June 6, 2002
Dr. Jeffrey Runge, Administrator
National Highway Traffic Safety Administration (NHTSA)
400 7th Street SW
Washington DC 20590
Dear Dr. Runge:
On May 15, CAS wrote you about how outrageous geographic recalls have become when NHTSA says, "It’s not hot in Death Valley and it doesn’t snow hard In Buffalo." CAS pointed out how NHTSA attempted to cover up the inadequacy of geographic recalls by withholding the city and state information on the public domain website and from the Vehicle Owner Questionnaires (VOQs). This makes it very difficult for the public to analyze the inadequacies of geographic recalls. An agency that does its job should not make it difficult for the public to determine whether it is doing its job.
CAS has filed a number of Freedom of Information Act requests to document the safety hazards of geographic recalls and to discover the basis for NHTSA covering up the evidence of hazards by making it difficult for the public to learn about defect failures in states outside the geographic recall states. one of the requests sought "any and all records relating to the redaction of personally identifiable information from all investigatory files maintained by NHTSA’s Technical Information Services." This covers the redaction policy on VOQ’s since they often provide the basis for an investigation.
In response, NHTSA Associate Chief Counsel Heidi Coleman stated the agency could find only two documents and provided one. (Attachment A., .PDF) The released February 10, 1992 policy document reflects the agency’s current policy according to Ms. Coleman since her search uncovered no subsequent policy documents. If this is in fact the case, and we have no reason to doubt Ms. Coleman’s representation, the agency is violating its own policy by redacting city and state from VOQ’s as shown by the enclosed examples. (Attachment B., .PDF)
CAS requests the agency to investigate why the policy to keep the city and state in the VOQ’s has been violated and to restore this information to all VOQ’s and letters from consumers as provided for in the February 10, 1992 policy statement. CAS repeats its request to place the city and state on each complaint summarized on the complaint data base on NHTSA’s Website.
I look forward to your response to this letter and our May 15 request that NHTSA revert to its prior policy of requiring every state recalls.
Clarence M. Ditlow