We are writing to alert you to the fact that the Federal Government is currently considering the adoption of European developed (UNECE) regulations governing the design and safety performance of vehicles that come into contact with pedestrians.  In simple terms, if the regulation were adopted in full, there would be a requirement for every new vehicle sold in Australia to meet pedestrian safety criteria, which would be administered via the Australian Design Rule (ADR) process.  While it does seem reasonable that regulators are looking to the vehicle design to reduce harm to pedestrians, this regulation also incorporates the design and performance of vehicle frontal protection systems (bull bars & nudge bars).  In our view, full adoption of this standard could spell the end of the Australian steel and alloy bull bar as we know them. 

As part of this process the Federal Government has prepared a Regulation Impact Statement and is inviting public comment over a three month period  (ending 15 April 2011) which will be factored into their final decision process. To read and respond to the Federal Government Regulation Impact Statement for Pedestrian Safety Standards, visit:

http://www.infrastructure.gov.au/roads/environment/files/Pedestrian_safety_RIS_PUBLIC_CONSULT_FINAL.pdf

The AAAA through the 4WD Industry Council has been consulting closely with Government and other key stakeholders such as the vehicle manufacturers, 4WD User Groups and fellow industry associations on this issue for over 18 months and our activities are being coordinated via a Bull Bar sub-committee. We have already been successful in lobbying for some concessions to the main recommendations contained in the RIS however in our view these concessions do not yet go far enough.

The Australian landscape and our broad expanse of rural roads often expose road users to encounters with animals, with the majority of serious collisions occurring in regional, rural and outer urban areas.  The condition of many regional roads and our road design which includes verges and drainage ditches running alongside major roads increases the risk of animal strike, particularly in drought conditions.  The urban spread of our major cities and mobility of our population has also blurred the line between urban and regional Australia.

While the AAAA understands the merits of international harmonisation of standards, we believe that harmonisation should only be considered if the relevant standard or regulation is appropriate for the local conditions.  Australian driving conditions vary enormously from European conditions; particularly the physical and weather environment, the increasing incidents of large native animals on urban roads, the level and concentration of built up areas in Europe compared to Australia.  These factors all make Australia a unique driving environment and in our part of the world, bull bars are designed to save the lives of the drivers and passengers of the vehicle.  An impact at over 25 kilometres an hour with a large native or domestic animal may result in driver and passenger injury and death.  Whilst some members of the public perceive these accessories as unnecessary – the producers, distributors and users of bull bars know that they save lives. 

In addition to developing a comprehensive and researched response to the RIS, we will also be coordinating a communication campaign to encourage other impacted stakeholders to respond to the RIS on behalf of their constituents. We are also rolling out a coordinated and comprehensive Government relations strategy to ensure that the views of our industry are factored into the decision making process.  AAAA members potentially impacted by these regulations will be called on to assist with these efforts over the coming months.

To assist in gathering up-to-date data to support our submission, the 4WD Industry Council has developed an online survey to be completed by vehicle owners on the use of bull and nudge bars. The objective of the survey is to learn more about vehicle types, driving patterns and critical safety issues, such as animal strikes and other impacts. This information will assist us to address the lack of uniform data about the estimated 25,000 to 30,000 vehicle-to-animal strikes occurring each year across Australia. We do not believe that good regulatory decisions can be made without proper research and without canvassing all key issues.

We would appreciate your assistance in directing relevant vehicle users to www.4wdcouncil.com.au to complete the survey. For every person completing the questionnaire, the industry will donate $1 to the Royal Flying Doctor Service, to a maximum of $20,000.

We will keep you updated regularly on progress on this issue.