Mister President,

 The Federation I am presiding reassembles the national Federations or Clubs of Belgium, Spain, France, Great Britain, Italy, Luxembourg, Portugal and Switzerland. Germany and Scandinavian countries could rejoin us in a near future. That is to prove how much we represent the big motorhome family. That is why I officially beg you for  a modification of the directive 2006/126/CE of the European Parliament and the Council dated Dec. 20th, 2006 concerning the driving licence published in the official paper n° L 403 dated 31/12/2006 p. 0018-0060
 
In fact, according to an investigation made in early 2008, about 80% of the motorhomes actually run in overload. The origin of the situation is due to several levels of responsibility:
- The dealers who propose, often free of charge, to equip the new motorhomes with all sorts of accessories.
- The manufacturers build motorhomes of big dimensions, always better equipped, and, for this reason, no more charge can be carried in the motorhomes.
- The authorities in charge of the official approval of the vehicles who do not respect the laws concerning the maximum authorized load.
-The authorities who oblige the manufacturers and the engine- designers to increase the security and to diminish the pollution.
This increases the weight of the vehicles according to the same models of vehicles which were built before.
- To some extent, the owners of motorhomes themselves.

As far as we are concerned, we think that the easy way out of this problem would be to accept these vehichles as « heavy goods vehicles » with carrying capacity of 400 kg.
This requires, of course, that the owners of motorhomes would be allowed to drive vehicles of a total weight (PTAC) above 3'500 Kg.

Several country-members have been able to accept driving licences for motorhomes weighing more than 3'500 Kg, as long as their owners had obtained their driving licence B before 1970.
Nevertheless, these facts regard only a small part of the motorhome’s owners. The others would then have to be put to a new exam for heavy goods driving licence, and they do not want to do so.

We hoped it would have been possible to have the Parliament’s amendment allowing the driving of a motorhome of 4'250 Kg with a licence B but the directive 2006/126/CE of Dec. 20th 2006 does not envisage that feasibility.

This directive came into effect on January 19th, 2007 but will not be applicable in the Union before January 19th 2013.

Nevertheless, in view of the modifications already brought to this text by the Commission and of the necessary delay in this kind of procedure, we think it essential that our request be dealt with in the nearest future.

According to the dispositions agreed to, it is possible to drive with the licence E (B) a group of vehicles consisting of a type B tractor vehicle and a trailer or semi-trailer of no more than 3'500 Kg, i.e. a group the weight of which could reach 7'000 Kg.

It would then seem logical to create a licence C1 « leisure vehicles » allowing to drive a motorhome which weight could be over 3'500 Kg but less than 7'500 Kg. This licence could be submitted to the same requirements as the licence E (B) The driving tests could remain the same as the ones for the classical licence C1.

I remain at your entire disposal to participate in any reunion you would see fit to get organized on this subject.

                                                                   Pully, december 1st, 2009

                                                                   Very truly Yours,

                                                                   Alessandro ICHINO

                                                                   President FICM aisbl