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3DLD Urgent - Fast - Targeted Lobby Required
3rd European Driving Licence Directive – Big brief – Your Turn For Action!
The 3rd European Driving Licence Directive saga moves into a critical penultimate stage.
The final text of the Directive has been published and it is expected that a Second Reading will take place in the European Parliament in the coming months.
However before the Second Reading there will be a TRAN Committee (Transport and Tourism) meeting taking place in Brussels on the 9th and 10th October.
As you are aware MAG has worked closely with Conservative MEP Philip Bradbourn who has tabled motorcycle friendly amendments previously and attended the MAG National Demo in July.
Through our work and with FEMA (Federation of European Motorcyclists Associations) Philip Bradbourn will be tabling amendments at the TRAN Committee meeting.
Our main objective at this stage is the support of the non Conservative MEPs who sit on the Tran Committee for the amendments.
If the amendments are accepted by the Tran Committee they will be read, discussed, voted on at the Second Reading in Parliament and not just rubber stamped.
I will be at the Tran Committee meeting and will be presenting MAGs petition opposing the motorcycle licensing and testing regime contained in the Directive.
If you haven’t signed the petition please do so Here
This full document can be downloaded from Here and the Campaign website Here
What we are Lobbying for in the Tran Committee
Regarding the amendments: Ask your MEPs to support Bradbourn amendments. Details of the selected MEPs to contact is below
Regarding the Directive: ask the selected MEPs to make sure the proposals in the Directive are opposed, to ensure a full debate in Plenary Session in the European Parliament (According to the rules of procedure, the amendments (our fall back positions) will be voted on first, then only the full proposal of the Directive. If less than 1/10 of the Committee (6) votes against the proposal, it does not go through Plenary. So we need to make sure (only in the case our amendments are not carried) that the proposal goes to Plenary for debate and therefore we need over6 MEPs to vote against the proposal.)
Suggested Letter
We usually state that standard letters can get ignored and for maximum impact every letter needs to be personal.
To give you an idea the sample letter below should be used as a guide when drafting your letters to MEPs.
However this is a complicated issue and the suggested letter below reflects this complexity. So at this stage if you wish you may just want to replicate the letter, bearing in mind the parts in italics and brackets.
A list of MEPs to contact is included at the end of this document.
Re: 3rd EU Driving Licence Directive – 2nd reading
Dear [Name of your MEP],
You are no doubt aware that the European Parliament is to undertake the Second Reading of the Third EC Driving Licence Directive at some time in October.
As an [active motorcyclist/Motorcycle Action Group member] I have followed [and participated] in the debate regarding this directive through FEMA (Federation of European Motorcyclists Associations).
I am extremely concerned that the opinions of motorcyclists and their representatives have been ignored throughout the whole legislative process by the European Commission and their representatives.
FEMA supported the principles behind progressive access to motorcycles as proposed by the initial draft from the Commission. However, successive modifications made by the Parliament in the First Reading, then the Transport Council, have transform this progressive access into what I can only describe as a series of hoops and hurdles which I consider both unjustified and unfair. I have enclosed a graph in Annex 2 [or can be viewed at http://tinyurl.com/fjzel] which outlines the complexity of the proposal and why the rational of licence harmonization will never be achieved.
While it is claimed that the currently proposed progressive access will improve motorcycle safety, we motorcyclists believe the contrary.
In its current form, the draft Directive clearly disadvantages motorcyclists, creating unacceptable financial barriers to motorcycling without any guarantee of improving motorcycle safety. The motorcycle provisions in the current version take into account Member State local characteristics rather than harmonization or safety improvement.
United Kingdom member, Philip Bradbourn is proposing amendments to counter a number of issues raised by the Directive. As a member or substitute of the TRAN Committee, we ask you to consider the concerns listed at the end of this letter regarding proposals relating to motorcycling.
Please note that the proposals below reflect not only the position of myself but both rider organisations in the UK the Motorcycle Action Group (MAG UK), the British Motorcyclists Federation (BMF)] and the pan-European riders’ organisation, the Federation of European Motorcyclists’ Associations (FEMA).
I believe that the motorcycle part of the Directive is damaging for the following reasons.
While it is undoubtedly desirable to improve motorcycle safety regardless of the accuracy of casualty statistics, the rationale behind the motorcycling proposals is questionable. The review of the Road Safety Action Plan has been cited as alleging an increase in motorcyclists’ casualties. It has failed to take into account the increase in usage of motorcycles with a constantly falling rate and the reduction in casualties.
The main reasoning is that the strict application and moving age limits upwards and the complicated regime of testing without looking at how riders are trained will not improve motorcycling or the safety of riders.
The complexity of the proposals will not be understood by potential motorcyclists leading to less compliance diminishing the safety sought by the draft Directive.
In seeking to reduce road casualties, the European institutions have ignored the expert opinions of the motorcycle community and their representatives.
