Our Official Comments on the Proposed Vehicle Safety Ratings Overhaul

Tomorrow is the last day to submit comments on an important federal rulemaking.

Tomorrow is the last day to submit comments on an important federal rulemaking. The safety agency is overhauling its New Car Assessment Program (N-CAP) which you probably know as the five-star vehicle safety rating system.

America Walks (which was one of our first clients, and this was one of our first projects) has been leading an effort to generate a bunch of public comments in response to what is in some ways a disappointing first draft at a time when, as we know, pedestrian deaths are skyrocketing.

Because it’s very important, we drafted our own comments. And just to help raise awareness (you can submit comments too!) we wanted to share them here:

“I am writing in response to the request for comments on NHTSA’s proposed overhaul of the New Car Assessment Program (N-CAP) [No. 2023-11201].

I am the author of a book about pedestrian safety, “Right of Way: Race, Class and the Silent Epidemic in America” and the founder of 3MPH Planning and Consulting, a Cleveland-based planning firm focused on pedestrian safety. I am also a well known speaker and media authority on the topic. 

I was very encouraged when I heard the requirement to overhaul N-CAP and consider pedestrian protection for the first time had been included in the Infrastructure Bill. My extensive research points to many causes of the current “pedestrian safety crisis,” but I consider the rise of SUVs and large pickup trucks to be the clearest cause based on the available data. I felt certain, given the alarming rise in pedestrian deaths that has taken place over the past decade-plus, the new ratings would finally at least inform consumers of the increased risks presented by certain vehicles for vulnerable road users. 

That the initial proposed approach would instead avoid incorporating this element of safety into the “Monroney labels” — five star stickers — displayed at dealerships is extremely disappointing, and will result in needless deaths and injuries. I urge NHTSA to take bolder action. Giving cars and trucks a separate pass fail rating on pedestrian safety that is only displayed on NHTSA’s website — as proposed — strikes me as a half-measure that is very much insufficient to address the near-record 7,500 killed last year.

It is also disappointing that NHTSA has decided at this time not to crash test vehicle front ends with crash dummies. Passive safety for pedestrians and cyclists on vehicle front ends is an extremely promising frontier, and one in which the U.S. is a shameful laggard. Interior passive safety features have saved thousands of lives. It’s time to apply those same lessons — about cushioning — to the outside of the vehicle. The U.S. is a decade or more behind our peer nations in Europe and Asia that have made passive pedestrian protection part of the N-CAP programs, and our traffic safety record increasingly reflects the disparity. 

Thank you for taking the time to read my comments. I am hopeful the final product will rise to the challenge of not just mounting pedestrian fatalities but the U.S.’s increasingly grim toll on traffic deaths altogether.”