Consumer Reports (CR), the independent, nonprofit, and nonpartisan member organization, welcomes the opportunity to provide comments to the National Highway Traffic Safety Administration (NHTSA) on the request for reinstatement and extension of the Fatality Analysis Reporting System (FARS) and related Non-Traffic Surveillance (NTS) information collection activities. CR strongly supports the continuation of these data collection activities, as they are fundamental to NHTSA’s mission of saving lives and preventing injuries. FARS remains one of the most complete and accurate censuses of roadway fatalities, and it provides a critical foundation for research, policy development, and the evaluation of safety countermeasures.
Meaningful progress in roadway safety requires high quality data to identify emerging trends. CR, for example, drew on FARS data in a June 2020 white paper, which estimated that fleetwide adoption of currently available vehicle safety technologies—including automatic emergency braking, pedestrian detection, and advanced drunk driving prevention systems—could save upwards of 20,000 lives annually, effectively cutting roadway fatalities in half. Any analyses of this kind depend on the data FARS provides, as does the work of state transportation and highway safety agencies, federal and congressional staff evaluating safety programs, and other safety stakeholders making the case for different policy interventions to help save lives on our nation’s roads.
FARS data also underpins NHTSA’s own work. When the agency moves to address a safety problem, it has to be able to understand the scope of that problem, and FARS is central to that analysis. The agency likewise relies on FARS to estimate the benefits of a proposed vehicle safety standard.
FARS is also essential to NHTSA’s NTS data-collection effort, particularly to ensure that the agency can publicly document fatal motor vehicle-related incidents—such as low-speed frontovers and backovers—that typically occur in driveways, parking lots, or other locations off of public roads. We strongly support the continued NTS information collection with respect to data obtained via FARS.
At the same time, CR recognizes the growing burden associated with this collection. The appropriate response is to adequately resource collection activities, and build on improvements the agency has already identified to address the growing burden and persistent delays in the public release of annual FARS datasets. There should be no reduction in the scope or depth of data collected. The value FARS provides to public safety fully justifies continued investment.
As NHTSA works to evaluate current data elements and considers possible changes to the data collection systems, the agency should continue to seek stakeholder input to ensure that any such changes preserve the program’s utility and reliability. CR appreciates the opportunity to comment, and looks forward to continued engagement with NHTSA on this important work.