Graham Siebe - Comment

Document ID: NHTSA-2009-0047-0002
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: July 14 2009, at 12:00 AM Eastern Daylight Time
Date Posted: July 15 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: June 15 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: August 14 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 809f104b
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I just want to say I think this is great idea. I am writing as a private citizen concerned about the reasons people drive larger and less efficient vehicles than they might otherwise need to. My education is in economics, which has led me to identify a couple perverse incentives that could cause a rational person to make a sub-optimal decision. First, you have probably heard people say they don't feel safe driving with larger vehicles. If the other vehicle in an accident is too high, the safety features of a smaller car can be rendered ineffective. Smaller cars would give up fuel economy if re-designed, because a low bumper height is dictated by aerodynamics. Therefore, it should be mandated that larger cars and SUVs be designed in the future so they won't overrun a small vehicle. This need not diminish the off-road capability of a large vehicle. There ought to be a way to fit a detachable or retractable "under-bumper" to Jeeps and similar vehicles that would be required for on-road use, but optional elsewhere. Another benefit should be in reduced vehicle damage in minor accidents. The difference in damage between hitting bumper-to-bumper and bumper-to-higher-on-the-car can be seen in recent IIHS low speed crash tests. In fact, if this has played out in real life, insurance rates on small cars are higher than the need to be relative to larger cars. If this imbalance were corrected, people should tend to drive slightly smaller cars. Both of these effects transfer costs from the owners of light trucks and SUVs to the owners of small passenger cars. In this era of global warming and high oil prices, government should be at least leveling the playing field between larger and smaller vehicles. This regulation appears to do just that, and I hope you will put it into effect. Sincerely, -Graham Siebe

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