Protecting Your Rights In Our Nation's Capital!
to Position Papers Listing
MRF's Public Comments Regarding NHTSA's Proposed Study
of Rider Characteristics
June 20, 2003
400 Seventh Street, S.W.
Washington, D.C. 20590
Docket NHTSA 2003-14375
letter provides the official comments of the Motorcycle
Riders Foundation to Docket Number NHTSA 2003-14375,
specifically the proposal by the National Highway Traffic
Safety Administration to study "Characteristics of Motorcycle
Operators." We should note that the above referenced
docket number is the one provided in the "Federal Register,"
April 28, Volume 68, Number 82, with a stated deadline
for public comment of 30 June 2003. Another source for
the same NHTSA study proposal provides a deadline of
24 June. We request that the agency honor all public
comments submitted and keep the public comment period
open until 30 June 2003.
want to begin by thanking Marvin M. Levy, Ph.D., of
NHTSA for the insights and information he provided to
us via telephone. We also thank the many motorcyclists
who, at our suggestion, read the study proposal and
shared with us their comments and observations. This
public comment reflects the input of these many motorcyclists,
the vast majority of whom oppose the study proposal
as fruitless and a waste of taxpayer dollars.
are particularly concerned that NHTSA chose to cite
the National Agenda for Motorcycle Safety as the rationale
for its proposed interview of thousands of riders.
study proposal states unequivocally, "Recommendations
from the National Agenda for Motorcycle Safety (National
Agenda) indicated that additional research is needed
to determine rider characteristics and factors leading
to motorcycle crashes. This study supports the National
Agenda and future efforts to reduce motorcycle injuries
and deaths by providing updated information about rider
operator characteristics, attitudes, and behaviors."
our telephone conversation, however, Dr. Levy equivocated
as to the degree to which the study proposal truly stemmed
from, was supportive of or was supported by the National
Agenda for Motorcycle Safety.
the Motorcycle Riders Foundation was and remains critical
of the "urgent" priority assigned to "additional research"
recommended by the National Agenda, we participated
in the development of the agenda and remain supportive
of additional research. With respect to "urgency," we
believe - and our member-State Motorcyclists' Rights
Organizations (SMROs) believe - that the "urgent" priority
for this Administration and this Congress is to enhance
the delivery of motorcycle safety - both skill training
to riders and motorcycle awareness to motorists. From
the wearing of protective gear and the separating of
drinking from riding to the application of collision
avoidance skills, every conceivable behavioral concern
on the part of NHTSA and motorcycle safety specialists
is addressed, by experts, when training and awareness
you know, a modest but effective resource injection
to assist motorcycle safety is the top priority of the
joint MRF-SMRO agenda for the reauthorization of the
Transportation Equity Act for the Twenty-First Century
(TEA-21), and we await the Administration's support
of this initiative that will prevent accidents, thwart
injuries and save lives. An additional priority of ours
is the establishment of a "Motorcyclist Advisory Council"
in the immediate office of the Administrator of the
Federal Highway Administration (FHWA) so that a meaningful
dialogue can be established and maintained between motorcyclists,
researchers who ride and the engineers of FHWA. The
priority in TEA-21 reauthorization of our ally, the
American Motorcyclist Association, is a major crash
causation study employing "Organization for Economic
Cooperation and Development (OECD) Common Methodology."
National Agenda does not support any research,
but specific research. Regardless of whether
reasonable individuals and organizations disagree as
to the scope and breadth of an OECD study, it is this
study methodology that is called for and supported by
the National Agenda, not the proposed interviews of
thousands of riders.
ask whether "the proposed collection of information
is necessary for the proper performance of the functions"
of NHTSA and if it will have "practical utility." The
proposed study is neither necessary nor will it offer
assert that 12-minute interviews of riders in 7 states
will "help focus current programs and activities to
achieve the greatest benefit,…develop new programs,…decrease
the likelihood of such crashes, and…provide informational
support to states, localities, law enforcement agencies,
and motorcyclists that will aid them in their efforts
to reduce motorcyclist crashes, injuries and fatalities."
of these goals, however, will be achieved by the proposed
study. And the rationale for that assertion is the National
National Agenda itself indicates that only a crash causation
study using OECD methodology will produce the results
desired by NHTSA and the stakeholders who took part
in developing the National Agenda. Rider interviews
cannot possibly achieve the same ends as a crash causation
study that involves "in-depth investigation and analysis
[at the accident scene employing] "engineering, medical,
motorcycle-qualified investigators [to include] crash
causation as well as injury causation factors…human,
vehicle, and environmental factors and all possible
interactions." (Source: National Agenda for Motorcycle
interviews of the crash-involved rider will yield results
of highly questionable reliability, as interviews cannot
possibly provide "an audit path between the raw data
and final results" or even "verify crash configuration,"
two of the many prerequisites of a study employing OECD
common methodology. (Source: National Agenda for Motorcycle
the document the agency cites as justification for its
interview proposal states that a common methodology
study "requires analysis of the population-at-risk to
coincide with investigation of the crash population.
Large-scale data sources such as departments of motor
vehicles can be surveyed and compared to the population-at-risk
identified through concurrent exposure data collection."
The document goes on to caution, however, that even
"exclusive reliance on these data will not define the
true population-at-risk." If that is so, then surely
reliance on rider interviews in 7 states, even if buttressed
by data from NHTSA's National Center for Statistics
and Analysis "will not define the true population-at-risk."
(Source: National Agenda for Motorcycle Safety.)
no way does the National Agenda for Motorcycle Safety
support or serve as justification for the proposed interviews
of riders, and NHTSA is in error in citing the National
Agenda in this way.
want to emphasize our unshakable commitment to preventing
the crash in the first place, and we continue to appeal
to you for a meaningful partnership and effective programs
that lead to crash prevention. Properly structured
and carefully monitored, a crash causation study will
contribute directly to crash prevention (e.g., through
incorporation of new lessons learned into rider training
curricula). Rider interviews cannot. In this regard,
we concur in an observation made by NHTSA in its recent
"Motorcycle Safety Program:" the agency stated that
"crash prevention...offers the greatest potential safety
benefit for motorcyclists."
is time to stop nibbling at the fringes of a problem
we riders take very seriously and, I hasten to point
out, very personally. NHTSA and Administration support
for a resource injection to help motorcycle safety is
Vice President, Government Relations
Motorcycle Riders Foundation
also invite you to view and print the following .pdf
version of the MRF's Public Comments Regarding NHTSA's
Proposed Study of Rider Characteristics.
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