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Three ways to strengthen the Commission’s GSR proposal:
1. Minimum ambition levels: Details of safety requirements are not provided in the Commission’s proposal. Instead, the Commission outsource the development of details to a Geneva-based body known as the United Nations Economic Commission for Europe (UNECE). The EU must define the minimum requirements in the regulation so that the UNECE has a framework that is adhered to.
2. Shorter lead-in times: The lead times for many of the technologies/design features are too far in the future. For example, direct vision for all trucks would not be an obligation before 2029 (assuming the final regulation is agreed in 2019). This delay is unnecessary and undesirable for improving vehicle safety. Bringing forward the date to 2024 would ensure that vulnerable road users are protected sooner while giving manufacturers sufficient time to adhere to the new requirements.
3. Deadlines for the UNECE: There must be a clear delegation of power to the Commission to bring forward legislation if (a) the ambition level at UNECE does not meet the minimum ambition level outlined in the GSR or (b) timely progress is not being made at the UNECE. Specifically, the law needs to require the Commission to bring forward legislative proposals three years ahead of the deadlines provided for each safety feature in the regulation so the EU is ready and able to step in if the UNECE is not delivering.