In drafting the Directive, it failed to take into account recent research into motorcycle safety including the Motorcycle Accident In-Depth Study (MAIDS).
It will cut across the positive recommendations such as those made in the UK’s The Government’s Motorcycling Strategy:
Improving standards of training
A register of instructors.
Incentives for better post-test training.
More Bikesafe assessments, Rider Improvement courses and Speed Awareness courses.
Raising awareness of motorcyclists by other road users.
The whole process of the directive can be seen as a philosophical approach that tougher testing and training will reduce accidents. It may well reduce accidents but simply by reducing the numbers of motorcyclists.
They will limit access to motorcycling, particularly for younger riders making the take-up of motorcycling more complex and expensive.
The inevitable fall in the take-up of motorcycling by new riders will lead to a decline in the number of motorcyclists diminishing the influence of the motorcycling community and denying society motorcycling’s benefits in addressing social exclusion, congestion and land use (parking).
The Directive is premature as the 2nd European Directive regarding motorcycle testing has still to be implemented in several countries.
The enforcement community, already struggling with the requirements of the 2nd EC Driving Licence Directive will not fully comprehend the 3rd EC Driving Licence rendering it unenforceable.
Overall I would ask you to support the following positions tabled by the motorcycle community across Europe.
[I have included a list of the amendments see Annex 1/which can be viewed at http://tinyurl.com/epu8a]
That Common Position of the 3rd EC Driving Licence Directive is subject to a full Second Reading as opposed to a formal reading. We anticipate that the Rapporteur will call for a formal reading which we believe MEPs should reject. The European Parliament should be prepared to go to the Conciliation Procedure if necessary.
That the motorcycle aspects of the directive should be withdrawn so that a more meaningful directive can be redrafted with full consultation with the motorcycle experts.
That you support the amendments tabled by Mr. Bradbourn to improve the current draft directive if the full withdrawal of the motorcycle aspects can not be obtained.
Deletion of the “test of skills and behaviour only, or completed a training pursuant to Annex VI” between A2 and A categories – it introduces an unacceptable and additional unnecessary barrier to motorcycling, both in terms of time spent and financial outlay. This test or training is not consistent with the logic of the step-up age approach. Germany abolished such an approach after discovering that the additional practical test did not positively contribute to improved road safety. Road safety has not been impaired as a result.
Direct access category A at 21 years of age - direct access to upper category of motorcycle licence should be applied at 21 years instead of 24. Access age to a motorbike should be seen in the context of access to other categories of vehicles, which is 18 years for a passenger car of any power. Motorcycle Direct Access is currently 21 years in the UK. 24 years of age is excessive: studies and accident statistics indicate that the age bracket 18-21 is the most vulnerable for any category of motorised vehicle.
Deletion of reference to cylinder capacity - This proposal unjustifiably restricts the vehicle models which can be used for the test. An engine power criteria is sufficient. It would be a real barrier if applicants were forced to pass this test on a different type of vehicle (i.e. >400cc motorcycle) instead of very often their own vehicle. Further, the possibility of using their own vehicle for the training and for the test reduces costs for the applicant and also increases road safety as the applicant improves its knowledge of the vehicle he will be allowed to use in traffic once the licence is obtained.
MEPs To Contact
These are the UK MEPS who sit on the TRAN - Committee on Transport and Tourism in Europe.
Only contact these MEPs if you are in their constituency. For details see HERE
Labour
Gary Titley – North West MEP - Socialist Group in the European Parliament
gary.titley@europarl.europa.eu
contact@gary-titley-mep.new.labour.org.uk
www.garytitley.com
Visited at the European Parliament by MAG
Robert Evans – London MEP - Socialist Group in the European Parliament
robertevansmep@btclick.com
robert.evans@europarl.europa.eu
robertevansmep@yahoo.co.uk
Catherine Stihler – Scotland MEP - Socialist Group in the European Parliament
cstihler@cstihlermep.freeserve.co.uk
www.cstihlermep.com
Labour MEPs generally support the Directive or certain aspects of the directive. The main support would be for the amendments without the removal of the whole directive.
Independent
Ashley Mote – South East MEP - Non-attached Members
ashley.mote@europarl.europa.eu
www.ashleymote.co.uk
We have had no contact or rather no response from Ashley Mote
UKIP
Michael Henry Nattrass – West Midlands MEP
michaelhenry.nattrass@europarl.eu
www.mikenattrassmep.co.uk
Public support of motorcyclists’ position regarding the removal of the whole directive.
However we would wish him to support amendments and not just the removal of the directive as a whole which would be presented at the Second Reading in Parliament or in Committee.
