APPENDIX ONE
Response from Transport for London
PEDESTRIAN PROTECTION—CONSULTATION
ON A NEGOTIATED AGREEMENT WITH THE CAR MANUFACTURERS
INTRODUCTION
This document represents the response of Transport
for London to the Pedestrian Protection Consultation issued by
the DTLR on 3 September.
BACKGROUND
Transport for London regards reducing pedestrian
casualties as a high priority. The Mayor's Transport Strategy
adopts as a target a reduction in pedestrian killed and seriously
injured casualties of 40 per cent by the year 2010.
In 2000 in London 140 fatalities from road crashes
were pedestrians out of a total 284 fatalities—almost half.
Fatal and serious pedestrian casualties made up 30 per cent of
the total fatal and serious casualties from road crashes.
The crash records for 1999 for London show that
cars were involved in 73 per cent of all road incidents that involved
a pedestrian casualty.
The majority of the pedestrian casualties occurred
on roads with 30mph speed limits. It is under these lower speed
situations that improving the front of vehicles is likely to have
the most benefit for reducing deaths and severe injuries for pedestrians.
These figures show that there is scope to make
a significant reduction in the total number of killed and seriously
injured casualties from road crashes in London through improving
the front of cars.
Improvements to the front of cars could also
benefit cyclists by reducing the severity of their injuries when
struck by a car. The Mayor's Transport Strategy seeks to increase
the extent of walking and cycling and improved safety for both
these categories of road users will be invaluable.
It can be seen from the above that safer car
fronts for pedestrians, that could also be of benefit to cyclists,
are of vital importance for the Mayor and Transport for London.
RESPONSE
Transport for London opposes the draft voluntary
agreement because it does not offer an equivalent level of protection
compared with the four tests required by the European Enhanced
Vehicle-safety Committee (EEVC) methods.
The voluntary agreement is likely to lead to
fewer and weaker tests and result in vehicles that cause greater
injuries and deaths to pedestrians in London that would arise
if vehicles were designed to meet the full test standards.
It is not clear what sanctions can be applied
to such a voluntary agreement, and what confidence can be placed
on the manufacturers not amending and further weakening the proposals.
The success of the Honda Civic in meeting 70
per cent of the EEVC test requirements for pedestrians now shows
that real progress can be achieved quickly and without undue costs.
The voluntary agreement proposes that all new
cars will meet the Phase 1 tests by 2012. It is forecast that
these Phase 1 tests will be only 50 per cent as effective in reducing
fatalities as the full tests devised by the EEVC. This is inadequate
and appears to be a retrograde step in comparison with what Honda
has already achieved.
With the exception of the Honda Civic the European
can industry has not acted voluntarily to provide safer car fronts
for pedestrians and cyclists despite the available information
on the injury problem.
This is such an important matter for London
that TfL believe that the full power of the EC should be brought
to bear to ensure that new cars satisfy the four EEVC tests by
2008 at the latest.
The case for adopting a traditional European
Parliament and Council Directive for achieving safer car fronts
has been well made by the European Transport Safety Council and
this position is fully supported by Transport for London.
If the challenging targets set by the Government
to reduce the number of deaths and injury are to be met it is
vitally important that the car industry is seen to be playing
an active role in contributing to this challenge, sooner rather
than later, by adopting proven design standards, that provide
improved safety for pedestrians and cyclists.
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