Statement to LVM on the evaluation memorandum on the amendment of the directive on the management of road infrastructure safety

Investing in road maintenance significantly improves traffic safety. The better condition the pavement and road markings and traffic signs are in, the better the driver is able to drive proactively

INFRA ry's statement on the evaluation memorandum on the implementation of Directive (EU) 2008/96 on the amendment of Directive 2019/1936/EC on the management of road infrastructure safety and the need for changes in national legislation and other needs for changes in the law on the transport system and roads.

INFRA ry thanks for the opportunity to make a statement on the matter and states the following in its statement.

What are the costs of the actions required by the current directive and the estimated effects on traffic safety?

INFRA ry estimates that the actions required by the directive will improve traffic safety. The actions required by the directive will increase, depending on the chosen scope option, the costs of road infrastructure management and maintenance, as well as investment costs for new road investments.

If it is possible to put a price tag on the traffic safety that has improved as a result of the directive, it is likely that the calculated total costs will nevertheless decrease.

The increase in direct costs would be the largest for the options presented on pages 3–4 of the estimate memorandum in option 1, where the scope would in the future cover 8 km instead of the current 950 km. However, if it can be shown that the financial savings from improved traffic safety are greater than the costs incurred from expanding the scope of the directive with regard to option 5, it makes the most sense to choose option 195. Also from a humane point of view, option 1 is the most justified. Our goal should be to reduce traffic deaths and injuries to zero.

INFRA ry supports choosing option 1 to define the scope of application.

How does traffic safety improve with the measures required by the directive and how can it be evaluated statistically and computationally as cost effects (reduction of serious injuries and traffic deaths)?

The improvement of traffic safety depends on the measures implemented, which in turn depends on the seriousness with which the proper monitoring of road infrastructure safety management procedures according to the new article of the directive is taken.

According to the evaluation report: "With the change, the regulation regarding the targeting of road safety inspections and corrective measures would be further refined, also linking them together with the new network-wide road assessment and the findings made in it. In particular, it would be new if every decision concerning compliance with a recommendation based on a road safety inspection is properly justified. Member States should also draw up and regularly update a risk-based prioritized action plan to monitor the implementation of the decided corrective actions. In the further preparation, the connection of the action plan required from the member states to the national transport system plan and the Traffic Safety Strategy, as well as how the financing of the actions required by the action plan will be ensured, must be clarified."

In other words, the more attention is paid to traffic safety and the more effective it is perceived as a reducer of total costs, the better traffic safety will develop.

What do the requirements of the directive mean in practice in the activities of the Finnish Transport Agency, the ELY centers and the Finnish Transport and Communications Agency (e.g. tasks, procedures, costs)?

As regards the Norwegian Railways Agency, the ELY centers and the Finnish Transport and Communications Agency, the requirements of the directive slightly increase the need for resources. Regarding procedures, one change would be the "Road safety assessment procedure" mentioned on page 5 of the assessment memorandum. In terms of procedures, the size of the change would be affected by how literally the new procedure would be followed and how effective the connection between safety observations and corrective measures would become. This connection would naturally also have an impact on costs.

In terms of costs, depending on the chosen option of the scope of application, the costs of road maintenance will rise more or less.

How do the requirements affect the planning, construction and maintenance of roads in practice?

In practice, the importance of traffic safety in the planning, construction and maintenance of roads would increase even more.

If the steering effect of traffic safety in road planning were increased, we would see more solutions that would improve traffic safety, but also increase immediate investment and maintenance costs.

Particularly effective ways to prevent serious traffic accidents are, for example, removing level crossings (especially so-called "space junctions") from the main road network, building the main road network into four lanes (2 lanes in each direction) and separating oncoming traffic with a median lane or guardrail.

Investing in maintenance (=maintenance contracts), which is also mentioned in the evaluation report, significantly improves traffic safety. For example, the better condition the pavement and road markings and traffic signs are, the better the driver is able to drive proactively. This is particularly emphasized when it comes to the functionality of automatic driver assistance systems.

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