Right To Report – RWT

Riders groups in the UK and the rest of Europe have started to make announcements concerning the European Commission’s proposal for periodic roadworthiness tests for motor vehicles and their trailers, which includes mandatory Road Worthiness Testing (RWT) for motorcycles.

These announcements are in addition to those by the riders groups from Norway (NMCU), Sweden (SMC) and the Netherlands (MAG Netherlands).

As we wait for the riders’ groups to present their positions, we have declared our support for a protest that MAG Netherlands has organised with MAG Belgium and NMCU (Norway) to take place in Brussels on the 22nd of September 2012.  These organisations are taking their national issues to the seat of the European Commission to express their disagreement with this proposal.

In our opinion, however, there needs to be a communiqué published by the participating rider organisations with the reasons for supporting the Brussels protest and more importantly, what the organisations attending this protest are going to present on that day.

Just to clarify our position on Road Worthiness Testing and motorcyclist/rider organisations.

Our view is simply that these are different countries with different situations and require a different solution.

We have reported on the Commission’s proposal and stated that within the proposal the status quo for the UK remains, i.e. there will be no change to the frequency of MoT (aka RWT) for motorcyclists in this country, and from what we have read, the focus of this proposal is on cars.

In any event, we will continue to report the progress of this proposal and any effects it will have for UK riders.

British Motorcyclists Association

The British Motorcyclists Association has issued a briefing entitled – The EU, MOTs, RWTs (Road Worthiness Tests) and You – concerning the recently announced European Commission proposal on Road Worthiness Testing.

The BMF claims that it was due to lobbying from the European manufacturers’ representative body ACEM and German International Testing standards organisation DEKRA that the European Commission (the civil service of the European Union), is drafting plans to include motorcycles in the current EU Road Worthiness Testing (RWT) Legislation.

The BMF states that, “While the UK already has compulsory annual MOTs for all vehicles, RWT will replace them and for eleven of the 35 Member states, including France, Ireland and the Netherlands (who test other vehicles but do not currently test bikes), they will now have to include motorcycles in their annual RWTs.”

Commenting on the Road Worthiness Test the BMF states, “The RWT will cover basically those items already covered by the UK MOT plus: Engine Performance. A visual inspection and if ECU and engine are illegally* modified will result in failure.” And “when the safety and environmental systems and components of the vehicle have been altered or modified.”

However they note that, “Modifications to the transmissions and engine as referred to (…)will only result in a failure in those countries where modifications are already illegal (not the UK). This is unrelated to potential new rules on Type Approval for motorcycles.”

The article continues “The only significant aspect for the UK concerns emissions testing would expect only new bikes manufactured under the new type approval rules to be tested for emissions as these are designed to last up to 50,000km without failing; however, the draft implies that current bikes would be tested too, but it is not yet clear as to what standards they will be tested to”.

In the briefing under the subject title “Background” the BMF gives an explanation that the EU sponsored and BMF part-funded Motorcycle Accidents In Depth Study (MAIDS), the most comprehensive in-depth data currently available for Powered Two-Wheelers (PTWs) accidents in Europe, proved a point that vehicle defects are rarely the cause of accidents.

The BMF states that, “The investigation (MAIDS)was conducted over 3 years on 921 accidents from 5 countries and the results indicate that only 1.1% of accidents were caused by vehicle defects.

However at Right To Ride we dispute these figures because as we previously reported, the MAIDS study indicated that technical failures were 1.6%.  (Although if contributory factors due to technical failures as a cause of accidents are included, then the proportion increases to 5%).

The 5 countries sampled i.e. France, Germany, Netherlands, Spain and Italy include countries that have RWT (Italy, Spain and Germany) and refers to the period from 1999-2000 (Twelve years ago!).  However, as the three of the five countries already had RWT, these figures are skewed and effectively are meaningless.   It would have been far better if the authors of the MAIDS report had compared France and the Netherlands (countries without RWT) to the other three countries (Italy, Spain and Germany).

