March 31, 2021
The Honorable Pete Buttigieg
Secretary
U.S. Department of Transportation
1200 New Jersey Ave., S.E.
Washington, D.C. 20590
Dear Secretary Buttigieg:
As President Joseph Biden, Vice President Kamala Harris and you prepare to unveil the framework for a major infrastructure-and-jobs program this week, we urge you to prioritize the safety of all road users.
Over the last three decades, every major surface transportation bill signed into law by the President in office has included provisions resulting in significant public safety improvements such as airbags,[i] electronic stability control to prevent rollovers,[ii] improved roof strength requirements,[iii] child safety protections,[iv] and safety belts on motorcoaches.[v] These advances have garnered bipartisan support and saved tens of thousands of lives. In fact, the National Highway Traffic Safety Administration (NHTSA) estimated that between 1960 and 2012, over 600,000 lives have been saved by motor vehicle safety technologies.[vi]
The recent crash involving Tiger Woods is a prime example of the lifesaving benefits of federal safety regulations. Mr. Woods’ life was saved, at least in part, by a seat belt, air bags and roof crush performance standards, all of which are required by NHTSA regulations as standard equipment in cars. As Auto Week succinctly explained, “The details of Tiger Woods’ crash are still being sorted out by investigators, but in general, the world’s greatest golfer can thank more than 50 years of government-mandated safety advances that he is alive.”[vii]
There are many more available and affordable technologies, such as advanced driver assistance systems (ADAS) and impaired driving prevention systems, that could be saving thousands of lives now if similarly mandated as standard equipment on new vehicles. The Insurance Institute for Highway Safety (IIHS) has conducted numerous studies demonstrating the effectiveness of technologies to reduce and mitigate crashes. For example:
- Automatic emergency braking (AEB) can decrease front-to-rear car crashes with injuries by 56 percent.[viii]
- Impairment detection systems in cars and other vehicles could save upwards of 9,000 lives each year.[ix]
- Equipping large trucks with AEB with forward collision warning (FCW) could eliminate more than two out of five crashes in which a large truck rear-ends another vehicle.[x]
These technologies should be required in new vehicles, subject to a minimum performance standard which sets a floor, not a ceiling, from which manufacturers can innovate. Currently, these safety features are often sold as part of an additional, expensive trim package coupled with other non-safety features, or included as standard equipment in high end models or vehicles, which are simply unaffordable to many families. For example, a recent analysis by Consumer Reports found an astounding upcharge of more than $16,000 for AEB with pedestrian detection in the second most popular vehicle sold in the U.S.[xi] ADAS protect not only vehicle occupants but also the many individuals who rely on rolling, walking or biking for transportation to school, work or everyday errands for requisite, economic or environmental reasons.
We know from past efforts to require vehicle safety technology as standard equipment that the base cost drops dramatically due to economies of scale. The most dramatic example of this phenomenon is the reduction in the cost of airbags once they were mandated and became standard equipment following legislation amending Federal Motor Vehicle Safety Standard 208 to require their use.[xii] Furthermore, government regulations make safety equitable, ensure the protection of vulnerable road users and expedite broad market saturation. Just as we determined more than 30 years ago with airbags, now is the time to act. As we have witnessed time and time again, a minimum safety standard will greatly accelerate these well-established technologies, through reducing their cost. These technologies will deliver many of the desired benefits of automated vehicle technology without some of the safety transition pains many experts have raised about automated driving.
The universal adoption of these technologies will literally save tens of thousands of lives by accelerating their wide scale availability. Given the many effective systems that have already been developed, this can be done in a few years instead of taking more than a decade. Without timely action on urgently needed safety advances, over the next four years approximately 144,000 people will be killed and nearly 11 million people will be injured in motor vehicle crashes. A third of those will be caused by impaired drivers. Nearly 25,000 of the fatalities will be pedestrians and more than 3,300 will be bicyclists. Approximately 20,000 people will be killed in crashes involving a large truck. According to the U.S. Department of Labor, truck driving is one of the most dangerous occupations in the United States.
The spiraling cost of motor vehicle crashes is a massive and unnecessary drain on our nation’s economy. Based on 2010 NHTSA data, the overall annual societal cost of crashes exceeds $800 billion, including $242 billion in direct economic costs. When adjusted only for inflation, comprehensive crash costs now near one trillion dollars, with direct economic costs amounting to $292 billion. This is equivalent to an $885 “crash tax” on every American.
Yet, despite the fact that 95 percent of transportation-related fatalities involve motor vehicles, NHTSA receives only one percent of the overall U.S. Department of Transportation (DOT) budget. In the past 50 years, federal spending on lifesaving and cost-effective vehicle safety programs has declined based on inflation while the death toll continues to mount, and NHTSA’s program responsibilities have experienced a major expansion. A course correction of DOT’s vehicle safety budget priorities is long overdue and badly needed. In developing the Biden Administration’s infrastructure proposal, we urge you to prioritize safety for all road users, achieve safety equity, and realize significant reductions in the death and injury toll by proposing substantial and essential increases in funding and staff resources for NHTSA’s vehicle safety programs.
