vehicles
circulating in the Community [Reporting periods 2005–2006 and 2007–2008. [116] Europe Economics, op. cit. [117] Ibid. [118] These are: Bulgaria, Cyprus, Greece, Finland, France,
Lithuania, Malta, The Netherlands, Portugal, Romania and Sweden. [119] As stated by Dutch Royal Service for Road Safety (RDW)
during the experts workshop. [120] Europe Economics, February 2011. [121] Europe Economics, op. cit., p. 170. [122] Data used for the calculation of these costs can be
found in Europe Economics, op. cit., p. 173-176. [123] Handbook on estimation of external costs in the
transport sector (2008): http://ec.europa.eu/transport/sustainable/doc/2008_costs_handbook.pdf.
[124] This figure relates only to accidents involving cars as
it has been assumed that accidents with motorcycles don’t cause huge
congestions. [125] European Commission report on the technical roadside
inspection of the roadworthiness of commercial vehicles COM(2010)754. [126] NOx equivalent represents the toxicity of all
CO, HC and NOx gaseous emissions. [127] We use the methodology established by Directive
2009/33/EC on clean and efficient vehicles, which provides the price of
emissions which should be used for calculating the monetary impact of CO2
emissions (€ 30/ton) and NOx equivalent emissions (€ 4,400/ton). [128] DG MOVE estimate based on CITA General Questionnaire,
2006, op. cit. [129] Source EGEA (European Garage Equipment Manufacturers). [130] Europe Economics, op.cit. [131] Ibid. [132] DG MOVE own calculations. [133] Ibid. [134] CITA, 2006, op. cit. [135] Staff costs calculation based on the Standard Cost Model. [136] Calculations using the Standard Cost Model. [137] These countries are Belgium, Bulgaria, Cyprus, Czech
Republic, Germany, Greece, Finland, France, Lithuania, Malta, The Netherlands,
Portugal, Romania, Sweden and UK. [138] Calculation of Europe Economics based on the Annual report
of Austrian Rechnungshof (2006). [139] Using the methodology established by Directive
2009/33/EC on clean and efficient vehicles (See footnote 127). [140] DG MOVE estimate based on CITA 2006, op. cit. [141] Europe Economics, op.cit. [142] Staff costs calculation based on the Standard Cost Model. [143] Europe Economics, op.cit. [144] Based on the assumption that the test for a Heavy Duty
Vehicle costs € 75 (Source: CITA General Questionnaire 2009). [145] Using the methodology established by Directive
2009/33/EC on clean and efficient vehicles. [146] DG MOVE estimate based on CITA 2006, op. cit. [147] DG MOVE estimations. [148] IA report on measures enhancing the security,
effectiveness and efficiency of the tachograph in road transport, not yet
published. [149] These estimates are the result of the following
calculation: for each policy option, we divided its total costs by 300 million. [150] Annex 13a shows the details behind this calculation
based on the average hourly wage in the EU Member States. [151] White Paper on Transport. Roadmap to a single European
transport area – towards a competitive and resource efficient transport system,
COM (2011) 144 final. [152] Policy orientations on Road Safety 2011-2020,
op.cit. [153] Proposal for a Regulation of the European Parliament and
of the Council on the approval and market surveillance of two- or three-wheel
vehicles and quadricycles COM(2010)542 final. [154] Registration of motor vehicles previously registered in
another Member State http://ec.europa.eu/enterprise/policies/single-market-goods/files/car_registration/roadmap_en.pdf. [155] IASG: Impact Assessment Steering
Group. [156] For example tyre-pressure is checked only in France,
electronic safety systems are checked only in Germany. [157] e.g. for Powered Two Wheelers PTW [158] Prof. Dr W. Schultz, from the University of Cologne [159] See FEMA position statement on
PTI
http://www.fema-online.eu/uploads/documents/vehicle%20aspects/20100903_FEMA_Position_Statement_PTI.pdf [160] www.motorcyclenews.com, 22 September 2010. [161] See FEMA position on PTI http://www.fema-online.eu/uploads/documents/vehicle%20aspects/20100903_FEMA_Position_Statement_PTI.pdf, and www.motorcyclenews.com, 22 September 2010. [162] A detailed summary of the results of the consultation is
contained in annex 4 and is also available on the Commission website http://ec.europa.eu/transport/road_safety/take-part/public-consultations/pti_en.htm).
[163] Exemptions
were granted to armed forces, the forces of law and order and the fire service.
Member States may, after consulting the Commission, exclude from the scope of
this Directive, certain vehicles operated or used in exceptional conditions and
vehicles which are never, or hardly ever, used on public highways, including
vehicles of historic interest which were manufactured before 1 January 1960 or
which are temporarily withdrawn from circulation. [164] Defined as: an inspection of a technical nature, not
announced by the authorities and therefore unexpected, of a commercial vehicle
circulating within the territory of a Member State carried out on the public
highway by the authorities, or under their supervision. [165] Commission interpretative communication on procedures
for the registration of motor vehicles originating in another Member State,
2007/C 68/04. [166] Directive 2007/46/EC on the framework for approval of
vehicles and their trailers Directive 2002/24/EC
on the approval of powered two- or three-wheeled vehicles Directive 2003/37/EC
on the approval of agricultural tractors and their trailers [167] Regulation 1014/2010 on the content of CoC documents [168] Directive 1999/37/EC on the registration documents for
vehicles [169] Directive 2000/53/EC on end of life vehicles [170] Europe Economics, op.cit. [171] Directive 2009/40/EC requires
annual testing of taxis and ambulances [172] AUTOFORE (2007) [173] AUTOFORE [174] Ibid. [175] http://webarchive.nationalarchives.gov.uk/+/http://www.dft.gov.uk/pgr/roads/vehicles/mot/mot/
[176] http://ec.europa.eu/transport/road_safety/specialist/statistics/care_reports_graphics/index_en.htm.
[177] Handbook on estimation of
external costs in the transport sector (2008), op.cit. [178] COWI (2006), Cost-benefit assessment and prioritisation
of vehicle safety technologies. [179] Related to
the functionality testing of electronic safety components today, only a few
pilots are in place in Europe. Examples of the benefits of a functionality
testing have been presented by FSD (Fahrzeug System Daten GmbH, Germany) where
i.a. in case of ESC a wrong mounting of the yaw rate sensor (mounted 180°
rotated) after a repair of the audio system in the car has been detected. This
kind of wrong mounting would result in an additional destabilisation of the car
in case of an activation of the ESC ending up in supporting the accident!
Furthermore from practical experience by the different testing organisations
and by CITA the interface between electronic and mechanic parts – called
activators - are those with the highest defect rates of such systems. Such
activators cannot be checked by electronic means and therefore testing of the
functionality is important. [180] CARE, DG MOVE. [181] A theoretical
approach to assess road safety campaigns (CAST 2009). [182] 'MOT scheme evidence base', op.cit. [183] DG MOVE estimations. [184] Source: ACEA [185] The economical impact of mileage fraud and the cost benefit analysis of the Car-Pass system [186] Draft Impact Assessment on registration of motorvehicles
(Agenda Planning 2011/ENTR/010) [187] Data used for the calculation of these costs can be
found in Europe Economics, op. cit., p. 173-176.