ANNEX: Department for Transport's initial findings
CONSULTATION RESPONSES
We asked the consultees the following specific questions
as well as for their general comments on the proposal. Our initial
findings and initial responses are:
Q1. Do you Support Proposal? 70% of respondents support
the proposal and 20% are against it.
Initial DfT Response:
The majority of respondents are in favour of any road safety initiatives
— Those who are not in favour are concerned about the initial.
cost compared with the projected benefits.
Q2. Do you Foresee any Problems? 53% of respondents
foresee problems with supply and compliance and 16% see no problems.
16% did not respond either positively or negatively but expressed
concerns.
Initial DfT Response:
Industry is concerned that the supply of suitable mirrors will
not be readily available in the time scale available.
Q3. Is Front Mirror a Good Idea? 63% of respondents
agree with front mirror, 10% disagree and 16% did not respond
either positively or negatively but expressed concerns
Initial DfT Response:
The majority of respondents are in favour of any road safety initiatives
— Those who are not in favour are concerned about the difficulty
and cost of installation on cabs not designed for these mirrors.
Q4. Are PRIA [partial Regulatory Impact Assessment]
Costs and Benefits Reasonable? 21% of respondents agree with PRIA
costs. 36% disagree and 10% did not respond either positively
or negatively but expressed concerns.
Initial DfT Response:
Some respondents appear to show bias according [to] their support
for the proposal and others appear to have confused the EP [European
Parliament] and UK PRIA figures.
Q5. Competition and Small Business Effect Reasonable?
26% of respondents agree. 26% disagree and 10% did not respond
either positively or negatively but expressed concerns.
Initial DfT Response:
Most respondents did not answer this question. Those that did,
appear to show bias according [to] their support for the proposal.
RESPONDENTS VIEWS
Industry representatives (53%) were concerned about
the:
1. financial impact, which would be borne by
their members over a short time period — financial support
should be given by Government
2. evidence in PRIA not justified, overestimates
benefits and underestimates costs
3. mirror manufacturers, who may not be able
to supply the quantity of mirrors required in the short time frame
available — phased implementation preferred
4. difficulty of installing additional mirrors
onto older vehicles — fitment should be optional
5. difficulty of verifying mirror compliance
LOCAL GOVERNMENT AND POLICE FORCE (15.5%):
1. fully supported the proposals
2. wanted awareness campaigns in the proposal
3. had no concerns
VULNERABLE ROAD USER REPRESENTATIVES (21%):
1. PRIA underestimates benefits and overestimates
costs
2. wanted the front mirror included in the proposal
3. wanted awareness campaigns included in the
proposal
4. were not concerned about the financial impact
on industry
5. some wanted full [Directive] 2003/97 compliance
included in the proposal
Camera/monitor manufacturers (10.5%) were concerned
that:
1. camera/monitor systems are not an option and
the proposal should be reworded to include these
2. one mirror manufacturer (allegedly) supplies
more than 50% of the EU market
| Q1. Do you Support Proposal? |
Q2. Do you Foresee any Problems? |
Q3. Is Front Mirror a Good Idea? |
Q4. Are RIA Costs and Benefits Reasonable? |
Q5. Competition and Small Business Effect Reasonable? |
| 70% of respondents support proposal. 20% against (main industry stakeholders). Others — No comment |
53% of respondents foresee problems with supply and compliance. 16% see no problems and 16% have concerns (mainly pro camera). Others — No comment. |
63% of respondents agree with front mirror. 10% disagree and 16% have concerns (mainly pro camera). Others — No comment. |
21% of respondents agree with RIA costs. 36% disagree and 10% have concerns (mainly pro camera). Others — No comment. |
26% of respondents agree with small business effects. 26% disagree and 10% have concerns (mainly pro camera). Others — No comment. |
Respondent Representation
10 of 19 = Road Haulage Industry (53%), 1 of 19
= Local Government (5%), 2 of 19 = Police Force (10.5%), 4 of
19 = Vulnerable Road User Representatives (21%), 2 of 19 = Camera/Monitor
Manufacturers (10.5%)
| 
