IIHS comment to NHTSA concerning fuel economy standards

August 18, 2010 The Honorable David L. Strickland Administrator National Highway Traffic Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 Motorcycle Antilock Braking Systems and Crash Risk Estimated from Case-Control Comparisons, Mathematical Analysis Division, July 7, 2010; Docket No. NHTSA-2002-11950 Dear Administrator Strickland: On July 19, 2010, the National Highway Traffic Safety Administration (NHTSA) published the report referenced above to Docket No. NHTSA-2002-11950. From the introduction, it is apparent that this report responds to a recent Insurance Institute for Highway Safety (IIHS) study, which found that antilock braking systems (ABS) reduce by 37 percent the rate of fatal motorcycle crashes per 10,000 registered vehicle years (Teoh, 2010). IIHS is concerned that the conclusion of NHTSA’s report — it “did not find statistically-significant results to suggest that ABS affects motorcycle crash risk” — will be used inappropriately to delay action on a federal mandate to equip future motorcycles with this lifesaving technology. As you know, motorcycle crash fatalities are the only category of motor vehicle deaths to grow in recent years, and it is imperative to apply the same level of technological innovation to this problem that has been so effective with passenger vehicles. The appropriate conclusion from the NHTSA analysis is that there is no significant contradiction of the IIHS finding, which is buttressed ...