We did mention that there were quite a few mistakes in the MAIDS report (so did Harry Hurt!).

At that time (2004) we were not very popular…..

BMF Summary

The BMF finish in their summary that, “While the implications for the UK are minor compared with member states without RWTs, we fear that nevertheless the plans could mean higher costs for bike maintenance, especially with the emissions testing implications.”

The BMF are fully supporting their sister organisations across Europe in opposing this completely unnecessary legislation with the reason given, “Because for many EU countries these proposals will mean either the implementation of a new test, making their current test much stricter or doubling the frequency, FEMA estimates that across Europe, affected motorcyclists will have to spend an extra €1.2bn in additional operational costs.”

(NB:  According to the FEMA press release,  35 million powered two-wheelers are registered across the European Union. If the price for an inspection is set at 50 euros, riders would have to pay 1.7 Billion euros on a biannual basis for having their vehicles inspected. Based on an estimated stock of 70% of motorcycle and mopeds being older than 6 years, the proposed annual testing for these older vehicles would mean an additional 1.2 Billion euros annually! And these numbers still don’t include the social costs arising from the fact that vehicle owners usually need to take half a day off in order to bring their vehicles to an authorised testing service!”

However, in Northern Ireland the cost of an MoT is £22.50 or 29 Euros….Also, this does not exclude those PTWs that do not need to have RWT (i.e. those under 4 years).

Original Source: Click Here

Motorcycle Action Group (MAG UK)

MAG UK have put out their information which in parts seems to contradict what the BMF are saying especially regarding the “new rules” on the European Commission’s Regulation proposal which is still being discussed.

MAG UK says,” We also predicted it (Road Worthiness Testing) would be linked to the new EU Type-Approval Regulation to control any changes to the power-train, etc.”  while as above, the BMF says, “This is unrelated to potential new rules on Type Approval for motorcycles.”

At Right To Ride we are firmly on the BMF side of the fence on this.

MAG has referenced what others have said regarding their reporting on the issue, “Some scoffed, accusing MAG of deliberately scaremongering – judge for yourself, the official documents can be found on the EU website.”

While they mention that they predicted that, “The Commission might concentrate on making sure all EU member states have at least a basic road worthiness test, “ they tack onto the end that the Commission is, “Likely to aim high and we might get something more like the German TuV test, rather than the UK’s MoT.”

We might, but there are no inklings that we (in the UK) will have anything other than the present “depth” of MoT.

But as we frequently tried to point out in another situation – it is a PROPOSAL.

There may perhaps be some extra testing on bikes as technology moves on, such as emissions testing (which will also mean that this could be linked to lower road tax) just like cars.  The Commission’s proposal, which is what it is at the moment, is for cars as well as motorcycles.

However MAG also says that, “Our National Committee is giving careful consideration to MAG’s policy on RWT, which will form the basis for our campaigning with riders, media, politicians and officials.”

We await that policy and we would never scoff!

Original Source: Click Here

BVDM – Bundesverband der Motorradfahrer  –  Germany

Meanwhile BVDM, one of three German rider national organisation of the Federation of European Motorcyclists are reported as opposing the European Commission’s proposal for annual inspections for older motorcycles.

BVDM, has informed FEMA that, “BVDM is against the new proposal of the European Commission to reduce the frequency of Road Worthiness Testing from 2 years to annually. Motorcycles especially are kept in good condition by their owners (better than cars, which a recent study shows – at Right To Ride we would like to see this recent study as statements like this when made need qualified).”

The BVDM continues: “Accidents caused by technical defects are very rare therefore a change in the testing frequency makes no sense. If any change is needed then Motorcycles and Cars should be treated equally. In Germany at present new cars are first tested after 3 years while motorcycles already after 2 years. A situation that has no justification”

Original Source: Click Here

MAG Ireland – Republic of Ireland

In the Republic of Ireland, MAG Ireland has put out a press release to highlight their position against Roadworthiness Testing.

