U.S. Department of Transportation
Room PL-401
400 Seventh Street, SW
Washington, DC 20590-0001
Via: http://dms.dot.gov
National Highway Traffic Safety Administration
on
Docket No. NHTSA-02-13546; Notice 1
RIN 2127-AI72
Motor Vehicle Safety Standards:
Event Data Recorders
COMMENTS OF CONSUMERS UNION
Consumers Union submits these comments in response to the Administration’s request for comments on the future role of the agency in the continued development and installation of event data recorders (EDRs) in motor vehicles.
I. Introduction
Consumers Union, publisher of Consumer Reports, believes that the installation of EDRs in motor vehicles provides enormous potential for increasing road safety. Accurate crash data, and a better understanding of which components of vehicles and of driver behavior are most associated with crashes, unquestionably serve an important societal purpose. However, the installation of EDRs, and more importantly, the collection and distribution of the information these devices record, raise several significant concerns for consumers. Consumers Union
believes that NHTSA should take these concerns into account when developing its regulations for EDRs.
In addition, given that NHTSA’s goal is to maximize the utility of this data in service of enhanced traffic safety, it is imperative that NHTSA play a central role in the collection, access, and management of EDR data. NHTSA’s playing a prominent role will also help prevent improper access to or use of EDR data by third parties.
According to the August 2001 report produced by NHTSA’s Working Group1, the majority of vehicles on American roadways today contain some sort of data capture capabilities.
For the full comments, click here.