Devon TRF Group Forum

The UK supports effective safety measures provided a robust Impact Assessment demonstrates a positive cost benefit.  ABS on two-wheelers has been shown by a recent study carried out on behalf of the Department2 to have the potential to prevent up to 6% of injury accidents in the UK. Further work is now required to determine the cost
implications that any mandatory requirements would impose.  Our study indicates that the benefits are likely to be greater for larger capacity machines. From this we conclude that extension of ABS to all categories on a mandatory basis is unlikely to offer sufficient benefits that outweigh the significant costs. It is necessary to understand this issue better and the possibilities should be considered jointly by the Commission and the Member States working closely with stakeholders in the sectors involved.

Question 7: In your opinion, are there other/supplementary solutions better
suited for certain categories (i.e. coupled braking, stability control systems,
etc.) that would produce the same/better effect at better costs?

This should be explored with industry and other stakeholders. There is a risk
that mandating ABS will deter manufacturers from developing alternative solutions that may offer similar or greater benefits and be more cost effective for particular categories of vehicle. The potential for alternative solutions, for example, voluntary commitments or consumer awareness schemes should also be explored. Simple alternatives to ABS may be more appropriate and cost effective for smaller machines however care is needed to ensure that technologies fitted to bikes used by inexperienced and learner riders are consistent in their performance with those fitted to larger machines. If this is not the case then there will be the possibility that riders will need to adapt their riding style to
accommodate different braking technologies on different machines. Our research suggests coupled braking is likely to provide additional safety benefits for motorcyclists although these are expected to be lower than ABS.  However, this assessment was based on very limited information highlighting the need for a better understanding of the effectiveness of such systems. At present it is probably premature to consider legislation mandating the fitment of these systems.

Question 8: Do you think that the additional measures proposed by the TüV
study and the one proposed in the Motorcycle working group mentioned
above? Why?

With respect to the recommendations for additional anti-tampering measures in the TUV study, proposals to prohibit removable components from silencers, cycle beating in respect of noise and to address modifications to electronic control systems/software seem sensible. We have not commented on TUV proposals which relate to roadworthiness enforcement etc, which we presume to be outside the scope of this consultation.
We are sceptical of the benefit of current anti-tampering provisions and would expect to see a cost benefit assessment for any additional measures. We can see the logic of anti-tampering requirements on vehicles where licencing restrictions exist and so extending anti-tampering requirements to motorcycles limited to 25kW may be justified. However we see no justification for extension to higher performance machines which are not associated with driver licensing restrictions.