We in MAG Ireland are in the process of studying the published proposals in tandem with our colleagues in FEMA. MAG Ireland is opposed to roadworthiness testing for motorcycles because there is no evidence that mechanical failure of the motorcycle is in any way a statistically significant factor in motorcycle accidents.

The Road Safety Authority agrees wit

h us on this point and had this to say in the National Motorcycle Safety Action Plan 2010-2014:

Motorcycle Testing

4.2.8 Currently, motorcycles are not required to be tested in a scheme equivalent to the National Car Test, NCT. While it is accepted that there is little evidence that defective motorcycles are a major factor in causing collisions it is a matter of equity that all vehicles of the road should be maintained to the safest level possible.

4.2.9 The Motorcycle Safety Action Plan will undertake a cost benefit analysis on the introduction of a road worthiness test for motorcycles.

If testing was a significant factor in casualty reduction, we would expect to see big differences between casualty rates between countries which have motorcycle testing and those which don’t.  In fact there is no discernible effect. For example, Sweden is the only country in Scandinavia where periodic roadworthiness tests are mandatory for motorcycles. However, Sweden does not have better motorcycle accident statistics than Denmark, Finland or Norway”. 

Original Source: Click Here

Right To Ride Comments

In our opinion there needs to be a communiqué published by the participating rider organisations with the reasons for supporting the Brussels protest and more importantly, what the organisations attending this protest are going to present on that day.

Just to clarify our position on Road Worthiness Testing as regards to motorcyclist and rider organisations. Our view is simply that these are different countries with different situations and require a different solution.

Thus we support the protest that MAG Netherlands has organised with MAG Belgium and NMCU (Norway) in Brussels on the 22nd of September by taking their national issues to the heart of the European Commission where they have the right to express their views.

We reported on the Commission’s proposal and stated that within the proposal the status quo for the UK remains, i.e. there will be no change to the frequency of MoT (aka RWT) for motorcyclists in this country, and from what we have read, the focus of this proposal is on cars.

In fact in that respect, the Commission’s proposal refers to the UNECE document ECE/TRANS/ WP.29/2009/135

For information, a specific “Proposal for Draft Rule No.2 On Uniform Provisions for Periodical Technical Inspections of Wheeled Vehicles with Regard to their Roadworthiness” can be found by – Clicking Here

It appears that the Commission’s proposal has been drawn from this.

Presentations – Secretary of the UNECE WP29

In fact, in a presentation at an International conference hosted by CITA (International Motor Vehicle Inspection Committee) in 2009, the secretary of the UNECE WP29 explains the position of this group:

  • Periodical Technical Inspections are essential to increase road traffic safety
  • Developed economies have national/regional provisions
  • Developing economies need the Rules annexed to the Agreement to reduce road traffic accidents and mitigate emission of pollutants, including CO2
  • Need for minimum harmonized provisions
  • Make the Rules attractive for the EU
  • CITA has an important role to play

Original Source – pdf 570kb – Click Here

Presentations – ACEM – Antonio Perlot

In a presentation by ACEM at the same conference, their representative explains the industry’s reason for supporting EU wide RWT for PTWs (with relevant statistics):

Expected benefits

1. Safety:

  • Periodic inspection would reduce the incidence of safety related defects of the tyres, the brakes and the lights, particularly those of which the owner is unaware
  • Periodic inspection addresses the growing number of urban commuters, less motivated by technical features and maintenance
  • Periodic inspection is likely to discourage tampering of mopeds

2. Environment:

  • Periodic inspection will contribute to maintain polluting and noise emissions controls installed as OE
  • Periodic inspection will ensure durability requirement and reduce tampering
  • Periodic inspection will reduce the use of illegal RESS (Replacement Exhaust Silencing Systems)

Original Source – pdf 291kb – Click Here

In any event, we will continue to report the progress of this proposal.