We look forward to working with you to ensure that every person in every state on every road for every mode of travel will be provided equitable transportation protections. Meaningfully addressing the current inequitable physical, emotional, and economic toll of motor vehicle crashes is achievable now.
Sincerely,
Catherine Chase, President, Advocates for Highway and Auto Safety
David Nadig, Senior Vice President and General Counsel, Allstate Insurance Company
Mike McGinn, Executive Director, America Walks
American Property Casualty Insurance Association
Dr. Georges C. Benjamin, Executive Director, American Public Health Association
Dr. Deanna Wathington, Executive Board Chair, American Public Health Association
Jennifer Morrison, Vice President and General Counsel, Amica Mutual Insurance Company
Jason Levine, Executive Director, Center for Auto Safety
Center for Disability Rights
Joan Claybrook, Board Chair, Citizens for Reliable and Safe Highways, and Former Administrator, National Highway Traffic Safety Administration
Jack Gillis, Executive Director, Consumer Federation of America
David Pittle, Ph.D., Former Technical Director, Consumer Reports, and Former Commissioner, U.S. Consumer Product Safety Commission
Rosemary Shahan, President, Consumers for Auto Reliability and Safety
Emergency Nurses Association
Mary Jagim, MSN, RN, CEN, FAEN, Former President, Emergency Nurses Association
Amy Cohen, Co-Founder, Families for Safe Streets
Natalie Draisin, Director, N. American Office & United Nations Representative, FIA Foundation
Independent Insurance Agents and Brokers of America
Commander Chris Olson, Oro Valley, AZ Police Department and International Association of Chiefs of Police Highway Safety Committee Member
James P. Hoffa, General President, International Brotherhood of Teamsters
Janette Fennell, President, KidsAndCars.org
Bill Nesper, Executive Director, League of American Bicyclists
Alex Otte, National President, Mothers Against Drunk Driving
Corinne Kisner, Executive Director, National Association of City Transportation Officials
Tom Karol, General Counsel, National Association of Mutual Insurance Companies
Michael Becker, Executive Vice President and CEO, National Association of Professional Insurance Agents
Melissa Wandall, President, National Coalition for Safer Roads
Sally Greenberg, Executive Director, National Consumers League
Lorraine M. Martin, President and CEO, National Safety Council
Steven English, Senior Vice President, External Affairs, Nationwide Mutual Insurance Company
Daphne Izer and Russ Swift, Co-Chairs, Parents Against Tired Truckers
Rob Weissman, President, Public Citizen
Selective Insurance Company of America
Dr. Stephen Hargarten, Founding President, Society for the Advancement of Violence and Injury Research
Alan Maness, Vice President of Federal Affairs, State Farm Insurance Companies
Danny Harris, Executive Director, Transportation Alternatives
Andrew McGuire, Executive Director, Trauma Foundation
Dawn King, President, Truck Safety Coalition
Leah Shahum, Founder and Director, Vision Zero Network
Ralf Hotchkiss, Technical Consultant, Whirlwind Wheelchair International
Bella Dinh-Zarr, Co-founder, .05 Saves Lives Coalition, and Former Vice Chair, National Transportation Safety Board
[i] Pub. L. 102-240 (Dec. 18, 1991).
[ii] Pub. L. 109-59 (Aug. 10, 2005).
[iii] Id.
[iv] Pub. L. 107-318 (Dec. 4, 2002); Pub. L. 112-141 (Jul. 6, 2012).
[v] Pub. L. 112-141 (Jan. 3, 2012).
[vi] Lives Saved by Vehicle Safety Technologies and Associated Federal Motor Vehicle Safety Standards, 1960 to 2012, DOT HS 812 069 (NHTSA, 2015); See also, NHTSA AV Policy, Executive Summary, p. 5 endnote 1.
[vii] Mark Vaughn, Tiger Woods Owes His Life to Decades of Government Safety Standards, Auto Week (Feb 26, 2021).
[viii] IIHS, Real-world benefits of crash avoidance technologies (May 2018). See also the Moving Forward Act (116th Congress, H.R. 2), the 21st Century Smart Cars Act (116th Congress, H.R. 6284), and the Protecting Roadside First Responders Act (116th Congress, S. 2700/H.R. 4871).
[ix] Insurance Institute for Highway Safety, Alcohol-detection systems could prevent more than a fourth of U.S. road fatalities (Jul. 23, 2020). See also the Moving Forward Act (116th Congress, H.R. 2) Sec. 32005, the RIDE Act (116th Congress, S. 2604), and the HALT Drunk Driving Act (117th Congress, H.R. 2138; 116th Congress, H.R. 4354).
[x] Teoh, E, Effectiveness of front crash prevention systems in reducing large truck crash rates, IIHS (Sep. 2020). See also the Moving Forward Act (116th Congress, H.R. 2), the Protecting Roadside First Responders Act (116th Congress, S. 2700/H.R. 4871), and the Safe Roads Act (116th Congress, H.R. 3773).
[xi] Douglas, E., A High Price on Safety, Consumer Reports (Jun. 1, 2020). Preston, B, Lawmakers Should Require Proven Safety Systems on All New Cars, Consumer Reports (Jun. 29. 2020).
[xii] Pub. L. 102-240 (Dec. 18, 1991).