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European Federation of Road Traffic Victims

FEVR

The "Federacion Europeenne des Victimes de la Route AISBL" was established in 1991, now registered in Belgium, and is an umbrella organisation of national associations advocating for road victims, supporting them and improving road safety.

Lobbying Activity

Response to Technical requirements and test procedure for approval of intelligent speed assistance (ISA)

28 Apr 2021

FEVR welcomes the European Commission's draft Delegated Regulation on Intelligent Speed Assistance (ISA) systems. Inappropriate speed is a key factor in around one third of fatal collisions and an aggravating factor in most collisions. Research has shown that ISA systems could help to achieve a high level of compliance with speed limits and eventually cut road deaths by 20%. We therefore welcome the draft Delegated Regulation implementing the requirement in the General Safety Regulation for all new types of vehicles to be fitted with ISA systems, which will contribute to making our roads safer as from July 2022. The draft Delegated Regulation does not require the ISA system’s speed limit information function to take into account “special variable conditions”, including time of day and time of year (3.4.2.3.2.). Road victims often have to fight for their rights for years, often in vain due to insufficient evidence. Moreover, we regret that it furthermore does not require ISA systems to detect sub-signs on vehicle categories and time of day (5.3.3.). These are important for the correct determination of the speed limit, and thereby for the correctness of the speed limit information provided to the driver. Drivers are again very likely to be annoyed if they are presented with incorrect speed limit information based on these conditional speed limits. FEVR particularly welcomes the 90% performance target for the detection of applicable speed limits, as ISA systems will only be able to assist the driver in complying with the speed limit, if the system can detect the applicable speed limits accurately and reliably. Any lower performance requirement would mean that ISA systems will not be sufficiently effective in improving road safety, both directly by not being able to assist the driver correctly, and indirectly as incorrect information would cause annoyance to drivers which may lead them to turn off the ISA systems. In this regard, we call on EU Member States to assist the European Commission in completing Annex II on the catalogue of road signs, given its importance for the correct functioning of ISA systems. We furthermore call on the European Commission to improve the draft Delegated Regulation by removing the un-tested cascading warnings, which have not been shown to be effective nor appropriate, as well as by requiring regional speed limits to be taken into account by ISA systems and conditional speed limits such as time of day to be detected.
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Meeting with Violeta Bulc (Commissioner) and

9 Mar 2017 · Quick meeting with Robert Staba, VP of FEVR

Meeting with Jean-Claude Juncker (President) and

5 Feb 2016 · Meeting with with Mr Antonio Avenoso and Mr Jeannot Mersch on EU action to support Road Safety

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

4 Feb 2016 · Road safety

Meeting with Paula Duarte Gaspar (Cabinet of Commissioner Vytenis Andriukaitis)

13 Oct 2015 · Health angle (prevention, effect) of traffic accidents

Meeting with Violeta Bulc (Commissioner) and

12 Oct 2015 · Meeting FEVR representatives