More Links

You can view SMC (Sweden) and NMCU (Norway) positions on Road Worthiness Testing (RWT) and details of the MAG Netherlands protest ride in Brussels on Right To Ride EU

Click Here

The EU, MOTs, RWTs (Road Worthiness Tests) and You

A briefing document from the British Motorcyclists Federation, 2 August 2012

After lobbying from the European manufacturers’ representative body ACEM and German International Testing standards organisation DEKRA, the European Commission (the civil service of the European Union), is drafting plans to include motorcycles in the current EU Road Worthiness Testing (RWT) Legislation.

Background

While the UK already has compulsory annual MOTs for all vehicles, RWT will replace them and for eleven of the 35 Member states, including France, Ireland and the Nederlands (who test other vehicles but do not currently test bikes), they will now have to include motorcycles in their annual RWTs.

For new vehicles the Commission proposes that the first inspection will be after four years, followed by a second inspection two years later and thereafter annually. The proposed scheme will apply to all cars, motorcycles, mopeds, scooters, trikes and quads.

The proposals are based on EU figures that claim that more than five people die on roads every day due to technical failures in all vehicles, however, statistics show that there is little correlation in fatality rates in member states that have MOTs (notably UK, Germany and Sweden) and the eleven Member states that don’t, therefore the BMF and FEMA (Federation of European Motorcyclists Associations) are firmly against these proposals because critically, vehicle defects are rarely the cause of accidents.

In fact, the EU sponsored and BMF part-funded Motorcycle Accidents In Depth Study (MAIDS), the most comprehensive in-depth data currently available for Powered Two-Wheelers (PTWs) accidents in Europe, proved this point. The investigation was conducted over 3 years on 921 accidents from 5 countries and the results indicate that only 1.1% of accidents were caused by vehicle defects.

The Road Worthiness Test

The RWT will cover basically those items already covered by the UK MOT plus:

1. Emissions testing. Tested with a gas analyser or data from On-Board Diagnostic devices. This simply brings bikes into line with cars and the test will specifically show whether the bike is within tolerances set by the manufacturer or by Type Approval. (We don’t yet have word on whether this only applies to new bikes or what the rules will be for existing bikes).

2. Nuisance – Noise check/testing. As in the UK, the tester will assess noise level subjectively by ear and by checking exhaust system marking, but if the tester thinks the noise level is borderline, he will carry out an objective stationary test with a noise meter.

3. Brake fluid. Water content / boiling point analysed. Failure if contaminated

4. Anti-theft. Devices will be tested for functionality. If defective will result in failure.

5. Transmission. Inspected for soundness and illegal* power train modifications

6. Engine Performance. A visual inspection and if ECU and engine are illegally* modified will result in failure.

*Note: Modifications to the transmissions and engine as referred to in 6 and 7 will only result in a failure in those countries where modifications are already illegal (not the UK). This is unrelated to potential new rules on Type Approval for motorcycles.

7. Re-testing. This may be required after an accident has caused serious damage to the main safety related components such as wheels, suspension, steering or brakes

– when the safety and environmental systems and components of the vehicle have been altered or modified

– in case of a change of the holder of the registration certificate of a vehicle.

Note: Failures are categorised, Minor being down to the owner to rectify without necessarily needing a retest, Major within six weeks but those classed as Dangerous will result in the vehicle’s registration being revoked until it passes the test (currently in the UK, such vehicles can’t be driven on the road anyway).

The Effects

The only significant aspect for the UK concerns emissions testing. We would expect only new bikes manufactured under the new type approval rules to be tested for emissions as these are designed to last up to 50,000km without failing; however, the draft implies that current bikes would be tested too, but it is not yet clear as to what standards they will be tested to.

Also of interest is that there will be an option to exempt ‘historic vehicles’ over 30 years old.

