Larry O. Anderson - Comment

Document ID: NHTSA-2012-0070-0003
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: October 01 2012, at 12:00 AM Eastern Daylight Time
Date Posted: October 3 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: June 1 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: October 1 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 1jw-815u-mi5m
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This Greenwell report says that pickup trucks are deadlier after auto companies’ self- commitment to improve compatibility. Combine this with data that pickup trucks are major sellers in US and their total number is growing. The result? Bad news for people who drive smaller cars and bad news for the USA. Why? Because Greenwell confirms that those in smaller cars are now even more likely to die when hit by this growing number of pickups. So “small = more unsafe” means fewer and fewer people wanting to buy smaller cars. This reinforces auto companies’ arguments that few people want to buy smaller cars and companies should not be forced to make such cars via fuel efficiency rules. “Let the marketplace decide” will be the argument given for turning back fuel efficiency law. But the marketplace is being shaped by poor image of “small = more unsafe”. What will be the net result of this? More and more larger vehicles will be sold in the US which is not exactly a negative for companies selling them. It is very clear that auto industry's self-rule has not delivered all that was promised. Greenwell confirms this in more than one way. His non-specific analysis means that whatever improvements have happened for SUVs are not necessarily from following the self-rule for compatibility. It is not even known if this self-rule is really being followed with rigor by all auto companies in ways that a subject of such importance demands. No data is found anywhere on how an LTV met their self-rule.It should be alarming to all concerned that there are no bad consequences for a company if it fails to meet this self-rule. But there is consequence if it follows the self-rule - mass and $$ are added to its LTV. This situation just about assures strong incentive to ignore this self-imposed burden.In this one auto company where I am, a large team of engineers, marketers, execs etc designs an LTV. The execs’ performance assessment is based on meeting product costand mass target.

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