Postal Address
[Name of MEP]
Altiero Spinelli Building
European Parliament
60 Rue Wiertz
B-1047 Brussels
Belgium
Please forward any responses to myself:
Trevor Baird
Director Of Public Affairs (MAG UK)
public-affairs@mag-uk.org
MAG UK
PO BOX 750
Rugby
CV21 3ZR
ANNEX 1
Proposal for Third Directive on Driving Licences
FEMA (Federation of European Motorcyclists Associations)
Proposed Amendments
Amendment Article 4 Paragraph 3, Letter C, Category A
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- The minimum age for category A is fixed at 20 years. However, access to the driving of motorcycles of this category shall be subject to a minimum of two years' experience on motorcycles under an A2 licence. This requirement as to previous experience may be waived if the candidate is at least 24 years old.
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- The minimum age for category A is fixed at 20 years. However, access to the driving of motorcycles of this category shall be subject to a minimum of two years' experience on motorcycles under an A2 licence. This requirement as to previous experience may be waived if the candidate is at least 21 years old.
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Justification
Access age to a motorbike should be seen in the context of access to other categories of vehicles, which is 18 years for a passenger car of any power. 24 years of age is excessive: studies and accident statistics indicate that the age bracket 18-21 is the most vulnerable for any category of motorised vehicle.
Amendment Article 4 Paragraph 6, Category A
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6. Member States may raise or lower the minimum age for issuing a driving licence:
(a) for category AM down to 14 years or up to 18 years;
(b) for category B1 up to 18 years;
(c) for category A1 up to 17 or 18 years,
if there is a two years difference between the minimum age for category A1
and the minimum age for category A2, and
– there is a requirement of a minimum of two years experience on motorcycles of category A2 before access to the driving of motorcycles for category A can be granted, as referred to in Article 4(3)(c)(i);
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6. Member States may raise or lower the minimum age for issuing a driving licence:
(a) for category AM down to 14 years or up to 17 years;
(b) for category B1 up to 18 years;
(c) for category A1 up to 17 [-deleted - or 18] years, if there is a two years difference between the minimum age for category A1 and the minimum age for category A2, and – there is a requirement of a minimum of two years experience on motorcycles of category A2 before access to the driving of motorcycles for category A can be granted, as referred to in Article 4(3)(c)(i);
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Justification
The main aim of the original proposal was the harmonisation across Europe. The above provision is indeed against European harmonization as it distorts the system proposed by the European Commission unjustifiably discriminating European citizens.
However, some Member States expressed the will to maintain their motorcycle access scheme, which will determine a too big disparity amongst citizens across the EU. Hence, taking the latter into due consideration, is a good compromise to limit the Member States age flexibility for motorcycle access to 1 year only.
Amendment Article 7, Letter C, Category A
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- (C) who have, as regards category A2 or category A, on the condition of having acquired a minimum of 2 years' experience on a motorcycle in category A1 or in category A2 respectively, passed a test of skills and behaviour only, or completed a training pursuant to Annex VI;
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- (C) who have, as regards category A2 [ category A – deleted -], on the condition of having acquired a minimum of 2 years' experience on a motorcycle in category A1 [category A2 – deleted - ], passed a test of skills and behaviour only, or completed a training pursuant to Annex VI;
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Justification
Please refer to the next amendment
Amendment Article 7, new Letter C(1), Category A
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- (C) (1) who have, as regards category A, on the condition of having acquired a minimum of 2 years' experience on a motorcycle in category A2.
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Justification
The proposed “test of skills and behaviour only, or completed a training pursuant to Annex VI” introduces an unacceptable and additional unnecessary barrier to motorcycling, both in terms of time spent and financial outlay. This test or training is not consistent with the logic of the step-up age approach.
Germany abolished such an approach after discovering that the additional practical test did not positively contribute to improved road safety. Road safety has not been impaired as a result.
Amendment Annex II Part B, Category A2
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- Category A2:
Motorcycle without sidecar, with a cylinder capacity of at least 400 cm3, and an engine power of at least 25 kW
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- Category A2:
Motorcycle without sidecar, with [a cylinder capacity of at least 400 cm3, and– deleted -] an engine power of at least 25 kW
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Justification
This proposal unjustifiably restricts the vehicle models which can be used for the test. An engine power criteria is sufficient. In fact, in many Member States, the most common powered two-wheelers are 200-250cc scooters, which can be used with an A2 licence. It would be a real barrier if applicants were forced to pass this test on a different type of vehicle (i.e. >400cc motorcycle) instead of very often their own vehicle.
Further, the possibility of using their own vehicle for the training and for the test reduces costs for the applicant and also increases road safety as the applicant improves its knowledge of the vehicle he will be allowed to use in traffic once the licence is obtained.
Amendment Annex II Part B, Category A
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- Category A
Motorcycle without sidecar, with a cylinder capacity of at least 600 cm3, and an engine power of at least 40 kW
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- Category A
Motorcycle without sidecar, with [a cylinder capacity of at least 600 cm3, and - deleted -] an engine power of at least 35 kW
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Justification
This proposal unjustifiably restricts the vehicle models which can be used for the test. An engine power criteria is sufficient.
ANNEX 2
Graph available at http://tinyurl.com/fjzel
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