Summary

The UK already has MOTs, so while the implications for the UK are minor compared with member states without RWTs, we fear that nevertheless the plans could mean higher costs for bike maintenance, especially with the emissions testing implications.

Because for many EU countries these proposals will mean either the implementation of a new test, making their current test much stricter or doubling the frequency, FEMA estimates that across Europe, affected motorcyclists will have to spend an extra €1.2bn in additional operational costs

Therefore we fully support our sister organisations across Europe in opposing this completely unnecessary legislation.

Original Source: Click Here

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  1. Interesting press release from European Commission – Representation In The United Kingdom.

    “The impact on the UK industry will be limited due to the high standards in relation to vehicle inspections already in force.”

    and

    “The proposals establish EU-wide minimum standards taking into account technological developments to strengthen and revise the current rules which date back to 1977.”

    Interesting comments to discuss?

    Click Here

  2. Put your pitchforks away and go home?

    The Association of Car Enthusiasts (ACE) have been very proactive with their concerns regarding the European proposal on Road Worthiness Testing and how they interpret its effect.

    Already they have had a response from UK MEPs:

    Philip Bradbourn MEP and Malcolm Harbour MEP (CON) said:

    Many correspondents, like you, have been concerned about the alarmist comments on this proposal that have appeared on some car enthusiasts web sites. We want to reassure you that it will certainly not be “sneaked into existence” to the detriment of owners and users of historic, modified and low volume specialist vehicles.

    To set this into context, this proposal is very far from being agreed, and has already been subject to extensive consultation. It is certainly not within “8 weeks” of being decided! It will go through a full Co-Decision procedure involving the European Parliament and all the Member Governments. The proposed content will certainly be modified extensively. It has many flaws and it is not at all clear that there will be a majority of Member States in favour of any EU intervention in this policy area. The UK has yet to take a position on it.

    Within the European Parliament, review of the dossier is being led by the Transport Committee, where Phil Bradbourn is a long standing and active member. The Internal Market Committee, which Malcolm Harbour chairs, will give an opinion along with 2 other Committees. A large number of UK MEPs will be examining the dossier and proposing amendments. No work has yet started on Parliament. We would not expect agreement before the end of 2013.

    Conservative MEPs will take great care to ensure that sympathetic treatment for historic and modified vehicles will be encompassed in any final legislation. For several years we have been working with the Federation of British Historical Vehicles Clubs, and their European Federation, to respond to consultations that the EU has been having on this proposal. The attached note from the FBHVC web site shows what has been going on. In the European Parliament we have a well-supported, all party and cross country Historic Vehicles Group that meets regularly to co-ordinate activities. We are very much aware of the economic importance of the historic vehicle movement.

    Original Source: Association of Car Enthusiasts (ACE) – Click Here

  3. Thank you John for your comments and encouragement. Reading positive remarks such as yours makes it all worthwhile.

    Trevor and Elaine

  4. John Chatterton-Ross says:

    Dear Right to Ride

    Thank you for this very helpful information from across all spectrums of opinion. This is a very difficult issue as riders have strong views affected by their national experience. In the UK this type of testing having been the norm since 1958 and now also adapted to check on basic environmental performance of a vehicle.

    In the discussions we have frequently had in the FIM we have always taken the view that this is a matter for national legislation. Now the EU is pressing ahead it is important that the outcome is as good as we can get it. Therefore it makes sense to review what is done at national level that works best, and to encourage governments when they finally have to follow a new EU law to follow examples that work well.

    The protests will go ahead, but I think that the chances of persuading the EU to abandon something that is already a norm for car and truck users is slight. If not for safety reasons then for reasons of policing environmental compliance I think this form of testing will be established.

    Thanks again for this very useful internet site which I find ranks up alongside MotoNet as a great source of news!

    kind regards,

    John Chatterton-Ross
    Director of Public Affairs
    FIM

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