October 25, 2021
Contact: Jason Levine, [email protected] or (202) 328-7700
Re: Notice and Request for Comments; Request for approval of Event Data Recorder Information Collection by the Office of Management and Budget (OMB) for Docket No. NHTSA– 2021–0058
Thank you for the opportunity to provide comments on the request for approval from the Office of Management and Budget (OMB) for Notice and Request for Comments; Event Data Recorders (EDRs). 1 The Center for Auto Safety (CAS), founded in 1970, is an independent, member supported, non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy. In 2020, we celebrated 50 years of advocacy for automotive safety and consumer protection. Motor vehicle crash data supplied by EDRs is a critical component for investigators and researchers evaluating current tragedies in hopes of preventing them in the future. To that end, the Center is pleased to provide the responses below.
Whether the proposed collection of information is necessary for the proper performance of the functions of the Department, including whether the information will have practical utility
CAS believes that the proposed collection of information is necessary for the proper performance of the functions of the Department, and that the information will have practical utility. The numbers of deaths and injuries from vehicle crashes remains stubbornly, unacceptably high. 2020 saw a reversal in the decades-long trend of decreasing motor vehicle death rates, 2 and preliminary data for 2021 indicates the death rates are continuing to trend in the wrong direction. Therefore, all available tools must be employed by both the government and industry to address the continued and accelerating highway carnage. EDR data is an important tool that greatly contributes to our understanding of the causes of motor vehicle crashes. EDRs function as a silent witness to events that frequently have no living witness and are indispensable to law enforcement and other federal and state government safety agencies as they evaluate factors contributing to crash deaths and injuries. Data recorded by EDRs is often critical to a full understanding of the circumstances involved.