Alliance Comments On NCAP Changes


The following statement was presented by Robert Strassburger, Vice President, Safety & Harmonization at the Alliance of Automobile Manufacturers to NHTSA at its public hearing on possible changes to the New Car Assessment Program (NCAP):


NHTSA’s New Car Assessment Program (NCAP) provides comparative information on the safety of new vehicles to assist consumers with vehicle purchasing decisions and to encourage motor vehicle manufacturers to make additional safety enhancements.

To keep pace with advancements in occupant protection and the introduction of advanced technologies, NHTSA has periodically updated NCAP.

Currently, NHTSA is proposing and seeks public comment on an update to NCAP that includes, among other things: additional crash test configurations; the use of new, unregulated test dummies; and the addition of a crash avoidance rating.

Policy Talking Points

  • At the outset, the Alliance commends NHTSA for soliciting public comments before adopting any upgrades to NCAP.
  • Since the passage of the National Traffic and Motor Vehicle Safety Act in 1966, fatalities as a share of miles travelled are down 80 percent, and are down 26 percent just over the past decade alone.
  • Passenger vehicle occupant fatalities in the last decade have fallen to a level not experienced since 1949. The fact that vehicle miles travelled has increased 223 percent since 1966 and nearly 600 percent since 1949 underscores the significance of this achievement.
  • The progress with respect to motor vehicle safety over the last several decades is due to a variety of factors including but not limited to: enhanced public health approaches, auto industry innovations, enhanced roadway infrastructure and trauma care improvements.
  • Much of the advanced safety technology on today’s cars and trucks is installed voluntarily by the Alliance’s 12 global automakers, several of which are among Boston Consulting Group’s 2015 Most Innovative Companies.
  • NCAP has changed the paradigm for enhancing vehicle safety by helping to create additional consumer awareness that emphasizes automakers’ commitment to the development of advanced safety technologies; thus, the program helps to accelerate market penetration of advanced safety technologies.
  • Current NCAP provides ratings on approximately 85 percent of the new model year U.S. vehicle fleet.
  • For model year 2014, roughly 90 percent of the vehicles rated were awarded 4– or 5–stars.
  • The current NCAP was implemented for 2011 model year. The fact that most of the current fleet achieves 4 or 5-stars does not mean something is wrong with today’s NCAP, but rather, shows vehicle manufacturers’ commitment to safety advancements over time.
  • NCAP changes implemented for 2011 model year were originally targeted by NHTSA for 2010 model year. NHTSA’s decision to provide an additional year was based in part to ensure that the technical aspects of NCAP revisions were reliable, repeatable, reproducible and containable by NHTSA itself. NHTSA can learn from previous experience that appropriate lead-time is a critical aspect to successful implementation of significant changes to NCAP this time.
  • We are in the midst of a transformative period in personal mobility that is leading to passenger vehicles that are even safer, more fuel efficient and more environmentally friendly.
  • The Alliance welcomes the Department of Transportation’s recognition that it has a key role to play in cooperating with the auto industry to accelerate development and deployment of advanced safety technology.
  • For example, the Alliance applauds the Department’s efforts to identify obstacles in its current regulatory framework that impede adoption of advanced technologies.
  • As NHTSA acknowledges, the current rulemaking process, which is appropriately diligent and rigorous, can take longer than the pace of technology innovation in today’s society.
  • Although, quasi–regulation itself, NCAP might be one means for accelerating the adoption of advanced safety technologies, rulemaking efforts to eliminate regulatory barriers or to establish minimum performance requirements should be pursued as needed.
  • Because it is quasi–regulation, when adopting upgrades to NCAP, including recent changes mandated by the FAST Act (P.L. 114–94), the “good government” provisions of the Safety Act that guide NHTSA rulemaking should be rigorously followed.
  • To this end, each advanced safety technology rating or information disclosure to be included in NCAP should be:
    • Supported by a statement of the safety concern being addressed;
    • Supported by definable data quantifying that the advanced technology to be rated is likely to provide significant safety enhancements;
    • Distinguish meaningful performance differences between vehicles in a simple and easy to understand manner to aid in vehicle purchase decision;
    • Based on safety performance rating metrics vetted by peer review, public notice and comment;
    • Include test procedures, for determining if the advanced technology meets the established safety performance rating metrics, that are:
      • Practicable,
      • Stated in objective terms, and
      • Appropriate for the type of motor vehicle for which the technology is intended;
    • Evolve from and relate to the existing NCAP rather than a dramatic departure from the existing Program to help aid consumer understanding;
    • Subject to periodic effectiveness assessment once implemented (PDCA – Plan, Do, Check Action);
    • Spur research and the achievement of safety goals that exceed regulatory requirements; and
    • Subject to public notice and comment.
  • The Alliance recognizes that implementation of some aspects of the proposed upgrade of NCAP dictates rulemaking and that this can work effectively in concert with advances that are appropriate outside the traditional rulemaking framework.
  • Specifically, the specifications of any anthropomorphic test devices (ATDs) to be used in NCAP, along with the associated Injury Assessment Reference Values (IARVs) to be measured by these devices must be tightly controlled to ensure that test results are repeatable and reproducible – the underpinnings of any reliable consumer information program.
  • Similarly, test devices for advanced safety system evaluations, e.g., vehicle and pedestrian targets, must replicate the characteristics of real–world vehicles and pedestrians to ensure reliable classification of those objects.
  • Given the breadth of NHTSA’s NCAP proposal, the Alliance recommends that the agency develop a strategic plan for implementing any changes ultimately adopted.
  • The Alliance also recommends that the agency hold a series of workshops to further explore various aspects of its proposal, such as the test procedures to be used, vehicle selection criteria, test devices and dummies to be used, performance metrics to be applied, and rating methods all deserve focus examination in public workshops.
  • Finally, in 1970, only 5.1 percent of passenger vehicles were 15 years old or older. By 2013 that number was nearly 20 percent – 4 times higher than in 1970.
  • A NHTSA analysis indicates that drivers in vehicles 15 years old or older are at least 50 percent more likely to be fatality injured compared to a driver in a new vehicle (0 to 3 years old).
  • According to R.L. Polk, the median age of light duty vehicles on the road in the U.S. is currently 11.5 years.
  • When considering changes to NCAP, NHTSA should consider that pushing fleetwide fitment of new and emerging technologies, without demonstrated reliable real-world performance, may incrementally increase the purchase price of new vehicles, which may delay fleet turnover and the realization of the anticipated safety benefits of the current state-of-the-art.
  • In closing, extending the application of the “good government” provisions to NCAP and “docketing” any ATDs to be used in NCAP, will help to ensure that information provided to consumers is objective, reliable, and allows for meaningful comparisons in performance to be made.
  • The Alliance expects to submit to the agency additional information to support today’s testimony.
  • Well–designed enhancements to the existing NCAP have the potential to provide consumers with meaningful information on the ever–improving safety of new vehicles.

Thank you. I would be happy to answer any questions that you may have.