1 February 2008
Mr. Jacques Barrot
Vice-president of the European Commission,
in charge of transport
Rue de la Loi 200
CONCERNING: Texts in the Road Traffic Act and the Regulation on its Application, which are dangerous for the pedestrians
DEAR Mr. BARROT,
My name is Jordan Philipov and I am citizen of the Republic of Bulgaria.
I turn to you in your capacity of Vice-president of the European Commission with responsibility for transport. I am convinced that you treat road safety as a top priority of the institutions dealing with the problem. In states where there is real reduction of road accidents, the rate of the number of pedestrians - victims of traffic accidents is lower than the other participants in the traffic. This makes the pedestrian as the most endangered road user.
I have been prompted to write this letter by some texts of the Bulgarian Road Traffic Act and Regulations thereto, which, to say the least, do not safeguard the safety of the pedestrian. Moreover, they put this safety at risk.
To be precise, Article 94. par. 3 and Article 98 of the Road Traffic Act and Article 96. par. 3 and Article 101, item 2, point 2 of the Regulations allow vehicle traffic on the pavement (parking and short-time parking). The texts dealing with places where it is forbidden to stop or park any vehicle do not mention specifically the pavement. At the end of my letter I have attached the relevant excerpts of the Act and the Regulations commented by me.
As Chairman of Foundation “PEDESTRIANS” I have tried to initiate amendments of the text at the time of its approval by the Transports and Communications Committee at the Bulgarian Parliament in May 2007. However it is to be regretted that the Members of Parliament did not pay any attention to this problem.
My request to the President of Bulgaria not to approve the Act in this part had similar result.
Here are some parts of the reasons why the commented texts, which allow “taking up” the vehicles on the pavements, produce sharp objections, I dare say, not just by me:
I think it would be correct that the texts of the law explicitly ban any traffic, stopping, parking of any vehicles on the pavement. The owner or the administrator of the roads should have the right and the responsibility, when they reason that it would be admissible to turn any pavement or part of it into a parking place, to demarcate and make safe any such place. In this way every one will know that it is according to the law that pavements remain exclusively for pedestrians and are banned for cars.
The pedestrians of the Republic of Bulgaria are tax-payers of a member-state of the European Union and through you they seek protection of their rights being the most endangered consumers of roads in Bulgaria.
It is with special hope that I address this letter to you asking for protection and support of the pedestrians. Any human being is first of all a pedestrian.
We are looking forward to your understanding and taking any measures you think necessary to amend the legislation mentioned by me.
Thanks in advance
Address: Dianabad bl.43 en.2 ap.30 1172 Sofia Bulgaria
Tel/fax: +359 2 862 9383 GSM +359 888 364 694
Road Traffic Act
Article 94 (3) (Amended SG No. 43/2002, 51/2007) Vehicles shall stop and park in populated places possibly at the extreme right on the traffic lane in the direction of traffic and parallel to the axis of the road. Stopping and parking of vehicles with maximum mass less than 2.5 tons on the pavement shall be allowed, only on places defined by the owners or administration, parallel to the axis of the road, if a distance of at least 2 meters remains between the vehicle and the opposite building to allow the passing of the pedestrians.
Article 98 (1) Stopping and the parking shall be banned when:
(2) In Addition to the cases indicated in Par.1 parking shall be banned:
2. on the traffic lane and on the pavement directly in front of the entrances of living buildings and garages when this makes access thereto difficult.
6.(new – SG No. 51/2007) in front of entrances and adjacent pavements of children facilities and schools.
Article 101 (2) 2. On the traffic lane and on the pavement directly in front of the entrances of living buildings and garages when this makes access thereto difficult=
Regulation for application of the Road Traffic Act
Article 96 (1) Vehicles shall stop outside populated places out of the traffic lane. When this is impossible they shall stop parallel of the traffic lane in the extreme right on the lane.
(3) Vehicles shall stop and park in populated places possibly at the extreme right on the traffic lane in the direction of traffic and parallel to the axis of the road. Stopping and parking of vehicles with maximum mass less than 2.5 tons on the pavement shall be allowed, if a distance of at least 1.5 meters remains between the vehicle and the opposite building to allow the passing of the pedestrians