June 29, 2020
Office of the Administrator
c/o James C. Owens, Deputy Administrator
National Highway Traffic Safety Administration Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue SE
West Building, Ground Floor, Room W12-140 Washington, DC 20590-0001
Submitted electronically via www.regulations.gov
RE: Notice and Request for Public Comment, Government 5-Star Safety Ratings, Docket No. NHTSA–2020–0006
Dear Deputy Administrator Owens,
The Center for Auto Safety (“the Center”) appreciates the opportunity to provide comments in response to the request for public comment on the proposed collection of information regarding Government 5-Star Safety Ratings Label Consumer Research. The Center, founded in 1970, is an independent, member-supported, non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy, on behalf of all drivers, passengers, and pedestrians. In 2020, we are celebrating 50 years of advocacy for consumer automotive safety and informed choice.
At this time, it is a misuse of limited government resources to conduct a consumer survey on the 5-star safety ratings label when there are more immediate concerns with overall improvements to the New Car Assessment Program (NCAP) and vehicle safety ratings. It is premature for NHTSA to design new safety labels when they have not properly defined the testing regime for which the labels will be providing information. As you are aware, the NCAP program has not been updated since 2010, since which time over 150 million new vehicles have been sold.
The Center suggests NHTSA focus first on updated testing, specifically adapting improved vehicle crashworthiness ratings; addressing gaps in occupant and pedestrian safety across different vehicle manufacturers and models; redefining injury criteria to account for all body types, ages, seating positions, and available passenger-protection technology; defining the scope of how to test or rate ADAS features; and implementing a system for comparing all of these features.
It would be both puzzling and troubling if NHTSA were proposing to use public opinion rather than qualified technical expertise to restructure the scope of NCAP. NCAP is fundamentally an experimental engineering study of the response of complex structural designs, passive restraints, automated protective sensors and data processing, and pyrotechnic devices. NCAP compares the forensic results of carefully staged crashes to provide reliable comparative safety data to consumers. It would be bad policy if the proposed survey were to inexcusably replace the needed technical insights potentially available from NCAP results with a popularity contest that results in lasting damage to NCAP and its utility to consumers.