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A Modest Rebuttal of the NTSB’s 2013 Most Wanted List for Cars

by Roger Lanctot | 11月 18, 2012

The U.S. National Transportation Safety Board (NTSB) released its 2013 “Most Wanted List” of solutions for transportation hazards including everything from enhanced pipeline safety to improved safety for airport surface operations. Near the bottom of the list were three items relevant to the automotive industry: reducing distracted driving in all environments, reducing impaired driving and mandating collision avoidance technologies.

The announcement from the NTSB is reminiscent of what Abraham Maslow said in 1966: “I suppose it is tempting, if the only tool you have is a hammer, to treat everything as if it were a nail.” I believe this statement accurately characterizes the NTSB’s position - replace "hammer" with "mandate" - but it only hints at the potential negative consequences from mandating safety technologies.

The concerns of the NTSB are significant and worthy of note.  While annual highway fatalities have been in a steady decline for the past decade, the U.S. still sees approximately 100 fatalities per day on its roads.  This is clearly not acceptable.  According to NTSB estimates 10,000 lives are lost annually to impaired drivers – the single greatest source of death and injury on the road. 

The National Highway Traffic Safety Administration (NHTSA) has developed a much quoted figure of 3,000 annual fatalities from distracted driving most often ascribed to the use of smartphones.  NHTSA representatives have stated publicly they are seeking better metrics for this phenomenon, but executives at the NTSB have already voiced their preference for a ban on mobile phones in cars – something which is opposed by the automotive industry and the Consumer Electronics Association among other interested parties.

The NTSB further estimates that run-off-road, rear-end, and lane change maneuvers account for 23%, 28%, and 9% of highway accidents, respectively. The agency says collision avoidance technologies can prevent these types of accidents - or 60% of the total.

NTSB cites data from the Insurance Institute for Highway Safety for its claims that mandating collision avoidance technologies will prevent crashes and save lives.  NTSB says the IIHS “estimates that forward collision warning can prevent 879 fatal crashes annually for passenger vehicles and 115 fatal crashes annually for large trucks. The (IIHS) estimates that lane departure warning can prevent 247 fatal crashes annually, and electronic stability control, 439 fatal crashes annually.

There are a host of issues raised by this call for a mandate and I have an alternative proposal.  First, the problems.

1)      The NTSB’s call to mandate collision avoidance technologies has immediately put automotive industry lobbyists on the defensive, although some have actually already gone into attack mode.  Unfortunately, the predictable path of resistance lies in decrying the high cost of fulfilling technology mandates, which will translate as more expensive vehicles.  The agency has responded that the industry cost estimates are too high and they will decline over time anyway.  The real problem here is that it puts the automotive industry in the awkward position of arguing indirectly or directly over the value of saved lives.  This is unproductive and corrosive to the regulatory process while introducing an undue level of emotion and exposing, inaccurately,  the auto industry as possessed of a callous disregard for human life.

2)      The IIHS as a source of statistical validation is hardly a disinterested party, funded as it is by the insurance industry.  In spite of the IIHS findings regarding the efficacy of certain safety systems, consumers have seen little reward from their insurers in the form of lower insurance rates for cars equipped with these systems.  And the IIHS was not nearly as sanguine as the NTSB regarding lane departure warning, which the IIHS said, earlier this year, can harm rather help avoid accidents, in the organizaton’s own words.

3)      The mandate process itself will require years of testing to determine the efficacy of these systems for preventing crashes and fatalities.  Even if the NTSB and the industry could agree that something should be done, each technology will require extensive testing and review virtually halting existing development in the industry - which is currently moving at a rapid pace - for fear of selecting the “wrong” solution.

4)      NHTSA has already set out a target of crash avoidance and is rewarding car makers with higher safety ratings.


Here are my modest proposals for resolving this scenario.  My ideas are market driven although they will benefit from

endorsement or implementation within the existing regulatory framework.

1)      Require insurers to offer discounts for vehicles equipped with the very safety systems for which the agency is seeking “robust” industry adoption.  It’s almost impossible – if not actually impossible – to find an insurer willing to offer a discount on a Volvo equipped with City Safety collision avoidance.  If this is a life-saving technology, it is time for the insurance industry to put its money on what its data has validated and it may also be time for the NTSB or some other regulator to compel such action.

2)      We are currently at the outset of the World Health Organization’s Decade of Action for Road Safety.  There couldn’t possibly be a better time for the NTSB, perhaps in concert with NHTSA, to set forth a set of targets along the lines of the Corporate Average Fuel Economy standard of 54.5 miles per gallon by 2025.  The automotive industry howled when the 54.5 mpg standard was first proposed, but has now agreed to go along.  Could the U.S. put together individual car maker targets for lives saved/deaths prevented?  Could the NTSB and or NHTSA build a database intended to identify best practices in vehicle safety system design?  Could auto makers be forced to take more responsibility for the actions and behaviors of their drivers?

3)      How about tax credits for new cars equipped with specific qualifying safety systems?

4)      It is worth noting that car makers are already bringing a wider portfolio of safety systems to more and more of their cars at lower price ranges.  Market conditions suggest that mandates at this time are almost completely unnecessary and, if anything, will only slow adoption and deployment.

There are a lot of ways to save lives and there are a lot of lives to be saved.  Mandates aren’t the only path to less motor vehicle bloodshed.  The government and insurers should recognize and reward those car makers that have made the greatest progress in ending highway mayhem.  And drivers, too, should be rewarded for choosing safety.

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